ML13322A890
ML13322A890 | |
Person / Time | |
---|---|
Site: | South Texas |
Issue date: | 11/30/2013 |
From: | Tam Tran Office of Nuclear Reactor Regulation |
To: | |
Beltz G | |
References | |
NUREG-1437 Supp 48 | |
Download: ML13322A890 (633) | |
Text
NUREG-1437 Supplement 48 Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 48 Regarding South Texas Project, Units 1 and 2 Final Report Office of Nuclear Reactor Regulation
AVAILABILITY OF REFERENCE MATERIALS IN NRC PUBLICATIONS NRC Reference Material Non-NRC Reference Material As of November 1999, you may electronically access Documents available from public and special technical NUREG-series publications and other NRC records at libraries include all open literature items, such as books, NRCs Public Electronic Reading Room at journal articles, transactions, Federal Register notices, http://www.nrc.gov/reading-rm.html. Publicly released Federal and State legislation, and congressional reports.
records include, to name a few, NUREG-series Such documents as theses, dissertations, foreign reports publications; Federal Register notices; applicant, and translations, and non-NRC conference proceedings licensee, and vendor documents and correspondence; may be purchased from their sponsoring organization.
NRC correspondence and internal memoranda; bulletins and information notices; inspection and investigative Copies of industry codes and standards used in a reports; licensee event reports; and Commission papers substantive manner in the NRC regulatory process are and their attachments. maintained at The NRC Technical Library NRC publications in the NUREG series, NRC Two White Flint North regulations, and Title 10, Energy, in the Code of 11545 Rockville Pike Federal Regulations may also be purchased from one Rockville, MD 20852-2738 of these two sources.
- 1. The Superintendent of Documents These standards are available in the library for reference U.S. Government Printing Office use by the public. Codes and standards are usually Mail Stop SSOP copyrighted and may be purchased from the originating Washington, DC 20402-0001 organization or, if they are American National Standards, Internet: bookstore.gpo.gov from Telephone: 202-512-1800 American National Standards Institute Fax: 202-512-2250 11 West 42nd Street
- 2. The National Technical Information Service New York, NY 10036-8002 Springfield, VA 22161-0002 www.ansi.org www.ntis.gov 212-642-4900 1-800-553-6847 or, locally, 703-605-6000
Legally binding regulatory requirements are stated only A single copy of each NRC draft report for comment is in laws; NRC regulations; licenses, including technical available free, to the extent of supply, upon written specifications; or orders, not in NUREG-series request as follows: publications. The views expressed in contractor-Address: U.S. Nuclear Regulatory Commission prepared publications in this series are not necessarily Office of Administration those of the NRC.
Publications Branch The NUREG series comprises (1) technical and Washington, DC 20555-0001 administrative reports and books prepared by the staff E-mail: DISTRIBUTION.RESOURCE@NRC.GOV (NUREG-XXXX) or agency contractors (NUREG/CR-Facsimile: 301-415-2289 XXXX), (2) proceedings of conferences (NUREG/CP-XXXX), (3) reports resulting from international Some publications in the NUREG series that are agreements (NUREG/IA-XXXX), (4) brochures posted at NRCs Web site address (NUREG/BR-XXXX), and (5) compilations of legal http://www.nrc.gov/reading-rm/doc-collections/nuregs decisions and orders of the Commission and Atomic and are updated periodically and may differ from the last Safety Licensing Boards and of Directors decisions printed version. Although references to material found on under Section 2.206 of NRCs regulations (NUREG-a Web site bear the date the material was accessed, the 0750).
material available on the date cited may subsequently be DISCLAIMER: This report was prepared as an account removed from the site. of work sponsored by an agency of the U.S.
Government. Neither the U.S. Government nor any agency thereof, nor any employee, makes any warranty, expressed or implied, or assumes any legal liability or responsibility for any third partys use, or the results of such use, of any information, apparatus, product, or process disclosed in this publication, or represents that its use by such third party would not infringe privately owned rights.
NUREG-1437 Supplement 48 Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 48 Regarding South Texas Project, Units 1 and 2 Final Report Manuscript Completed: October 2013 Date Published: November 2013 Office of Nuclear Reactor Regulation
NUREG-1437, Supplement 48, has been reproduced from the best available copy.
ABSTRACT This supplemental environmental impact statement (SEIS) has been prepared in response to an application submitted by STP Nuclear Operating Company (STPNOC) to renew the operating licenses for South Texas Project (STP), Units 1 and 2, for an additional 20 years.
This SEIS includes the analysis that evaluates the environmental impacts of the proposed action and alternatives to the proposed action. Alternatives considered include new nuclear generation, natural gas-fired combined-cycle generation, supercritical coal-fired generation, combination alternative, purchased power, and not renewing the license (the no-action alternative).
The U.S. Nuclear Regulatory Commission staffs (NRCs) recommendation is that the adverse environmental impacts of license renewal for STP are not great enough to deny the option of license renewal for energy planning decisionmakers. This recommendation is based on the following:
- the analysis and findings in NUREG-1437, Volumes 1 and 2, Generic Environmental Impact Statement for License Renewal of Nuclear Plants;
- the Environmental Report submitted by STPNOC;
- consultation with Federal, state, local, and tribal government agencies;
- the NRCs environmental review; and
- consideration of public comments received during the scoping process.
iii
TABLE OF CONTENTS ABSTRACT ................................................................................................................................ iii TABLE OF CONTENTS ..............................................................................................................v FIGURES ................................................................................................................................. xiii TABLES .................................................................................................................................... xv EXECUTIVE
SUMMARY
......................................................................................................... xix ABBREVIATIONS AND ACRONYMS ..................................................................................... xxv 1.0 PURPOSE AND NEED FOR ACTION ......................................................................... 1-1 1.1 Proposed Federal Action.................................................................................. 1-1 1.2 Purpose and Need for the Proposed Federal Action ........................................ 1-1 1.3 Major Environmental Review Milestones .......................................................... 1-1 1.4 Generic Environmental Impact Statement ........................................................ 1-3 1.5 Supplemental Environmental Impact Statement ............................................... 1-5 1.6 Cooperating Agencies ...................................................................................... 1-6 1.7 Consultations ................................................................................................... 1-6 1.8 Correspondence .............................................................................................. 1-7 1.9 Status of Compliance ....................................................................................... 1-7 1.10 References ...................................................................................................... 1-7 2.0 AFFECTED ENVIRONMENT ...................................................................................... 2-1 2.1 Facility Description ........................................................................................... 2-1 2.1.1 Reactor and Containment Systems ...................................................... 2-1 2.1.2 Radioactive Waste Management .......................................................... 2-1 2.1.3 Nonradiological Waste Management .................................................... 2-4 2.1.4 Plant Operation and Maintenance ........................................................ 2-6 2.1.5 Power Transmission System ................................................................ 2-6 2.1.6 Cooling and Auxiliary Water Systems ................................................... 2-8 2.1.7 Facility Water Use and Quality ............................................................. 2-9 2.2 Surrounding Environment .............................................................................. 2-12 2.2.1 Land Use ............................................................................................ 2-13 2.2.2 Air Quality and Meteorology ............................................................... 2-13 2.2.3 Geologic Environment ........................................................................ 2-15 2.2.4 Surface Water Resources .................................................................. 2-17 2.2.5 Groundwater Resources..................................................................... 2-19 2.2.6 Aquatic Resources ............................................................................. 2-24 2.2.7 Terrestrial Resources ......................................................................... 2-38 2.2.8 Protected Species and Habitats ......................................................... 2-47 2.2.9 Socioeconomics ................................................................................. 2-63 2.2.10 Historic and Archaeological Resources .............................................. 2-75 2.3 Related Federal and State Activities .............................................................. 2-77 v
Table of Contents 2.4 References .................................................................................................... 2-78 3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT ................................................ 3-1 3.1 References ........................................................................................................... 3-3 4.0 ENVIRONMENTAL IMPACTS OF OPERATION ......................................................... 4-1 4.1 Land Use ......................................................................................................... 4-1 4.2 Air Quality ........................................................................................................ 4-1 4.3 Surface Water Resources ................................................................................ 4-2 4.3.1 Generic Surface Water Issues .............................................................. 4-2 4.3.2 Surface Water Use ConflictsPlants Using Makeup Water from a Small River with Low Flow .................................................................... 4-3 4.4 Groundwater Resources .................................................................................. 4-5 4.4.1 Generic Groundwater Issues ................................................................ 4-5 4.4.2 Groundwater Use Conflicts ................................................................... 4-6 4.4.3 Groundwater Quality ............................................................................ 4-9 4.5 Aquatic Resources ......................................................................................... 4-11 4.5.1 Generic Aquatic Ecology Issues ......................................................... 4-12 4.5.2 Entrainment and Impingement............................................................ 4-12 4.5.3 Thermal Shock ................................................................................... 4-24 4.5.4 Mitigation ............................................................................................ 4-26 4.6 Terrestrial Resources ..................................................................................... 4-27 4.7 Protected Species and Habitats ..................................................................... 4-28 4.7.1 Species and Habitats Protected Under the Endangered Species Act ...................................................................................................... 4-28 4.7.2 Species Designated as NMFS Species of Concern ............................ 4-33 4.7.3 Species Protected Under the Bald and Golden Eagles Protection Act ...................................................................................................... 4-33 4.7.4 Species Protected Under the Migratory Bird Treaty Act ...................... 4-33 4.7.5 Species Protected Under the Marine Mammal Protection Act............. 4-33 4.7.6 Species Protected Under the Magnuson-Stevens Act........................ 4-33 4.7.7 Species Protected Under State of Texas Statutes .............................. 4-34 4.7.8 Conclusion ......................................................................................... 4-34 4.8 Human Health ................................................................................................ 4-34 4.8.1 Generic Human Health Issues ............................................................ 4-35 4.8.2 Radiological Impacts of Normal Operations ........................................ 4-35 4.8.3 Microbiological Organisms ................................................................. 4-39 4.8.4 Electromagnetic FieldsAcute Effects ............................................... 4-39 4.8.5 Electromagnetic FieldsChronic Effects ............................................ 4-41 4.9 Socioeconomics ............................................................................................. 4-41 4.9.1 Generic Socioeconomic Issues .......................................................... 4-42 4.9.2 Housing .............................................................................................. 4-42 vi
Table of Contents 4.9.3 Public ServicesPublic Utilities ......................................................... 4-43 4.9.4 Public ServicesTransportation ........................................................ 4-43 4.9.5 Offsite Land Use................................................................................. 4-43 4.9.6 Historic and Archaeological Resources .............................................. 4-45 4.9.7 Environmental Justice ........................................................................ 4-46 4.10 Evaluation of New and Potentially Significant Information .............................. 4-53 4.11 Environmental Issues Contained in the Revised 10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions ....................................................................... 4-54 4.11.1 Geology and Soils .............................................................................. 4-55 4.11.2 Radionuclides Released to Groundwater............................................ 4-56 4.11.3 Exposure of Aquatic Organisms and Terrestrial Resource to Radionuclides ..................................................................................... 4-56 4.11.4 Effects on Terrestrial Resources (Non-cooling System Impacts) ........ 4-56 4.11.5 Human Health Impacts From Chemicals and Physical Occupational Hazards ........................................................................ 4-57 4.11.6 Environmental Justice ........................................................................ 4-58 4.11.7 Cumulative Impacts ............................................................................ 4-58 4.12 Cumulative Impacts ....................................................................................... 4-58 4.12.1 Land Use ............................................................................................ 4-59 4.12.2 Air Quality........................................................................................... 4-59 4.12.3 Water Resources................................................................................ 4-61 4.12.4 Aquatic Resources ............................................................................. 4-65 4.12.5 Terrestrial Resources ......................................................................... 4-69 4.12.6 Human Health .................................................................................... 4-71 4.12.7 Socioeconomics ................................................................................. 4-72 4.12.8 Historic and Archaeological Resources .............................................. 4-74 4.12.9 Summary of Cumulative Impacts ........................................................ 4-75 4.13 References .................................................................................................... 4-76 5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS ................................. 5-1 5.0 Environmental Impacts of Postulated Accidents .................................................... 5-1 5.1 Design Basis Accidents.................................................................................... 5-1 5.2 Severe Accidents ............................................................................................. 5-2 5.3 Severe Accident Mitigation Alternatives ........................................................... 5-3 5.3.1 Overview of Severe Accident Mitigation Alternative Process ................ 5-3 5.3.2 Estimate of Risk ................................................................................... 5-3 5.3.3 Potential Plant Improvements ............................................................... 5-8 5.3.4 Evaluation of Risk Reduction and Costs of Improvements .................... 5-9 5.3.5 Cost-Benefit Comparison ..................................................................... 5-9 5.3.6 Conclusions ........................................................................................ 5-11 5.4 References .................................................................................................... 5-12 vii
Table of Contents 6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE, WASTE MANAGEMENT, AND GREENHOUSE GAS EMISSIONS .......................................... 6-1 6.1 The Uranium Fuel Cycle .................................................................................. 6-1 6.2 Greenhouse Gas Emissions ............................................................................ 6-3 6.2.1 Existing Studies .................................................................................... 6-3 6.3 References ...................................................................................................... 6-9 7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING ............................................ 7-1 7.1 Decommissioning............................................................................................. 7-1 7.2 References ...................................................................................................... 7-2 8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES.................................................... 8-1 8.1 New Nuclear Generation .................................................................................. 8-4 8.1.1 Air Quality............................................................................................. 8-5 8.1.2 Surface Water Resources .................................................................... 8-6 8.1.3 Groundwater Resources....................................................................... 8-7 8.1.4 Aquatic Ecology.................................................................................... 8-8 8.1.5 Terrestrial Ecology ............................................................................... 8-9 8.1.6 Human Health ...................................................................................... 8-9 8.1.7 Land Use ............................................................................................ 8-10 8.1.8 Socioeconomics ................................................................................. 8-10 8.1.9 Transportation .................................................................................... 8-11 8.1.10 Aesthetics........................................................................................... 8-11 8.1.11 Historic and Archaeological Resources .............................................. 8-12 8.1.12 Environmental Justice ........................................................................ 8-13 8.1.13 Waste Management ........................................................................... 8-14 8.1.14 Summary of Impacts of New Nuclear Generation ............................... 8-14 8.2 Natural Gas-Fired Combined-Cycle Generation ............................................. 8-14 8.2.1 Air Quality........................................................................................... 8-16 8.2.2 Surface Water Resources .................................................................. 8-18 8.2.3 Groundwater Resources..................................................................... 8-19 8.2.4 Aquatic Ecology.................................................................................. 8-19 8.2.5 Terrestrial Ecology ............................................................................. 8-20 8.2.6 Human Health .................................................................................... 8-21 8.2.7 Land Use ............................................................................................ 8-21 8.2.8 Socioeconomics ................................................................................. 8-22 8.2.9 Transportation .................................................................................... 8-22 8.2.10 Aesthetics........................................................................................... 8-23 8.2.11 Historic and Archaeological Resources .............................................. 8-23 8.2.12 Environmental Justice ........................................................................ 8-24 8.2.13 Waste Management ........................................................................... 8-25 viii
Table of Contents 8.2.14 Summary of Impacts for the NGCC Generation Alternative ................ 8-25 8.3 Supercritical Coal-Fired Generation ............................................................... 8-26 8.3.1 Air Quality........................................................................................... 8-28 8.3.2 Surface Water Resources .................................................................. 8-31 8.3.3 Groundwater Resources..................................................................... 8-31 8.3.4 Aquatic Ecology.................................................................................. 8-32 8.3.5 Terrestrial Ecology ............................................................................. 8-33 8.3.6 Human Health .................................................................................... 8-33 8.3.7 Land Use ............................................................................................ 8-34 8.3.8 Socioeconomics ................................................................................. 8-35 8.3.9 Transportation .................................................................................... 8-35 8.3.10 Aesthetics........................................................................................... 8-36 8.3.11 Historic and Archaeological Resources .............................................. 8-36 8.3.12 Environmental Justice ........................................................................ 8-37 8.3.13 Waste Management ........................................................................... 8-38 8.3.14 Summary of Impacts for the Supercritical Coal-Fired Generation Alternative .......................................................................................... 8-38 8.4 Combination Alternative ................................................................................. 8-39 8.4.1 Air Quality........................................................................................... 8-40 8.4.2 Surface Water Resources .................................................................. 8-43 8.4.3 Groundwater Resources..................................................................... 8-44 8.4.4 Aquatic Ecology.................................................................................. 8-44 8.4.5 Terrestrial Ecology ............................................................................. 8-45 8.4.6 Human Health .................................................................................... 8-46 8.4.7 Land Use ............................................................................................ 8-46 8.4.8 Socioeconomics ................................................................................. 8-47 8.4.9 Transportation .................................................................................... 8-48 8.4.10 Aesthetics........................................................................................... 8-49 8.4.11 Historic and Archaeological Resources .............................................. 8-49 8.4.12 Environmental Justice ........................................................................ 8-50 8.4.13 Waste Management ........................................................................... 8-51 8.4.14 Summary of Impacts of the Combination Alternative .......................... 8-51 8.5 Purchased Power........................................................................................... 8-52 8.5.1 Air Quality........................................................................................... 8-53 8.5.2 Surface Water and Groundwater Resources ...................................... 8-53 8.5.3 Terrestrial and Aquatic Ecology .......................................................... 8-53 8.5.4 Human Health .................................................................................... 8-54 8.5.5 Land Use ............................................................................................ 8-54 8.5.6 Socioeconomics (including transportation and aesthetics) .................. 8-54 8.5.7 Historic and Archaeological Resources .............................................. 8-54 8.5.8 Environmental Justice ........................................................................ 8-54 ix
Table of Contents 8.5.9 Waste Management ........................................................................... 8-55 8.5.10 Summary of Impacts of the Purchased Power Alternative ................... 8-55 8.6 Alternatives Considered but Dismissed .......................................................... 8-55 8.6.1 Offsite Nuclear-, Gas-, and Coal-Fired Capacity ................................. 8-56 8.6.2 Energy Conservation and Energy Efficiency ....................................... 8-56 8.6.3 Wind Power ........................................................................................ 8-57 8.6.4 Solar Power ........................................................................................ 8-58 8.6.5 Hydroelectric Power ........................................................................... 8-59 8.6.6 Wave and Ocean Energy ................................................................... 8-59 8.6.7 Geothermal Power ............................................................................. 8-59 8.6.8 Municipal Solid Waste ........................................................................ 8-60 8.6.9 Biomass ............................................................................................. 8-61 8.6.10 Biofuels .............................................................................................. 8-61 8.6.11 Oil-Fired Power .................................................................................. 8-62 8.6.12 Fuel Cells ........................................................................................... 8-62 8.6.13 Delayed Retirement ............................................................................ 8-62 8.7 No-Action Alternative ..................................................................................... 8-63 8.7.1 Air Quality........................................................................................... 8-63 8.7.2 Surface Water Resources .................................................................. 8-63 8.7.3 Groundwater Resources..................................................................... 8-63 8.7.4 Aquatic Ecology.................................................................................. 8-64 8.7.5 Terrestrial Ecology ............................................................................. 8-64 8.7.6 Human Health .................................................................................... 8-64 8.7.7 Land Use ............................................................................................ 8-64 8.7.8 Socioeconomics ................................................................................. 8-64 8.7.9 Transportation .................................................................................... 8-64 8.7.10 Aesthetics and Noise .......................................................................... 8-65 8.7.11 Historic and Archaeological Resources .............................................. 8-65 8.7.12 Environmental Justice ........................................................................ 8-65 8.7.13 Waste Management ........................................................................... 8-65 8.7.14 Summary of Impacts of No-Action Alternative .................................... 8-65 8.8 Alternatives Summary .................................................................................... 8-66 8.9 References .................................................................................................... 8-68
9.0 CONCLUSION
............................................................................................................ 9-1 9.1 Environmental Impacts of License Renewal ..................................................... 9-1 9.2 Comparison of Alternatives .............................................................................. 9-1 9.3 Resource Commitments................................................................................... 9-2 9.3.1 Unavoidable Adverse Environmental Impacts ...................................... 9-2 9.3.2 Short Term Versus Long Term Productivity .......................................... 9-2 9.3.3 Irreversible and Irretrievable Commitments of Resources .................... 9-3 x
9.4 Recommendations ........................................................................................... 9-3 10.0 LIST OF PREPARERS .............................................................................................. 10-1 11.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES OF THIS SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT ARE SENT......................................................................................................................... 11-1 12.0 INDEX ....................................................................................................................... 12-1 APPENDIX A. COMMENTS RECEIVED ON THE STP ENVIRONMENTAL REVIEW ............ A-1 APPENDIX B. NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE RENEWAL OF NUCLEAR POWER PLANTS .................................................. B-1 APPENDIX C. APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS ......................... C-1 APPENDIX D. CONSULTATION CORRESPONDENCE ........................................................D-1 APPENDIX E. CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE ....... E-1 APPENDIX F. NRC STAFF EVALUATION OF SEVERE ACCIDENT MITIGATION ALTERNATIVES .............................................................................................. F-1 xi
Figures Figure 1-1. Environmental Review Process .......................................................................... 1-2 Figure 1-2. Environmental Issues Evaluated For License Renewal ...................................... 1-4 Figure 2-1. Surface Water Bodies and Groundwater Wells in Vicinity of STP (STPNOC 2011b) ............................................................................................. 2-11 Figure 2-2. The STP Site and 1975 to 1976 Aquatic Ecology Sampling Location (NRC 2011b) .................................................................................................... 2-27 Figure 2-3. The STP Site and 2007 to 2008 Aquatic Ecology Sampling Locations from Segment C through the Upstream Portion of Segment B (NRC 2011b) .............................................................................................................. 2-28 Figure 2-4. The STP Site and 2007 to 2008 Aquatic Ecology Sampling Locations from the Downstream Portion of Segment B through Segment A (NRC 2011b) .............................................................................................................. 2-29 Figure 2-5. Most Commonly Recorded CBC Species, 2007 through 2011 (Audubon 2011) ................................................................................................................ 2-41 Figure 2-6. STP 50-mi (80-km) Radius Map (STPNOC 2010b) .......................................... 2-45 Figure 2-7. STP 6-mi (10-km) Radius Map (STPNOC 2010b) ............................................ 2-46 Figure 4-1. Species Richness of Aquatic Species Captured in Trawl Surveys from 1974, 1983, and 2007 through 2008................................................................. 4-23 Figure 4-2. 2010 Census Minority Block Groups Within a 50-mi Radius of STP ................. 4-49 Figure 4-3. Census 2010 Low-Income Block Groups Within a 50-mi Radius of STP .......... 4-51 xiii
Tables Table 2-1. Macroinvertebrates Collected in the Colorado River by Gear Type, 2007 to 2008 ............................................................................................................. 2-31 Table 2-2. Fish Collected in the Colorado River by Gear Type, 2007 to 2008 ................... 2-32 Table 2-3. Species Richness (number of species) in Three River Segments by Gear Type ................................................................................................................. 2-33 Table 2-4. Fish and Invertebrates Collected in the MCR by Gill Nets, Seines, and Trawls, 2007 to 2008. ....................................................................................... 2-35 Table 2-5. Fish and Invertebrates Collected in the MCR by Plankton Tows, 2007 to 2008 ................................................................................................................. 2-36 Table 2-6. Birds Observed in High Numbers for One Christmas Count Year, 2007 through 2011 .................................................................................................... 2-40 Table 2-7. Birds Documented on the STP Site, 2007 through 2008 .................................. 2-42 Table 2-8. ESA Species Under NMFS Jurisdiction That Occur in Matagorda County ........ 2-48 Table 2-8a. ESA Species Under FWS Jurisdiction That Occur in Matagorda County .......... 2-50 Table 2-8b. TXMM CBC Results for Federally Listed Species, 2008-2012 ......................... 2-53 Table 2-9. NMFS Species of Concern ............................................................................... 2-56 Table 2-10. Ecoregion 5 Species with Designated EFH ...................................................... 2-59 Table 2-11. State-listed Species.......................................................................................... 2-62 Table 2-12. STP, Employee Residence by County .............................................................. 2-64 Table 2-13. Housing in Brazoria and Matagorda Counties in 2010 ...................................... 2-64 Table 2-14. Brazoria and Matagorda County City Public Water Supply Systems (in mgd)................................................................................................................. 2-65 Table 2-15. Major Commuting Routes in the Vicinity of STP, 2010 AADT ........................... 2-66 Table 2-16. Population and Percent Growth in Brazoria and Matagorda Counties from 1970 to 2010 and Projected for 2020 to 2050 ........................................... 2-68 Table 2-17. Demographic Profile of the Population in the STP Two-County Socioeconomic ROI in 2010 ............................................................................. 2-68 Table 2-18. Seasonal Housing in Counties Located within 50 mi of STP............................. 2-69 Table 2-19. Migrant Farm Workers and Temporary Farm Labor in Counties Located within 50 mi of STP .......................................................................................... 2-70 Table 2-20. Major Industries in Matagorda County .............................................................. 2-71 Table 2-21. Major Industries in ROI..................................................................................... 2-71 Table 2-22. Estimated Income Information for STP ROI ...................................................... 2-72 Table 2-23. Comparison of STP Owner Payments with Taxing District Property Tax .......... 2-73 Table 2-24. STP, Units 1 and 2, Owner Payments to Other Taxing Districts in Matagorda ........................................................................................................ 2-75 Table 3-1. Category 1 Issues Related to Refurbishment ..................................................... 3-1 Table 3-2. Category 2 Issues Related to Refurbishment ..................................................... 3-2 Table 4-1. Land Use Issues ................................................................................................ 4-1 Table 4-2. Air Quality Issues ............................................................................................... 4-2 Table 4-3. Surface Water Resources Issues ....................................................................... 4-2 xv
Tables Table 4-4. Surface Water Withdrawals and Usage for Calendar Years 2003-2010 for STP, Units 1 and 2 ........................................................................................ 4-4 Table 4-5. Groundwater Resources Issues ......................................................................... 4-5 Table 4-6. Projected Drawdown and Change in Drawdown in Feet for the Deep Chicot Aquifer for Selected Distances ................................................................ 4-7 Table 4-7. Aquatic Resource Issues .................................................................................. 4-11 Table 4-8. Number (per 100 m3) of Macrozooplankton and Ichthyoplankton Collected in Plankton Samples in Front of the RMPF from 1984 and 1985....... 4-14 Table 4-9. Invertebrates and Fish Impinged at the RMPF during 1983-1984 Studies ....... 4-16 Table 4-10. Aquatic Species Collected during Entrainment Sampling in the MCRs CWIS for Units 1 and 2, 2007-2008 ................................................................. 4-17 Table 4-11. Aquatic Species Collected during Impingement Sampling in the MCRs CWIS for Units 1 and 2, 2007-2008 ................................................................. 4-18 Table 4-12. Terrestrial Resources Issues Identified in the GEIS.......................................... 4-27 Table 4-13. Protected Species Issues Identified in the GEIS............................................... 4-28 Table 4-14. ESA Effect Determinations for Federally Listed Species Under NMFS Jurisdiction ....................................................................................................... 4-29 Table 4-14a. ESA Effect Determinations for Federally Listed and Candidate Species Under NMFSs Jurisdiction ............................................................................... 4-30 Table 4-15. Human Health Issues ....................................................................................... 4-34 Table 4-16. Socioeconomics during the Renewal Term ...................................................... 4-41 Table 4-16a. Newly Revised 10 CFR Part 51 Issues ............................................................ 4-55 Table 4-17. Summary of Cumulative Impacts on Resource Areas ........................................ 4-75 Table 5-1. Issues Related to Postulated Accidents Two issues related to postulated accidents are evaluated under the National Environmental Protection Act (NEPA) in the license renewal reviewDBAs and severe accidents. ................. 5-1 Table 5-2. STP Core Damage Frequency for Internal Events .............................................. 5-5 Table 5-3. STP Core Damage Frequency for Fire Events ................................................... 5-6 Table 5-4. STP Core Damage Frequency for Seismic Events ............................................. 5-6 Table 5-5. STP Core Damage Frequency for Other External Events ................................... 5-7 Table 5-6. Breakdown of Population Dose by Containment Release Mode ......................... 5-8 Table 5-7. Phase II SAMA List (Cost-Benefit) for STP....................................................... 5-10 Table 6-1. Issues Related to the Uranium Fuel Cycle and Waste Management .................. 6-1 Table 6-2. Nuclear Greenhouse Gas Emissions Compared to Coal .................................... 6-5 Table 6-3. Nuclear Greenhouse Gas Emissions Compared to Natural Gas ........................ 6-6 Table 6-4. Nuclear Greenhouse Gas Emissions Compared to Renewable Energy Sources .............................................................................................................. 6-7 Table 7-1. Issues Related to Decommissioning ................................................................... 7-1 Table 8-1. Expected Annual Emissions from the Largest Stationary Sources of Emissions........................................................................................................... 8-6 Table 8-2. Summary of Environmental Impacts of the New Nuclear Alternative Compared to Continued Operation of STP, Units 1 and 2 ................................ 8-14 Table 8-3. Summary of Environmental Impacts of the NGCC Alternative Compared to Continued Operation of STP ........................................................................ 8-25 xvi
Tables Table 8-4. Summary of Environmental Impacts of the Supercritical Coal-Fired Alternative Compared to Continued Operation of STP, Units 1 and 2 ............... 8-38 Table 8-5. Summary of Environmental Impacts of the Combination Alternative Compared to Continued Operation of STP, Units 1 and 2 ................................ 8-52 Table 8-6. Summary of Environmental Impacts of the Purchased Power Alternative Compared to Continued Operation of STP, Units 1 and 2 ................................ 8-55 Table 8-7. Summary of Environmental Impacts of the No-Action Alternative Compared to Continued Operation of STP, Units 1 and 2 ................................ 8-66 Table 8-8. Summary of Environmental Impacts of Proposed Action and Alternatives ........ 8-67 Table 10-1. List of Preparers ............................................................................................... 10-1 Table A-1. Individuals Providing Comments During the Scoping Comment Period .............. A-1 Table A-2. Individuals Providing Comments During the Comment Period .......................... A-20 Table B-1. Summary of Issues and Findings ....................................................................... B-1 Table C-1. Licenses and Permits .........................................................................................C-1 Table C-2. Federal, State, and Local Laws and Other Requirements .................................. C-2 Table D-1. Consultation Correspondence ............................................................................D-1 Table E-1. Environmental Review Correspondence............................................................. E-1 Table F-1. STP Core Damage Frequency for Internal Events .............................................. F-4 Table F-2. STP Core Damage Frequency for Fire Events ................................................... F-5 Table F-3. STP Core Damage Frequency for Seismic Events ............................................. F-5 Table F-4. STP Core Damage Frequency for Other External Events ................................... F-6 Table F-5. Breakdown of Population Dose by Containment Release Mode ......................... F-7 Table F-6. STP PRA Historical Summary ............................................................................ F-9 Table F-7. SAMA Cost-Benefit Screening Analysis for STP .............................................. F-26 Table F-8. SAMA Cost-Benefit Screening Analysis for STP Using Conservative Source Terms................................................................................................... F-31 Table F-9. SAMA Cost-Benefit Screening Analysis for STP Using Updated Fire and Seismic Risk Analysis and Conservative Source Terms ................................... F-32 xvii
EXECUTIVE
SUMMARY
BACKGROUND By letter dated October 25, 2010, STP Nuclear Operating Company (STPNOC) submitted an application to the U.S. Nuclear Regulatory Commission (NRC) to issue renewed operating licenses for South Texas Project (STP), Units 1 and 2, for an additional 20-year period.
Pursuant to Title 10, Part 51.20(b)(2) of the Code of Federal Regulations (10 CFR 51.20(b)(2)),
the renewal of a power reactor operating license requires preparation of an environmental impact statement (EIS) or a supplement to an existing EIS. In addition, 10 CFR 51.95(c) states that the NRC shall prepare an EIS, which is a supplement to the Commissions NUREG-1437, Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants (GEIS).
Upon acceptance of STPNOCs application, the NRC staff began the environmental review process described in 10 CFR Part 51 by publishing a notice of intent to prepare a supplemental EIS (SEIS) and conduct scoping. In preparation of this SEIS for STP, the NRC staff performed the following:
- conducted public scoping meetings on March 2, 2011, in Bay City, Texas;
- conducted a site audit at the plant in July 2011;
- consulted with other agencies;
- conducted a review of the issues following the guidance set forth in NUREG-1555, Standard Review Plans for Environmental Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal; and
- considered public comments received during the scoping process.
PROPOSED ACTION STPNOC initiated the proposed Federal actionissuing renewed power reactor operating licensesby submitting an application for license renewal of STP, for which the existing licenses (NPF-76 and NPF-80) for STP, Units 1 and 2, will expire on August 20, 2027, and December 15, 2028, respectively. The NRCs Federal action is the decision whether or not to renew the licenses for an additional 20 years.
PURPOSE AND NEED FOR ACTION The purpose and need for the proposed action (issuance of a renewed license) is to provide an option that allows for power generation capability beyond the term of the current nuclear power plant operating license to meet future system generating needs. Such needs may be determined by other energy-planning decisionmakers, such as State, utility, andwhere authorizedFederal (other than NRC). This definition of purpose and need reflects the NRCs recognition that, unless there are findings in the safety review required by the Atomic Energy Act or findings in the National Environmental Policy Act (NEPA) environmental analysis that would lead the NRC to reject a license renewal application, the NRC does not have a role in the xix
Executive Summary energy-planning decisions of whether a particular nuclear power plant should continue to operate.
If the renewed license is issued, the appropriate energy-planning decisionmakers, along with STPNOC, will ultimately decide if the reactor units will continue to operate based on factors such as the need for power. If the operating licenses are not renewed, then the facility must be shut down on or before the expiration dates of the current operating licensesAugust 20, 2027, and December 15, 2028.
ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL The SEIS evaluates the potential environmental impacts of the proposed action. The environmental impacts from the proposed action are designated as SMALL, MODERATE, or LARGE. As set forth in the GEIS, Category 1 issues are those that meet all of the following criteria:
- The environmental impacts associated with the issue SMALL: Environmental is determined to apply either to all plants or, for some effects are not detectable or are so minor that they will issues, to plants having a specific type of cooling neither destabilize nor system or other specified plant or site characteristics. noticeably alter any important attribute of the resource.
- A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to the impacts, except MODERATE: Environmental effects are sufficient to alter for collective offsite radiological impacts from the fuel noticeably, but not to cycle and from high-level waste and spent fuel destabilize, important disposal. attributes of the resource.
- Mitigation of adverse impacts associated with the LARGE: Environmental effects are clearly noticeable issue is considered in the analysis, and it has been and are sufficient to determined that additional plant-specific mitigation destabilize important attributes measures are likely not to be sufficiently beneficial to of the resource.
warrant implementation.
For Category 1 issues, no additional site-specific analysis is required in this SEIS unless new and significant information is identified. Chapter 4 of this report presents the process for identifying new and significant information. Site-specific issues (Category 2) are those that do not meet one or more of the criterion for Category 1 issues; therefore, an additional site-specific review for these non-generic issues is required, and the results are documented in the SEIS.
On June 20, 2013, the NRC published a final rule (78 FR 37282) revising its environmental protection regulation, 10 CFR Part 51, Environmental protection regulations for domestic licensing and related regulatory functions. The final rule updates the potential environmental impacts associated with the renewal of an operating license for a nuclear power reactor for an additional 20 years. A revised GEIS, which updates the 1996 GEIS, provides the technical basis for the revised rule. The revised GEIS specifically supports the revised list of NEPA issues and associated environmental impact findings for license renewal contained in Table B-1 in Appendix B to Subpart A of the revised 10 CFR Part 51. The final rule consolidates similar Category 1 and 2 issues, changes some Category 2 issues into Category 1 issues, and consolidates some of those issues with existing Category 1 issues. The revised rule also adds new Category 1 and 2 issues.
The final rule became effective 30 days after publication in the Federal Register. Compliance by license renewal applicants is not required until 1 year from the date of publication (i.e., license renewal environmental reports submitted later than 1 year after publication must be xx
Executive Summary compliant with the new rule). Nevertheless, under NEPA, the NRC must now consider and analyze, in its license renewal SEISs, the potential significant impacts described by the final rules new Category 2 issues and, to the extent there is any new and significant information, the potential significant impacts described by the final rules new Category 1 issues.
The NRC staff has reviewed STPNOCs established process for identifying and evaluating the significance of any new and significant information (including the consideration and analysis of new issues associated with the recently approved revision to 10 CFR Part 51) on the environmental impacts of license renewal of STP. Neither STPNOC nor NRC identified information that is both new and significant related to Category 1 issues that would call into question the conclusions in the GEIS. This conclusion is supported by NRCs review of the applicants ER, other documentation relevant to the applicants activities, the public scoping process and substantive comments raised, and the findings from the environmental site audit conducted by the NRC staff. Further, the NRC staff did not identify any new issues applicable to STP that have a significant environmental impact. The NRC staff, therefore, relies upon the conclusions of the GEIS for all Category 1 issues applicable to STP.
Table ES-1 summarizes the Category 2 issues applicable to STP, if any, as well as the NRC staffs findings related to those issues. If the NRC staff determined that there were no Category 2 issues applicable for a particular resource area, the findings of the GEIS, as documented in Appendix B to Subpart A of 10 CFR Part 51, stand.
Table ES-1. NRC Conclusions Relating to Site-Specific Impacts of License Renewal Resource Area Relevant Category 2 Issues Adverse Impacts Land Use None SMALL Air Quality None SMALL Geology & Soils None SMALL Surface Water Resources Surface water use conflicts SMALL Groundwater Resources Groundwater use conflicts SMALL Radionuclides released to groundwater SMALL Aquatic Resources Entrainment & impingement of fish & shellfish SMALL Heat shock SMALL Terrestrial Resources Effects on terrestrial resources (non-cooling SMALL system impacts)
Protected Species Threatened or endangered species SMALL Human Health Issues Electromagnetic fieldsacute effects (electric SMALL to shock vs. chronic effects) MODERATE Microbiological organisms SMALL Socioeconomics Housing Impacts SMALL Public services (public utilities) SMALL Offsite land use SMALL Public services (public transportation) SMALL Historic & archaeological resources SMALL xxi
Executive Summary Resource Area Relevant Category 2 Issues Adverse Impacts Cumulative Impacts Air Quality MODERATE Water Resources SMALL to MODERATE Aquatic Resources MODERATE Terrestrial Resources MODERATE Socioeconomics SMALL to LARGE All Other Evaluated SMALL Resources With respect to environmental justice, the NRC staff has determined that there would be no disproportionately high and adverse impacts to these populations from the continued operation of STP during the license renewal period. Additionally, the NRC staff has determined that no disproportionately high and adverse human health impacts would be expected in special pathway receptor populations in the region as a result of subsistence consumption of water, local food, fish, and wildlife.
SEVERE ACCIDENT MITIGATION ALTERNATIVES Since STPNOC had not previously considered alternatives to reduce the likelihood or potential consequences of a variety of highly uncommon, but potentially serious, accidents at STP, 10 CFR 51.53(c)(3)(ii)(L) requires that STPNOC evaluate severe accident mitigation alternatives (SAMAs) in the course of the license renewal review. SAMAs are potential ways to reduce the risk or potential impacts of uncommon, but potentially severe accidents, and they may include changes to plant components, systems, procedures, and training.
The NRC staff reviewed the ERs evaluation of potential SAMAs. Based on the staffs review, the NRC staff concluded that none of the potentially cost beneficial SAMAs relate to adequately managing the effects of aging during the period of extended operation. Therefore, they need not be implemented as part of the license renewal, pursuant to 10 CFR Part 54.
ALTERNATIVES The NRC staff considered the environmental impacts associated with alternatives to license renewal. These alternatives include other methods of power generation and not renewing the STP operating licenses (the no-action alternative). Replacement power options considered were as follows:
- new nuclear generation,
- natural gas-fired combined-cycle generation (NGCC),
- supercritical coal-fired generation,
- combination alternative (NGCC, wind, and conservation or efficiency), and
- purchased power (coal, gas, wind, or nuclear).
The NRC staff initially considered many additional alternatives for analysis as alternatives to license renewal of STP; these were later dismissed due to technical, resource availability, or xxii
Executive Summary commercial limitations that currently exist and that the NRC staff believes are likely to continue to exist when the existing STP licenses expire. The no-action alternative by the NRC staff, and the effects it would have, were also considered. Where possible, the NRC staff evaluated potential environmental impacts for these alternatives located both at the STP site and at some other unspecified alternate location. Alternatives considered, but dismissed, were as follows:
- offsite nuclear-, gas-, and coal-fired capacity,
- energy conservation and energy efficiency,
- wind power,
- solar power,
- hydroelectric power,
- wave and ocean energy,
- geothermal power,
- municipal solid waste,
- biomass,
- biofuels,
- oil-fired power,
- fuel cells, and
- delayed retirement.
The NRC staff evaluated each alternative using the same impact areas that were used in evaluating impacts from license renewal.
RECOMMENDATION The staffs recommendation is that the adverse environmental impacts of license renewal for STP are not great enough to deny the option of license renewal for energy-planning decisionmakers. This recommendation is based on the following:
- analysis and findings in the GEIS,
- ER submitted by STPNOC,
- consultation with Federal, state, local, and tribal government agencies,
- the NRC staffs own independent review, and
- consideration of public comments received during the scoping process.
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ABBREVIATIONS AND ACRONYMS AADT average annual daily traffic ABWR advanced boiling-water reactor ac acre ac-ft acre-foot ACHP Advisory Council on Historic Preservation ADAMS Agencywide Documents Access and Management System AEA Atomic Energy Act of 1954 AEO Annual Energy Outlook AFW auxiliary feedwater ALARA as low as is reasonably achievable AMP aging management program AOC averted offsite property damage costs AOSC averted onsite costs APE area of potential effect AQCR air quality control region ASME American Society of Mechanical Engineers ATWS anticipated transient without scram BACT best available control technology BEG Bureau of Economic Geology BGS below ground surface BMP best management practice Bq/l becquerels per liter BTU British thermal unit C Celsius CAA Clean Air Act CAES compressed air energy storage CAPS Missouri Census Data Center Circular Area Profiling System CCW component cooling water CDF core damage frequency xxv
Abbreviations and Acronyms CDM control drive mechanism Ceq carbon equivalent CET containment event tree CFR U.S. Code of Federal Regulations cfs cubic feet per second CLB current licensing basis cm centimeter CO2 carbon dioxide COE cost of enhancement COL combined license Corps U.S. Army Corps of Engineers CPGCD Coastal Plains Groundwater Conservation District CWA Clean Water Act CWIS cooling water intake structure DBA design-basis accident dBA decibel A-weighting DG diesel generator DMR discharge monitoring report DOE U.S. Department of Energy DSEIS draft supplemental environmental impact statement DSHS Department of State Health Services DWS drinking water standard ECP essential cooling pond ECW essential cooling water ECWIS essential cooling water intake structure EFH essential fish habitat EIA Energy Information Administration EIS environmental impact statement ELF extremely low frequency EMF electromagnetic field EO Executive Order EOE Encyclopedia of Earth EPA U.S. Environmental Protection Agency xxvi
Abbreviations and Acronyms EPCRA Emergency Planning and Community Right-to-Know Act EPRI Electric Power Research Institute EPZ emergency planning zone ER Environmental Report ERCOT Electric Reliability Council of Texas ESA Endangered Species Act ESRP environmental standard review plan F Fahrenheit F&O facts and observations FES final environmental statement FIP Federal Implementation Plan FM Farm-to-Market FR Federal Register FRN Federal Register Notice FSAR final safety analysis report FSEIS final supplemental environmental impact statement ft foot ft3 cubic foot ft/s feet per second FWS U.S. Fish and Wildlife Service g gram gal gallon GCBO Gulf Coast Bird Observatory GCC global climate change GE General Electric GEA Geothermal Energy Association GEIS generic environmental impact statement GHG greenhouse gas GIWW Gulf Intercoastal Waterway GL generic letter GMFMC Gulf of Mexico Fishery Management Council gpd gallons per day gpm gallons per minute xxvii
Abbreviations and Acronyms GWMS gaseous waste management system ha hectare HAP hazardous air pollutant HARC Houston Advanced Research Center hr hour HVAC heating, ventilation, and air conditioning Hz hertz IAEA International Atomic Energy Agency IEEE Institute of Electrical and Electronics Engineers, Inc.
IES Institute of Educational Sciences IGCC integrated gasification combined cycle in. inch IPA integrated plant assessment IPCC Intergovernmental Panel on Climate Change IPE individual plant examination IPEEE individual plant examination of external events ISD independent school district ISEPA Iowa Stored Energy Plant Agency ISLOCA interfacing system loss-of-coolant accident kg kilogram km kilometer 2
km square kilometer kV kilovolt kWh kilowatt hour L/min liters per minute lb pound LCRA Lower Colorado River Authority LCRWPG Lower Colorado River Water Planning Group LERF large early release frequency LLNL Lawrence Livermore National Laboratory LLW low-level waste xxviii
Abbreviations and Acronyms LOCA loss-of-coolant accident LOOP loss of offsite power LRA license renewal application LWPS liquid waste processing system m meter m3 cubic meter m3/s cubic meters per second mA milliampere MAAP Modular Accident Analysis Program MACCS2 MELCOR Accident Consequence Code System 2 MACR maximum averted cost-risk MBTA Migratory Bird Treaty Act MCR main cooling reservoir MDC main drainage channel mg/l milligrams per liter mgd millions of gallons per day mGy milligray mi mile min minute MIT Massachusetts Institute of Technology mm millimeter MMI Modified Mercalli Intensity MMS U.S. Minerals Management Service mo month mrad millirad mrem millirem MSA Magnuson-Stevens Fishery Conservation and Management Act MSL mean sea level mSv millisievert MT metric ton MW megawatt MWd megawatt day MWe megawatt electric xxix
Abbreviations and Acronyms MWt megawatt thermal NAAQS National Ambient Air Quality Standards NASS National Agriculture Statistics Service NCES National Center for Education Statistics NEA Nuclear Energy Agency NEI Nuclear Energy Institute NEPA National Environmental Policy Act NESC National Electrical Safety Code NETL National Energy Technology Laboratory NGCC natural gas-fired combined-cycle NHPA National Historic Preservation Act NIEHS National Institute of Environmental Health Sciences NMFS National Marine Fisheries Service NPCC Northwest Power and Conservation Council NPDES National Pollutant Discharge Elimination System NRC U.S. Nuclear Regulatory Commission NRCS Natural Resources Conservation Service NREL National Renewable Energy Laboratory NRHP National Register of Historic Places NRR Office of Nuclear Reactor Regulation NWS National Weather Service OECD Organization for Economic Co-operation and Development OMB Office of Management and Budget OPSB Ohio Power and Siting Board PACR potential averted cost-risk pCi/L picocuries per liter PDP positive displacement pump PGA peak ground acceleration PM10 particulate matter, 10 m PM2.5 particulate matter, 2.5 m PNNL Pacific Northwest National Laboratory POST Parliamentary Office of Science and Technology xxx
Abbreviations and Acronyms PRA probabilistic risk assessment PSD prevention of significant deterioration PWR pressurized-water reactor RAI request for additional information RCB reactor containment building RCP reactor coolant pump RCRA Resources Conservation and Recovery Act RCS reactor coolant system rem roentgen equivalent man REMP Radiological Environmental Monitoring Program RG regulatory guide RMPF reservoir makeup pumping facility RMTS risk managed technical specification ROI region of influence ROW right-of-way RPC replacement power costs RRW risk reduction worth RTC Report to Congress SAMA severe accident mitigation alternative SAR safety analysis report SAWS San Antonio Water System SBDG standby diesel generator SCR selective catalytic reduction SEIS supplemental environmental impact statement SER safety evaluation report SG steam generator SGTR steam generator tube rupture SHPO State Historic Preservation Office SIP State Implementation Plan SNL Sandia National Laboratory SOARCA State-of-the-Art Reactor Consequence Analysis SPDES State Pollutant Discharge Elimination System SSC system, structure, and component xxxi
Abbreviations and Acronyms SSE safe shutdown earthquake STP South Texas Project STPNOC South Texas Project Nuclear Operating Company Sv sievert SWPS solid waste processing system TAC Texas Administrative Code TCEQ Texas Commission on Environmental Quality TCPA Texas Comptroller of Public Accounts TDS total dissolved solids THC Texas Historical Commission TMMSN Texas Marine Mammal Stranding Network TPDES Texas Pollutant Discharge Elimination System TPWD Texas Parks and Wildlife Department tpy tons per year TS technical specification TSC Technical Support Center TSECO Texas State Energy Conservation Office TSHA Texas State Historical Association TSP total suspended particles TSWGW Texas Saltwater and Fishing Guides Web TWDB Texas Water Development Board USCB U.S. Census Bureau USGS U.S. Geological Survey VOC volatile organic compound WEG Wild Earth Guardians WMA Wildlife Management Area WOE weight-of-evidence WSEC White Stallion Energy Center yr year xxxii
1.0 PURPOSE AND NEED FOR ACTION Under the U.S. Nuclear Regulatory Commissions (NRCs) environmental protection regulations in Title 10, Part 51, of the Code of Federal Regulations (10 CFR 51)which implement the National Environmental Policy Act (NEPA)issuance of a new nuclear power plant operating license requires the preparation of an environmental impact statement (EIS).
The Atomic Energy Act of 1954 (AEA) specifies that licenses for commercial power reactors can be granted for up to 40 years. NRC regulations (10 CFR 54.31) allow for an option to renew a license for up to an additional 20 years. The initial 40-year licensing period was based on economic and antitrust considerations rather than on technical limitations of the nuclear facility.
The decision to seek a license renewal rests entirely with nuclear power facility owners and, typically, is based on the facilitys economic viability and the investment necessary to continue to meet NRC safety and environmental requirements. The NRC makes the decision to grant or deny license renewal based on whether the applicant has demonstrated that the environmental and safety requirements in the agencys regulations can be met during the period of extended operation.
1.1 Proposed Federal Action STP Nuclear Operating Company (STPNOC) initiated the proposed Federal action by submitting an application for license renewal of South Texas Project (STP), Units 1 and 2, for which the existing licenses (NPF-76 and NPF-80) expire on August 20, 2027, and December 15, 2028, respectively. The NRCs Federal proposed action is the decision whether to renew the licenses for an additional 20 years.
1.2 Purpose and Need for the Proposed Federal Action The purpose and need for the proposed action (issuance of a renewed license) is to provide an option that allows for power generation capability beyond the term of a current nuclear power plant operating license to meet future system generating needs, as such needs may be determined by other energy-planning decisionmakers. This definition of purpose and need reflects the NRCs recognition that, unless there are findings in the safety review required by the AEA or findings in the NEPA environmental analysis that would lead the NRC to reject a license renewal application (LRA), the NRC does not have a role in the energy-planning decisions of State regulators and utility officials as to whether a particular nuclear power plant should continue to operate.
If the renewed license is issued, State regulatory agencies and STPNOC will ultimately decide whether the plant will continue to operate based on factors such as the need for power or other matters within the States jurisdiction or the purview of the owners. If the operating license is not renewed, then the facility must be shut down on or before the expiration dates of the current operating licensesAugust 20, 2027, and December 15, 2028, respectively.
1.3 Major Environmental Review Milestones STPNOC submitted an Environmental Report (ER) (STPNOC 2010b) as part of its LRA (STPNOC 2010a) in October 2010. After reviewing the LRA and ER for sufficiency, the NRC staff published a Federal Register Notice of Acceptability and Opportunity for Hearing 1-1
(76 FRN 2426) on January 13, 2011. Then, on January 31, 2011, the NRC published another notice in the Federal Register (76 FR 5410) on the intent to conduct scoping, thereby beginning the 60-day scoping period.
The NRC staff held two public scoping meetings on March 2, 2011, in Bay City, Texas. The comments received during the scoping process are presented in their entirety in Environmental Impact Statement Scoping Process, Summary Report, South Texas Project, Units 1 and 2, Bay City, published in 2012 (NRC 2012a). The staff presents comments considered to be within the scope of the environmental license renewal review and the NRC responses in Appendix A of this supplemental environmental impact statement (SEIS).
In order to independently verify information provided in the ER, the NRC staff conducted a site audit at STP, Units 1 and 2, in July 2011. During the site audit, the staff met with plant personnel, reviewed specific documentation, toured the facility, and met with interested Federal, State, and local agencies. A summary of that site audit and the attendees is contained in the Audit Summary Report, published in August 2011 (NRC 2011).
Upon completion of the scoping period and site audit, the NRC staff compiled its findings in the draft SEIS (Figure 1-1). This document is made available for public comment for 45 days.
During this time, the staff would host public meetings and collect public comments. Based on the information gathered, it would amend the draft SEIS findings, as necessary, and publish the final SEIS for license renewal.
Figure 1-1. Environmental Review Process The NRC has established a license renewal review process that can be completed in a reasonable period with clear requirements to assure safe plant operation for up to an additional 20 years of plant life. The NRC staff conducts the safety review simultaneously with the environmental review. The staff documents the findings of the safety review in a safety 1-2
evaluation report (SER). The findings in the SEIS and the SER are both factors in the NRCs decision to either grant or deny the issuance of a renewed license.
1.4 Generic Environmental Impact Statement The NRC staff performed a generic assessment of the environmental impacts associated with license renewal to improve the efficiency of its license renewal review. The Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants (GEIS),
NUREG-1437 (NRC 1996, 1999), documented the results of the staffs systematic approach to evaluate the environmental consequences of renewing the licenses of individual nuclear power plants and operating them for an additional 20 years. The staff analyzed in detail and resolved those environmental issues that could be resolved generically in the GEIS.
The GEIS establishes 92 separate issues for the NRC staff to independently verify. Of these issues, the NRC staff determined that 69 are generic to all plants (Category 1) while 21 issues do not lend themselves to generic consideration (Category 2). Two other issues remain uncategorized (environmental justice and chronic effects of electromagnetic fields). The staff evaluated these issues on a site-specific basis (along with the Category 2 issues). Appendix B provides the list of all 92 issues.
For each potential environmental issue, in the GEIS, the NRC staff performs the following:
- describes the activity that affects the environment,
- identifies the population or resource that is affected,
- assesses the nature and magnitude of the impact on the affected population or resource,
- characterizes the significance of the effect for both beneficial and adverse effects,
- determines whether the results of the analysis apply to all plants, and
- considers whether additional mitigation measures would be warranted for impacts that would have the same significance level for all plants.
The NRCs standard of significance for impacts was established using the Council on Environmental Quality (CEQ) terminology for significant. The NRC established three levels of significance for potential impactsSMALL, MODERATE, and LARGE, as defined below.
SMALL: Environmental effects are not Significance indicates the importance of likely detectable or are so minor that they will neither environmental impacts and is determined by destabilize nor noticeably alter any important considering two variables: context and intensity.
attribute of the resource. Context is the geographic, biophysical, and social context in which the effects will occur.
MODERATE: Environmental effects are sufficient to alter noticeably, but not to destabilize, Intensity refers to the severity of the impact, in whatever context it occurs.
important attributes of the resource.
LARGE: Environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource.
The GEIS includes a determination of whether the analysis of the environmental issue could be applied to all plants and whether additional mitigation measures would be warranted (Figure 1-2). Issues are assigned a Category 1 or a Category 2 designation. As set forth in the GEIS, Category 1 issues are those that meet the following criteria:
1-3
- The environmental impacts associated with the issue have been determined to apply either to all plants or, for some issues, to plants having a specific type of cooling system or other specified plant or site characteristics.
- A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to the impacts (except for collective offsite radiological impacts from the fuel cycle and from high-level waste and spent fuel disposal).
- Mitigation of adverse impacts associated with the issue has been considered in the analysis, and it has been determined that additional plant-specific mitigation measures are likely not to be sufficiently beneficial to warrant implementation.
Figure 1-2. Environmental Issues Evaluated For License Renewal In the GEIS, 92 issues were evaluated.
A site-specific analysis is required for 23 of those 92 issues On June 20, 2013, the NRC published a final rule (78 FR 37282) revising its environmental protection regulation, 10 CFR Part 51, Environmental protection regulations for domestic licensing and related regulatory functions.
1-4
Specifically, the final rule updates the potential environmental impacts associated with the renewal of an operating license for a nuclear power reactor for an additional 20 years. A revised GEIS (NRC 2013), which updates the 1996 GEIS, provides the technical basis for the final rule. The revised GEIS specifically supports the revised list of NEPA issues and associated environmental impact findings for license renewal contained in Table B-1 in Appendix B to Subpart A of the revised 10 CFR Part 51. The revised GEIS and final rule reflect lessons learned and knowledge gained during previous license renewal environmental reviews.
In addition, public comments received on the draft revised GEIS and rule and during previous license renewal environmental reviews were re-examined to validate existing environmental issues and identify new ones.
The final rule identifies 78 environmental impact issues, of which 17 will require plant-specific analysis. The final rule consolidates similar Category 1 and 2 issues, changes some Category 2 issues into Category 1 issues, and consolidates some of those issues with existing Category 1 issues. The final rule also adds new Category 1 and 2 issues. The new Category 1 issues include geology and soils, exposure of terrestrial organisms to radionuclides, exposure of aquatic organisms to radionuclides, human health impact from chemicals, and physical occupational hazards. Radionuclides released to groundwater, effects on terrestrial resources (non-cooling system impacts), minority and low-income populations (i.e., environmental justice),
and cumulative impacts were added as new Category 2 issues.
The final rule became effective 30 days after publication in the Federal Register. Compliance by license renewal applicants is not required until 1 year from the date of publication (i.e., license renewal environmental reports submitted later than 1 year after publication must be compliant with the new rule). Nevertheless, under NEPA, the NRC must now consider and analyze, in its license renewal SEISs, the potential significant impacts described by the final rules new Category 2 issues and, to the extent there is any new and significant information, the potential significant impacts described by the final rules new Category 1 issues.
1.5 Supplemental Environmental Impact Statement The SEIS presents an analysis that considers the environmental effects of the continued operation of STP, Units 1 and 2, alternatives to license renewal, and mitigation measures for minimizing adverse environmental impacts. Chapter 8 contains analysis and comparison of the potential environmental impacts from alternatives while Chapter 9 presents the recommendation of the NRC (the Commission) on whether or not the environmental impacts of license renewal are so great that preserving the option of license renewal would be unreasonable. The final recommendation will be made after consideration of comments received on the draft SEIS during the public comment period.
In the preparation of this SEIS for STP, Units 1 and 2, the NRC staff carried out the following activities:
- reviewed the information provided in the STPNOCs ER;
- consulted with other Federal, State, local agencies, and tribal nations;
- conducted an independent review of the issues during site audit; and
- considered the public comments received for the review (during the scoping process and, subsequently, on the draft SEIS).
1-5
New information can be identified from many sources, including the applicant, the NRC, other New and significant information either identifies agencies, or public comments. If a new issue is a significant environmental issue that was not covered in the GEIS or was not considered in the revealed, it is first analyzed to determine whether analysis in the GEIS and leads to an impact it is within the scope of the license renewal finding that is different from the finding presented environmental evaluation. If the new issue is not in the GEIS.
addressed in the GEIS, the NRC staff would determine the significance of the issue and document the analysis in the SEIS.
1.6 Cooperating Agencies During the scoping process, no Federal, State, or local agencies were identified as cooperating agencies in the preparation of this SEIS.
1.7 Consultations The Endangered Species Act of 1973, as amended; the Magnuson-Stevens Fisheries Management Act of 1996, as amended; and the National Historic Preservation Act of 1966 require that Federal agencies consult with applicable State and Federal agencies and groups prior to taking action that may affect endangered species, fisheries, or historic and archaeological resources, respectively. The NRC consulted with the following agencies and groups (Appendix D to this SEIS includes copies of consultation documents):
- Advisory Council on Historic Preservation (ACHP),
- State Historic Preservation Office (SHPO),
- Ysleta del Sur Pueblo,
- Alabama-Coushatta Tribe,
- Kiowa Tribe of Oklahoma,
- Comanche Nation,
- Tonkawa Tribe of Oklahoma,
- Apalachicola Creek,
- Lipan Apache Tribe of Texas,
- Lipan Apache Band of Texas,
- Tap Pulam-Coahuiltecan Nation,
- Kickapoo Traditional Council,
- Pamaque Clan of Coahuila Y Tejas, and
- Apalachicola Band of Creek Indians.
1-6
1.8 Correspondence During the course of the environmental review, the NRC staff contacted Federal, State, regional, local, and tribal agencies listed in Section 1.7. Appendix E contains a chronological list of all documents sent and received during the environmental review.
In addition, Chapter 11 provides a list of persons who requested and received a copy of this SEIS.
1.9 Status of Compliance STPNOC is responsible for complying with all NRC regulations and other applicable Federal, State, and local requirements. Appendix H of the GEIS describes some of the major applicable Federal statutes.
There are numerous permits and licenses issued by Federal, State, and local authorities for activities at STP, Units 1 and 2. Appendix C contains further discussion by the staff about status of compliance. Regarding Coastal Zone Management Act (CZMA) compliance status, pursuant to Section 506.11(13) of Texas Administrative Code, STPNOC has obtained and maintained satisfactorily a consistency certification in accordance with the CZMA (Section 2.3 contains further discussion about CZMA compliance status for STP license renewal).
1.10 References 10 CFR 51. Code of Federal Regulations, Title 10, Energy, Part 51, Environmental protection regulations for domestic licensing and related regulatory functions.
10 CFR 54. Code of Federal Regulations, Title 10, Energy, Part 54, Requirements for renewal of operating licenses for nuclear power plants.
76 FR 2426. U.S. Nuclear Regulatory Commission. Notice of Acceptance for Docketing of the Application and Notice of Opportunity for Hearing Regarding Renewal of Facility Operating License Numbers NPF-76 and NPF-80 for an Additional 20-Year Period, STP Nuclear Operating Company, South Texas Project, Units 1 and 2. Federal Register. Volume 76(9):
2426-2428. January 13, 2011.
76 FRN 5410. U.S. Nuclear Regulatory Commission. STP Nuclear Operating Company; Notice of Intent To Prepare an Environmental Impact Statement and Conduct the Scoping Process for South Texas Project, Units 1 and 2. Federal Register. Volume 76(20):
5410-5411. January 31, 2011.
78 FR 37282. U.S. Nuclear Regulatory Commission. Revisions to Environmental Review for Renewal of Nuclear Power Plant Operating Licenses. June 20, 2013.
[AEA] Atomic Energy Act of 1954, as amended. 42 U.S.C. §2011, et seq.
Endangered Species Act of 1973, as amended. 16 U.S.C. §1531, et seq.
Magnuson-Stevens Fishery Conservation and Management Act, as amended.
16 U.S.C. §1801 et seq.
[NEPA] National Environmental Policy Act of 1969, as amended. 42 U.S.C. §4321, et seq.
National Historic Preservation Act of 1966. 16 U.S.C. §470, et seq.
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[NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG-1437. May 1996.
ADAMS Nos. ML040690705 and ML040690738.
[NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3, Transportation, Table 9.1, Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC:
NRC. NUREG-1437, Volume 1, Addendum 1. August 1999. ADAMS No. ML040690720.
[NRC] U.S. Nuclear Regulatory Commission. 2011. Summary of site audit related to the review of the license renewal application for South Texas Project, Units 1 and 2.
August 4, 2011. ADAMS No. ML11196A005.
[NRC] U.S. Nuclear Regulatory Commission. 2012a. Environmental Impact Statement Scoping Process, Summary Report, South Texas Project, Units 1 and 2, Bay City, TX.
Washington, DC: NRC. 2012. ADAMS No. ML11153A082.
[NRC] U.S. Nuclear Regulatory Commission. 2013. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: Office of Nuclear Reactor Regulation.
NUREG-1437, Revision 1, Volumes 1, 2, and 3. June 2013. ADAMS Nos. ML13106A241, ML13106A242, and ML13106A244.
[STPNOC] South Texas Plant Nuclear Operating Company. 2010a. South Texas Project, Units 1 and 2, Docket Nos. STN 50-498, STN 50-499, License Renewal Application.
October 25, 2010. ADAMS No. ML103010257.
[STPNOC] South Texas Plant Nuclear Operating Company. 2010b. South Texas Project, Applicants Environmental ReportOperating License Renewal Stage, South Texas Project Units 1 & 2. September 2010. ADAMS No. ML103010263.
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2.0 AFFECTED ENVIRONMENT South Texas Project (STP) is located in Matagorda County, Texas, approximately 70 mi (110 km) south-southwest of Houston. The plant consists of two reactor units. Each nuclear reactor is a pressurized-water reactor (PWR) with steam generators producing steam that turns turbines to generate electricity. For purposes of the evaluation in this report, the affected environment is the environment that currently exists at and around STP. Because existing conditions are at least partially the result of past construction and operation at the plant, the impacts of these past and ongoing actions and how they have shaped the environment are presented here. The facility and its operation are described in Section 2.1, and the affected environment is presented in Section 2.2.
2.1 Facility Description STP is a two-unit, nuclear-powered steam electric generating facility that began commercial operation in August 1988 (Unit 1) and June 1989 (Unit 2). The nuclear reactor for each unit is a Westinghouse PWR, producing a reactor core rated thermal power of 3,853 megawatts-thermal 2-1 (MWt). The nominal net electrical capacity is 1,250 megawatts-electric (MWe). In this supplemental environmental impact statement (SEIS), the use of STP is referring to the site where the existing STP, Units 1 and 2 are located. The use of STPNOC is referring to the applicant (STP Nuclear Operating Company) who submitted the license renewal application (LRA). The use of STP, Units 1 and 2 is referring to the distinction between the existing reactor units and the proposed new reactor units, STP, Units 3 and 4.
2.1.1 Reactor and Containment Systems The nuclear steam supply system at STP is a four-loop Westinghouse PWR. The reactor core heats water, which is pumped to four steam generators where the heat boils the water on the shell-side into steam that is routed to the turbines. The steam turns the turbines, which are connected to the electrical generator. The Units 1 and 2 steam generators were replaced in 2000 and 2002, respectively, with new Westinghouse steam generators.
The nuclear fuel is low-enriched uranium dioxide with enrichments less than 5 percent by weight uranium-235 and fuel burnup levels with a batch average of approximately 45,000 megawattdays (MWd) per metric ton uranium at discharge. Maximum burnup would not exceed 60,000 MWd per metric ton uranium. STP operates on an 18-month refueling cycle.
The reactor, steam generators, and related systems are enclosed in a containment building.
The containment building is a post-tensioned, reinforced concrete cylinder with a slab base and a hemispherical dome. A welded steel liner is attached to the inside face of the concrete shell to ensure a high degree of leak tightness. In addition, the 4-ft (1.2-m)-thick concrete walls serve as a radiation shield.
2.1.2 Radioactive Waste Management STP uses liquid, gaseous, and solid waste By design, the operation of nuclear power plants processing systems to collect and treat, as is expected to result in small releases of radiological effluents (gaseous, liquid, and solid) needed, radioactive materials that are produced through controlled processes. However, releases as by-products of plant operations. These must meet stringent NRC and EPA regulatory materials are produced in the form of limits.
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Affected Environment (a) activation products resulting from irradiation of reactor water and impurities, principally metallic corrosive products, therein and (b) fission products resulting from their migration through the fuel cladding. Radioactive materials in liquid and gaseous effluents (controlled releases from STP) are reduced to levels that ensure compliance with U.S. Nuclear Regulatory Commission (NRC) radiation protection regulations in Title 10, Part 20, of the U.S. Code of Federal Regulations (10 CFR Part 20), and they are as low as is reasonably achievable (ALARA), in accordance with Appendix I to 10 CFR Part 50.
Reactor fuel assemblies that have exhausted some of their fissile uranium content (related to the ability to sustain nuclear criticality chain reaction) are referred to as spent fuel (or used fuel).
Spent fuel assemblies are removed from the reactor core and replaced by new fuel assemblies during routine refueling outages, typically every 18 months. The spent fuel assemblies are then stored in the spent fuel pool.
Systems used at STP to process radioactive liquid, gaseous, and solid wastes are described in the following sections.
2.1.2.1 Radioactive Gaseous Waste System The objectives of the gaseous waste management system (GWMS) are to process and control the release of radioactive gaseous effluents into the environment to be within the requirements of 10 CFR Part 20 and to be consistent with the ALARA guidelines set forth in Appendix I to 10 CFR Part 50. The GWMS also removes fission product gases from the reactor coolant system and from equipment and piping (i.e., reduces the amount of radioactivity from the gases before they are released into the environment). The GWMS is designed so that radiation exposure to plant workers is within NRC dose limits in 10 CFR 20.1201 and ALARA.
The GWMS processes the waste gas to control and limit the amount of radioactive noble gas and iodine released into the environment. An inlet header water removal system removes water vapor and heat from the gas stream prior to processing the gas through charcoal beds. The charcoal beds are designed to delay the passage of the gases, which allows for radioactive decay of the noble gases and adsorption of radioiodine as the gas stream moves through the charcoal beds. At the end of the charcoal bed, the gas is filtered by high efficiency filters to remove charcoal dust. There is also a radiation monitor that measures the radioactivity in the waste gas and can automatically terminate the release in the event radioactivity exceeds predetermined levels.
The primary sources of radioactive gas in the plant are as follows:
- the turbine generator building process vents,
- the auxiliary feedwater pump turbine exhaust, which is vented directly to the atmosphere through the isolation valve cubicle process vent,
- the reactor containment building ventilation system,
- the mechanical auxiliary building,
- the fuel handling building ventilation system, and
- the reactor coolant gases.
2.1.2.2 Radioactive Liquid Waste System The function of STPNOCs liquid waste processing system (LWPS) is to collect and process radioactive liquid wastes to reduce radioactivity and chemical concentrations to levels acceptable for discharge to the environment or to recycle the liquids for use in plant systems.
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Affected Environment The principal objectives of the LWPS are to collect liquid wastes that may contain radioactive material and to maintain sufficient processing capability so that liquid waste may be discharged to the environment below the regulatory limits of 10 CFR Part 20 and consistent with the ALARA guidelines in Appendix I to 10 CFR Part 50.
Sources of liquid waste sent to the LWPS include floor drains, equipment drains, laundry and hot shower drains, and contaminated wastes from plant systems and components. Processing of the liquid waste is performed using several different methods including filtration, demineralization, evaporation, or a combination of the three methods.
Liquid releases from the plant are made in accordance with NRC radiation protection standards in 10 CFR Part 20 and the ALARA guidelines set forth in Appendix I to 10 CFR Part 50. The waste is routed through a monitor that measures the radioactivity and can automatically terminate the release in the event radioactivity exceeds predetermined levels. The liquid waste is discharged into the main cooling reservoir (MCR). The entire MCR is within the STP site boundary, and the public is prohibited from access to the MCR.
2.1.2.3 Radioactive Solid Waste Processing Systems The solid waste processing system (SWPS) is designed to process, package, and store the solid radioactive wastes generated by plant operations until they are shipped off site to a vendor for further processing or for permanent disposal at a licensed burial facility or both. The SWPS is designed to meet the following objectives:
- to collect process, package, temporary store, and prepare the waste for shipment;
- to maintain radiation exposes to plant personnel within the dose limits of 10 CFR Part 20.1201 and ALARA;
- to package and transport the waste in compliance with NRC regulations 10 CFR Parts 61 and 71 and the U.S. Department of Transportation regulations 49 CFR Parts 170 through 179; and
- to stabilize wet waste using either an onsite or offsite system from a qualified vendor.
The permanently installed portion of the SWPS is located within the mechanical-electrical auxiliary building. Identical systems containing the following major subsystems are used for STP, Units 1 and 2:
- Concentrate storage tank and transfer subsystemThis subsystem includes a 5,000-gallon storage tank equipped with a mixer, heat tracing, and level controls to prevent overflows. The applicant states that this system is currently not in use.
- Spent resin transfer subsystemThis system is used to transfer spent resin filter media to a vendor-supplied processing system.
- Expended cartridge filter transfer subsystemThis system handles filter cartridges used to process radioactive liquid wastes. The system uses shielding and long-handled tools to safely handle the filters for insertion into a shielded cask that will be transported to a disposal facility.
- Overhead crane subsystemThis is a remotely operated 7 1/2-ton overhead bridge crane with automatic grapples to move loaded containers from the 2-3
Affected Environment storage areas to the truck loading area and to stabilize wet waste using either an onsite or offsite system from a qualified vendor.
- Dry active waste areaThis area is used to sort and package dry active waste. The waste is typically sent to an offsite vendor for volume reduction prior to disposal.
- Chemical addition subsystemThis subsystem provides chemical adjustment of liquids to maintain pH control for efficient processing.
- Vendor-supplied onsite subsystemThis subsystem consists of control panels used to control dewatering pumps, fill and dewatering heads, level controls, and monitoring instruments.
Radioactive waste is stored within plant buildings until it is shipped off site for further processing by a vendor or disposal or both. The storage areas have restricted access and shielding to reduce radiation rates to plant workers. The radioactive waste is divided into high activity and low activity storage areas. Separation of the high activity storage area from the building exterior by the low activity area provides for a reduction in radiation levels to plant workers in the truck loading area.
The Texas Low-Level Radioactive Waste Disposal Compact Facility, located in Andrews County, Texas, opened on November 10, 2011. The facility is licensed by the State of Texas to dispose of Class A, B, and C low-level waste (LLW). This LLW disposal facility is available to STP for the disposal of its LLW. With the availability of this disposal facility, the current LLW handling and storage facilities are expected to be adequate to handle LLW waste generated during the license renewal term.
In the event of an interruption in LLW disposal capability, STP has the ability to store its waste on site. STP has an onsite staging facility, located west of STP Unit 2. This facility can provide a staging area for the waste for up to 5 years of operation of both reactor units.
2.1.3 Nonradiological Waste Management STP generates nonradioactive wastes as part of routine plant maintenance, cleaning activities, and plant operations. In general, Resources Conservation and Recovery Act (RCRA) waste regulations governing the disposal of solid and hazardous waste are contained in 40 CFR Parts 239 through 299. Specifically, 40 CFR Parts 239 through 259 contain regulations for solid (nonhazardous) waste, and 40 CFR Parts 260 through 279 contain regulations for hazardous waste. RCRA, Subtitle C, establishes a system for controlling hazardous waste from cradle to grave, and RCRA, Subtitle D, encourages states to develop comprehensive plans to manage nonhazardous solid waste and mandates minimum technological standards for municipal solid waste landfills. Texas State RCRA regulations are administered by the Texas Commission on Environmental Quality (TCEQ) and address the identification, generation, minimization, transportation, and final treatment, storage, or disposal of hazardous and nonhazardous waste.
2.1.3.1 Nonradioactive Waste Streams STP generates solid waste, defined by the RCRA, as part of routine plant maintenance, cleaning activities, and plant operations. Texas administers the RCRA Program in Texas Administrative Code (TAC) 335.
The U.S. Environmental Protection Agency (EPA) classifies certain nonradioactive wastes as hazardous based on characteristics including ignitability, corrosivity, reactivity, or toxicity (hazardous wastes are listed in 40 CFR Part 261). State-level regulators may add wastes to 2-4
Affected Environment EPAs list of hazardous wastes. RCRA supplies standards for the treatment, storage, and disposal of hazardous waste for hazardous waste generators (regulations are available in 40 CFR Part 262).
EPA recognizes the following main types of the hazardous waste generators (40 CFR 260.10) based on the quantity of the hazardous waste produced:
- large quantity generators that generate 2,200 lb (1,000 kg) per month or more of hazardous waste, more than 2.2 lb (1 kg) per month of acutely hazardous waste, or more than 220 lb (100 kg) per month of acute spill residue or soil;
- small quantity generators that generate more than 220 lb (100 kg) but less than 2,200 lb (1,000 kg) of hazardous waste per month; and
- conditionally exempt small quantity generators that generate 220 lb (100 kg) or less per month of hazardous waste, 2.2 lb (1 kg) or less per month of acutely hazardous waste, or less than 220 lb (100 kg) per month of acute spill residue or soil.
TCEQ recognizes STP as a small quantity generator of hazardous wastes under TAC 335. STP hazardous wastes include waste oil, grease, electrohydraulic fluid, adhesives, liquid paint, and solvent for fuel blending and thermal energy recovery. Used oil diesel fuels and used oil filters are sent to a recycling vendor for re-processing. Lead-acid batteries are returned, when possible, to the original manufacturer for recycling or are shipped to a registered battery recycler.
EPA classifies several hazardous wastes as universal wastes; these include batteries, pesticides, mercury-containing items, and fluorescent lamps. TCEQ has incorporated EPAs regulations (40 CFR Part 273) regarding universal wastes in TAC 335.261. Universal wastes produced by STP are disposed of or recycled in accordance with TCEQ regulations.
Conditions and limitations for wastewater discharge by STP are specified in Texas Pollution Discharge Elimination System (TPDES) Permit No. WQ0001908000. In 2009, STP applied for a renewal of this wastewater discharge permit and, at the writing of this SEIS, continues to work with TCEQ on its renewal. Radioactive liquid waste is addressed in Section 2.1.2 of this SEIS.
Section 2.2.4 gives more information about STP TPDES permit and permitted discharges, including a discussion of the NRC staffs request for information about the STP TPDES permit status.
The Emergency Planning and Community Right-to-Know Act (EPCRA) requires applicable facilities to supply information about hazardous and toxic chemicals to local emergency planning authorities and EPA (42 USC 11001). On October 17, 2008, EPA finalized several changes to the Emergency Planning (Section 302), Emergency Release Notification (Section 304), and Hazardous Chemical Reporting (Sections 311 and 312) regulations (63 FR 31268). STP is subject to Federal EPCRA reporting requirements; thus, STP submits an annual Section 312 (Tier II) report on hazardous substances to local emergency response agencies.
2.1.3.2 Pollution Prevention and Waste Minimization The EPA encourages the use of environmental management systems (EMSs) for organizations to assess and manage the environmental impacts associated with their activities, products, and services in an efficient and cost-effective manner. The EPA defines an EMS as a set of processes and practices that enable an organization to reduce its environmental impacts and increase its operating efficiency. EMSs help organizations fully integrate a wide-range of environmental initiatives, establish environmental goals, and create a continuous monitoring process to help meet those goals. The EPA Office of Solid Waste especially advocates the use 2-5
Affected Environment of EMSs at RCRA-regulated facilities to improve environmental performance, compliance, and pollution prevention (EPA 2010a).
Related to the use of EMSs, STP has waste minimization measures in place currently, as verified during the STP site visit conducted by NRC in July 2011. In support of nonradiological waste-minimization efforts, EPAs Office of Prevention and Toxics has established a clearinghouse that supplies information about waste management and technical and operational approaches to pollution prevention (EPA 2010c). The EPA clearinghouse can be used as a source for additional opportunities for waste minimization and pollution prevention at STP, as appropriate.
2.1.4 Plant Operation and Maintenance Maintenance activities conducted at STP include inspection, testing, and surveillance to maintain the current licensing basis (CLB) of the facility and to ensure compliance with environmental and safety requirements. Various programs and activities currently exist at STP to maintain, inspect, test, and monitor the performance of facility equipment. These maintenance activities include inspection requirements for reactor vessel materials, boiler and pressure vessel inservice inspection and testing, the Maintenance Structures Monitoring Program, and maintenance of water chemistry.
Additional programs include those carried out to meet technical specification (TS) surveillance requirements, those implemented in response to the NRC generic communications, and various periodic maintenance, testing, and inspection procedures. Certain program activities are carried out during the operation of the unit, while others are carried out during scheduled refueling outages. Nuclear power plants must periodically discontinue the production of electricity for refueling, periodic inservice inspection, and scheduled maintenance. STP operates on an 18-month refueling cycle.
2.1.5 Power Transmission System Nine 345-kV lines were constructed specifically to connect STP to the regional power grid.
These lines share transmission line corridors and are owned by four service providers:
American Electric Power Texas Central Company, CenterPoint Energy, City of Austin, and CPS Energy. This section summarizes each line and discusses vegetative maintenance procedures.
Below, the common name for each line appears first, followed by its Electric Reliability Council of Texas (ERCOT) name in parentheses. The discussion of the power transmission system is adapted from the ER (STPNOC 2010b), the COL application (STPNOC 2010d), STPNOCs October 2011 response to requests for additional information (STPNOC 2011f), or information gathered at NRCs July 2011 environmental site audit. The transmission line description discusses the entire length of the transmission lines. However, in its analysis, the NRC staff only considers the portion of the transmission lines extending from STP to the first substation 1.
At STP, an onsite switchyard lies east of the ECP and connects lines from the plant into the regional power distribution system. Lines beyond this switchyard have been integrated into the 1
On June 20, 2013, the NRC published a final rule (78 FR 37282) revising its environmental protection regulation, 10 CFR Part 51, Environmental protection regulations for domestic licensing and related regulatory functions. A revised GEIS (NRC 2013), which updates the 1996 GEIS, provides the technical basis for the final rule. The final rule redefines the number and scope of the environmental impact issues that must be addressed by the NRC and applicants during license renewal environmental reviews.
The rule incorporates lessons learned and knowledge gained from license renewal environmental reviews conducted by the NRC since 1996. Among other changes, the final rule revises the definition of in-scope transmission lines to be those transmission lines that connect the nuclear power plant to the substation where electricity is fed into the regional power distribution system and transmission lines that supply power to the nuclear plant from the grid.
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Affected Environment regional electric grid and would stay in service regardless of STP license renewal and, thus, would not be affected by the proposed action. Additionally, each of these lines is owned and operated by one of four service providers (American Electric Power Texas Central Company, CenterPoint Energy, City of Austin, or CPS Energy) rather than the applicant, STPNOC; therefore, they are outside of NRCs regulatory purview. The in-scope transmission lines are contained within the footprint of the STP site.
2.1.5.1 Transmission Line Descriptions Velasco Line (DOW 18 and DOW 27). The Velasco Line is a 45-mi (72-km)-long, double-circuit line that extends east from the STP site to the Velasco substation in Brazoria County. Its corridor is 100 ft (30 m) wide. CenterPoint Energy owns and operates this line.
Blessing Line (Blessing 44). The Blessing line extends west and then north from the STP site for 15 mi (24 km) to its termination point at the Blessing substation in Matagorda County. Its corridor is 100 ft (30 m) wide. American Electric Power Texas Central Company owns and operates this line.
Hillje Line (Hillje 64). The Hillje line extends 20 mi (32 km) northwest from the STP site to the Hillje substation in Wharton County. Its corridor is 400 ft (120 m) wide and is shared with the remaining lines discussed in this section. For simplification, this corridor will be referred to as the Hillje corridor in this section. CenterPoint Energy owns and operates the Hillje Line.
Hillje W.A. Parrish Loop (WAP 39). The Hillje W.A. Parrish Loop is one of two 20-mi (32-km) connector lines that join the STP site to a pre-existing (and out of scope) transmission line, the W.A. Parrish-to-Lon Hill Line. The Hillje W.A. Parrish Loop travels along the Hillje corridor.
CenterPoint Energy owns and operates this line.
Hillje Lon Hill Loop (White Point 39). The Hillje Lon Hill Loop is the second of two 20-mi (32-km) connector lines that join the STP site to a pre-existing (and out of scope) transmission line, the W.A. Parrish-to-Lon Hill Line. The line travels along the Hillje corridor, and CenterPoint Energy owns and operates this line.
Holman Line (Hillje 44). The Holman Line travels through the Hillje corridor and then extends northwest for an additional 75 mi (121 km) to the Holman substation in Fayette County. The total length of the line is 95 mi (153 km). Beyond the Hillje corridor, the corridor is 100 ft (30 m) wide. CenterPoint Energy owns and operates the portion of the line within the Hillje corridor, and the City of Austin owns and operates the remaining length of the line.
Skyline Line (Elm Creek 27). The Skyline Line travels through the Hillje corridor, extends west an additional 119 mi (192 km) to the Elm Creek substation in Guadalupe County, and then extends an additional 29 mi (47 km) to the Skyline substation in Bexar County. The total length of the line is 168 mi (271 km). Beyond the Hillje corridor, this lines corridor is 100 ft (30 m) wide. CPS Energy owns and operates the full length of this line.
Hill Country Line (Elm Creek 18). The Hill Country line follows the same corridor path as the Skyline Line. However, the Hill County line extends an additional 12 mi (19 km) from the Skyline substation (where the Skyline Line terminates) to the Hill Country Substation in Bexar County. The total length of this line is 180 mi (290 km).
White Point Loop (White Point 39). The White Point Loop is a connector line that joins the STP site to the Lon Hill Line. This line is 10 mi (16 km) long and travels along a 100-ft (30-m) wide corridor. American Electric Power Texas Central Company owns and operates this line.
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Affected Environment 2.1.5.2 Transmission Line Maintenance American Electric Power Texas Central A transmission line right-of-way (ROW) is a strip Company, CenterPoint Energy, City of Austin, of land used to construct, operate, maintain, and repair transmission line facilities. The and CPS Energy use an integrated vegetative transmission line is usually centered in the ROW.
management program that combines manual, The width of a ROW depends on the voltage of mechanical, biological, and chemical control the line and the height of the structures. ROWs techniques to maintain proper clearance from must typically be clear of tall-growing trees and structures that could interfere with a powerline.
transmission lines and structures. The degree and type of clearance varies by line voltage and the type, growth rate, and branching characteristics of trees and vegetation. The transmission lines traverse predominantly agricultural land and grasslands. Therefore, maintenance activities are minimal. Those areas that are not already cultivated or developed in some other way are maintained to promote herbaceous vegetation, which includes shrubs, bushes, and other low-growing groundcover.
2.1.6 Cooling and Auxiliary Water Systems STP uses a cooling pond-based heat-dissipation system that withdraws and discharges cooling water to the MCR. STPNOC intermittently withdraws and discharges makeup water from the lower Colorado River to raise the water level and maintain water quality within the MCR. Unless otherwise cited, the NRC staff drew information about STPNOCs cooling and auxiliary water systems from the TPDES Permit (TCEQ 2005) and the applicants ER (STPNOC 2010b).
Circulating Water System. Water is intermittently drawn from the lower Colorado River through the Reservoir Makeup Pumping Facility (RMPF) to the MCR. The RMPF is located on the west bank of the lower Colorado River and consists of four makeup pumps with a total current capacity of approximately 269,000 gallons per minute (gpm) (600 cubic feet per second (cfs) or 17 m3/s). STPNOC intermittently draws water from the Colorado River to replace water lost in the MCR due to evaporation and seepage. This is depending on weather (patterns of rainfall in the river basin), water quality conditions in the MCR, Colorado River flows, operational considerations, and TPDES restrictions.
The RMPF withdraws water through a 406-ft (124-m) long intake structure located parallel to the shoreline. Water flows through a coarse trash rack with 4-in. (10-cm) openings and into traveling water screens (STPNOC 2010d). Each traveling screen is 10-ft (3-m) wide and has a mesh size of 3/8 in. (9.5 mm) (STPNOC 2010d, 2010e). A handling and bypass system on the traveling screens collects fish caught on the screens and returns them via a sluice downstream to the river (STPNOC 2010d). Water that passes through the traveling screens goes into a siltation basin, across a sharp-crested weir, and into the pumping station. The water is then pumped into the northeast corner of the MCR through two buried 108-in. (274-cm) diameter pipelines.
The MCR is a 7,000-ac (2,833-ha) engineered impoundment enclosed by a 12.4-mi (20-km) embankment that consists of a clay fill and is lined with a soil-cement to prevent erosion (located adjacent to and south of STP, Units 1 and 2; see Figure 2-1). At the maximum normal operating pool of 49 ft (15 m) above mean sea level (MSL), the reservoir contains approximately 202,700 ac-ft (250 million m3) of water. The normal operating level is 47 ft (14.3 m) above MSL due to a procedural limit for a two-unit operation.
Water flows from the MCR to the main condensers as water is suctioned by four circulating water pumps located within the cooling water intake structure (CWIS). Water then passes to a common distribution header for the condensers for both units. In the condenser, the circulating 2-8
Affected Environment water absorbs waste heat. Heated water is discharged to the MCR through a discharge structure. Each unit circulates 906,957 gpm (3,433 cfs or 97.2 m3/s) for circulating water flow (STPNOC 2009a).
Dikes within the MCR slow the flow of cooling water from the circulating water system discharge structure to the CWIS. As the heated water circulates in the MCR, the heat is gradually dissipated to the environment through evaporation, conduction, and long-wave radiative cooling.
To maintain water chemistry and quality within the MCR, STPNOC discharges water from the MCR to the Colorado River. Discharge from the MCR enters the Colorado River along the west bank through a series of seven 36-in. (91-cm) pipes directed downstream at an angle of 45 degrees from the shore. The discharge structures are 2 mi (3 km) downstream of the RMPF.
The pipes entering the river are spaced 250 ft (76 m) apart. STPNOCs TPDES permit limits the daily discharge to 144 mgd (5.45 million m3/d) and shall not exceed 12.5 percent of the flow of the Colorado River at the discharge point (TCEQ 2005). The TPDES permit also prohibits STPNOC from discharging wastewater when the Colorado River adjacent to the plant is less than 800 cfs (22.7 m3/s). The Texas Administrative Code limits the daily average temperature to 95 °F (35 °C) and daily maximum temperature to 97 °F (36 °C) (STPNOC 2010b). STPNOC has discharged to the Colorado River once during the operation of STP in 1997 as part of a system test (STPNOC 2010b).
Auxiliary Cooling Water and Essential Cooling Water Systems. The MCR supplies the auxiliary cooling water system with cooling water for nonsafety-related systems. Water travels from the MCR to the auxiliary cooling water system through a separate bay in the MCR intake structure and then heated water discharges to the MCR. The design flow rate is 23,600 gpm (52.6 cfs or 1.5 m3/s).
The essential cooling pond (ECP) supplies the essential cooling water system with cooling water for safety-related systems. The ECP is approximately 46 ac (19 ha). Three groundwater wells are the primary makeup to the ECP. The design flowrate is 19,280 gpm (43 cfs or 1.2 m3/s). After going through the essential cooling water system, the water is discharged to the ECP, which is the ultimate heat sink. STPNOC discharges water from the ECP to the MCR to maintain water chemistry.
2.1.7 Facility Water Use and Quality STP, Units 1 and 2, use water systems that include the circulating water systems (CWSs), the freshwater and service water systems, the potable and sanitary water systems, and the auxiliary cooling water and essential cooling water systems (ECWSs) (see Section 2.1.6). STP uses a cooling pond to reject waste heat from normal operations to the atmosphere. The 7,000-ac (2,830-ha) MCR is located adjacent to and south of STP, Units 1 and 2 (see Figure 2-1). The MCR has a spillway near its southeast corner for the discharge of excess water from the MCR to the Colorado River during heavy precipitation events. The MCR also has a buried discharge pipe that runs for 1.1 mi (1.8 km), adjacent to the spillway discharge channel, which ends at a seven-port outfall. This is STPNOCs combined outfall (001) under STPNOCs TPDES permit.
This pipe allows for the discharge of blowdown (i.e., water high in dissolved solids) from the MCR to the Colorado River. The MCR spillway is seldom used, and the blowdown pipeline has only been used as part of a test in 1997. The MCR has a normal maximum operating level of 49 ft (15 m) above MSL for a four-unit operation, but it currently operates under a procedural limit of 47 ft (14 m) above MSL for a two-unit operation (STPNOC 2010b).
The RMPF diverts water from the Colorado River to the MCR to replenish water lost due to evaporation and seepage. The RMPF is located on the Colorado River to the east of the 2-9
Affected Environment operating units and delivers water to the MCR through two buried 108-in. (274-cm) diameter makeup water lines. As currently configured (e.g., screens and pumps), the intake structure has a pumping capacity of 269,000 gpm (600 cfs or 17 m3/s).
In addition to the water supply from the Colorado River, STPNOC maintains five groundwater supply wells at STP as the source for the freshwater and service water systems (including the demineralizer system), potable and sanitary water systems, the firewater storage tanks, the Nuclear Support Center cooling tower, and fire protection for the Nuclear Training Facility.
Three of the five onsite wells provide water to the service system and the fire water storage tanks, and one well each supports the Nuclear Support Center cooling tower and the Nuclear Training Facility (STPNOC 2010b).
The auxiliary cooling water system draws cooling water for nonsafety-related systems from the MCR. Heated water from this system returns to the MCR. The design flow rate of this system is 23,600 gpm (53 cfs or 1.5 m3/s). The essential cooling water system (ECWS) draws cooling water for safety-related systems from the ECP. Heated water from this system returns to the ECP. The design flow rate for this system is 19,280 gpm (43 cfs or 1.2 m3/s). Makeup to the ECP is from one of the three groundwater wells providing service water and fire water storage.
The ECP also is equipped with the capability to discharge blowdown to the MCR to maintain water chemistry (STPNOC 2010b).
A description of surface water resources at STP and vicinity is provided in Section 2.2.4, and a description of the groundwater resources is presented in Section 2.2.5. The following sections further describe the water use from these resources.
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Affected Environment Figure 2-1. Surface Water Bodies and Groundwater Wells in Vicinity of STP (STPNOC 2011b) 2-11
Affected Environment 2.1.7.1 Surface Water Use Feedwater for the STP, Units 1 and 2, CWS is supplied by the MCR, with makeup water for the MCR diverted from the lower Colorado River using the RMPF, as previously described. The RMPF was designed to accommodate operations of four units at the STP site. Currently, the RMPF has 269,000 gpm (600 cfs or 17 m3/s) of installed pumping capacity to support the operation of Units 1 and 2. The MCR also supplies water to the auxiliary cooling water systems, which provide cooling for nonsafety-related systems (STPNOC 2010b).
Through a Certificate of Adjudication issued by the Texas Water Commission, STPNOC has priority water rights through the Lower Colorado River Authority (LCRA) to use 102,000 ac-ft/yr (126 million m3/yr) of water from the lower Colorado River. STP can withdraw river water up to a maximum rate of 540,000 gpm (1,200 cfs or 34.4 m3/s). However, STPNOCs diversions are limited to 55 percent of the flow of the lower Colorado River that is in excess of a 300-cfs (8.5-m3/s) base flow at the diversion point. This is intended to protect freshwater inflows to Matagorda Bay during low flow conditions. The Certificate of Adjudication also provides rights for an additional 20,000 ac-ft (24.7 million m3) of water for operation of STP, Units 1 and 2.
Should sufficient water not be available from the lower Colorado River to maintain the MCR at or above an elevation of 27 ft (8.2 m) above MSL, stored water would be released by the LCRA from sources (i.e., Highland Lakes) upstream of Bay City Dam (STPNOC 2009b, 2010b).
To operate STP, Units 1 and 2, STPNOC diverted an average of 37,850 ac-ft (46.7 million m3) of water per year from the Colorado River between 2003 and 2010. STPNOCs diversion during this period ranged from zero in 2003, due to low flow restrictions, to 72,464 ac-ft (89.4 million m3) during 2009 (STPNOC 2010b, 2011b).
2.1.7.2 Groundwater Use Groundwater is withdrawn at STP via five onsite wells to supply the freshwater and service water systems, potable and sanitary water systems, and fire protection storage tanks and to provide makeup water for the ECWS (see Section 2.1.7).
The five water-supply wells (see Figure 2-1) were installed during construction of STP, Units 1 and 2, and all are completed in the Deep Chicot Aquifer, as further described in Section 2.2.5.
These wells range in depth below ground surface (BGS) from 600 to 700 ft (183 to 213 m) and have design capacities between 200 and 500 gpm (760 to 1,890 L/min) (NRC 2011b; STPNOC 2010b). STP holds a permit from the Coastal Plains Groundwater Conservation District (CPGCD) to withdraw 9,000 ac-ft (11.1 million m3) of groundwater over an approximately 3-year permit period (CPGCD 2011). This is a pumping rate of approximately 1,860 gpm (7,040 L/min) or 3,000 ac-ft/yr (3.7 million m3/yr). Based on data from 2001 through 2010, STPNOCs total annual groundwater production ranged from 682 to 863 gpm (2,580 to 3,270 L/min) or 1,100 to 1,392 ac-ft/yr (1.4 to 1.7 million m3/yr) and averaged 768 gpm (2,910 L/min) or 1,239 ac-ft/yr (1.5 million m3/yr) (STPNOC 2010b, 2010d, 2011b).
2.2 Surrounding Environment Sections 2.2.1 through 2.2.10 provide general descriptions of the environment near STP as background information. They also provide detailed descriptions, where needed, to support the analysis of potential environmental impacts of operation during the renewal term, as discussed in Sections 3 and 4.
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Affected Environment 2.2.1 Land Use STP is located in Matagorda County, 8 mi (3.2 km) north-northwest of Matagorda and sits between Farm-to-Market Road (FM) 1095 to the west and the Colorado River to the east. The STP site is located on approximately 12,220 ac (4,945 ha). The operations area, consisting of the reactor buildings, support facilities, and transmission ROWs occupies approximately 65 ac (26 ha); the ECP, approximately 46 ac (19 ha); and the MCR, an additional 7,000 ac (2,833 ha).
Another 1,700 ac (688 ha) is natural low land habitat. The rest of the site is mostly undeveloped land; a portion of which, east of the MCR, is leased for cattle grazing (STPNOC 2010b).
Onsite facilities include the two reactor and steam generator containment buildings, various buildings auxiliary to the reactors such as warehouses, a chemical storage building, switchyard, fuel handling buildings, radioactive waste building, training center, outdoor firing range, administrative buildings, and miscellaneous supporting buildings (STPNOC 2010b).
Nearby communities include Matagorda, approximately 8 mi (13 km) north-northwest; Palacios, 11 mi (18 km) north-northwest; and Bay City, 13 mi (21 km) southeast. The western bank of the Colorado River forms the eastern STP property boundary. A 13-ac (5-ha) park, developed by the LCRA and operated by Matagorda County, is located on FM 521 on the west side of the Colorado River. The Port of Bay City terminal is located approximately 5 mi (8 km) north-northeast of the STP site.
2.2.2 Air Quality and Meteorology STP is located in Matagorda County, a coastal county located on the Gulf of Mexico in the southeastern portion of Texas. There are 10 climatic divisions of Texas, with Matagorda County falling into the Gulf Coastal Plain, primarily a combination of prairies and marshes. The climate for this region is classified as maritime subtropical, which is marked by relatively short, mild winters; long, hot summers; and mild springs and falls. The Azores high-pressure system is the source of maritime tropical air masses much of the year. During the winter months, occasional cold continental air masses displace the maritime air. The STP site is flat with no topographic features that would cause the local climate to deviate significantly from the regional climate.
While tornadoes and floods are the primary weather hazards in the rest of the State, the Gulf Coastal Plain is most vulnerable to hurricanes.
The closest first-order National Weather Service (NWS) station representative of the STP site is Victoria, Texas, located about 53 mi (85.3 km) to the west of the site. The NWS station at Corpus Christi, Texas, about 100 mi (161.0 km) to the southwest, is also representative of the site due to its proximity to the coast. Summer climate extends from May through September, with the highest average temperatures occurring during July and August, which are 83.8 °F (28.8 °C) and 83.7 °F (28.7 °C), respectively. The winter climate extends from December through February, with the coldest weather occurring in January at 55.7 °F (13.2 °C) on average. The fall climate occurs in October and November, with average temperatures of 72.6 °F (22.6 °C) and 64.6 °F (18.1 °C) respectively. The spring climate at STP extends from March to April, with average temperatures of 65.4 °F (18.6 °C) and 70.2 °F (21.2 °C),
respectively. The Gulf of Mexico can modify outbreaks of polar air masses such that temperatures below 32 °F (0 °C) may occur, on average, less than four times per year.
2.2.2.1 Air Quality Matagorda County is within the Metropolitan Houston-Galveston Intrastate Air Quality Control Region (AQCR). Other counties in the region include Austin, Brazoria, Chambers, Colorado, Fort Bend, Galveston, Harris, Liberty, Montgomery, Walker, Waller, and Wharton Counties (40 CFR 81.38).
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Affected Environment The EPA regulates six criteria pollutants under the National Ambient Air Quality Standards (NAAQS)carbon monoxide, lead, nitrogen dioxide, ozone, sulfur dioxide, and particulate matter. Matagorda County is designated as unclassified or in attainment for all NAAQS criteria pollutants. However, the counties of Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller are classified as [N]onattainment[/]Severe (40 CFR 81.344) for the 8-hour ozone standard. These counties are located northeast or north-northeast of Matagorda County, with the closest being Brazoria County, located approximately 21 mi northeast of the STP site. All other counties in this AQCR are designated as unclassified or in attainment with respect to the NAAQS criteria pollutants.
STP has many stationary emission sources, such as standby emergency diesel generators, an auxiliary boiler to furnish steam for start-up when the nuclear steam supply is unavailable, and several petroleum fuel storage tanks. STP submits a report of air emissions to TCEQ annually.
Actual total emissions from all sources at STP from 2004 to 2010 were 62.86 tons per year (tpy), 58.15 tpy, 56.24 tpy, 47.07 tpy, 60.68 tpy, 59.97 tpy, and 65.37 tpy, respectively. With the exception of volatile organic compounds (VOC), the highest emissions were reported in 2004, with 1.11 tpy of particulate matter, 12.41 tpy of carbon monoxide, 46.62 tpy of oxides of nitrogen, and 0.78 tons per year of sulfur dioxide. The highest VOC emissions were reported in 2009 and were 2.07 tpy. There are no plans for refurbishment of structures or components at the STP site for license renewal. Therefore, there are no changes to expected air emissions associated with license renewal (STPNOC 2010b, 2012a)
Mandatory Class I Federal Areas, where visibility is an important value, are listed in 40 CFR Part 81, Subpart D. There are no mandatory Class I Federal areas within 50 mi (81 km) of the STP site. The closest Class I area to STP is the Big Bend National Park located in west Texas, which is over 500 mi (805 km) west of the STP site. Due to the significant distance from the site and prevailing wind direction, no adverse impacts on Class I areas are anticipated from STP operation. Furthermore, there are no expected additional air emissions associated with license renewal (no new emission sources).
STP has had a Meteorological Monitoring Program on site since July 1973. The initial measurements were to provide the onsite meteorological information required for licensing of STP, Units 1 and 2. Measurements have continued in support of the existing STP, Units 1 and 2, operations. The primary meteorological tower is approximately 1.5 mi (2.4 km) to the east of STP, Units 1 and 2. Its instruments include wind speed and direction and temperature sensors at 10 m (33 ft) and 60 m (197 ft) above ground, dew point temperature at 10 m (33 ft) above ground, and precipitation and solar radiation near ground level. A 10 m (33 ft) backup meteorological tower is located about 0.4 mi (0.6 km) south of the primary tower.
Instrumentation on the backup tower consists of wind speed and direction and temperature at 10 m (33 ft).
2.2.2.2 Meteorology Wind at the STP site is consistent with the dominant influence of the Azores high-pressure system and the coastal location of the site. Seasonal variation of the prevailing directions shows a predominance of southeasterly winds except in January, July, and August, when south winds prevail, and November and December, when northerly winds prevail. The coastal location of the site leads to typical onshore (southeast) winds during the day and offshore winds at night.
Precipitation at the STP site ranges from about 2 in. (5.1 cm) per month in February, peaking to about 4 to 5 in. (10.2 to 12.7 cm) per month in May and June and again in September and October. Snow occurs during more than 50 percent of the winters, but snowfall is generally limited to trace amounts. STP can experience severe weather in the form of thunderstorms, 2-14
Affected Environment tornadoes, and tropical storms. Thunderstorms are the most frequent severe weather events.
They occur on an average of about 55 days per year at the Victoria NWS station and about 31 days per year at Corpus Christi NWS station. The majority of the thunderstorms occur from the months of May through September. It is likely that the frequency of thunderstorms at the STP site is closer to that of the Corpus Christi NWS station than the Victoria NWS station due to Corpus Christis proximity to the coastline. Tropical cyclones, including hurricanes and tropical storms, pass near the STP site an average of about once every other year, and an average of about two to three hurricanes pass near the site every 10 years. Nine hurricanes have made landfall between Corpus Christi and Galveston since 1950, the most recent being hurricanes Humberto in 2007 and Ike in 2008. Tornadoes are the least frequent of these extreme weather events.
2.2.3 Geologic Environment This section describes the current geologic environment of the STP site and vicinity including landforms, geology, soils, and seismic setting.
Physiography. STP is located within the Coastal Prairies portion of the Texas Gulf Coastal Plains physiographic province. The Coastal Prairies subprovince is a broad band paralleling the Texas Gulf coasts (BEG 1996). The topography in the immediate vicinity of the site is characterized by a relatively flat coastal plain with elevations generally ranging from 20 to 30 ft (6 to 9 m) above MSL, with an average elevation of 23 ft (7 m) above MSL across STP (NRC 2011b; STPNOC 2009a).
One unique topographic feature in the region is the presence of pimple mounds, which can be seen throughout the Texas coastal area. These round or elliptical features are typically about 2 ft (0.6 m) high and 50 ft (15 m) or less in diameter. They are most frequently associated with low-lying, poorly drained areas or bodies of water. These mounds are not restricted to a specific soil series or type, but they occur on many different types of soils with various moisture contents and have no connection to deeper sediments. Although many theories have been proposed for their origin, their structure indicates that they result from normal sedimentary deposition in calm water environments (STPNOC 2009a).
Geology. STP sits on the Beaumont depositional plain, one of several such surfaces trending northeast-southwest along the Texas Gulf coasts that formed during the Pleistocene Age (i.e., between approximately 12,000 and 2.6 million years ago), due to changes in sea level associated with coastal subsidence and inland geologic uplift. This plain reflects the uppermost surface of a sequence of Quaternary Age sediments approximately 3,000 ft (910 m) thick that were deposited by ancient river systems and in deltas. Test borings indicate such sediments are present to a depth of at least 2,619 ft (798 m) beneath the site with ages of no more than 700,000 years. Nevertheless, there has been little modification of this depositional plain since the uppermost Beaumont Formation was deposited approximately 70,000 years ago. Today, this plain is crossed by the very shallow but relatively wide (4 mi or 6.6 km) Colorado River valley, which the river has meandered back and forth across over time (STPNOC 2009a).
The uppermost geologic unit across and underlying the STP site is the Beaumont Formation, which is estimated to extend to a depth of 1,400 ft (430 m). The top 125 ft (38 m) of this unit is comprised of silt, sandy silt, and fine- to medium-grained sand, interbedded with clay. Clay predominates below 125 ft (38 m). Lenses of moderately dense to very dense reddish-brown to gray silty sand are found in the clay layers. Along the eastern boundary of the site, Holocene (recent) Age alluvial age sediments, which range up to 50 ft (15 m) thick, overlie the Beaumont Formation. In addition, Holocene sand, silt, and clay deposits are found in the Colorado River meander belt and floodplain east of the plant site. While finer sediments (silt, clay) were 2-15
Affected Environment generally deposited in low areas, sand was deposited as point bars or sheet deposits during flood stages (STPNOC 2009a).
No geologic (tectonic) faults capable of producing earthquakes have been identified in the STP region, and no unstable subsurface materials or conditions (e.g., salt domes) have been identified at the plant site. The closest tectonic faults are located approximately 85 mi (140 km) northwest of the STP site in association with the Ouachita geologic province. Many growth faults have been mapped at depth in the STP site area and extensively studied through geophysical data. Common across the Texas Gulf coasts, these features are thought to arise from gravity-related processes associated with the consolidation, slumping, and creeping of sediments during and after being deposited. At STP, nearly all of these features are confined to strata at depths of at least 5,000 ft (1,520 m) BGS in Oligocene age strata comprised of the massive marine shales of the Anahuac Formation. This indicates that the growth faults are at least as old as the strata in which they are found (i.e., as old as 26 million years) and further indicates that they are depositional and not tectonic in nature (STPNOC 2009a).
Soils. Soil unit mapping by the National Resources Conservation Service (NRCS) identifies the natural soils across the STP main plant complex as Laewest clay, 0 to 1 percent slopes, with areas of Dacosta sandy clay loam, 0 to 1 percent slopes, to the east and north of the main plant complex. These units are deep (greater than 80 in. (200 cm)), moderately well drained soils, which developed from clayed clayey fluviomarine deposits. Both soils are prime farmland where otherwise not committed to developed uses (7 CFR 675.5). The soils have some limitations for site development due to shrink-swell from high expansive clay content and a slight erosion hazard (NRCS 2011).
Overall, the plant area excavation consisted of a large open-cut excavation covering the footprint of both units to a depth of approximately 40 ft (12 m) BGS. Excavations for the two reactor containment buildings (RCBs) extended deeper to nearly 70 ft (21 ft) BGS. These excavations penetrated the shallow aquifer zone (see Section 2.2.5 for details), requiring groundwater dewatering during construction. The excavated area was backfilled to the foundation elevations and to within 18 in. (46 cm) of surface grade with clean, well-graded, medium-to-coarse sand. The total amount of Category I structural backfill used for Units 1 and 2 was approximately 1.6 million tons (1.45 million MT) (STPNOC 2009a).
Seismic Setting. The central Texas Gulf coast is a region of very low historical seismicity and very low seismic risk (USGS 2011a). No earthquakes have been recorded within a radius of 62 mi (100 km) of STP. Within a radius of 124 mi (200 km), only seven earthquakes have been recorded. The closest event was a magnitude 2.7 event with an epicenter 70 mi (113 km) northwest of STP (USGS 2011b).
Site and regional studies across the Gulf coasts have concluded that the geologic strata in which the previously described growth faults are known to occur are not capable of storing strain energy sufficient to produce earthquakes larger than about magnitude 4.0 or shaking greater than Modified Mercalli Intensity (MMI) IV or both. Historically, earthquake activity in the region attributed to growth faulting has been of magnitude 1.5 or less (microseismic). Further, as reported in the applicants updated final safety analysis report (FSAR), no earthquakes are known to have occurred or been felt at the STP site. Nevertheless, larger earthquakes have occurred along the Gulf coasts. The largest historical earthquake in the Gulf coasts region occurred in October 1930 near Donaldsonville, Louisiana, approximately 320 mi (515 km) east-northeast of the STP site. Although not recorded on instruments, its epicenter and effects were based on historical accounts. It is believed to have occurred in the upper basement rock rather than in the overlying strata and produced shaking of MMI of V to VI at its epicenter (STPNOC 2009a). USGS information provides an estimated magnitude of 4.2 with a 2-16
Affected Environment conservative MMI of VI for this event (USGS 2011c). Nevertheless, the 1930 Donaldsonville earthquake was used as one of the bases to establish the safe shutdown earthquake (SSE) for STP where an earthquake producing shaking of MMI VI at the surface was assumed to occur in basement rock directly beneath the site. The maximum vibratory (peak) ground acceleration (PGA) associated with an MMI VI earthquake is about 0.07 g (i.e., force of acceleration relative to that of Earths gravity, g). Nonetheless, because 0.07 g is below the minimum PGA value in 10 CFR Part 100, Appendix A, 0.10 g was adopted for the SSE (STPNOC 2009a).
For the purposes of comparing the SSE with a more contemporary measure of predicted earthquake ground motion for the site, the NRC staff also reviewed current PGA data from the U.S. Geological Survey (USGS) National Seismic Hazard Mapping Project. The PGA value cited is based on a 2 percent probability of exceedance in 50 years. This corresponds to an annual frequency (chance) of occurrence of about 1 in 2,500 or 4x10-4 per year. For STP, the calculated PGA is approximately 0.03 g (USGS 2008).
2.2.4 Surface Water Resources The STP site is situated on the west bank of the lower Colorado River, approximately 13 mi (21 km) southwest of Bay City, Texas, and 10 mi (16 km) north of Matagorda Bay. The STP site is approximately 12,200 ac (4.940 ha) in size, the majority of which is occupied by the 7,000-ac (2,830-ha) MCR. This reservoir is formed by approximately 12.4 mi (20 km) of embankment consisting of clay fill that is constructed above natural ground elevation. The MCR also has 7 mi (11 km) of internal baffles (raised berms) to enhance the circulation of cooling water (STPNOC 2010b).
As described in Sections 2.1.6 and 2.1.7, the MCR is part of the closed-loop cooling system for the normal operations of STP, Units 1 and 2. The CWSs of STP, Units 1 and 2, discharge heated water to the MCR, where rejected heat is dissipated mostly via evaporation. To replenish the waters lost to evaporation, the RMPF supplies makeup water from the lower Colorado River. The pumps in the RMPF are operated intermittently consistent with Colorado River flow conditions, operational considerations, and permit restrictions.
2.2.4.1 Surface Water Hydrology The Colorado River Basin is approximately 42,318 mi2 (109,600 km2) in area (NRC 2011b).
STP is located at lower Colorado River Mile 14.6 upstream from Matagorda Bay. The river is tidally influenced in the vicinity of the STP site, and this tidal influence extends as far as 32 mi (51 km) upstream from Matagorda Bay under conditions of low flow. The extent of tidal influence depends on tidal fluxes at the mouth of the river, freshwater inflow down the river, and other conditions. In addition, saltwater may move as far as 24 mi (39 km) upstream of Matagorda Bay, along the bottom of the Colorado River (STPNOC 2010b). The mean annual discharge measured at the USGS gauge near Bay City for water years 1949 through 2010 is 2,620 cfs or 1.17 million gpm (74.1 m3/s) (USGS 2011d). August is the low-flow month, and June is the high-flow month (NRC 2011b).
Texas experiences frequent droughts, primarily caused by the formation of a stationary high-pressure system called the Bermuda High. Multi-year droughts have occurred in the past in the Colorado River Basin; for example, annual discharges during 1951 to 1956, 1962 to 1967, 1983 to 1986, and 1988 to 1991 ranged from 23 to 48 percent, 21 to 79 percent, 25 to 72 percent, and 21 to 78 percent of the mean annual discharge, respectively (NRC 2011b). Of 2-17
Affected Environment the 56 years of data reported by USGS from 1949 to 2010 water years, 2 the annual discharge was less than the mean annual discharge during 26 years.
In the Colorado River Basin, the LCRA operates six dams that impound six Highland Lakes, having a combined water storage capacity of 2.18 million ac-ft (2,690 million m3). The LCRA is one of many river authorities that were created by the State legislature to manage surface water resources in river basins within the State. The LCRA operates the Colorado River and Lakes Buchanan and Travis as a single system for water supply in the lower Colorado River Basin, including for STP (see Section 2.1.7.1). Water from the lakes is released when the flow in the river is insufficient to meet downstream water rights(NRC 2011b).
Other noteworthy surface water features at STP include Little Robbins Slough, an intermittent stream, which originates approximately 2 mi (3.2 km) northwest of the STP site; it has a drainage area of approximately 4 mi2 (10.4 km2). During construction for Units 1 and 2, the original course of Little Robbins Slough was relocated along the west portion of the MCR embankment. Currently, the relocated Little Robbins Slough flows south along the west MCR embankment, turns east at the southwest corner of the MCR embankment, and rejoins its original course approximately 1 mi (1.6 km) east of the southwest corner of the MCR embankment (NRC 2011b) (see Figure 2-1).
Kelly Lake is a 34-ac (14-ha) natural water body located north of the northeast edge of the MCR embankment and is fed by a small catchment area to its north. The ECP, which serves as the ultimate heat sink for STP, Units 1 and 2, is located east of the power block and comprises another 46 ac (19 ha) of land (NRC 2011b; STPNOC 2010b).
2.2.4.2 Surface Water Quality and Effluents In support of maintaining the quality of waters of the State and in establishing designated uses of surface waters, TCEQ has designated the segment of the lower Colorado River (Segment 1401, Colorado River Tidal), adjacent to STP, for use in primary contact recreation and for high aquatic life use, as well as for general and fish consumption uses applicable to all surface waters (30 TAC 1-307). The numeric water quality criteria specified for the river segment include a minimum 24-hour mean dissolved oxygen at any point of 4.0 mg/L, a pH range of 6.5 to 9.0 units, an indicator bacteria count of 35 colonies per 100 milliliters (mL), and a maximum temperature of 95 °F (35 °C) (NRC 2011b; TCEQ 2011).
The LCRA has a water quality monitoring station on the lower Colorado River at Selkirk Island, located approximately 0.7 mi (1.1 km) downstream from the STPNOCs RMPF. For the period of October 1982 through November 2008, dissolved oxygen levels ranged from 0 to 13.5 mg/L with an average of 6.5 mg/L, pH ranged from 6.6 to 9.8 units with an average of 7.9, and water temperatures ranged from 43.5 to 92.1 °F (6.4 to 33.4 °C) with an average of 72.5 °F (22.5 °C).
Between 1994 and 2001, fecal coliform ranged from 0 to 13,000 colonies per 100 mL, with an average of 391 colonies per 100 mL (NRC 2011b).
Texas draft 2010 Clean Water Act, Section 303(d), list of impaired waters proposes to continue the listing of the tidal lower Colorado River as impaired by bacteria; it was first listed for bacteria exceedances in 2006 (based on best available information). The other surface water bodies near the STP siteincluding Little Robbins Slough, West Branch of the Colorado River, and Kelly Lakeare not on the Section 303(d) list (NRC 2011b; TCEQ 2011).
2 For statistical calculations, the USGS does not use years during which data are incomplete. For calculating the annual statistics for Colorado River stream flow at Bay City, the USGS did not use water years 1996 through 2000 and 2009.
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Affected Environment Wastewater discharges from STP are governed by a TCEQ-issued TPDES permit. This is the Texas equivalent of a National Pollutant Discharge Elimination System permit. STPNOCs current TPDES permit (No. WQ0001908000) was issued by TCEQ with an effective date of July 27, 2005; the permit expired on December 1, 2009. However, STPNOC submitted a permit renewal application to the State on June 2, 2009, which the TCEQ accepted as administratively complete on July 13, 2009. Subsequently, TCEQ issued STPNOC its new TPDES permit on April 5, 2012, with the new permit having an expiration date of December 1, 2014 (STPNOC 2011d, 2012c, 2013a; TCEQ 2009). Regarding Water Quality Certification requirements under Section 401 of the Clean Water Act, TCEQ issued a waiver to STPNOC with respect to renewal of STPNOCs NRC operating licenses as STP discharges are otherwise subject to TPDES permitting requirements (STPNOC 2012b).
The sites TPDES permit sets effluent limitations for site discharges to the Colorado River from the MCR via outfall 001 including comingled recirculated cooling water, MCR blowdown, stormwater, uncontaminated groundwater, and makeup water from Colorado River. This also includes limits on several previously monitored effluent streams or internal outfalls that discharge to the MCR and identified as outfall numbers 101, 201, 401, 501, and 601.
Additionally, the revised permit covers discharges from other miscellaneous sources such as MCR relief well water (outfall numbers 002, 003, 004, 005, and 006) and MCR spillway gate leakage that may flow to the Colorado River, to the West Branch of the Colorado River, to Little Robbins Slough, and to the East Fork of Little Robbins Slough, as appropriate (STPNOC 2012c; TCEQ 2005).
In addition to limitations on specific pollutants and on discharge temperature, the current TPDES permit requires that the discharge from outfall 001 not exceed 12.5 percent of the flow of the Colorado River at the discharge point and prohibits discharges from outfall 001 when river flow adjacent to the plant is less than 800 cfs (23 m3/s). It also imposes an average daily discharge flow limit of 144 million gallons per day (mgd) (585,000 m3/day) (STPNOC 2012c; TCEQ 2005). As noted above (and previously in Section 2.1.7), the MCR is equipped with a blowdown discharge pipeline to reduce the level of dissolved solids in the circulating water.
While this blowdown pipeline has only been used once before, it may be necessary to discharge from the MCR via outfall 001 in the future to maintain proper circulating water chemistry (STPNOC 2010b).
The NRC staffs review of the last 3 years of TPDES discharge monitoring reports submitted by STPNOC to the TCEQ revealed no exceedances of TPDES effluent limitations. Further, STPNOC has not received any Notices of Violation, nonconformance notifications, or related infractions associated with the sites TDPES permit or related to other water quality matters within the past 5 years (STPNOC 2011e).
2.2.5 Groundwater Resources 2.2.5.1 Site Description and Hydrogeology Underlying the STP site is a wedge of southeasterly dipping sedimentary deposits. Three depositional environments are evidentcontinental (alluvial plain), transitional (delta, lagoon, beach), and marine (continental shelf). As further discussed in Section 2.2.3, oscillations of the ancient shoreline and other processes have resulted in overlapping mixtures of sediments.
Numerous local aquifers exist in the thick sequences of alternating and interfingering beds of clay, silt, sand, and gravel, which yield groundwater ranging in quality from fresh to saline (Ryder 1996; STPNOC 2010d).
The USGS identified the aquifers underlying the STP site as the Texas coastal lowlands aquifer system, and it divides the aquifer system into hydrogeologic units or permeable zones A 2-19
Affected Environment through E (Ryder and Ardis 2002). Within the State of Texas, both the Texas Water Development Board (TWDB) and the LCRA refer to the aquifer system as both the Gulf Coast Aquifer system and the coastal lowlands aquifer system, and they use hydrogeologic unit names rather than letters to describe the aquifer system (TWDB 2006, 2007; Young et al. 2007). Common hydrogeologic unit names, from shallow to deep, are as follows (STPNOC 2010d):
- Chicot Aquifer,
- Evangeline Aquifer,
- Burkeville Confining Unit,
- Jasper Aquifer,
- Catahoula Confining Unit, and
- Vicksburg-Jackson Confining Unit.
This SEIS adopts the naming convention used by the State of Texas. The aquifers underlying the site are located in the Holocene-aged alluvium and the Pleistocene-aged Beaumont, Montgomery, Bentley Formations, and Willis Sands that make up the Chicot Aquifer (NRC 2011b). In descending order from the land surface, the aquifers of interest are the Upper Shallow Chicot Aquifer, the Lower Shallow Chicot Aquifer, and the Deep Chicot Aquifer. The Upper and Lower Shallow Chicot aquifers exhibit semi-confined behavior with some movement of groundwater between them. Local to STP, Units 1 and 2, this communication between the upper and lower zones is also a result of the excavation of the semi-confining material separating the two zones during construction of the units. The top of the Upper Shallow Chicot Aquifer is designated at approximately 15 to 30 ft (4.6 to 9.1 m) BGS, and its base is at about 50 ft (15 m) BGS. The Lower Shallow Chicot Aquifer lies between 50 and 150 ft (15 to 46 m)
BGS (NRC 2011b). The depth to groundwater within this shallow aquifer system lies at approximately 15 to 20 ft (4.6 to 6.1 m) BGS (MACTEC 2009). The upper surface of the Deep Chicot Aquifer is between 250 and 300 ft (76 to 91 m) BGS. The approximate depth where groundwater has a total dissolved solids (TDS) concentration of more than 10,000 mg/L defines the base of the Deep Chicot Aquifer. Beneath the STP site, the Chicot Aquifer thickness is somewhat greater than 1,000 ft (305 m). The Upper Shallow Chicot Aquifer exhibits a somewhat higher potentiometric head than the Lower Shallow Chicot Aquifer, and groundwater moves from the Upper into the Lower Shallow Chicot Aquifer through the confining zone that separates them. The Deep Chicot Aquifer is separated from the Lower Chicot Aquifer by 100 to 150 ft (30 to 46 m) of low-conductivity confining zone sediments (NRC 2011b).
Recharge to the Chicot Aquifers underlying the STP site occurs to the northwest of the site, and discharge occurs generally to the east, south, and southeast of the site. The Shallow Chicot Aquifer outcrops at the land surface, is recharged a few miles northwest of the STP site in Matagorda County, and discharges to the Colorado River alluvium near the site. The Deep Chicot Aquifer outcrops and is recharged farther north and northwest in Wharton County. It discharges into Matagorda Bay and the Colorado River estuary approximately 5 mi (8 km) southeast of the STP site. In the upland areas of the aquifer watersheds, where the aquifer sediments are exposed at the land surface, infiltration from irrigation also contributes to recharge of both the Shallow and Deep Chicot aquifers. The Colorado River is a gaining stream where the Shallow and Deep Chicot aquifers discharge to the river (NRC 2011b). The alluvial aquifer adjacent to the river also undergoes bank storage, whereby water is retained in and discharged from the permeable alluvium of the river bank, with the rise and fall of the Colorado River.
2-20
Affected Environment Additionally, the MCR, as described in Section 2.1.7, is unlined and acts as a local recharge source for the Upper Shallow Chicot Aquifer. A series of 770 relief wells surround the MCR embankment and collect and discharge some of the seepage from the MCR and otherwise relieve hydrostatic pressure on the outer slope and toe of the embankment. Analyses presented in the updated FSAR for STP, Units 1 and 2 (STPNOC 2009a), estimate total seepage from the MCR into the Upper Shallow Chicot Aquifer at 3,530 gpm or 5,700 ac-ft/yr (7 million m3/yr)). These analyses also estimate that 68 percent of the seepage (2,390 gpm or 3,850 ac-ft/yr (4.7 million m3/yr)) from the MCR would be captured by the relief well system for an MCR maximum pool elevation of 49 ft (14.9 m) above MSL. More recent simulations of the MCR indicate approximately 50 percent capture (NRC 2011b).
Groundwater quality and aquifer yields dictate that the Deep Chicot Aquifer is the primary source of groundwater in the region. STP wells completed in the Deep Chicot Aquifer and used for groundwater production at the site are described in Section 2.1.7.2 (see also Figure 2-1).
The nearest offsite public water supply wells are located in the communities of Selkirk and Exotic Isle, which are located adjacent to the STP site eastern boundary. Wells for these communities are approximately 1 mi (1.6 km) from the nearest STP production well, Well 7, and 3.75 mi (6 km) from STP, Units 1 and 2 (see Figure 2-1). Two non-public water supply wells used for livestock watering are located about 1,800 ft (549 m) north of STP Well 5 and 2,230 ft (680 m) west of STP Well 6. They are completed to depths of 500 and 400 ft (152 and 122 m) and have screened intervals of 200 to 300 ft (61 to 91 m), respectively, above the screened intervals of the STP production wells (STPNOC 2010b).
Groundwater use from the Gulf Coast Aquifer system increased between 1940 and the mid-1980s. One cause was rice irrigation, and Matagorda County was among the counties where this occurred. As a result of subsidence issues and substantial increases in pumping lift, groundwater use has declined in the region. The TWDB forecasts a decline in groundwater use from the Gulf Coast Aquifer through 2030. Matagorda County is projected to see a net decrease of 48 percent, with pumping decreasing from 21,528 gpm (81,490 L/min) or 31 mgd in 1985 to 11,111 gpm (42,060 L/min) or 16 mgd in 2030 (Ryder and Ardis 2002). Decreased usage, consistent with this estimate, occurred through the year 2000; however, drought periods since then have resulted in an increase in groundwater usage.
Established under Texas State law (Water Code, Title 2, Subtitle E, Chapter 36), the CPGCD, which has the same boundaries as Matagorda County, has the authority and responsibility to define the modeled available groundwater in the district, to define the amount of groundwater being used in the district, and to issue permits based on the available groundwater resource.
The CPGCD is one of approximately 100 such districts in Texas that were created either by the Texas legislature or by TCEQ using a local petition process. Groundwater Conservation Districts have the authority to regulate the spacing between water wells, the production of water from wells, or both. While the River Authorities, such as the LCRA (see Section 2.2.4.1) act as managers and suppliers of surface water, and Groundwater Conservation Districts act as managers and permitting authorities for groundwater within their respective areas, water planning at the regional level is performed by the designated regions, and the TWDB brings the Regional Water Plans together to adopt the State Water Plan. Regional and State-level water planning consider demands, supplies, and future development of both surface and groundwater resources (NRC 2011b).
The NRC staff interviewed the manager of the CPGCD in July 2011 and learned that the current modeled available groundwater in the district (i.e., Matagorda County) is 46,000 ac-ft (57 million m3) annually or 28,522 gpm (107,970 L/min), and the current usage is 36,000 ac-ft (44 million m3) or 22,322 gpm (84,500 L/min). Annual permitted groundwater withdrawals for the period 2008 through 2010 (i.e., permits are issued for a 3-year period) were 51,285 ac-ft/yr 2-21
Affected Environment (63.2 million m3) or 31,800 gpm (120,400 L/min) (NRC 2011b). Groundwater use in the largely agricultural region encompassing STP fluctuates with the availability of surface water (e.g., with the occurrence of drought). Thus, annual permits that total in excess of the modeled available groundwater, an annual average value, is not unexpected. As presented in Section 2.1.7.2, annual average groundwater use by STP, Units 1 and 2 (i.e., 768 gpm), represents approximately 2.7 percent of the modeled available groundwater quantity in Matagorda County and 3.4 percent of current usage.
2.2.5.2 Groundwater Quality The Shallow Chicot Aquifer exhibits poor water quality and low productivity, and it is used in the vicinity of the STP site primarily for livestock watering. However, occasional domestic use is not precluded. Of 12 wells completed in the Shallow Chicot Aquifer within 10 mi (16 km) of the STP site, 9 wells have TDS concentrations above the EPA secondary drinking water standard (DWS) of 500 mg/L (STPNOC 2010b).
As noted above, the MCR is unlined and acts as a local recharge source for the Upper Shallow Chicot Aquifer. Therefore, locally to the STP site, the MCR also influences the groundwater quality of the Upper Shallow Chicot Aquifer. A maximum tritium concentration of 17,410 picocuries per liter (pCi/L) was reported for MCR waters in 1996 (STPNOC 2010b).
While 50 to 68 percent of the MCR seepage into the aquifer is estimated to be removed by the series of 770 relief wells surrounding the MCR embankment, the remainder of the MCR waters seep into the aquifer, migrate downgradient, and discharge to the Colorado River southeast of the STP site. Monitoring of relief wells and monitoring wells around the MCR has shown that tritium from the MCR arrived at relief wells approximately 2 years after plant startup in 1988. It arrived at monitoring wells south of the MCR (wells MW-235 and MW-251) in 1999 and 2000 and at monitoring wells west of the MCR (wells MW-258 and MW-259) in 2006 (STPNOC 2007, 2011a).
Since its first detection, the concentration of tritium in relief wells increased to a peak of approximately 7,500 pCi/L in 1999 and now varies between 5,000 and 6,000 pCi/L. Since 2000, the concentration of tritium in MW-251, which is located south of the MCR, peaked in 2001 and then declined somewhat, and has generally remained close to the concentrations in the relief wells since then (i.e., 5,000 to 6,000 pCi/L). However, in mid-2012, a spike to 8,600 pCi/L was observed in MW-251 before levels declined again. Since its first detection in 2006, the concentration of tritium in monitoring wells west of the MCR (i.e., wells MW-258 and 259) has increased, peaked, and remained relatively steady since 2009 at around 2,500 pCi/L, although a slight increase in concentration to around 3,000 pCi/L was noted at MW-259 toward the end of 2012. Monitoring wells to the west of the MCR also include wells slightly beyond the site boundary (i.e., MW-270 and MW-271), which were observed by the NRC staff during the site audit. Since the end of 2010, decreasing tritium concentration levels have been noted in MW-271. This well is located adjacent to the STP site boundary in a county road easement.
In 2012, this well had the highest tritum concentration observed to date at 920 pCi/L, which is still a small fraction of the EPA primary DWS. To date, the most distant location at which tritium has been detected in shallow groundwater is at MW-267. This onsite station is a windmill-powered well located just northeast of the MCR adjacent to the heavy haul road. Tritium was first detected in 2011 and was detected at a slightly above background concentration of 280 pCi/L in 2012. (STPNOC 2010a, 2012d, 2013b). In summary, all observed values for tritium remain below the EPA primary DWS of 20,000 pCi/L (40 CFR Part 141).
The 2006 annual environmental operating report (STPNOC 2007) presents information generated from sampling 18 groundwater wells outside the STP, Units 1 and 2, protected area 2-22
Affected Environment and from sampling 16 groundwater wells within the STP, Units 1 and 2, protected area.
Sampling of wells within the protected area resulted from STPNOCs participation in the Nuclear Energy Institutes (NEIs) Groundwater Protection Initiative. During site characterization for STPNOCs application for proposed Units 3 and 4, 28 groundwater observation wells were installed in 2006, and an additional 26 observation wells were installed in 2008 (STPNOC 2010d). Since 2006, additional wells have been installed and added to the Environmental Monitoring Program to further characterize plumes within the protected area and originating from the MCR. For example, during 2008, three additional wells were installed in the protected area, and two additional wells were installed outside the protected area.
In 2006, sampling of wells (i.e., 800-series wells) completed in the Shallow Chicot Aquifer within the protected area provided eight positive results for tritium, all below the EPA primary DWS of 20,000 pCi/L (40 CFR Part 141). Eight wells had no detectable tritium. The results were attributed to seepage of MCR water into the Shallow Chicot Aquifer and underground pipe failures within the protected area. Two of these wells (807 and 808) located between the Unit 1 and 2 RCBs showed relatively higher values of tritium at 15,000 pCi/L and 1,250 pCi/L (STPNOC 2007, 2011b). Tritium concentrations in the wells 807 and 808 decreased to 678 and 600 pCi/L, respectively, by 2010. Individual wells exhibiting lower concentrations have shown trends upward over individual years and over the period from 2005 through 2012. However, well sampling within the protected area through 2012 (STPNOC 2011a, 2011b, 2013b) continues to show concentrations well below the EPA DWS for tritium.
In response to the NEI initiative, STPNOC commissioned a report on the groundwater within the protected area (MACTEC 2009). Three sources of tritium in groundwater beneath the protected area were identified: (1) seepage from the MCR, (2) leaks from the TDS pipeline, and (3) discharge from the turbine steam trap drain or steam condensate lines of each reactor. The first potential source is limited in concentration to the tritium levels in the MCR and subsequent decay in the groundwater pathway from the reservoir. The second source is described as having a maximum tritium concentration of 80,000 pCi/L (MACTEC 2009). The third source is described as having a maximum tritium concentration of less than 90,000 pCi/L (STPNOC 2011d). Within the protected area, the highest tritium concentration in groundwater was approximately 15,000 pCi/L in 2006, as described above, but which have since substantially declined. The highest tritium concentration in the tendon galleries that circle the RCBs was less than 20,000 pCi/L in 2010 (STPNOC 2011d). The latter measurement may be indicative of tritium concentrations in groundwater resulting from discharge from the steam condensate lines. In 2012, STPNOC completed actions to redirect condensed steam or liquid water from the auxiliary steam system to the MCR. STPNOC has evaluated releases inside the protected area and concluded that no release is occurring from an unidentified pathway, and there is no impact on drinking water or on public health and safety (STPNOC 2011a, 2013b).
The monitoring program has observed tritium in the shallow aquifer for several years in wells to the south of the MCR. The tritium movement is consistent with simulations conducted during licensing of STP, Units 1 and 2, as referenced in NRC 2011b, and shows concentrations below the EPA DWS. Through 2012, results from STPNOCs monitoring program indicate generally stable tritium concentrations in groundwater wells surrounding the MCR. Higher levels reported in some monitoring periods and at select locations may be indicative of drought conditions and lower MCR water levels. From the latest STP groundwater monitoring data, the peak onsite groundwater tritium concentration in 2012 was 8,600 pCi/Lwell below the EPA DWS of 20,000 pCi/L (STPNOC 2013b).
Based on groundwater data from 2006 through 2008 presented in the FSAR for proposed STP, Units 3 and 4 (STPNOC 2010c), the piezometer head gradient from the existing STP, Units 1 and 2, to the site boundary to the east is approximately 3 ft (0.9 m), and the distance is 2-23
Affected Environment approximately 1 mi (1.6 km) (5,280 ft or 1,609 m). Representative values for saturated hydraulic conductivity and effective porosity of the lower shallow aquifer are 72 ft/day (22 m/day) and 0.31, respectively. The lower shallow aquifer is the more likely pathway for releases in the vicinity of the RCBs to offsite receptors (see Section 2.2.5.1) (NRC 2011b). Using these data, the travel time from STP, Units 1 and 2, to the site boundary is approximately 100 years. Such a travel time within the shallow aquifer presents adequate time for tritium source concentrations to decay (i.e., tritium has a 12.3 year half-life) to levels below the EPA DWS.
2.2.6 Aquatic Resources 2.2.6.1 Colorado River and Matagorda Bay The Colorado River extends approximately 862 mi (1,387 km) from the high plains to the coastal marshes in Matagorda County. It is one of the largest river systems within the State of Texas.
The drainage area for the lower Colorado River basin includes approximately 22,700 mi2 (58,792 km2), from Lake O.H. Ivie in Mills County, Texas, to Matagorda Bay (TWDB 2007).
STP is located in the Texas coastal plain physiographic province. The section of the Colorado River near STP is a diverse, fluvial system that meanders through the coastal plain providing sediments and nutrients to Matagorda Bay (ENSR 2008c). The river in this area is generally surrounded by steep banks. Little vegetation can grow on the steep banks, but some bottomland forests and wetlands occur on land adjacent to the river (ENSR 2008c).
The Colorado River is tidally influenced near STP, which means that saltwater from Matagorda Bay and the Gulf of Mexico regularly flows upstream and mixes with freshwater from the river.
During periods of low flow, the salinity can reach as high as 20 parts per thousand (ppt) near STP (ENSR 2008c). Flow from the gulf and bay influences the aquatic community near STP by transporting organisms and increasing the salinity in the river. The distribution and density of aquatic plants and animals living in tidally influenced rivers is often determined by salinity concentrations.
Environmental History. Freshwater flow between the Colorado River and Matagorda Bay has important ecological implications. Flow from the Colorado River can increase the biological productivity within Matagorda Bay by providing freshwater, soil, and debris, which can facilitate the growth of marsh habitats. Saltwater flow from the bay to the river can influence the species distribution and diversity within the river by transporting organisms up the river and providing habitat (e.g., higher salinity) for estuarine and marine organisms.
Various development projects have influenced the flow between the Colorado River and Matagorda Bay in the past 100 years. Prior to the 1920s, the Colorado River flowed directly into Matagorda Bay. In an attempt to control flooding, the U.S. Army Corps of Engineers (USACE) dredged a channel down the middle of Matagorda Bay (Holtcamp 2006). The USACE lined the channel with the dredged mud, which divided the bay into an eastern and western portion. As a result of the lined channel, the water from the Colorado River then flowed directly into the Gulf of Mexico (ENSR 2008c).
Dredging projects in the 1950s and 1990s reestablished flow between the Colorado River and Matagorda Bay. In the 1950s, the USACE dredged the Tiger Island Channel through the west side of Matagorda Bay, re-establishing flow between the river and the bay. In part because of ecological importance for freshwater to reach the bay, the USACE conducted a series of dredging projects to increase the flow from the river to the bay in the 1990s (Holtcamp 2006). In 1990, the USACE constructed a deeper river diversion channel northwest of the Tiger Island Channel. In 1991, the USACE constructed two dams to divert the river flow, including one across the Tiger Island Channel (called the Tiger Island Cut Dam, recently renamed to Parkers 2-24
Affected Environment Cut) and a diversion dam across the river channel on Matagorda Peninsula. By July 1992, the Colorado River flowed directly into Matagorda Bay, through the Gulf Intracoastal Waterway (GIWW) and the newly constructed diversion channel. Wilber and Bass (1998) determined that the changes in freshwater inflow to Matagorda Bay over time, and the changes to flow from the Gulf of Mexico into the Colorado River, have likely influenced the aquatic communities historically in the river and bay.
Common Taxa. The most comprehensive studies of the aquatic community within the lower Colorado River near STP are studies conducted as part of the licensing processes for STP, Units 1, 2, 3, and 4. Below is a brief summary of the aquatic surveys conducted near STP.
Although the owner of the STP site has changed over time, the owner is referred to as STPNOC for simplicity purposes below.
- 1973 to 1974: STPNOC sampled phytoplankton (microscopic floating photosynthetic organisms), zooplankton (small animals that float, drift, or weakly swim in the water column, including fish and invertebrate eggs and larvae), juvenile and adult macroinvertebrates (invertebrates visible without a microscope), and juvenile and adult fish (HPLC 1974). NRC (1975) summarized these results in the final environmental statement for the construction of STP, Units 1 and 2.
- 1975 to 1976 and 1983 to 1984: Due to the usually wet conditions during the 1973 to 1974 surveys, STPNOC conducted additional fish surveys in the Colorado River in 1975 to 1976 and 1983 to 1984 (McAden 1984, 1985).
NRC (1986) summarized these results in the final environmental statement for the operation of STP, Units 1 and 2.
- 2007 to 2008: In support of STPNOCs application to build and operate STP, Units 3 and 4, STPNOC sampled macroinvertebrates and fish within the Colorado River near STP (ENSR 2008c; STPNOC 2011d). NRC (2011b) summarized these results in its final EIS for the proposed construction and operation of STP, Units 3 and 4.
Since the Colorado River diversion project, which increased the flow between the Colorado River and Matagorda Bay, species diversity and the number of estuarine-marine species increased in the Colorado River near STP (NRC 2011b). Because of this change, the summary of aquatic organisms focuses on the most current studies. An analysis of the change in the aquatic community since the beginning of STP operations is provided in Section 4.5.2.
Phytoplankton: Phytoplankton are microscopic floating photosynthetic organisms that form the basis of the food chain. Phytoplankton play key ecosystem roles in the distribution, transfer, and recycling of nutrients and minerals. STPNOC most recently surveyed the phytoplankton community in the summer of 1973 in the lower Colorado River and an adjacent stretch of GIWW. STPNOC collected 524 taxa, representing six major divisions (NRC 1975, 2011b).
Diatoms and cynobacteria (blue-green algae) dominated the phytoplankton community.
Diatoms were more numerous at the bottom-water samples, and cyanobacteria and dinoflagellates were predominant in the water column.
Zooplankton: Zooplankton are small animals that float, drift, or weakly swim in the water column. Zooplankton include, among other forms, fish eggs and larvae with limited swimming ability, larvae of benthic invertebrates, medusoid forms of hydrozoans, copepods, shrimp, and krill (order Euphausiids).
STPNOC surveyed the lower Colorado River and an adjacent stretch of GIWW in 1973 to 1974 for macrozooplankton (HPLC 1974). STPNOC collected 319 zooplankton species, which 2-25
Affected Environment included protozoans (101 species), rotifers (75 species), copepods (31 species), and cladocerans (27 species) (NRC 1975). The survey showed that the zooplankton community structure changed based on salinity, such that during periods of higher salinity (e.g., low river flow and strong incoming tides), species diversity increased at upstream stations.
STPNOC most recently surveyed macrozooplankton in 1975 to 1976 and 1983 to 1984 at five stations in the lower Colorado River (Figure 2-2). The abundance and occurrence of invertebrate eggs and larvae were greatest downstream (Station 5); these decreased in fresher water upstream (NRC 1986). In the 1975 to 1976 samples, both freshwater and estuarine-marine decapod larvae dominated the macrozooplankton community from May to September, and estuarine-marine decapod larvae dominated the community from October to December (NRC 1986). The abundance and diversity of decapod larvae were lowest from January through April, when the copepod Acartia tonsa was most prevalent (NRC 1986). In 1983, the most abundant macrozooplankton were cladocerans, Malacostraca species, and copepods (NRC 1986). In 1984, the most abundant macrozooplankton were immature stages of the Harris mud crab (Rhithropanopeus harrissi), ghost shrimp (Callianassa spp.), and jellyfish (family Cnidaria) (NRC 1986).
STPNOC also collected commercially important species, including early life stages of blue crab (Callinectes sapidus), white shrimp (Litopenaeus setiferus), and brown shrimp (Farfantepenaeus aztecus, formerly known as Penaeus aztecus). In general, the density of these species was greatest in higher salinity water (e.g., in the salt wedge or further downstream), and lower densities occurred near the STP site (NRC 1975, 1986).
STPNOC most recently collected ichthyoplankton (fish eggs and larvae) in 1975 to 1976 and 1983 to 1984 at five stations in the lower Colorado River (Figure 2-2). NRC (1986) reported the highest densities of ichthyoplankton from May to October 1975 and March to April 1976.
Densities of ichthyoplankton was highest in higher salinity waters (NRC 1986). The most common species were often estuarine or marine species, such as Gulf menhaden (Brevoortia patronus), bay anchovy (Anchoa mitchelli), Atlantic croaker (Micropogonia undulatus), and naked goby (Gobiosoma bosc) (NRC 1986). In early May and August, when the salinity dropped in the Colorado River, the abundance of ichthyoplankton shifted to freshwater drum (Aplodinotus grunniens) and cyprinid species (NRC 1986). At the sampling station next to the RMPF, STPNOC collected three species (bay anchovy, darter goby (Ctenogobius boleosoma),
and naked goby), which were three of the most commonly collected species in the survey along the lower Colorado River.
Survey results suggest that the lower Colorado River near STP is an estuarine nursery ground for many commercially important species including Gulf menhaden, Atlantic croaker, sand seatrout (Cynoscion arenarius), spotted seatrout (C. nebulosus), spot croaker (Leiostomus xanthurus, also called spot), sheepshead (Archosargus probatocephalus), pigfish (Orthopristis chrysopterus), black drum (Pogonias cromis), red drum (Sciaenops ocellatus), and southern flounder (Paralichthys dentatus) (NRC 1986).
Adult and Juvenile Macroinvertebrates: STPNOC sampled adult and juvenile macroinvertebrates in 1975 to 1976 at eight sampling stations in the Colorado River (Figure 2-2). In 1983 to 1984, STPNOC sampled at Station 2, which is closest to the RMPF (Figure 2-2). In 2007 to 2008, STPNOC sampled along a 9-mi (14-km) stretch of the lower Colorado River extending from the GIWW north to the FM 521 bridge (Figure 2-3 and Figure 2-4). Within this portion of the river, STPNOC divided the area into three 3-mi (5-km) segments and randomly sampled each segment monthly from June 2007 through May 2008.
Within each month, STPNOC collected samples during a 2-day period randomly selected each 2-26
Affected Environment month. STPNOC collected samples if the river flow was 5,000 cfs or less to reduce variability in sampling conditions.
Figure 2-2. The STP Site and 1975 to 1976 Aquatic Ecology Sampling Location (NRC 2011b) 2-27
Affected Environment Figure 2-3. The STP Site and 2007 to 2008 Aquatic Ecology Sampling Locations from Segment C through the Upstream Portion of Segment B (NRC 2011b) 2-28
Affected Environment Figure 2-4. The STP Site and 2007 to 2008 Aquatic Ecology Sampling Locations from the Downstream Portion of Segment B through Segment A (NRC 2011b) 2-29
Affected Environment All studies used seines and trawls to sample macroinvertebrates. In 2007 to 2008, STPNOC also used gill nets and hoop nets primarily to capture fish (ENSR 2008c). However, STPNOC collected a few macroinvertebrates in gill nets and hoop nets; therefore, the methodology and results of these sampling programs is presented below. ENSR (2008c) used the four different types of gear to capture a variety of taxa in terms of size (or life stage) and habitat location (e.g., open water vs. benthic). The information below describes the sampling gear used in the 2007 to 2008 study within each of the three sampling segments (segments A, B, and C)
(Figure 2-3 and Figure 2-4):
- Trawls: STPNOC conducted two tows, each for 10 minutes, with a 6.1-m (20-ft) otter trawl fitted with a 3.5-cm (1.4-in.) stretched mesh and doors (i.e., otter boards) measuring 46 cm by 91 cm (18 in. by 36 in.) attached to each wing of the net. The trawl was designed to capture benthic or demersal fishes and macroinvertebrates.
- Gill nets: STPNOC set one gill net perpendicular to the shoreline. It set the net within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of sunset and retrieved it at sunrise the following morning.
The gill net was 33-m (108-ft) long, 1.2-m (3.9-ft) deep, and consisted of 10.2-cm (4-in.) stretched monofilament mesh. It was designed to capture adult fish using shoreline habitats.
- Hoop nets: STPNOC placed one set of hoop nets within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of sunset and retrieved them at sunrise the following morning. Hoop nets consisted of a multi-chambered conical net that was 3.6-m (12-ft) long with one 1-m (3-ft) diameter hoop at the beginning, followed by smaller hoops, and covered with 2.5-cm (1-in.) stretched mesh netting. Each hoop net had wings that were 7.5-m (25-ft) long by 1.8-m (5.9-ft) deep and comprised of 5-cm (2-in.)
stretched mesh. Hoop nets were designed to capture sub-adult fish using shoreline habitats.
- Seines: STPNOC conducted two seine pulls per month for 15.2 m (50 ft) parallel to the shoreline. Seines were comprised of a 19-mm (0.75-in.) mesh net that measured 18.3-m (60-ft) long and 1.8-m (6-ft) deep. In the center was a 1.8 m (6 ft) by 1.8 m (6 ft) by 1.8 m (6 ft) bag that was covered in 13-mm (0.5-in.) stretched mesh. Seines were designed to capture macroinvertebrates and juvenile and sub-adult fishes using shoreline habitats.
The most abundant invertebrate species in the 1975 to 1976 and 1983 to 1984 studies were river and white shrimp (McAden et al. 1984, NRC 1986). At Station 1, the most upriver station near STP, brown shrimp was the most abundant species in trawl samples, and blue crabs were the most abundant species in seine samples (NRC 2011b). At Station 2, which is closest to the RMPF, STPNOC collected river shrimp, white shrimp, blue crabs, and crayfish (NRC 1986).
In the 2007 to 2008 study, ENSR (2008c) reported the most common species to be white shrimp (30 percent), grass shrimp (Palaemonetes pugio) (29 percent), brown shrimp (7 percent), and blue crab (4 percent) (Table 2-1). ENSR (2008c) collected macroinvertebrates most often in the river segment with the highest salinity (segment A) and least often in the river segment with the lowest salinity (segment C) (Figure 2-3 and Figure 2-4). ENSR (2008c) reported the greatest density of macroinvertebrates and fish during the following periods:
- Trawls: October through January,
- Gill Nets: September through December and March through May, 2-30
Affected Environment
- Hoop Nets: October through February and April through June, and
- Seines: January through April.
Brown, pink (Farfantepenaeus brasiliensis), and white shrimp are of commercial importance in the vicinity of the STP site (TPWD 2002; USACE 2007). STPNOC observed various life stages of brown and white shrimp in all three studies (NRC 1986; STPNOC 2008c). STPNOC only observed pink shrimp during the 1984 to 1985 studies (NRC 1986).
Table 2-1. Macroinvertebrates Collected in the Colorado River by Gear Type, 2007 to 2008 Hoop Common Name Scientific Name Seine Gill Net Net Trawl Total % of Total Atlantic brief squid Lolliguncula brevis 1 0 0 30 31 <1 Atlantic seabob Xiphopenaeus kroyeri 0 0 0 127 127 2 Blue crab Callinectes sapidus 190 2 3 77 272 4 Farfantepenaeus Brown shrimp aztecus 264 0 0 192 456 7 Grass shrimp Palaemonetes pugio 1,762 0 0 1,762 29 white shrimp Litopenaeus setiferus 584 0 0 2,870 3,454 30 Other 11 0 1 12 24 <1 Total invertebrates 2,812 2 4 3,308 6,126 Source: ENSR 2008c Adult and Juvenile Fish: STPNOC sampled adult and juvenile fish in 1975 to 1976 at eight sampling stations in the Colorado River (Figure 2-3). In 1983 to 1984, STPNOC sampled at Station 2, which is closest to the RMPF (Figure 2-3). In 2007 to 2008, STPNOC sampled along a 9-mi (14-km) stretch of the lower Colorado River extending from the GIWW north to the FM 521 bridge (Figure 2-3 and Figure 2-4). All studies used seines and trawls to sample fish.
In 2007 to 2008, STPNOC also used gill nets, hoop nets, and trawls (ENSR 2008c).
ENSR (2008c) followed the same methodology described above for the macroinvertebrate sampling.
The most abundant fish species in the 1974 to 1975 study were Gulf menhaden, bay anchovy, Atlantic croaker, and striped mullet (Mugil cephalus) (NRC 1986). All of these species, except for menhaden, were most abundant at sampling stations furthest down the river (NRC 1986).
Similarly, STPNOC only collected many of the commercially important estuarine species (e.g., red drum and southern flounder) at the most downstream station, Station 5. The density of menhaden, on the other hand, was greatest at the most upstream station, Station 1.
In the 2007 to 2008 study, STPNOC (2008c) reported the most common species to be Gulf menhaden (35 percent), striped mullet (14 percent), black drum (Pogonia cromis) (12 percent),
and Atlantic croaker (9 percent) (Table 2-2). All other species comprised 3 percent or less of the total fish collected. ENSR (2008c) collected fish most often in the river segments with the highest salinity (segments A and B) and least often in the river segment with the lowest salinity (segment C) (Figure 2-3 and Figure 2-4).
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Affected Environment Table 2-2. Fish Collected in the Colorado River by Gear Type, 2007 to 2008 Hoop % of Common Name Scientific Name Seine Gill Net Net Trawl Total Total Atlantic croaker Micropogonias undulatus 562 1 0 482 1,045 9 Bay anchovy Anchoa mitchilli 24 0 0 264 288 2 Black drum Pogonias cromis 1 1 1 1,360 1,363 12 Blue catfish Ictalurus furcatus 51 22 3 677 753 6 Channel catfish Ictalurus punctatus 22 0 2 6 30 <1 Gafftopsail catfish Bagre marinus 0 9 0 183 192 2 Gizzard shad Dorosoma cepedianum 8 0 2 52 62 <1 Gulf menhaden Brevoortia patronus 2,960 5 2 1,076 4,043 35 Hardhead catfish Ariopsis felis 0 1 1 252 254 2 Red drum Sciaenops ocellatus 8 8 38 25 79 <1 Sailfin molly Poecilia latipinna 150 0 0 0 150 1 Sand seatrout Cynoscion arenarius 22 5 0 294 321 3 Sharptail goby Oligolepis acutipennis 39 0 0 0 39 <1 Sheepshead Archosargus probatocephalus 14 1 6 48 69 <1 Sheepshead minnow Cyprinodon variegatus 79 0 0 7 86 <1 Silver perch Bairdiella chrysoura 0 0 0 350 350 3 Smallmouth buffalo Ictiobus bubalus 0 32 5 0 37 <1 Spot croaker Leiostomus xanthurus 88 0 1 156 245 2 Spotted seatrout Cynoscion nebulosus 0 4 0 53 57 <1 Star drum Stellifer lanceolatus 0 0 0 86 86 <1 Striped mullet Mugil cephalus 1,676 0 1 1 1,678 14 White mullet Mugil curema 181 0 0 2 183 2 Other 109 15 33 78 235 2 Total Fish 5,994 104 95 5,452 11,645 Source: ENSR 2008c Species Richness: In the 2007 to 2008 studies, ENSR (2008c) calculated the species richness, or number of fish and macroinvertebrate species collected, within each river segment and for each type of sampling gear. ENSR (2008c) reported the highest species richness in the river segment with the highest salinity (segment A) for trawl, seine, and gill net samples (Table 2-3).
The species richness was similar across all three-river segments for hoop net samples (Table 2-3).
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Affected Environment Table 2-3. Species Richness (number of species) in Three River Segments by Gear Type River Segment Gear Type A B C Trawl 37 29 24 Seine 38 35 22 Gill nets 14 12 9 Hoop nets 11 12 12 Source: ENSR 2008c STPNOCs studies in the 1970s and 1980s also found greater species diversity and density further downstream in higher salinity waters (NRC 1975, 1986). NRC (1975) attributed the lower density and diversity near the STP site to the relatively large and frequent fluctuations in salinity. Downstream areas, on the other hand, exhibit relatively stable salinity, which allows for the establishment of a variety of estuarine and marine species assemblages.
2.2.6.2 Onsite aquatic features STP is located approximately 23 ft (7 m) above MSL on a site with relatively flat topography.
Water covers approximately 58 percent of the 12,220 ac (4,945 ha) STP site (STPNOC 2010b).
The onsite aquatic features include the MCR, the ECP, several sloughs, drainage areas, wetlands, and Kelly Lake.
Construction activities for STP, Units 1 and 2, extensively altered several aquatic features on the STP site. For example, during the building of the MCR, STPNOC removed up to 65 percent of the drainage area for Little Robbins Slough in the southern part of the site (NRC 1975).
STPNOC also created a new channel for the slough, which is the same as the current configuration (NRC 2011b). The reconfiguration of Little Robbins Slough reduced the annual freshwater runoff into onsite marshes and marshes south of the STP site. Reduced flow can displace freshwater species and reduce the quality of nursery grounds for estuarine-dependent organisms (NRC 1975). As a result of seepage flow from the MCR into the slough, NRC (1986) estimated the total long-term average annual reduction of freshwater input into the marshes to be 6 percent. NRC (1986) concluded that, at this rate, the reduction in flow of freshwater from the slough into the marshes, and any subsequent changes in salinity or nutrient input, were not expected to alter the structure and function of the upper marsh aquatic community (NRC 1986).
Below is a description of the main aquatic features currently located on the STP site.
Main Cooling Reservoir. The MCR is a 7,000-ac (2,833-ha), man-made impoundment that is the normal heat sink for waste heat generated during operations of STP, Units 1 and 2.
STPNOC maintains the water level and quality (e.g., total dissolved solids) in the MCR by pumping water from the Colorado River through the RMPF, as described in Section 2.1.6. A variety of aquatic organisms currently inhabit the MCR (ENSR 2008a; STPNOC 2010b).
Aquatic organisms were likely introduced into the MCR when small life stages (e.g., eggs or larvae) or species were entrained during the initial filling and subsequent refilling of the MCR.
ENSR (2008a) collected samples of the aquatic community within the MCR four times a year from May 2007 through April 2008. ENSR (2008a) sampled the aquatic community at fixed stations within five regions of the MCR. Each region was varying distance from the cooling water discharge and CWIS. ENSR (2008a) used four different types of gear to capture a variety of taxa in terms of size (or life stage) and habitat location (e.g., open water vs. benthic).
ENSR (2008a) used the following gear types within each region that was sampled:
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Affected Environment
- Trawls: STPNOC conducted five tows, each for 10 minutes, with a 6.1-m (20-ft) otter trawl fitted with a 3.5-cm (1.4-in.) stretched mesh and doors (i.e., otter boards) measuring 46 cm by 91 cm (18 in. by 36 in.) attached to each wing of the net. The trawl was designed to capture benthic or demersal fishes and macroinvertebrates.
- Gill nets: STPNOC set three gill nets within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of sunset and retrieved them at sunrise the following morning. Gill nets were 91.4-m (300-ft) long, 3.0-m (10-ft) deep, and consisted of four separate panels measuring approximately 22.9-m (75-ft) in length and comprised of 2.5, 5.1, 7.6, and 10.2-cm (1, 2, 3, and 4-in.) stretched mesh connected in ascending order.
The grill nets were designed to capture adult fish using open water surface habitats.
- Seines: STPNOC conducted one seine pull per sampling event. Seines were comprised of 6.4-mm (0.25-in.) mesh net and measured 30.5-m (100-ft) long and 3.0-m (10-ft) deep. Seines were designed to capture small macroinvertebrates and fish using shoreline habitats.
- Plankton nets: STPNOC conducted three oblique plankton tows through all depths of water per sampling event. It used a low speed Henson plankton net with a with a dimension of 30-cm (12-in.) mouth width by 120-cm (47-in.)
length and covered with mesh size of 0.363 mm (0.014 in.). Plankton nets were designed to capture pelagic ichthyoplankton, invertebrate larvae, and small invertebrates.
ENSR (2008a) collected 11,605 fish and invertebrates using gill nets, seines, and trawls (Table 2-4). ENSR (2008a) identified 25 species of fish and invertebrates. Threadfin shad (Dorosoma petenense) was the most commonly collected species, representing 62 percent of all fish and invertebrates collected using gill nets, seine pulls, or trawls. Other commonly collected species include inland silverside (Menidia beryllina) (18 percent), rough silverside (Membras martinica) (12 percent), and blue catfish (Ictalurus furcatus) (3 percent)
(ENSR 2008a). Blue crab was the most commonly collected invertebrate, and it comprised less than 1 percent of the total organisms collected using gill nets, seines, and trawls.
ENSR (2008a) collected a total of 5,362 organisms using plankton nets (Table 2-5). Greater than 99 percent of the organisms collected were invertebrates (crustaceans), and less than 1 percent was ichthoplankton (fish eggs and larvae). The most common species (84 percent of all plankton net samples) collected were Harris mud crab larvae (ENSR 2008a). ENSR (2008a) collected two fish taxaclupeid shad (Clupeidae spp.) and gobi (Gobiidae spp.).
The fish and invertebrates collected in the MCR suggest that a robust aquatic community has developed in the MCR. This community is more representative of an estuarine river rather than a freshwater impoundment, likely because the source of fish and invertebrates is from the Colorado River during filling of the MCR.
While a diverse aquatic community exists in the MCR, its organisms no longer contribute to the riverine ecosystem because they are separate from the Colorado River. In addition, the organisms are not available for harvest, and there is no public access or use of the MCR. The USACE has determined that the MCR is not waters of the U.S. (USACE 2009), and TCEQ has stated that the MCR is not waters of the State (TCEQ 2007).
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Affected Environment Table 2-4. Fish and Invertebrates Collected in the MCR by Gill Nets, Seines, and Trawls, 2007 to 2008.
Common Name Fish Scientific Name Gill Net Seine Trawl Total % of Total Atlantic croaker Micropogonias undulatus 17 86 103 <1 Black drum Pogonias cromis 26 26 <1 Blue catfish Ictalurus furcatus 308 35 50 393 3 Bluegill Lepomis macrochirus 31 31 <1 Channel catfish Ictalurus punctatus 3 21 6 30 <1 Common carp Cyprinus carpio carpio 97 9 106 <1 Freshwater drum Aplodinotus grunniens 7 3 39 49 <1 Gizzard shad Dorosoma cepedianum 45 28 73 <1 Gulf menhaden Brevoortia patronus 4 1 5 <1 Inland silverside Menidia beryllina 2,068 2,068 18 Ladyfish Elops saurus 36 1 37 <1 Gray (mangrove) snapper Lutjanus griseus 2 2 <1 Naked goby Gobiosoma bosc 3 3 <1 Needlefish Strongylura exilis 1 1 <1 Pinfish Lagodon rhomboides 3 1 4 <1 Red drum Sciaenops ocellatus 1 1 <1 Rough silverside Membras martinica 1,362 1,362 12 Sheepshead minnow Cyprinodon variegatus 4 4 <1 Smallmouth buffalo Ictiobus bubalus 2 2 <1 Spotted gar Lepisosteus oculatus 1 2 3 <1 Striped mullet Mugil cephalus 1 41 42 <1 Threadfin shad Dorosoma petenense 6,463 768 7,231 62 White mullet Mugil curema 7 7 <1 Invertebrates <1 Blue crab Callinectes sapidus 11 2 6 19 <1 Rangia clam Rangia cuneata 3 3 <1 Total 515 10,091 999 11,605 Source: ENSR 2008a 2-35
Affected Environment Table 2-5. Fish and Invertebrates Collected in the MCR by Plankton Tows, 2007 to 2008 Common Name Fish Taxa Total % of Total Clupeid shad Clupeidae spp. 15 <1 Gobi Gobiidae spp. 2 <1 Invertebrates Water flea Cladocera spp. 8 <1 Amphipods Amphipoda spp. 1 <1 Copepods Copepoda spp. 22 <1 Fish lice Branchiura spp. 1 <1 Decapods Panopeidae spp. 539 10 Harris mud crab Rhithropanopeus harrissi 4,582 85 Decapod zoea Decapoda spp. 153 3 Brachyuran decapod Brachyura spp. 29 1 Mysid shrimp Mysida spp. 2 <1 Bivalvia Bivalvia spp. 3 <1 Unidentified 5 <1 Total 5,362 Source: ENSR 2008a Essential Cooling Pond. The ECP is a 46-ac (19-ha) cooling pond and serves as the ultimate heat sink for Units 1 and 2. ENSR (2002) conducted a survey of the ECP and identified two fish species: sailfin molly (Poecilia latipinna) and sheepshead minnow (Cyprinodon variegates).
ENSR (2002) captured fewer fish near the discharge structure compared to elsewhere in the ECP. ENSR (2007, 2008c) identified sailfin molly and sheepshead minnow in the main drainage channel (MDC) and the Colorado River, and ENSR (2008a) identified sheepshead minnow in the MCR.
Other Aquatic Features. Other onsite aquatic features include the Little Robbins Slough, wetlands, Kelly Lake, and drainage areas.
Little Robbins Slough is a stream that flows across the site, from the northwest corner, along the western edge of the MCR embankment, and then out the southwest corner. This water flow is critical to the function and structure of the marshes both on site and south of the site (Mad Island Wildlife Management Area (WMA) and Clive Runnells Family Mad Island Marsh Preserve). These marshes provide nursery grounds for juvenile fish and shellfish. The water from Little Robbins Slough eventual flows into the GIWW.
Kelly Lake is located in the northeast edge of the MCR embankment (STPNOC 2010d). The lake covers approximately 34 ac (14 ha) and is primarily fed by drainage areas but may also receive groundwater discharge (STPNOC 2010d). The NRC staff is not aware of any aquatic ecology surveys of Kelly Lake (NRC 1975, 1986, 2011b; STPNOC 2010b).
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Affected Environment The STP site also includes numerous drainage areas, many of which are man-made ditches (NRC 2011b). NRC (1975, 1986) included a description of the prevalent aquatic communities on the STP site in drainage areas. The most common species from these studies include the following: grass shrimp (Palaemonetes kadiakensis; also known as Mississippi grass shrimp),
crayfish (possibly of several genera), blue crab, red shiner (Cyprinella lutrensis), mosquitofish (Gambusia affinis), silverband shiner (Notropis shumardi), sailfin molly, green sunfish (Lepomis cyanellus), warmouth (L. gulosus), bluegill (L. macrochirus), white crappie (Pomoxis annularis),
tidewater silverside (Menidia peninsulae), striped mullet, and several species of killifish (Family Cyprinodontidae, likely Lucania spp. and Fundulus spp.). NRC (1975, 1986) reported aquatic invertebrates, such as the early life stages of midges, beetles, mayflies, biting midges, dragonflies, and damselflies. The fish and invertebrates found in drainage areas are common species along the Texas coastline, and most are generally tolerant of salinity and water temperature fluctuations (Hassan-Williams and Bonner 2009; NRC 1975, 1986, 2011b; STPNOC 2010d; Thomas et al. 2007).
More recently, ENSR (2007) conducted a rapid bio-assessment of the MDC. The MDC is a 150-m (492-ft) unlined channel that runs north of the proposed STP, Units 3 and 4, power block, crosses the existing railroad track, and eventually joins the Little Robbins Slough west of the MCR (ENSR 2007; NRC 2011b). STPNOC relocated the MDC further north of the proposed STP, Units 3 and 4, power block as part of STPNOCs proposal to build Units 3 and 4 (STPNOC 2010e). There is no continual flow of water in the MDC. Saturated soils and possible groundwater support shallow pooled areas. Water depth increases during rain events, and water drains into Little Robbins Slough during high flows (ENSR 2007; NRC 2011b).
ENSR (2007) conducted the survey using seine nets and followed a modified version of EPAs rapid bioassessment protocols (Barbour et al. 1999). ENSR (2007) identified 11 fish taxa, 2 invertebrate taxa, and 1 turtle. The three most common species were largemouth bass (Micropterus salmoides), mosquitofish, and sailfin mollies. Other species included other sunfish species (redear sunfish (Lepomis microlophus), pumpkinseed (L. gibbosus), and bluegill),
killifish (Bayou killifish (undulus pulverous), Gulf killifish (Fundulus grandis), sheepshead minnows), gobies (Gobiidae), inland silverside, crayfish (several genera occur in the area, e.g., Procambarus spp.), grass shrimp, and red eared slider (Chrysemys scripta). Similar to the fish and invertebrates that inhabited drainages areas in 1970s and 1980s, the taxa found in the MDC are common species along the Texas coastline, and most are generally tolerant of salinity and water temperature fluctuations (Barbour et al. 1999; Ross 2001; STPNOC 2010d).
2.2.6.3 Transmission Lines Power generated from STP during the proposed license renewal term would be transmitted using existing transmission line corridors. The transmission corridors pass through forested, agricultural, and grasslands typical of the Texas coastal prairie (STPNOC 2010b). The water bodies crossed by the transmission corridors include small rivers, small streams, agricultural ponds, drainage areas, and wetlands (NRC 1975). The NRC staff is not aware of any aquatic surveys conducted along these corridors. The NRC staffs review of the terrain along the Hillje transmission line during a pre-application site visit for the proposed STP, Units 3 and 4, did not indicate any notable aquatic features within that region of the corridor (NRC 2008a). Observed water bodies included wetlands and small ponds. Aquatic species in the water bodies along the transmission corridors are likely similar to those communities typically found along the coastal plain and are likely tolerant to temporary changes in water quality (NRC 2011b; STPNOC 2010d).
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Affected Environment 2.2.7 Terrestrial Resources STP Ecoregion. Beginning in the 1980s, the USGS, EPA, the Commission for Environmental Cooperation, and various other Federal agencies and interagency groups have begun delineating North American ecoregions to provide a common geographical framework by which to assess and manage the environment. Ecoregions are divided into Levels I through IV; Level I encompasses large areas of land and is the broadest category, while Level IV is the most specific. Ecoregions are delineated by many factors to include location, climate, vegetation, hydrology, terrain, wildlife, and land use. The STP site lies within the following Level I through IV ecoregions:
- Level I: Great Plains,
- Level II: Texas-Louisiana Coastal Plains,
- Level III: Western Gulf Coastal Plain, and
- Level IV: Floodplains and Low Terraces.
The Great Plains cover the majority of the midwestern states and are broadly characterized by a subhumid to semiarid climate, shortgrass and tallgrass prairie, and little topographic relief (EOE 2008). Within the Great Plains, the Texas-Louisiana Coastal Plains contain flat coastal plains, barrier islands, dunes, beaches, bays estuaries, and tidal marshes (Wiken et al. 2011).
Historically, tallgrass prairie dominated the region. Within these coastal plains, STP lies within the floodplains and low terraces of the Western Gulf Coastal Plain, a 50- to 90-mi (80- to 140-km) wide strip of flat land adjacent to the Gulf of Mexico (Griffith et al. 2007). The Western Gulf Coastal Plain comprises 1,743 ac (705 ha), with an elevation range of 5 to 200 ft (2 to 60 m) above MSL (Griffith et al. 2007). The terrain is relatively flat, and grasslands dominate undeveloped areas. Inland regions contain some forested land and savannah lies inland, but the majority of this ecoregion is used as cropland for rice, cotton, and soybeans (Griffith et al. 2007). Other natural features include sloughs, natural levees, and alluvial terraces, as well as low gradient streams.
Natural habitats include deciduous bottomland forest and swamps. Maintained lands include cropland and pastureland. Common bottomland tree species include pecan (Carya illinoensis),
water oak (Quercus nigra), southern live oak (Q. virginiana), and elm (Ulmus spp.) (Griffith et al. 2007). Baldcypress (Taxodium distichum), black hickory (C. texana), post oak (Q. stellata) and winged elm (U. alata) also grow in this region but are not as common (Griffith et al. 2007).
Coastal marshes contain cordgrass (Spartina spp.), saltgrass (Distichlis spicata), needlerush (Juncus spp.), and saltmarsh bulrush (Scirpus paludosus) (Wiken et al. 2011). Common wildlife species include white-tailed deer (Odocoileus virginianus), ocelots (Leopardus pardalis),
jaguarondi (Puma yagouaround), coyote (Canis latrans), ringtail cat (Bassariscus astutus),
armadillo (Asypus novemcinctus), peccary (Pecari tajacu), swamp rabbit (Sylvilagus aquaticus),
American alligator (Alligator mississippiensis), ferruginous pygmy-owl (Glaucidium brasilianum),
green jay (Cyanocorax yncas), Altamira oriole (Icterus gularis), Attwaters prairie-chicken (Tympanuchus cupido attwater), whooping cranes (Grus americana), and various species of ducks and geese (Wiken et al. 2011).
STP Site. The STP site occupies about 12,220 ac (4,950 ha) immediately west of the Colorado River and approximately 10 mi (16 km) from the rivers confluence with Matagorda Bay (STPNOC 2010b). Of that 12,220 ac (4,950 ha), the MCR occupies 7,000 ac; the STP buildings, warehouses, and infrastructure occupy about 300 ac (120 ha); and the ECP occupies 46 ac (19 ha). The remaining land is undeveloped and includes bottomland, agricultural and pastureland, wetlands, mixed grasslands, and shrub scrub. ENSR conducted an ecological 2-38
Affected Environment survey of the STP site between 2006 and 2008. The NRC staff derived the majority of the information presented in this section from this assessment.
Along the Colorado River, on the eastern boundary of the STP site, lies about 1,176 ac (476 ha) of bottomland forested habitat that contains a mixture of trees, shrubs, and grasses. Dominant tree species include sugarberry (Celtis laevigata), pecan, cottonwood (Populus spp.), water oak, southern live oak, American elm (Ulmus americana), willow (Salix spp.), and Chinese tallow (Sapium sebifera). Common shrub species include yaupon (Ilex vomitoria), Chinese privet (Ligustrum sinense), McCartney rose (Rosa meizeli), and American beautyberry (Callicarpa americana). Grassy areas contain woodoats (Chasmanthium latifolium), carpet grass (Axonopus affinis), crab grass (Digitaria spp.), broomsedge, and Bermuda grass (Cynodon dactylon). Another 53-ac (21-ha) forested area lies on the STP site north of the heavy haul road. The dominant species are the same as in the larger bottomland area (ENSR 2008b).
Within the west and north of the developed portion of the site lies 976 ac (395 ha) of scrub shrub. Sea-myrtle (Baccharis halimifolia), goldenrod (Solidago spp.), ragweed (Ambrosia spp.),
aster (Aster spp.), southern dewberry (Rubus trivialis), peppervine (Ampelopsis arborea), and sumpweed (Iva annua) are the most common vegetation (ENSR 2008b).
About 486 ac (197 ha) of the site is mixed grasslands, some of which STPNOC regularly mows or maintains. Common grass species in these areas include angleton bluestem (Dichanthium aristatum), King Ranch bluestem (Bothriochloa ischaemum var. songarica), and bristle grass (Setaria spp.) (ENSR 2008b).
Many wetlands exist on the site, some of which the USACE has determined to be jurisdictional wetlands. The non-jurisdictional wetlands include Kelly Lake and a 110-ac (45-ha) managed wetland along the northern portion of the site.
Kelly Lake is a 34-ac (14-ha) natural water body within the northeast corner of the site along the MCR embankment. It is fed by a small catchment area north of the lake. At least two drainages flow into the lake, and one drainage flows south along the east site of the MCR embankment and exits the lake (NRC 2011b). Cattail (Typha spp.) and arrowhead (Sagittaria spp.) surround Kelly Lake (NRC 2011b).
The 110-ac (45-ha) managed wetland is part of the larger Texas Prairie Wetland Project, a series of at least 35,000 ac (14,100 ha) of wetlands along the Gulf coasts that have been set aside or restored through a partnership with Ducks Unlimited, the Texas Parks and Wildlife Department (TPWD), the U.S. Fish and Wildlife Service (FWS), the U.S. Department of Agriculture, and private landowners (Ducks Unlimited 2006). This wetland provides forage and wintering habitat for waterfowl, wading birds, and shorebirds (STPNOC 2010b). Houston Lighting and Power Company (HPLC), on behalf of STP, signed an agreement in October 1996 with Ducks Unlimited to manage and restore or enhance this portion of the STP property as part of the Texas Prairie Wetlands Project (Ducks Unlimited and HPLC 1996). As part of the agreement, HPLC committed to developing and managing the 110 ac (45 ha) to provide seasonal or semi-permanent wetland habitat for wintering migratory birds and other wetland-dependent wildlife (Ducks Unlimited and HPLC 1996). HPLC also built multiple impoundments to create foraging habitat (Ducks Unlimited and HPLC 1996).
The jurisdictional wetlands include 29 small wetlands within the northern portion of the site, most of which are ditches or depression wetlands (USACE 2009). The largest delineated wetland is 3.78 ac (1.53 ha), and 16 of the delineated wetlands are less than 0.5 ac (0.2 ha)
(ENSR 2008b). In total, jurisdictional wetlands cover 17.6 ac (7.1 ha) (USACE 2009).
Dominant wetland vegetation includes spikerush (Eleocharis spp.), cattail (Typha spp.), water hyssop (Bacopa monnieri), knotgrass (Polygonum spp.), bushy bluestem (Andropogon 2-39
Affected Environment glomeratus), sea-myrtle, and rattlebox (Crotalaria spp.) (ENSR 2008b). Additionally, the USACE has designated 24,639 linear feet (7,510 linear meters) of non-wetland areas as jurisdictional waters.
The most common wildlife on the site include white-tailed deer, rabbit (Silvilgus spp.), squirrel (Sciurus spp.), and feral hogs (Sus scrofa) (STPNOC 2010b). Cardinals (Cardinalis cardinalis),
mourning doves (Zenaida macroura), bobwhite quail (Colinus virginianus), red-winged blackbirds (Agelaius phoeniceus), grackles (Quiscalus spp.), black vultures (Coragyps atratus),
and turkey vultures (Cathartes aura) are the most common birds. Wading birds, such as great blue heron (Ardea herodias), great egret (Ardea alba), roseate spoonbill (Ajaia ajaja), white ibis (Eudocimus albus), and little blue heron (Egretta caerulea), are common near Kelly Lake, the MCR, and other water features (STPNOC 2010b). American alligators, discussed in more detail in Section 2.2.7, regularly inhabit the site. Other common reptiles include the copperhead snake (Agkistrodon contortrix contortrix), cottonmouth snake (A. piscivorus), eastern hog-nosed snake (Heterodon platirhinos), eastern racer (Coluber constrictor), corn snake (Elaphe guttata),
eastern rat snake (E. obsoleta), diamondback watersnake (Nerodia rhombifer rhombifer),
eastern box turtle (Terrapene carolina), ornate box turtle (T. ornata), snapping turtle (Chelydra serpentina), red-eared pond slider (Trachemys scripta elegans), green anole (Anolis carolinensis), and five-lined skink (Eumeces fasciatus) (NRC 2011b).
Each year, Matagorda County hosts a Christmas Bird Count (CBC), a volunteer bird count organized by the Audubon Society that runs from December 14 through January 5 of each year.
The count centers on Mad Island and encompasses about 113,000 ac (45,700 ha) within a 15-mi (24-km) radius. Because the STP site lies near the southern terminus of the Central Flyway, a great diversity of birds inhabit or pass through the site and surrounding region, and the region provides important stopover and wintering habitat for migrating birds. During the 2010 to 2011 bird count, participants recorded 231 different bird species (Audubon 2011).
Within the past 5 years of bird count data, red-winged blackbirds (Agelaius phoeniceus) and brown-headed cowbirds (Molothrus ater) accounted for the overwhelming majority (70 and 19 percent, respectively) of recorded observations. Figure 2-5 identifies the most commonly observed species in the past 5 years of CBCs. The birds in this figure were of the top 10 most commonly recorded species for at least 2 years out of the past five CBCs. In addition to the bird species in Figure 2-5, six additional species appeared in the top 10 recorded species for only one data year. Table 2-6 lists these species and the year and number of each.
Table 2-6. Birds Observed in High Numbers for One Christmas Count Year, 2007 through 2011 Year Recorded Within Top # of Individuals Species 10 Most Common Species Recorded American white pelican 2009-2010 1,700 blackbird spp. 2010-2011 5,115 lesser scaup 2010-2011 85,438 redhead 2008-2009 15,005 Rosss goose 2009-2010 2,537 sandhill crane 2008-2009 10,000 Source: Audubon 2011 2-40
Figure 2-5. Most Commonly Recorded CBC Species, 2007 through 2011 (Audubon 2011) 140000 120000 100000 80000 60000 40000 2-41 20000 Number of Individuals Observed 0
American greater boat- Brown- great- red- savanna American green- American Brewer's common white- northern snow tailed headed tailed winged h coot winged robin blackbird grackle fronted pintail goose grackle Cowbird grackle blackbird sparrow teal goose 2010-11 3994 3828 0 4340 0 20752 0 0 10419 0 317446 3626 56000 2009-10 4315 0 0 11328 0 20626 0 0 2796 3965 62183 3995 16000 2008-09 6400 0 0 23459 0 26100 5000 10700 0 6878 415000 0 29809 2007-08 0 10785 6006 0 5881 792077 93127 133443 0 5432 2561465 5404 48729 2006-07 0 10785 6006 0 5881 792077 93127 133443 0 5432 2561465 5404 48729 Affected Environment
Affected Environment In addition to the data available from the CBCs, ENSR conducted a bird survey in 2006 and 2007 on the STP site as part of the STP, Units 3 and 4, COL application.
Table 2-7 lists the bird species that ENSR observed on the STP site during this survey and the types of habitats or areas of the site in which each was associated.
Table 2-7. Birds Documented on the STP Site, 2007 through 2008 Habitat Type or Area Trans-Gulf Species Common Name Observed Migrant(a)
Agaelaius phoeniceus red-winged blackbird grassland/scrub-shrub Anhinga anhinga anhinga MCR Ardea herodias great blue heron wetland/MCR Bubulcus ibis cattle egret grassland/wetlands Buteo jamaicensis red-tailed hawk grassland/scrub-shrub Buteo lineatus red-shouldered grassland/scrub-shrub Caracara cheriway crested caracara grassland grassland/scrub-Cathartes aura turkey vulture shrub/developed Charadrius vociferus killdeer grassland/developed Circus cyaneus northern harrier grassland/scrub-shrub Colinus virginianus northern bobwhite grassland/scrub-shrub grassland/scrub-Coragyps atratus black vulture shrub/developed Corvus brachyrhynchos American crow grassland/scrub-shrub Cyanocitta cristata bluejay scrub-shrub Dendrocygna bicolor fulvous whistling-duck wetland Egretta caerulea little blue heron wetlands Egretta thula snowy egret wetland/MCR Egretta tricolor tri-colored heron wetland/MCR Eudocimus albus white ibis grassland/wetlands Fulica americana American coot wetlands Gelochelidon nilotica gull-billed tern MCR Geothlypis trichas common yellowthroat scrub-shrub x Haliaeetus leucocephalus bald eagle river shoreline Hirundo rustica barn swallow grassland/developed x Leucophaeus atricilla laughing gull MCR/developed Megaceryle alcyon belted kingfisher wetlands x Mimus polyglottos northern mockingbird MCR/developed 2-42
Affected Environment Habitat Type or Area Trans-Gulf Species Common Name Observed Migrant(a) grassland/scrub-Molothrus ater brown-headed cowbird shrub/developed Nycticorax nycticorax black-crowned night-heron grassland/scrub-shrub Pandion haliaetus osprey wetland Pelecanus erythrorhynchos American white pelican MCR Pelecanus occidentalis brown pelican MCR Petrochelidon pyrrhonota cliff swallow MCR x Platalea ajaja roseate spoonbill MCR grassland/scrub-Progne subis purple martin x shrub/developed grassland/scrub-Quiscalus major boat-tailed grackle shrub/developed Sturnella magna eastern meadowlark grassland/scrub-shrub Turdus migratorius American robin grassland Tyrannus forficatus scissor-tailed flycatcher grassland/scrub-shrub x Zenaida macroura mourning dove grassland/developed (a)
Birds that cross the Gulf of Mexico from the Yucatan Peninsula to the Gulf coasts Source: ENSR 2008b; NRC 2011b Waterbirds nest on the ends Y dike that directs water flow in the MCR. STPNOC first observed nesting on the MCR dikes in 1986 (STPNOC 2010d). The dominate nesting species include laughing gulls (Leucophaeus atricilla) (53 percent) and gull-billed terns (Gelochelidon nilotica) (31 percent), which account for a collective 84 percent of the 1,200 to 1,600 nests per year (STPNOC 2010d). Seven additional bird species nest on the dikes with typically fewer than 100 nests each (STPNOC 2010d).
Transmission Line Corridors. The transmission lines traverse mostly agricultural lands, as well as forests and grasslands in 12 counties. The habitat is typical of that described previously under STP ecoregion. The corridors do not cross any designated critical habitat, Federal or State parks, wildlife preserves, refuges, or sanctuaries (STPNOC 2010b).
Parks and Wildlife Preserves. Many parks and wildlife preserves provide valuable terrestrial habitat to native migrating birds. Those in the vicinity of STP are discussed briefly below.
The Brazos Bend State Park is a 5,000-ac (2,000-ha) park located about 35 mi (56 km) northeast of the STP site. The TPWD established this park in 1976. Natural habitats include the Brazos River floodplains, upland coastal prairie, bottomland hardwood forest, seasonal freshwater marshes, and oxbow lakes (TPWD 2011a). The park is home to over 300 species of birds, 21 species of reptiles and amphibians, 17 species of mammals, 39 species of dragonflies, and 500 species of plants (TPWD 2011a).
The Mad Island Marsh Preserve lies about 4 mi (6 km) southwest of STP. This preserve is situated on West Matagorda Bay around Mad Island Lake and encompasses a total of 7,063 ac (2,860 ha) (GCBO 2011). The preserve includes coastal prairie, freshwater wetlands, tidal 2-43
Affected Environment saltwater wetlands, and shrubland. The Gulf Coast Bird Observatory has recorded over 300 species of birds within the preserve, including sandhill cranes (Grus canadensis), cinnamon teal (Anas cyanoptera), blue-winged teal (A. discors), northern pintail (A. acuta), Canada goose (Branta canadensis), and snow goose (Chen caerulescens) (GCBO 2011). Many habitat restoration and enhancement projects within this preserveincluding prescribed burns, erosion control, and rotational cattle grazing in limited areascontinue to enhance the value of the habitat.
The TPWD manages the 7,200-ac (2,900-ha) Mad Island Wildlife Management Area, which lies about 3 mi (5 km) south of STP (TPWD 2011d). The State of Texas purchased this parcel of land to preserve coastal wetland habitat for wintering waterfowl. The management area contains brackish marsh and coastal prairies and provides habitat for a wide variety of wildlife The FWS manages the Big Boggy National Wildlife Refuge, which lies about 10 mi (16 km) southwest of STP (FWS 2011c). Figure 2-6 and Figure 2-7 show the STP 50-mi (80-km) radius map (STPNOC 2010b) and STP 6-mi (10-km) radius map (STPNOC 2010b),
respectively. The FWS established this 4,526-ac (1,832-ha) refuge in 1983 to protect saltmarsh habitat for migratory birds. Within the refuge, Dressing Point Island in East Matagorda Bay is an important rookery for brown pelicans, roseate spoonbills, white ibis, snowy egrets, and other colonial nesting birds.
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Affected Environment Figure 2-6. STP 50-mi (80-km) Radius Map (STPNOC 2010b) 2-45
Affected Environment Figure 2-7. STP 6-mi (10-km) Radius Map (STPNOC 2010b) 2-46
Affected Environment 2.2.8 Protected Species and Habitats This section discusses species and habitats that are:
- Federally protected under the Endangered Species Act (ESA) of 1973, as amended;
- designated as a species of concern under the National Marine Fisheries Service (NMFS)s Species of Concern Program;
- Federally protected under the Bald and Golden Eagles Protection Act of 1940, as amended;
- Federally protected under the Migratory Bird Treaty Act of 1918 (MBTA), as amended;
- Federally protected under the Magnuson-Stevens Fishery Conservation and Management Act (MSA), as amended;
- Federally protected under the Marine Mammal Protection Act (MMPA) of 1972, as amended; or
- State-protected under Title 5, Wildlife and Plant Conservation, Chapter 68, Endangered Species, and Chapter 88, Endangered Plants, of the State of Texass Statutes.
2.2.8.1 Species and Habitats Protected Under the Endangered Species Act The FWS and the NMFS jointly administer the ESA of 1973 (16 USC 1531 et seq.). The FWS manages the protection of and recovery effort for listed terrestrial and freshwater species, while the NMFS manages the protection of and recovery effort for listed marine and anadromous species.
Action Area The ESA regulations at 50 CFR 402.02 define action area to mean all areas to be affected directly or indirectly by the Federal action and not merely the immediate area involved in the action. The action area helps to frame the ESA effects analysis because species that occur within the action area may be affected by the Federal action, while species that do not occur within the action area would likely not be affected by the Federal action. NRC considers the action area to include the lands and water bodies described below.
STP site. The STP site lies in a rural area of Matagorda County, Texas, approximately 12 mi (19 km) south-southwest of the city limits of Bay City, Texas. The STP site encompasses about 12,220 ac (4,950 ha) immediately west of the Colorado River and approximately 10 mi (16 km) north of the rivers confluence with Matagorda Bay. Of that 12,220 ac (4,950 ha), the MCR occupies 7,000 ac; the STP reactor and facility buildings, warehouses, switchyard, and other infrastructure occupy about 300 ac (120 ha); and the ECP occupies 46 ac (19 ha). The remaining land is undeveloped and includes bottomland, agricultural and pastureland, wetlands, mixed grasslands, and shrub scrub.
The proposed license renewal would include continued operation of the site, including continued use of the MCR for plant cooling water; intermittent withdrawals from the Colorado River to provide makeup water to the MCR using the existing reservoir makeup pumping facility; and discharges from the MCR to the Colorado River via blowdown pipelines as necessary to maintain water quality in the MCR in accordance with the TCEQ-issued Texas Pollutant 2-47
Affected Environment Discharge Elimination System (TPDES) permit. The proposed license renewal would not involve any new construction or refurbishment activities.
Transmission line corridors to the first substation and 0.5-mi (0.8-km) buffer on either side of the lines. The proposed license renewal would use the existing onsite switchyard and transmission facilities and would not require the construction or modification of the existing transmission system. The scope of the transmission lines included in the ESA analysis has been modified since the NRCs issuance of the draft SEIS to include only those portions of the transmission lines that extend from the plant to the first substation where electricity is fed into the regional power distribution system and the portions of the lines that supply power to the nuclear plant from the grid. 3 At STP, an onsite switchyard lies east of the ECP and connects lines from the plant into the regional power distribution system. Lines beyond this switchyard have been integrated into the regional electric grid and would stay in service regardless of STP license renewal; thus, they would not be affected by the proposed action. Additionally, each of these lines is owned and operated by one of four service providers (American Electric Power Texas Central Company, CenterPoint Energy, City of Austin, or CPS Energy) rather than the applicant, STPNOC; therefore, they are outside of NRCs regulatory purview. Thus, the in-scope transmission lines, as well as the 0.5-mi (0.8-km) buffer, are contained within the footprint of the STP site.
Section 2.1.5 describes the transmission line system in more detail.
Colorado River in the vicinity of STP and onsite aquatic features. STP withdraws and discharges water to the MCR with intermittent makeup water withdrawals and discharges from the lower Colorado River to maintain water level and quality within the MCR. Section 2.2.6 describes the ecology of the Colorado River as well as other onsite aquatic features, including Little Robins Slough, wetlands, Kelly Lake, and drainage areas.
Species and Habitats Under NMFS Jurisdiction Table 2-8 identifies species under the NMFSs jurisdiction within Matagorda County. The NRC created this list based on correspondence with the NMFS (NMFS 2011c); the FWSs Endangered Species Program online database (FWS 2013a); and TPWDs Rare, Threatened, and Endangered Species of Texas online database (TPWD 2013a).
Table 2-8. ESA Species Under NMFS Jurisdiction That Occur in Matagorda County Federal Species Common Name Status(a)
Fish Pristis pectinata smalltooth sawfish LE 3
On June 20, 2013, the NRC published a final rule (78 FR 37282) revising its environmental protection regulation, 10 CFR Part 51, Environmental protection regulations for domestic licensing and related regulatory functions. A revised GEIS (NRC 2013), which updates the 1996 GEIS, provides the technical basis for the final rule. The final rule redefines the number and scope of the environmental impact issues that must be addressed by the NRC and applicants during license renewal environmental reviews.
The rule incorporates lessons learned and knowledge gained from license renewal environmental reviews conducted by the NRC since 1996. Among other changes, the final rule revises the definition of in-scope transmission lines to be those transmission lines that connect the nuclear power plant to the substation where electricity is fed into the regional power distribution system and transmission lines that supply power to the nuclear plant from the grid.
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Affected Environment Federal Species Common Name Status(a)
Mammals Trichechus manatus West Indian manatee LE Reptiles Caretta caretta loggerhead sea turtle LT Chelonia mydas green sea turtle LT Dermochelys coriacea leatherback sea turtle LE Eretmochelys imbricata hawksbill sea turtle LE Lepidochelys kempii Kemps ridley sea turtle LE (a)
LE=Federally listed as endangered; LT=Federally listed as threatened Table Sources: FWS 2013a; NMFS 2011c; TPWD 2013a The majority of the marine species under NMFSs jurisdiction that are listed in Table 2-8 occur in Matagorda Bay. None of these species would occur in the Colorado River due to their habitat requirements; therefore, they do not occur in the action area. Additionally, STPNOC (2010b) did not report occurrences of any of these species on the STP site. Therefore, these species are not discussed in any further detail in this section.
The NRC staff did not identify any candidate or proposed species or proposed or designated critical habitat under NMFSs jurisdiction within the action area.
Species and Habitats Under FWS Jurisdiction Table 2-8a identifies species under the FWSs jurisdiction within the action area. The NRC created this list based on the FWSs Endangered Species Program online database (FWS 2013a); the FWS Southwest Region Ecological Services Web site (FWS-SWR 2013);
TPWDs Rare, Threatened, and Endangered Species of Texas online database (TPWD 2013a);
and correspondence between NRC and the U.S. Department of Interior (DOI) and FWS (DOI 2013; FWS 2011b).
The species in this table differ from those included in the draft SEIS for several reasons. Some species were removed from the list because they only occur in counties no longer considered within the action area due to the revised transmission line scope (see the discussion to the action area above and Section 2.1.5). The NRC staff added three candidates for Federal listing.
The smooth pimpleback (Quadrula houstonensis) and Texas fawnsfoot (Truncilla macrodon) were added per DOIs recommendation in its correspondence with NRC (DOI 2013). The addition of Spragues pipit (Anthus spragueii) was the result of the NRC staffs independent analysis of species that may occur in the action area. The NRC staff added three Federally listed speciesthe eskimo curlew (Numenius borealis), red wolf (Canis rufus), and Louisiana black bear (Ursus americanus luteolus). The TPWD (2013a) lists the eskimo curlew and red wolf as historically occurring in Matagorda County and the Louisiana black bear as a transient in the county.
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Affected Environment Table 2-8a. ESA Species Under FWS Jurisdiction That Occur in Matagorda County Federal Species Common Name Status(a)
Birds Anthus spragueii Spragues pipit C Charadrius melodus piping plover LT Falco femoralis septentrionalis northern aplomado falcon LE Grus americana whooping crane LE Numenius borealis eskimo curlew LE Mammals Canis rufus red wolf LE Leopardus pardalis ocelot LE Ursus americanus luteolus Louisiana black bear LT Mollusks Quadrula houstonensis smooth pimpleback C Truncilla macrodon Texas fawnsfoot C Reptiles Alligator mississipiensis(b) American alligator LT(SA)
(a)
C=Candidate for Federal listing; LE=Federally listed as endangered; LT=Federally listed as threatened; LT(SA)=Federally listed as threatened due to similarity of appearance (b)
The American alligator is designated as threatened due to similarity of appearance with the American crocodile (Crocodylus acutus).
Table Sources: DOI 2013; FWS 2011b, 2013; FWS-SWR 2013; TPWD 2013a Spragues Pipit (Anthus spragueii). The FWS added the Spragues pipit to the list of candidate species for Federal listing in 2009 (74 FR 63337). Candidate species are not formally protected under the ESA but may be protected in the future if listed as threatened or endangered. In its most recent Candidate Notice of Review (77 FR 69994), the FWS assigned the Spragues pipit a listing priority number of (LPN) of 8 in a range of 1 to 12 where 1 is the highest listing priority.
The Spragues pipit breeds in the northern Great Plains; migrates through the central Great Plains in spring and fall; and winters in southern Arizona and New Mexico, Texas, eastern Louisiana, and Mexico. The species is most commonly observed in Texas from mid-September to early April. Spragues pipit is strongly associated with native upland prairie, is sensitive to patch size, and tends to avoid edge habitats (TPWD 2013a). Within Texas, the species inhabits heavily grazed grasslands and pastures dominated by little bluestem (Schizachyrium scoparium) and Andropogon spp. (Jones 2010). Pipits have also been observed on turf grass farms, golf courses, heavily grazed Bermuda grass, and burned pastureland (Jones 2010). Threats to the Spragues pipit within its wintering range include over-grazing, habitat fragmentation or degradation, and development or conversion of grasslands.
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Affected Environment The FWS Conservation Plan for the species notes that the second highest density of wintering Spragues pipits in Texas has been observed on grasslands at the Attwater Prairie Chicken National Wildlife Refuge in Colorado County and the Mad Island complex in Matagorda County (Jones 2010). During the Audubon Societys annual CBC, an average of 33 individuals each year for the past 15 years (1998 through 2012) have been recorded within the Matagorda County-Mad Island Marsh (TXMM) unit, which encompasses about 113,000 ac (45,700 ha) within a 15-mi (24-km) radius (Audubon 2013). The most individuals were recorded in 2002 (78 individuals), while the least number of individuals were recorded in 2003 (14 individuals)
(Table 2-8b).
As described in Section 2.2.7, the STP site includes about 486 ac (197 ha) of mixed grasslands, and a portion of the site east of the MCR is leased for cattle grazing. These areas of the site provide suitable habitat for the Spragues pipit. Given the available occurrence information above and habitat requirements of the species, the Spragues pipit likely occurs in the action area.
Piping Plover (Charadrius melodus). The FWS listed the piping plover as threatened in 1985 (50 FR 50726). The species occurs through much of the northern Great Plains, Great Lakes region, Atlantic coast, and Gulf Coast region. A recent study of the taxonomy of the species (Miller et al. 2009) confirmed genetic uniqueness of only two subspeciesAtlantic (C.m.
melodus) and Interior (C.m. circumcinctus). The FWS recognizes three distinct population segments in its ESA rulemakingsthe Atlantic Coast, the Great Lakes, and the Northern Great Plains populations (FWS 2009). The Atlantic Coast population is C.m. melodus, while the Great Lakes and Northern Great Plains populations are C.m. circumcinctus.
The Texas Gulf Coast provides wintering habitat for all three distinct population segments between September and March. Piping plover wintering grounds usually consist of ocean beaches or sand or algal flats in protected bays with high habitat heterogeneity (Haig 1992). At Laguna Madre, Texas, Drake et al. (2001) found piping plovers to be most abundant on algal flats in fall and spring months and on exposed sand flats in winter months. Relatively little information is known about the piping plovers winter diet, but the species is known to forage for various worms, fly larvae, beetles, crustaceans, mollusks, and other invertebrates in areas of open, sparsely vegetated ocean beaches, intertidal flats, and tidal pool edges (NatureServe 2013a).
Piping plovers inhabit the nearby shoreline of Matagorda Bay and the Gulf of Mexico near the STP site and are regularly observed during the CBC within the TXMM unit. Over the past 15 years, an average of 36 individuals have been observed in the TXMM unit with a high of 112 individuals in 2008 and a low of 4 individuals in 1998 (Table 2-8b). However, STPNOC (2010b) reported that it has not observed the species on the STP site. Though it is possible that the piping plover could occur on the STP site due to the sites proximity to Matagorda Bay, the STP site does not provide suitable habitat for the piping plover. As described in Section 2.2.7, the STP site includes developed land, bottomland forest, agricultural and pastureland, wetlands, mixed grasslands, and shrub scrub. None of these habitats provide open, sandy habitats preferred by the piping plover. In Laguna Madre, Texas, Drake et al. (2001) observed non-breeding home ranges to be larger in winter than in fall or spring with an overall mean of 12.6 km2 (7.8 mi2). For purposes of conservation and management planning, piping plovers are believed to move from areas of suitable habitat a mean linear distance of 1.9 km (1.2 mi) in fall, 4.2 km (2.6 mi) in winter, and 3.6 km (2.2 mi) in spring (Hammerson and Cannings in NatureServe 2013a). Matagorda Bay, which provides the nearest suitable habitat, lies 10 mi (16 km) south of the STP site. Thus, piping plovers are unlikely to occur as far north as the STP site and, therefore, would not occur in the action area.
The NRC will not consider this species in any further detail in this SEIS.
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Affected Environment Piping Plover Critical Habitat. STP is in close proximity to four units of designated piping plover critical habitat. The closest critical habitat unit is TX 26, Colorado River Diversion Delta, which consists of 13 ac (5 ha) that follow the shore of the northeast corner of West Matagorda Bay from Culver Cut to Dog Island Reef (66 FR 36038). This unit is about 7 mi (11 km) south of the STP site boundary. It includes roosting areas and is infrequently inundated by seasonal winds.
The other three units are (66 FR 36038):
(a) TX 23, West Matagorda Peninsular Beach769 ac (311 ha) of Gulf of Mexico shoreline from the Matagorda Ship Channel jetties to the old Colorado River channel, (b) TX 25, West Matagorda Bay and Eastern Peninsula Flats575 ac (232 ha) following the bayside of Matagorda Peninsula from Maverick Slough southwest for 3 mi (5 km), and (c) TX 27, East Matagorda Bay and Matagorda Peninsular Beach West728 ac (295 ha) of Gulf of Mexico shoreline from the mouth of the Colorado River northeast along the peninsula for 14 mi (23 km).
Within these units, only the areas that contain primary constituent elements (the physical and biological landscape features that a species requires to survive and reproduce) are considered critical habitat (FWS 2000). Therefore, buildings, marinas, parking lots, and other developed areas do not constitute critical habitat. Though these critical habitat units lie near the STP site, they do not occur within the action area.
Northern Aplomado Falcon (Falco femoralis septentrionalis). The FWS listed the northern aplomado falcon as endangered in 1986 (51 FR 6686). Historically, this species breeding range encompassed southern Arizona, New Mexico, and Texas as well as parts of Mexico and Guatemala; today, the species may be extirpated from Arizona (NatureServe 2013b). Northern aplomado falcons nest along the Gulf Coast of Mexico in northern and central Veracruz, northern Chiapas, western Campeche, and eastern Tabasco (Matthews and Moseley 1990).
Within Texas, the species inhabits open country such as savannah and open woodlands as well as grassy plains and valleys with scattered mesquite, yucca, and cactus (TPWD 2013a). The FWS (2013b) notes that within these habitats, the essential habitat elements are open terrain with scattered trees, relatively low ground cover, an abundance of insects and small to medium-sized birds, and a supply of nest sites.
Northern aplomado falcon breeding pairs usually remain together throughout the year. The species typically nests in the abandoned nests of other large birds, such as crows, ravens, hawks, and kites (Hector 1990). Females typically lay two to three eggs between January to June with peak egg laying occurring in April, and both parents incubate eggs. Young hatch in roughly 31 to 32 days and can fly at 4 to 5 weeks, though they may remain in nest area for several weeks more. The species primarily hunts at night for small birds and insects (NatureServe 2013b).
The species has been recorded during the CBC as occurring within the TXMM unit in 7 of the past 15 years (1998 through 2012) (Audubon 2013). Two individuals were recorded in 2003 and 2008, and one individual was recorded in 2000, 2002, 2005, 2007, and 2009 (Table 2-8b).
No individuals were recorded in the remaining years. This information indicates that the species is present, though rare, in Matagorda Bay.
Within the STP site boundary, the 976 ac (395 ha) of scrub shrub habitat that lies west and north of the developed portion of the site could provide suitable habitat for the northern aplomado falcon as could the mixed grasslands and leased pastureland on the site. Thus, this species could occur within these areas of suitable habitat in the action area.
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Affected Environment Whooping Crane (Grus americana). The FWS listed the whooping crane as endangered in 1967 under the Endangered Species Preservation Act of 1966, the predecessor regulation to the ESA. The species is currently composed of three populations, one of whichthe Aransas-Wood Buffalo National Park Populationmigrates to coastal marshes in Texas in the winter with significant migration stopovers in southern Saskatchewan, Nebraska, Kansas, and Oklahoma (NatureServe 2013c). This population winters at the Aransas National Wildlife Refuge in Texas, which lies approximately 35 mi (56 km) south of the STP site (NRC 2011b).
The other two populations are reintroduced populations: a non-migratory population in central Florida and a migratory population that migrates between Wisconsin and Florida (NatureServe 2013c).
Whooping cranes migrate to the Texas coast between late October and mid-November and generally stay through late March to mid-April (FWS 2011b). Migratory and winter habitat includes marshes, shallow lakes, lagoons, salt flats, grain and stubble fields, and barrier islands with good horizontal visibility, water depth of 30 cm (12 in.) or less, and minimum wetland size of 0.04 ha (0.10 ac) for roosting (NatureServe 2013c). Whooping cranes feed on blue crabs (Callinectes sapidus), clams, frogs, minnows, rodents, small birds, and berries (TPWD 2013b).
Although birds move to uplands to forage for food, they return to the salt marshes in the evening to roost. Use of uplands or croplands adjacent to the refuge is rare (TPWD 2013b).
Whooping cranes fly relatively high when migrating (1,000 to 6,000 ft (300 to 1,800 m) in altitude) but will fly lower when searching for stopover habitat (FWS 2011b). These birds may fly over the STP site as they migrate through the Central Flyway. However, the whooping crane has not been observed on the STP site (STPNOC 2010b), and the inland habitat on the site is not likely to provide suitable habitat for the species. Additionally, the whooping crane has not been recorded in the TXMM unit during the CBC since 1998 (Table 2-8b). Thus, this species is unlikely to occur in the action area, and the NRC will not consider the whooping crane in any further detail in this SEIS.
Eskimo Curlew (Numenius borealis). The eskimo curlew migrates annually between breeding grounds in North America and wintering grounds in South America. During spring migration (beginning in late February to March), the species passes through Central America, crosses the Gulf of Mexico into Texas and continues northward through the Midwestern U.S. The last confirmed observation of an Eskimo curlew took place in Nebraska in 1987 (76 FR 36491). The species could travel through the STP site during migration; however, due to the lack of recorded sightings in the past 25 years, the species is unlikely to occur in the action area. Additionally, though the TPWD (2013a) identifies this species as occurring historically in Matagorda and Brazoria Counties, the FWSs Endangered Species Program online database (FWS 2013a) does not include this species in its lists for any of the three counties. Therefore, the NRC will not consider this species in any further detail in this SEIS.
Table 2-8b. TXMM CBC Results for Federally Listed Species, 2008-2012 Individuals Individuals Recorded/Hours Species Year Recorded(a) Effort northern aplomado falcon 2000 1 0.0033 (Falco femoralis septentrionalis) 2002 1 0.0027 2003 2 0.0062 2005 1 0.0028 2007 1 0.0027 2-53
Affected Environment Individuals Individuals Recorded/Hours Species Year Recorded(a) Effort 2008 2 0.0067 2009 1 0.0032 piping plover 1998 4 0.0122 (Charadrius melodus) 1999 9 0.0253 2000 6 0.0195 2001 22 0.073 2002 31 0.0831 2003 20 0.0618 2004 69 0.1816 2005 26 0.0735 2006 33 0.0863 2007 77 0.2059 2008 112 0.3758 2009 33 0.1068 2010 16 0.0424 2011 50 0.1462 2012 27 0.0754 Spragues pipit 1998 21 0.064 (Anthus spragueii) 1999 27 0.0758 2000 49 0.1596 2001 25 0.0829 2002 78 0.2091 2003 14 0.0433 2004 20 0.0526 2005 22 0.0622 2006 24 0.0627 2007 36 0.0963 2008 44 0.1477 2009 68 0.2201 2010 18 0.0477 2011 22 0.0643 2012 23 0.0642 whooping crane 1998 2 0.0061 (Grus americana) eskimo curlew no records (Numenius borealis) 2-54
Affected Environment Individuals Individuals Recorded/Hours Species Year Recorded(a) Effort (a)
Data from the Matagorda County-Mad Island Marsh (TXMM) unit, which is centered at (28.6833 N, -95.9833 W) and encompasses a 15-mi (24-km) radius Table Source: Audubon 2013 Red Wolf (Canis rufus). The red wolf formerly occurred throughout the eastern half of Texas in brushy and forested areas, as well as coastal prairies, but has been recognized by FWS as being extinct in the wild since 1980 (Parker et al. 1990). The FWSs Red Wolf Recovery Program has since introduced a captive-bred population of wolves on Alligator River National Wildlife Refuge in northeastern North Carolina (FWS 2013c). Red wolves now inhabit five North Carolina counties but have not been reintroduced into other states. Thus, the red wolf does not occur in the action area, and the NRC will not consider this species in any further detail in this SEIS.
Ocelot (Leopardus pardalis). The ocelot inhabits dense, low brush and requires 70 to 90 percent canopy cover (FWS 2011b). The species historically occurred throughout southern Texas but is now restricted to southern Edwards Plateau and along the Coastal Plain (TPWD 2011e). This species is unlikely to occur on the STP site due to habitat requirements. Therefore, the ocelot is unlikely to occur within the action area, and the NRC will not consider this species in any further detail is this SEIS.
Louisiana Black Bear (Ursus americanus luteolus). The Louisiana black bear may transiently occur within bottomland hardwoods and large tracts of inaccessible forested areas within Matagorda County. However, the species is unlikely to occur within the action area due to the lack of suitable habitat. Additionally, the FWS (2011b) stated that the species does not occur within the area under review for the proposed STP license renewal in a June 2011 letter to the NRC. Thus, the NRC will not consider this species in any further detail in this SEIS.
Smooth Pimpleback (Quadrula houstonensis). The smooth pimpleback is a candidate species for Federal listing; therefore, it is not formally protected under the ESA. The smooth pimpleback inhabits small to moderate streams and rivers as well as moderately sized reservoirs with mixed mud, sand, and fine gravel substrate and slow to moderate flow rates (TPWD 2013a). The species does not tolerate dramatic water level fluctuations, scoured bedrock substrates, or shifting sand bottoms. Smooth pimplebacks occur in the Brazos and Colorado River Basins and may occur in the lower Trinity River Basin.
Smooth pimplebacks have not been recorded as occurring in the MCR or the Colorado River in the vicinity of STP during any of the ecological studies discussed in Section 2.2.5. Additionally, because these waters have become more estuarine over time, the salinity levels would likely make any waters within the action area unsuitable for this freshwater mussel. Thus, the NRC will not consider this species in any further detail in this SEIS.
Texas Fawnsfoot (Truncilla macrodon). The Texas fawnsfoot is a candidate species for Federal listing; therefore, it is not formally protected under the ESA. This species occurs in the Colorado, Trinity, and Brazos River drainages in Central Texas (NatureServe 2013d). Little is known about habitat requirements for this species, but NatureServe (2013d) reports that it prefers rivers and larger streams with sand, gravel, or sandy-muddy bottoms and moderate flows. The species has not been documented in reservoirs, which suggests an intolerance to impoundment (NatureServe 2013d).
Texas fawnsfoot mussels have not been recorded as occurring in the MCR or the Colorado River in the vicinity of STP during any of the ecological studies discussed in 2-55
Affected Environment Section 2.2.5. The species would be unlikely to occur in the MCR due to lack of water flow.
Additionally, because the MCR and Colorado River within the vicinity of STP have become more estuarine over time, the salinity levels would likely make any waters within the action area unsuitable for this freshwater mussel. Thus, the NRC will not consider this species in any further detail in this SEIS.
American Alligator (Alligator mississipiensis). The FWS listed the American alligator in 1967 under the Endangered Species Preservation Act of 1966, the predecessor regulation to the ESA. Following reclassification actions in several states, the FWS declared the species fully recovered in 1987 and reclassified it as threatened due to similarity of appearance to the American crocodile (Crocodylus acutus) throughout the remainder of the species range (52 FR 21059). American alligators inhabit coastal swamps from North Carolina southward and around the Gulf of Mexico as far west as Texas (Audubon 2004). They also occur in coastal flatlands as far north as Arkansas (Audubon 2004).
Alligators inhabit the wetlands on the STP site as well as the MDC and MCR (STPNOC 2010b).
During a 1987 to 1988 ecological study, Baker and Greene (1989) observed small numbers of alligators near Kelly Lake, the south drainage canal, Little Robins Slough, and the various dikes associated with the MCR. In 2007 through 2008, ENSR (2008b) did not observe any Federally listed species during a threatened and endangered species survey. However, ENSR conducted this survey during the winter months, during which time alligators are less active and likely seek refuge in swamps and wetlands near the STP site that provide more shelter. American alligators are known to inhabit the STP site and, thus, occur within the action area.
2.2.8.2 Species Designated as NMFS Species of Concern The NMFS established a Species of Concern Program and species of concern list in 2004 to distinguish between candidate species under the ESA and other species that the NMFS identifies as potentially at risk but for which no ESA listing action has been initiated (69 FR 19975). The NMFS defines species of concern as those species about which the NMFS has some concerns regarding threats to continued existence and population status, but for which insufficient information is available to initiate listing actions under the ESA (NMFS 2011d).
The term species of concern does not appear in either the ESA or its implementing regulations; therefore, it does not carry any procedural or substantive protections under the ESA. Only the NMFS, and not the FWS, maintains a Species of Concern Program and species of concern list. Species of concern in the vicinity of STP appear in Table 2-9.
Table 2-9. NMFS Species of Concern Species Common Name Area of Concern(a) Habitat Anthrozoa Oculina varicosa ivory tree coral Atlantic OceanWest inhabit shallow subtidal waters, Indies, Bermuda, North limestone rubble and ledges, and Carolina, Florida, Gulf soft-bottom sloping habitats from of Mexico, Caribbean 2-152 m in depth Fish Carcharhinus obscurus dusky shark Atlantic Ocean; Gulf of surf zone to waters 400 m deep; Mexico; Pacific not commonly found in estuaries due to salinity requirements 2-56
Affected Environment Species Common Name Area of Concern(a) Habitat Carcharias taurus sand tiger shark Atlantic Ocean; Gulf of surf zone to depths of 25 m; Mexico shallow bays; around coral reefs Epinephelus speckled hind Atlantic OceanNorth offshore rocky bottoms with drummondhayi Carolina to Gulf of depths of 25-183 m; most Mexico common between 60-120 m Epinephelus nigritus warsaw grouper Atlantic OceanMaine continental shelf reefs in waters southward to Gulf of 76-219 m deep Mexico Fundulus jenkinsi saltmarsh topminnow Atlantic OceanTX, small, tidal marshes with salinity LA, MS, AL, FL of 1-4 ppt (a)
Areas of concern are specified by the NMFS species of concern list (NMFS 2011e).
Sources: 75 FR 25174; Aronson et al. 2008; Musick et al. 2007; NMFS 2011c; NRC 2011b; Pollard and Smith 2005; Wai and Huntsman 2006a, 2006b; WEG 2010 Ivory Tree Coral. The ivory tree coral (Oculina varicosa) inhabits marine waters from Cape Hatteras, North Carolina, through the Gulf of Mexico and the Caribbean. However, it is only an NMFS species of concern along the eastern U.S. coast from North Carolina through Florida.
Most of the species population is concentrated off east-central Florida, where it occurs in its deep-water form and creates thicket-type structures. The species may occur in Matagorda Bay in its shallow form, in which the coral forms a symbiotic relationship with zooxanthellae. The shallow form reproduces in July and August via broadcast spawning. Ivory tree coral suspension feeds on planktonic organisms and provides refuge for over 300 species of invertebrates. (NMFS 2010d)
Sand Tiger Shark. The sand tiger shark (Carcharias taurus) is a species of concern in the western Atlantic and northern Gulf of Mexico, though the species is globally distributed in all warm and temperate seas and oceans except the eastern Pacific. Tiger sharks mature at about 6 ft (1.9 m) in length and reach up to 10.4 ft (3.18 m) in length. Individuals are generally solitary but occur in schools for feeding, courtship, mating, and birthing. Females give birth to one or two pups every other year. Sand tiger sharks migrate toward the equator in fall and winter and move poleward during the summer. They prey on bony fishes, small sharks, rays, squid, crabs, and lobster. (NMFS 2010e)
Saltmarsh Topminnow. The saltmarsh topminnow (Fundulus jenkinsi) is a species of concern in the coastal waters of Texas, Louisiana, Mississippi, Alabama, and Florida. Saltmarsh topminnow occur in estuaries, coastal salt marshes, and back water sloughs and tolerate water with salinities of 1 to 20 ppt (NMFS 2009). Females grow up to 60 mm (2.4 in.) in length and males grow to 50 mm (1.9 in.) (NMFS 2009). The NMFS (2009) reports that no information on reproductive behavior or diet is available for this species.
Other Species of Concern. The dusky shark (Carcharhinus obscurus), speckled hind (Epinephelus drummondhayi), and warsaw grouper (Epinephelus nigritus) are unlikely to occur in Matagorda Bay due to their habitat requirements.
In addition to the species already discussed, the NMFS (2011c) listed the night shark as a species of concern occurring in the vicinity of STP. However, the NMFS (2010c) removed the night shark from its species of concern list in 2010. It most often occurs in waters 50 to 100 m (160 to 330 ft) deep, but it can inhabit waters as deep as 600 m (2,000 ft) (Santana et al. 2006).
Because of its depth requirements, the night shark is unlikely to occur in Matagorda Bay.
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Affected Environment 2.2.8.3 Species Protected Under the Bald and Golden Eagles Protection Act The Bald and Golden Eagle Protection Act prohibits anyone from taking bald eagles (Haliaeetus leucocephalus) or golden eagles (Aquila chrysaetos), including their nests or eggs, without an FWS-issued permit. The term take in the Act is defined as to pursue, shoot, shoot at, poison, wound, kill, capture, trap, collect, molest, or disturb (50 CFR 22.3). Disturb means to take action that causes injury to an eagle; decreases its productivity by interfering with breeding, feeding, or sheltering behavior; or results in nest abandonment (50 CFR 22.3).
Bald eagles are present year-round throughout Texas. Breeding populations primarily inhabit the eastern half of the State and the coastal counties from Rockport to Houston (Campbell 2003). During ecological surveys associated with the COL application for STP, Units 3 and 4, ENSR (2007) listed bald eagles as one of the bird species observed on the STP site. An active bald eagle nest lies near the sites eastern boundary in remote woodlands along the Colorado River (NRC 2011b). STPNOC (2010c) first observed this nest site in 2004. A second bald eagle nest lies within 6 mi of the STP site (NRC 2011b).
2.2.8.4 Species Protected Under the Migratory Bird Treaty Act The FWS administers the MBTA, which prohibits anyone from taking native migratory birds or their eggs, feathers, or nests. The MBTA definition of a take differs from that of the ESA and is defined as to pursue, hunt, shoot, wound, kill, trap, capture, or collect, or any attempt to carry out these activities (50 CFR 10.12). Unlike a take under the ESA, a take under the MBTA does not include habitat alteration or destruction. The MBTA protects 1,007 migratory bird species (75 FR 9282). Of these 1,007 species, the FWS allows for the legal hunting of 58 species as game birds (FWS undated). Within Texas, the TPWD manages migratory bird hunting seasons and associated licenses for ducks, geese, coot, rail, gallinules, snipe, woodcock, doves, and sandhill cranes. All Federally and State-listed bird species that appear in Table 28a and Table 2-11 are protected under the MBTA. MBTA-protected-bird species that commonly occur near the STP site are discussed in Section 2.2.6. Additionally, all U.S.-native bird species that belong to the families, groups, or species listed in 10 CFR 10.13 are protected under the MBTA.
2.2.8.5 Species Protected Under the Marine Mammal Protection Act The MMPA established a moratorium on the direct or indirect taking of all species of marine mammals in the U.S. The MMPA defines a take to mean to hunt, harass, capture, or kill.
The NMFS (for whales, dolphins, porpoises, seals, and sea lions) and FWS (for walrus, manatees, otters, and polar bears) may issue take permits for takes that are incidental to commercial fishing, scientific research, and other nonfishing activities.
Under the MMPA, the NMFS and FWS manage marine mammals by identifying the optimum sustainable population level for each species. Those species whose populations have fallen below the optimum sustainable level are considered depleted. Within the Gulf of Mexico, 29 marine mammals occur (NMFS 2011b; TMMSN 2011). Of these, only the bottlenose dolphin (Tursiops truncates) occurs within Matagorda Bay due to the bays shallow depth. Bottlenose dolphins inhabit pelagic waters along the continental shelf and may migrate into bays, estuaries, and river mouths (NMFS 2011a). Those bottlenose dolphins found in Matagorda Bay are part of the Northern Gulf of Mexico Bay, Sound, and Estuarine Stock. According to NMFSs 2010 stock assessment (NMFS 2010a), the status of this stock is unknown because the most recent population estimates are eight or more years old, but this stock is not considered depleted. The NMFS estimates the larger Northern Gulf of Mexico Coastal stock to be 4,191 individuals as of 2007 (NMFS 2011a).
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Affected Environment 2.2.8.6 Species Protected Under the Magnuson-Stevens Act The Gulf of Mexico Fishery Management Council (GMFMC) has designated the lower Colorado River, the GIWW, and Matagorda Bay as essential fish habitat (EFH) for many species in accordance with the MSA. These waters are collectively referred to as part of Ecoregion 5 in the GMFMCs Final EIS for the Generic Essential Fish Habitat Amendment for Gulf of Mexico fishery management plans (GMFMC 2004).
Table 2-10 lists those species with designated EFH within Ecoregion 5 and specifies which of those species life stages have the potential to occur in the vicinity of STP based on each stages life history requirements.
Table 2-10. Ecoregion 5 Species with Designated EFH Fishery EFH Life Stages Life Stages in the Species Common Name Management Plan in Ecoregion 5(a) Vicinity of STP(b)
Scomberomorus coastal migratory king mackerel all stages juveniles cavalla pelagic Scomberomorus coastal migratory Spanish mackerel all stages all stages maculatus pelagic Lutjanus griseus mangrove snapper reef fish all stages all stages Sciaenops ocellatus red drum red drum all stages all stages Farfantepenaeus brown shrimp shrimp all stages larvae, juveniles aztecus Farfantepenaeus pink shrimp shrimp all stages larvae, juveniles duorarum Litopenaeus setiferus white shrimp shrimp all stages larvae, juveniles Menippe adina Gulf stone crab stone crab all stages all stages (a)
All stages indicates that egg, larvae, juvenile, and adult EFH are present.
(b)
The species life stages that do not occur in the vicinity of STP were eliminated based on depth or salinity requirements or both, which are presented in GMFMCs Final EIS for the Generic Essential Fish Habitat Amendment for Gulf of Mexico fishery management plans (GMFMC 2004).
A brief discussion of each EFH species appears below. This section summarizes information on each species from the GMFMCs Final EIS for the Generic Essential Fish Habitat Amendment for Gulf of Mexico fishery management plans (GMFMC 2004) unless otherwise noted.
King and Spanish Mackerel. King mackerel (Scomberomorus cavalla) and Spanish mackerel (Scomberomorus maculates) occur in the Gulf of Mexico. Concentrated populations of king mackerel occur in the coastal waters of South Florida and Louisiana, and the most concentrated population of Spanish mackerel is off the coast of Florida. Adults of both species generally inhabit reefs and coastal waters with salinity ranging from 32 to 36 ppt. Spanish mackerel prefer waters of up to 75 m (250 ft) and will occasionally inhabit estuaries. King mackerel inhabit waters up to 200 m (660 ft), though they most often occupy waters less than 80 m (260 ft). Adult king mackerel eat jacks, snappers, grunts, halfbeaks, penaeid shrimp, squid, andless commonlycrustaceans and mollusks. Spanish mackerel eat clupeids, engraulids, carangids, and squid. Predators of both species include pelagic sharks, little tunny, and dolphin.
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Affected Environment King mackerel spawn over the outer continental shelf from May to October, while Spanish mackerel spawn over the inner continental shelf. Both species eggs are pelagic and buoyant.
King mackerel larvae inhabit the middle and outer continental shelf, while Spanish mackerel larvae move to the inner continental shelf. Larvae consume smaller larval fish such as carangids, clupeids, and engraulids. Young tuna and dolphins prey upon king mackerel larvae.
Juveniles inhabit both offshore and estuarine waters and eat smaller fish and invertebrates.
Little tunny, dolphin, and other pelagic fish prey on juveniles.
Mangrove Snapper. Larval, juvenile, and adult mangrove snapper (Lutjanus griseus) primarily occupy inshore habitats, such as estuaries and continental shelf waters up to 180 m (590 ft) in depth. They inhabit waters about 32 km (20 mi) offshore and inshore waters through freshwater creeks and rivers. Mangrove snappers use a wide variety of habitats, including mangrove, sandy grassbeds, and coral reefs. Mangrove snapper spawn pelagic eggs off shore near reefs from June to August. As larvae grow, they move inshore toward estuarine habitats, especially those with dense beds of Halodule and Syringodium sea grasses. As with adults, juveniles inhabit marine, estuarine, and riverine habitats. Juveniles and adults are most often found near mangroves, where they forage on small fish and crustaceans (Croker 1962; Patillo et al. 1997).
Patillo et al. (1997) indicated that only adults and juvenile stages occur within Matagorda Bay and that even these stages are rare.
Red Drum. Red drum (Sciaenops ocellatus) occur throughout the Gulf of Mexico in shallow estuarine waters up to about 40 m (130 ft) off shore. They inhabit a variety of substrates, including seagrass, sand, mud, and oyster reefs, and can tolerate freshwater through high salinity waters. Red drum move to deep offshore waters in the fall where they spawn in inlet and bay mouths. Eggs hatch in the Gulf, and larvae make their way into estuaries where they remain until maturity. Larvae feed exclusively on mysids, amphipods, and shrimp. Juveniles most often inhabit shallow, protected waters with grassy or muddy bottoms and feed on crabs, shrimp, and small fish. As red drum grow, they shift more of their diet to crabs and eat less fish.
Predators include many larger fish species, such as spot (Leiostomus xanthrus) and Atlantic croaker (Micropogon undulates), sharks, amberjacks (Seriola spp.), and other large piscivorous fish. Patillo et al. (1997) indicated that all life stages of red drum were common in Matagorda Bay.
Brown, White, and Pink Shrimp. Brown shrimp (Farfantepenaeus aztecus) inhabit rivers, estuaries, and offshore Gulf waters to depths of 100 m (330 ft). Adults spawn in spring and summer months in waters at least 18 m deep and of temperatures between 17 and 29 °C (63 to 84 °F). Eggs are demersal, and larvae are pelagic and feed on planktonic algae and zooplankton. On flood tides, larvae and juveniles move into estuaries with shallow waters and submerged aquatic vegetation. They are tolerant of a wide-range of salinities and have been recorded as occurring in waters from 0 to 70 ppt. Adults inhabit Gulf waters from mean low tide to the continental shelf in areas with silt, muddy sand, or sandy substrate.
White shrimp (Litopenaeus setiferus) inhabit shallower waters than brown shrimpgenerally only out to a depth of 40 m (130 ft) but most often less than 27 m (89 ft). They spawn in waters of 9 to 34 m (30 to 110 ft) in spring, summer, and fall. On flood tides, larvae and juveniles move into estuaries with muddy or peat bottoms and significant amounts of detritus. Juvenile white shrimp are often more highly associated with marsh edges, and they feed on sand, detritus, organic matter, mollusk fragments, ostracods, copepods, and insect larvae. Similar to brown shrimp, white shrimp emigrate from rivers and estuaries to deeper Gulf waters as adults.
Pink shrimp (Farfantepenaeus duorarum) occupy deeper waters (up to 110 m (360 ft)) than either the brown or white shrimp. They spawn year-round at depths of 22 to 47 m (72 to 150 ft) and temperatures from 19.6 to 30.6 °C (67.3 to 87.1 °F). Post-larvae migrate to estuaries on 2-60
Affected Environment the flood tides at night in the spring and fall. They inhabit seagrass and mangrove habitats where they burrow into sand and shell mud substrate and return to the water column to feed at night. Juveniles eat a wide variety of organisms, including red and blue-green algae, diatoms, dinoflagellates, polychaetes, nematodes, shrimp, mysids, copepods, isopods, amphipods, mollusks, forams, and fish. Adults move from estuaries into Gulf waters with sand and shell substrate. They are most abundant in waters with depths of 9 to 48 m (30 to 160 ft).
Gulf Stone Crab. The Gulf stone crab (Menippe adina) occupies bottom habitats from less than 1 m (3 ft) (shoreline) to depths of 61 m (200 ft). Adults seek out habitat in which they can burrow under the surface, including rock ledges, coral heads, seagrass patches, oyster bars, rock jetties, and artificial reefs. Adults feed mainly on oysters (Wilber 1989). Females maintain eggs on their abdomen until they hatch and become planktonic. As they metamorphose to larvae, they become epibenthic and settle to areas providing cover such as rubble and seagrass beds. Juveniles inhabit the bottom of the water column but do not burrow. Both adults and juveniles can tolerate salinities up to 33 ppt. Juveniles feed on small mollusks, worms, and crustaceans. Larvae require higher salinities of 30 to 35 ppt and warm water (greater than 86 °F (30 °C)) for optimum growth and survival. All life stages of Gulf stone crab are considered common throughout the year in Matagorda Bay (Patillo et al. 1997).
EFH Species Identified During STP Aquatic Studies. This section briefly discusses EFH species in STP aquatic studies. Section 4.5 discusses these studies in detail. Of the nine species with designated EFH, two species (brown and white shrimp) have appeared in STP impingement or entrainment samples. ENSR (2008a) collected mangrove snapper via gill net, but this species has not appeared in impingement or entrainment samples. Additionally, ENSR (2008a) observed red drum, but ENSR did not collect this species in impingement and entrainment samples or with any of the sample gears.
McAden et al. (1984, 1985) conducted studies to estimate entrainment impacts by collecting surface plankton samples in front of the RMPF. McAden et al. (1984, 1985) also conducted impingement studies by washing all organisms off two intake screens and filtering them through a dip net. Section 4.5 discusses this studys methods in more detail. McAden et al. undertook this study to confirm the accuracy of pre-operational entrainment and impingement loss predictions for 1975 through 1976. McAden (1984) collected the post-larval stage of brown and white shrimp sporadically in very low densities. Post-larval white and brown shrimp appeared in Colorado River plankton net, trawl, and seine samples sporadically and in very low densities (McAden et al. 1983). McAden et al. (1983, 1984) also collected white shrimp in plankton net samples in the siltation basin. White shrimp appeared in impingement samples in both 1983 (16 individuals) and 1984 (4 individuals) in very low numbers (McAden et al. 1983, 1984).
Brown shrimp did not appear in impingement samples in either year.
In 2007 and 2008, ENSR (2008a) conducted impingement and entrainment studies at the CWIS on the MCR from May 2007 through April 2008 as part of the STP, Units 3 and 4, COL application. Section 4.5 discusses this studys methods. During the study, ENSR (2008a) collected two mangrove snappers via gill net in the MCR. In October 2007, mangrove snappers accounted for 2 percent of the fish in trawl samples. The species was not present, or accounted for less than 1 percent of trawl samples, for all other sample months. ENSR noted that several large schools of red drum were observed during the study, but none were collected in any of the sample gears during the study. Of the shrimp species, ENSR (2008a) collected white shrimp and brown shrimp in entrainment samples. These species made up 3 percent and less than 1 percent of total samples, respectively. ENSR did not collect any king mackerel, Spanish mackerel, pink shrimp, or Gulf stone crab in any of the study samples.
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Affected Environment 2.2.8.7 Species Protected Under State of Texas Statutes The Texas legislature authorized the TPWD to establish a list of State-endangered species in 1973, for animals, and in 1988, for plants. Title 5, Wildlife and Plant Conservation, Chapter 68, Endangered Species, of the State of Texass Statutes prohibits individuals from capturing, trapping, taking, or killing as well as possessing, selling, or distributing listed animal species. Chapter 88, Endangered Plants, prohibits individuals from collecting or selling listed plants obtained from public land without a TPWD-issued permit. Table 2-11 contains State-listed species that have the potential to occur on the STP site or along the transmission line corridors. Additionally, all Federally listed species that appear in Table 2-9 are State-protected as well.
Table 2-11. State-listed Species Potential Occurrence(b)
State Along T-Species Common Name Onsite line ROWs Status(a)
Amphibians Eurycea latitans Cascade Caverns salamander T x Eurycea tridentifera comal blind salamander T x Birds Buteo albicaudatus white-tailed hawk T x x Buteo albonotatus zone-tailed hawk T x Egretta rufescens reddish egret T x x Falco peregrinus anatum American peregrin falcon T x x Falco peregrinus tundrius arctic peregrin falcon T x x Haliaeetus leucocephalus bald eagle T x x Mycteria americana wood stork T x x Pelecanus occidentalis brown pelican E x x Plegadis chihi white-faced ibis T x x Sterna fuscata sooty tern T x x Fish Cycleptus elongatus blue sucker T x x Satan eurystomus widemouth blindcat T x Trogloglanis pattersoni toothless blindcat T x Mollusks Lampsilis bracteata Texas fatmucket T x Quadrula aurea golden orb T x Quadrula houstonensis smooth pimpleback T x x 2-62
Affected Environment Potential Occurrence(b)
State Along T-Species Common Name Onsite line ROWs Status(a)
Quadrula petrina Texas pimpleback T x Truncilla macrodon Texas fawnsfoot T x Reptiles Cemophora coccinea lineri Texas scarlet snake T x x Crotalus horridus timber (canebrake) rattlesnake T x x Drymarchon melanurus Texas indigo snake T x erebennus Gopherus berlandieri Texas tortoise T x x Liochlorophis vernalis smooth green snake T x Macrochelys temminckii alligator snapping turtle T x Phrynosoma cornutum Texas horned lizard T x x (a)
E=endangered; T=threatened (b)
The STP site is located in Matagorda County. The transmission lines associated with the STP site traverse Matagorda County as well as Bexar, Brazoria, Colorado, DeWitt, Fayette, Gonzales, Guadalupe, Jackson, Lavaca, Wharton, and Wilson Counties.
Sources: NRC 2011b; STPNOC 2010b; TPWD 2011c, 2011f 2.2.9 Socioeconomics This section describes current socioeconomic factors that have the potential to be directly or indirectly affected by changes in operations at STP, Units 1 and 2. STP, and the communities that support it, can be described as a dynamic socioeconomic system. The communities provide the people, goods, and services required to operate the nuclear power plant. Power plant operations, in turn, provide wages and benefits for people and dollar expenditures for goods and services. The measure of a communities ability to support STP, Units 1 and 2, operations depends on the ability of the community to respond to changing environmental, social, economic, and demographic conditions.
The socioeconomics region of influence (ROI) is defined by the area where STP, Units 1 and 2, employees and their families reside, spend their income, and use their benefits, thereby affecting the economic conditions of the region. The ROI consists of a two-county area (Brazoria and Matagorda Counties), where approximately 84 percent of STP employees reside.
STPNOC employs a permanent workforce of approximately 1,378 workers at STP, Units 1 and 2, with approximately 84 percent living in Brazoria and Matagorda Counties (see Table 2-12) (STPNOC 2010b). Of the remaining 16 percent of the workforce, most are divided among 18 counties across Texas and other states, with numbers ranging from 1 to 62 employees per county. Given the residential locations of STP, Units 1 and 2, employees, the most significant impacts of plant operations are likely to occur in Brazoria and Matagorda Counties. The focus of the socioeconomic impact analysis in this SEIS is, therefore, on the impacts of continued STP, Units 1 and 2, operations on these two counties.
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Affected Environment Table 2-12. STP, Employee Residence by County County # of Employees % of Total Brazoria 298 22 Matagorda 851 62 Fort Bend 54 4 Wharton 62 4 Other 96 7 Other states 17 1 Total 1,378 100 Source: STPNOC 2010b Refueling outages at STP, Units 1 and 2, normally occur at 18-month intervals. During refueling outages, site employment increases by as many as 1,350 temporary workers for approximately 1 to 2 months (STPNOC 2010b). Most of these workers are assumed to be located in the same geographic areas as STP, Units 1 and 2, employees. The following sections describe the housing, public services, offsite land use, visual aesthetics and noise, population demography, and the economy in the ROI surrounding STP, Units 1 and 2.
2.2.9.1 Housing Table 2-13 lists the total number of occupied and vacant housing units, vacancy rates, and median value in the two-county ROI. According to American Community Survey, there were approximately 138,000 housing units in the socioeconomic region, of which approximately 117,000 were occupied. The median value of owner-occupied housing units in Brazoria and Matagorda Counties were $146,700 and $90,400 respectively. Brazoria County had a lower vacancy rate (12.6 percent) than Matagorda County, which had a 27.9 percent vacancy rate (USCB 2011).
Table 2-13. Housing in Brazoria and Matagorda Counties in 2010 Brazoria Matagorda ROI Total units 118,813 18,827 137,640 Occupied housing units 103,828 13,568 117,396 Vacant units 14,985 5,259 20,244 Vacancy rate (%) 12.6 27.9 14.7 Median value ($)* 146,700 90,400 118,550 Key:
- estimated Source: USCB 2010 2.2.9.2 Public Services Water Supply. Brazoria and Matagorda Counties are located in southeastern Texas.
Information about municipal water suppliers in these counties, their permitted capacities or maximum design yields or both, reported annual peak usage, and population served are presented in Table 2-14. The Texas TWDB divided Texas into 16 water-planning regions 2-64
Affected Environment (Region A through Region P). Brazoria County is located in Region H, while Matagorda County is located in Region K.
Brazoria County is 1 of 15 counties located in Region H, which includes the Houston metropolitan area. Over 20 percent of the States 2010 population resides in Region H. As seen in Table 2-14, the city of Pearland serves the largest population at 56,877 and has the highest average daily consumption (11.0 mgd), while the city of Clute serves the smallest at 10,737 and has the lowest average daily consumption (0.361 mgd). Alvin serves 15 less people than Angleton but consumes slightly more water daily (EPA 2010).
Matagorda County is 1 of 14 counties located in Region K. Bay City, located approximately 19.5 mi (31.4 km) north-northeast of STP, serves a population of 19,263 from a groundwater source with an average daily consumption of 2.41 mgd (EPA 2010).
STP withdraws potable water primarily from the deep-confined aquifer within the Beaumont Fountain. In 2009, STP withdrew 368,766,200 gal (1,395,931,917.5 liters) of water from five active onsite groundwater wells, of which 5 percent was used for sanitary and drinking purposes. STPNOC is permitted to withdraw an average of 2.7 mgd (STPNOC 2010b).
Table 2-14. Brazoria and Matagorda County City Public Water Supply Systems (in mgd)
Primary Water Average Daily System Population Water Supplier Source Demand (mgd) Capacity (mgd) Served Brazoria County Alvin GW 2.18 8.74 19,152 Angleton SW 2.05 5.47 19,167 Clute SW 0.36 2.08 10,373 0.00 (production vs.
Freeport SW 1.40 12,708 purchased)
Lake Jackson SW 3.10 6.69 25,890 Pearland SW 11.00 15,26 56,877 Matagorda County Bay City GW 2.41 8.86 19,263 Surface Water = SW, Groundwater = GW Source: EPA 2010 Education. Brazoria County has eight school districts consisting of 4 pre-kindergarten, 43 elementary, 23 middle/junior high/intermediate, 15 high schools, 10 alternative, 1 charter, and 1 grade 9 school. During the 2009 to 2010 school year, enrollment was 60,251 (NCES 2011).
Matagorda County has five districts consisting of 8 pre-kindergarten, 8 elementary, 4 middle/junior high/intermediate, 4 high schools, and 1 alternative school. During the 2009 to 2010 school year, enrollment was 7,185 (NCES 2011).
Transportation. STP is located in an area severed by U.S. highways, FMs, and county roads.
Within 50 mi of STP, there are no interstate highways; however, there are two U.S. highways (U.S. 59 and U.S. 87). U.S. 59 runs northeast to southwest connecting Fort Bend, Wharton, 2-65
Affected Environment Jackson, and Victoria Counties. U.S. 87 runs northwest to southeast connecting Victoria and Calhoun County.
STP can be accessed by FM 521, which runs east and west. FM 521 is accessible by several FM and State highways, which would be most commonly commuted by STP workers. Workers traveling from the east side of Matagorda County and all of Brazoria County would likely take TX-60 south and exit at FM 521. Workers commuting from the north would likely travel on TX-35 west, exiting on to FM 1468 south or FM 1095 south. Workers arriving from the west are likely to travel on TX-35 east, exiting onto FM 521 east.
Table 2-15 lists commuting routes to STP and average annual daily traffic (AADT) volume values. The AADT values represent traffic volumes for a 24-hour period factored by both day of week and month of year.
Table 2-15. Major Commuting Routes in the Vicinity of STP, 2010 AADT Roadway & Location AADT (a)
TX-60 South from Bay City to FM 521 West 2,400-3,000 FM 2078 West to FM 2668 South 310 FM 2668 South from Bay City to FM 521 West 1,050-2,200 FM 1468 South from TX-35 to FM 521 East 700-940 FM 1095 South from TX-35 to FM 521 East 390-630 FM 2853 South to FM 521 East 510-580 FM 521 West from TX-60 1,600-2,500 FM 521 East from FM 1095 1,150 (a)
All AADTs represent traffic volume during the average 24-hour day during 2010.
Key: FM = Farm-to-Market; TX = Texas Source: TXDOT 2011 2.2.9.3 Offsite Land Use Offsite land use conditions in Brazoria and Matagorda Counties are described in this section.
Approximately 84 percent of the STP permanent workforce lives in these two counties. Within the region of STP, approximately 61 percent of the land is agricultural, 18 percent forest, 10 percent rangeland, 5 percent wetland, 2.5 percent urban or developed land, 2 percent freshwater bodies, and less than 1 percent barren land (STPNOC 2010d).
Brazoria County occupies approximately 1,350 mi2 (3,496 km2) (USCB 2010). Agricultural land is principally used as pasture (52.8 percent) and cropland (35.2 percent). Livestock (mostly cattle and calves) comprise 45 percent of the total market value of agricultural products (livestock and crop product) sold in the county while crop sales comprise the remaining 55 percent (mostly grains, dry beans and peas, nursery, and floriculture). The number of farms in Brazoria increased about 5 percent from 2002 to 2007. Farmland acreage in the county decreased 14 percent during the same period, and the average size of a farm decreased 18 percent to 205 ac (82 ha) (NASS 2009).
Matagorda County occupies approximately 1,100 mi2 (2,849 km2) (USCB 2010). Agricultural land is principally used as pasture (51.08 percent) and cropland (40.63 percent). Crop sales (mostly nursery, greenhouse, floriculture, and sod) comprise 57 percent of the market value of 2-66
Affected Environment agricultural products sold from Matagorda County. Livestock sales (agricultural products of mostly cattle and calves) comprise the remaining 43 percent. The number of farms in Matagorda County decreased from 2002 to 2007 by 9 percent. The number of farmland acres decreased by 7 percent; however, the average size of farms increased by 2 percent from 625 ac to 640 ac (NASS 2009).
Even though population growth is projected to continue, there is ample urban and rural land to accommodate the anticipated growth over the next 20 years. However, agriculture will continue to be the major land use outside urban areas.
2.2.9.4 Visual Aesthetics and Noise The STP site boundary encloses approximately The EPA generally uses 55 decibels (dBA) as the 12,220 ac, with site buildings, operations area, noise threshold level to protect against excess noise during outdoor activities. However, support facilities, and transmission ROWs according to EPA, this threshold does not occupying approximately 65 ac. Approximately constitute a standard, specification, or regulation, 7,046 ac are occupied by other STP features, the but it was intended to provide a basis for State ECP, and the MCR (STPNOC 2010b). and local governments establishing noise standards.
The site includes approximately 1,700 ac of undeveloped natural lowland habitat, with characteristics of the Texas Coastal Plain Province, and the land surrounding the site is used for ranchland and farmland (STPNOC 2010b). STP is situated on low elevation, generally less than 60 feet MSL, with open prairie habitat interspersed with creek and river drainages flowing toward the Gulf coasts marshes. Trees are rare but can be found along streams and in oak groves (STPNOC 2010d). Given the flat nature of the land, the STP reactors are a prominent feature of the area, and the MCR is visible from the southeast along the Colorado River as well as other points around the site.
Noise from nuclear plant operations can be detected off site. Sources of noise at STP include the turbines and large pump motors. Given the industrial nature of the station, noise emissions from the station are generally nothing more than an intermittent minor nuisance. However, noise levels may sometimes exceed the 55 dBA level that EPA uses as a threshold level to protect against excess noise during outdoor activities (EPA 1974). However, according to EPA, this threshold does not constitute a standard, specification, or regulation, but it was intended to provide a basis for State and local governments establishing noise standards.
2.2.9.5 Demography According to 2000 Census information, an estimated 35,291 people lived within 20 mi (32 km) of STP, which equates to a population density of 36 persons per square mile (STPNOC 2010b).
This translates to a Category 1, most sparse, population density using the GEIS measure of sparseness (i.e., less than 40 persons per square mile and no community with 25,000 or more people within 20 mi). Based on the GEIS proximity matrix, the STP proximity population density is classified as Category 2 (no city with 100,000 or more people and less than 50 persons per square mile within 50 mi). Therefore, with STP regional population classifications of sparseness Category 1 and proximity Category 2, STP lies in a low-population area.
Table 2-16 shows population projections and growth rates from 1970 to 2050 in Brazoria and Matagorda Counties in Texas. The growth rate in Brazoria County showed an increase in population of nearly 30 percent between 2000 and 2010. Conversely, Matagorda County showed a 3.3 percent decrease in population between 2000 and 2010. Both county populations are projected to increase each decade through 2050.
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Affected Environment Table 2-16. Population and Percent Growth in Brazoria and Matagorda Counties from 1970 to 2010 and Projected for 2020 to 2050 Year Brazoria % Change Matagorda % Change 1970 108,312 N/A 27,913 N/A 1980 169,587 56.6 37,828 35.5 1990 191,707 13.0 36,928 -2.4 2000 241,767 26.1 37,957 2.8 2010 313,166 29.5 36,702 -3.3 2020 349,474 11.6 40,789 11.1 2030 397,663 13.8 42,559 4.3 2040 445,852 12.1 44,330 4.2 2050 494,041 10.8 46,101 4.0 Source: USCB (2011) provided the population data for 1970 through 2010. The data forecast for 2020 through 2050 was calculated.
Demographic Profile. The 2010 demographic profiles of the two-county ROI population are presented in Table 2-17. In 2010, minorities (race and ethnicity combined) comprised 47.4 percent of the total two-county population. The minority population is largely Hispanic or Latino (28.8 percent) with the next largest minority population being Black or African American (11.7 percent).
Table 2-17. Demographic Profile of the Population in the STP Two-County Socioeconomic ROI in 2010 Brazoria Matagorda ROI Total population 313,166 36,702 349,868 Race (not Hispanic or Latino)% of total population White 53.2 47.4 52.6 Black or African American 11.8 11.1 11.7 American Indian & Alaska Native 0.3 0.3 0.3 Asian 5.4 1.9 5.1 Native Hawaiian & Other Pacific Islander 0.0 0.0 0.0 Some other race 0.2 0.1 0.1 Two or more races 1.4 0.9 1.4 Ethnicity Hispanic or Latino 86,646 14,047 100,717
% of total population 27.7 38.3 28.8 Total minority 146,492 19,302 165,794 2-68
Affected Environment Brazoria Matagorda ROI
% minority 46.8 52.6 47.4 Source: USCB 2010 Transient Population. Within 50 mi (80 km) of STP, colleges and recreational opportunities attract daily and seasonal visitors who create demand for temporary housing and services. In 2010, there were approximately 11,118 students attending colleges and universities within 50 mi (80 km) of STP (IES 2010).
In 2000, 1.7 percent of all housing units were considered temporary housing for seasonal, recreational, or occasional use in Brazoria County. By comparison, seasonal housing accounted for 12.9 percent of total housing units in Matagorda County (USCB 2010). Calhoun and Jackson Counties have the highest percent of temporary housing for seasonal, recreational, or occasional use, at 17.1 and 18.5 percent, respectively (USCB 2010). Table 2-18 provides information on seasonal housing for the nine counties located all or partly within 50 mi of STP.
Table 2-18. Seasonal Housing in Counties Located within 50 mi of STP Vacant Housing Units: For Seasonal, County (a) Housing Units Recreational, or Occasional Use %
Texas Brazoria 90,628 1,496 1.7 Calhoun 10,238 1,757 17.1 Colorado 9,431 634 6.7 Fort Bend 115,991 5,076 4.4 Jackson 6,545 1,209 18.5 Lavaca 9,657 377 3.9 Matagorda 18,611 2,407 12.9 Victoria 32,945 261 0.8 Wharton 16,606 291 1.8 Total 310,652 13,508 7.5 (a)
Counties within 50 mi (80 km) of STP with at least one block group located within the 50-mi (80 km) radius Source: USCB 2010 Migrant Farm Workers. Migrant farm workers are individuals whose employment requires travel to harvest agricultural crops. These workers may or may not have a permanent residence.
Some migrant workers follow the harvesting of crops, particularly fruit, throughout rural areas of the U.S. Others may be permanent residents near the STP site who travel from farm to farm harvesting crops.
Migrant workers may be members of minority or low-income populations. Because they travel and can spend a significant amount of time in an area without being actual residents, migrant workers may be unavailable for counting by census takers. If uncounted, these workers would be underrepresented in USCB minority and low-income population counts.
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Affected Environment Information on migrant farm and temporary labor was collected in the 2007 Census of Agriculture. Table 2-19 provides information on migrant farm workers and temporary farm labor (less than 150 days) within 50 mi of the STP. According to the 2007 Census of Agriculture, approximately 6,513 farm workers were hired to work for less than 150 days and were employed on 2,233 farms within 50 mi of the STP. The county with the largest number of temporary farm workers (1,176) on 396 farms was Wharton County, Texas (NASS 2011).
In the 2002 Census of Agriculture, farm operators were asked for the first time whether or not they hired any migrant workers, defined as a farm worker whose employment required travel that prevented the migrant worker from returning to his or her permanent place of residence the same day. In the 50-mi radius of STP, 185 farms reported hiring migrant workers in the 2007 Census of Agriculture. Lavaca and Wharton Counties reported the most farms (35 and 31, respectively) with hired migrant workers, followed by Brazoria and Fort Bend County, with 28 and 25 farms, respectively (NASS 2011).
According to the 2007 Census of Agriculture estimates, 1,001 temporary farm workers (those working fewer than 150 days per year) were employed on 414 farms in Brazoria County, and 754 temporary farm workers were employed on 247 farms in Matagorda County, respectively (NASS 2011).
Table 2-19. Migrant Farm Workers and Temporary Farm Labor in Counties Located within 50 mi of STP Number of Farm Number of Farms Number of Farms Number of Farms Workers Working for Reporting with Hired Farm Hiring Workers for Less Than 150 days Migrant Farm County (a) Labor (b) Less Than 150 Days (b) (b) Labor (b)
Texas Brazoria 414 332 1,001 28 Calhoun 66 54 143 4 Colorado 372 319 853 23 Fort Bend 299 230 621 25 Jackson 200 164 408 12 Lavaca 475 410 925 35 Matagorda 247 208 754 16 Victoria 252 216 632 11 Wharton 396 300 1,176 31 Total 2,721 2,233 6,513 185 (a)
Counties within 50 mi of STP with at least one block group located within the 50-mi radius (b)
Table 7. Hired Farm LaborWorkers and Payroll: 2007 Census of Agriculture Source: NASS 2009 2.2.9.6 Economy Employment and Income. Between 2000 and 2010, the civilian labor force in Brazoria County increased 34.5 percent from 112,798 to 151,791. Matagorda County also increased during that 2-70
Affected Environment time, 5.6 percent from 16,434 to 17,365 (USCB 2010). Major industries in Matagorda County are presented in Table 2-20.
According to 2008 through 2010 American Community Survey 3-Year Estimates, educational, health, and social services industry employs the most workers in the socioeconomic ROI (22.5 percent) followed by wholesale trade (16.7 percent). A list of employment by industry in the ROI is presented in Table 2-21.
Table 2-20. Major Industries in Matagorda County Company Name Type of Business STPNOC Electricity generation Lyondell Basell High density polyethylene resins Valerus Compressors Compressor fabrication McAda Drilling Fluids Oilfield support OXEA Corporation Chemical products Celanese Chemical products Henderson Fabrication Steel fabrication Source: Matagorda County EDC 2007 Table 2-21. Major Industries in ROI Industry Brazoria Matagorda Total %
Total employed civilian workers 142,741 15,080 157,821 Agriculture, forestry, fishing & hunting, & mining 3,677 1,560 5,237 3.3 Construction 14,889 1,274 16,163 10.2 Manufacturing 17,962 1,422 19,384 12.3 Wholesale trade 4,638 310 26,299 16.7 Retail trade 13,694 2,273 15,967 10.1 Transportation, warehousing, & utilities 7,362 1,643 9,005 3.8 Information 2,382 219 2,601 1.6 Finance, insurance, real estate, rental, & leasing 7,061 458 7,519 4.8 Professional, scientific, management, administrative, & waste management services 15,182 812 15,994 10.1 Educational, health, & social services 32,613 2,887 35,500 22.5 Arts, entertainment, recreation, accommodation, & food services 9,196 960 10,156 6.4 Other services (except public administration) 7,758 802 8,560 5.4 Public administration 6,057 460 6,517 4.1 Source: USCB 2010 2-71
Affected Environment Estimated income information for the STP ROI is presented in Table 2-22. According to the USCB, people living in Brazoria County had a higher median household and per capita income than the State average, while Matagorda had a lower median household and per capita income (UCSB 2010). An estimated 10.6 and 19.2 percent of the population in Brazoria and Matagorda Counties were living below the official poverty level, respectively. The State of Texas as a whole had a higher percentage of persons living below the poverty level (17 percent) than Brazoria County, but lower than Matagorda County. The percentage of families living below the poverty level in Brazoria County (8.2 percent) was lower than the State of Texas average (13.2 percent), but Matagorda County (17.4 percent) was higher than the State average (UCSB 2010).
Table 2-22. Estimated Income Information for STP ROI Brazoria Matagorda Texas (a)
Median household income (dollars) 66,221 41,586 49,585 Per capita income (dollars) (a) 27,381 23,138 24,671 Individuals living below the poverty level (percent) 10.6 19.2 17 Families living below the poverty level (percent) 8.2 17.4 13.2 (a)
In 2008 inflation-adjusted dollars Source: USCB 2011 Unemployment. According to the USCBs 2006 through 2008 American Community Survey 3-Year Estimates, the unemployment rates in Brazoria and Matagorda Counties were 4.0 and 8.1 percent, respectively, in comparison to the unemployment rate of 4.8 percent for the State of Texas (USCB 2010).
Taxes. All privately owned property in Texas is subject to taxation by the county and school district in which it is located, unless specifically exempted by the Texas Constitution. Most private property owners in Texas also pay property taxes to local jurisdictions like cities and special districts within whose boundaries they reside. As such, property tax revenues are the major tax revenue source for counties and cities and the sole source of tax revenue for school districts. Exemptions from these standard practices are governed by the State, while county appraisal districts determine the value of properties with local jurisdictions setting the tax rates.
After assessment, private property owners then make a consolidated payment to the County Tax Assessor, who retains the countys portion and distributes the special district funds to the special districts, as appropriate (STPNOC 2010b).
STPNOC, owner of STP, Units 1 and 2, pays the majority of property taxes to the following taxing jurisdictions: Matagorda County, Matagorda County Hospital District, Navigation District #1, Drainage District #3, Palacios Seawall District, and the Coastal Plains Groundwater District (STPNOC 2010b). Table 2-23 presents each districts total property tax levies, STP payments, and the proportion of the total constituted by STP. STP payments represent a major portion of property tax revenues for each of the districts, ranging from 22 percent to 75 percent in the various districts from 2004 to 2008. From 2003 to 2007, in Matagorda County specifically (excluding special districts within the county), STP property tax payments to Matagorda County alone have represented approximately one-third of the countys total revenues (total revenues include property tax payments and other sources). In 2001, STPNOC negotiated an agreement with Matagorda County (to begin in 2002) to remit a county service fee in lieu of property taxes to the county, with a revenue cap of $6.1 million. STPNOC has a similar agreement with the 2-72
Affected Environment local hospital district, capped at $2.6 million, to compensate the hospital for its extensive support of STPNOCs emergency response requirements (STPNOC 2010b).
Table 2-23. Comparison of STP Owner Payments with Taxing District Property Tax Total STP
% of Property Tax Year(a)
Taxing District Property Tax Levy($) (b)
Payments($) (c) Levy 2003 Matagorda County (d) 8,214,934 6,100,000 74.3 Matagorda County Hospital(d) 4,126,692 2,461,132 59.6 Navigation District #1 459,261 360,394 78.5 Drainage District #3 288,179 249,859 86.7 Palacios Seawall 499,121 411,000 82.3 Coastal Plains Groundwater 137,930 45,264 32.8 Total 13,726,117 9,627,649 70.1 (d) 2004 Matagorda County 8,122,946 6,100,000 75.1 Matagorda County Hospital(d) 5,254,940 2,526,807 48.1 Navigation District #1 413,867 360,410 87.1 Drainage District #3 287,909 249,869 86.8 Palacios Seawall 433,674 411,018 94.8 Coastal Plains Groundwater 136,040 45,266 33.3 Total 14,649,376 9,693,370 66.2 (d) 2005 Matagorda County 8,191,213 6,100,000 74.5 Matagorda County Hospital(d) 5,613,566 2,343,558 41.7 Navigation District #1 370,191 251,822 68.0 Drainage District #3 254,311 203,684 80.1 Palacios Seawall 329,155 223,926 68.0 Coastal Plains Groundwater 141,239 31,628 22.4 Total 14,899,675 9,154,618 61.4 (d) 2006 Matagorda County 9,038,864 6,100,000 67.5 Matagorda County Hospital(d) 5,753,331 2,567,253 44.6 Navigation District #1 486,645 342,148 70.3 2-73
Affected Environment Total STP
% of Property Tax Year(a) Taxing District Property Tax Levy($) (b) Payments($) (c) Levy Drainage District #3 242,142 200,299 82.7 Palacios Seawall 327,813 230,162 70.2 Coastal Plains Groundwater 153,850 39,422 25.6 Total 16,002,645 9,479,284 59.2 (d) 2007 Matagorda County 9,785,561 6,100,000 62.3 Matagorda County Hospital(d) 6,236,490 2,600,000 41.7 Navigation District #1 519,472 377,347 72.6 Drainage District #3 229,254 190,125 82.9 Palacios Seawall 276,122 200,131 72.5 Coastal Plains Groundwater 166,556 45,019 27.0 Total 17,213,455 9,512,622 55.3 (d) 2008 Matagorda County 10,968,961 6,100,000 55.6 Matagorda County Hospital(d) 7,035,468 2,600,000 37.0 Navigation District #1 547,517 405,019 74.0 Drainage District #3 246,398 202,883 82.3 Palacios Seawall 276,565 203,844 73.7 Coastal Plains Groundwater 187,828 48,454 25.8 Total 19,262,737 9,560,200 49.6 6-Year Total 95,754,005 57,027,743 59.6 (a)
Year levy and rate are for the following budget year. STP, Units 1 and 2, owners pay the standard millage rate for the special districts.
(b)
Total levies for 2003-2007 are from the Texas Comptroller of Public Accounts, Annual Property Tax Reports for Tax Years 2003, 2004, 2005, and 2006, as well as 2007 Property Tax Rates and Taxes. Total levies for 2008 are from the Matagorda County Tax Office.
(c)
For 2003-2006, tax payments are based on estimates from the Matagorda County Tax Office. For 2007 and 2008, estimated payments are based on actual NRG property tax statements.
(d)
Payments to Matagorda County and the Matagorda County Hospital District are based on an agreement between those entities and STPNOC, which sets a fixed amount to be paid each year.
Note: Totals may not add due to rounding.
Source: STPNOC 2010b 2-74
Affected Environment In addition to tax payments to the districts discussed above, STP pays taxes to other districts within Matagorda County for undeveloped portions of the STP plant site that lie within other taxing districts and for other STP-related property within the county. The receiving districts are the Port of Bay City Conservation and Reclamation District, Drainage Districts 1 and 2, and the City of Bay City. Per State of Texas tax law, STP also pays taxes to three of the five independent school districts (ISDs) in Matagorda CountyMatagorda, Bay City, and Tidehaven.
Table 2-24 shows these payments. These payments represent a small proportion of those districts total levies in comparison to the percentages of the main district payments shown above.
Table 2-24. STP, Units 1 and 2, Owner Payments to Other Taxing Districts in Matagorda 2007 2008 Districts Districts Est. STP as STP Owner Est. Total STP as STP Owner Total Levy, % of Payments Levy, 2008 % of Special District (a) Payments ($) 2007 ($) Total ($) ($) Total Port of Bay City 3,097 723,680 0.43 5,080 388,907 0.61 Conservation &
Reclamation District 468 112,458 0.42 774 130,055 0.60 Matagorda ISD 74,943 2,525,549 2.97 75,038 2,677,920 2.80 Drainage District #1 6,419 1,607,005 0.40 6,179 1,681,062 0.37 Drainage District #2 2,000 342,514 0.58 6,278 419,134 1.50 Bay City ISD 0 12,840,989 - 1,942 14,265,846 0.01 Tidehaven ISD 22,837 5,029,792 0.45 79,465 6,541,043 1.21 City of Bay City 0 2,746,295 - 747 3,050,691 0.02 Total 111,771 25,925,282 0.43 175,502 29,599,657 0.59 (a)
Other = Taxing districts (Special District) other than Matagorda County; Matagorda County Hospital; Navigation District #1; Palacios Seawall District; Coastal Plains Groundwater District; and Drainage District #3.
Source: STPNOC 2010b STP is located in the Electric Reliability Council of Texas region, a deregulated area that is not set to change in the foreseeable future. As such, STPNOCs future taxation will continue to be based on the market value of the site and agreements with the county regarding service fees in lieu of property taxes (STPNOC 2010b).
2.2.10 Historic and Archaeological Resources In accordance with 36 CFR 800.8(c), the NRC has elected to use the National Environmental Policy Act of 1969, as amended (NEPA), process to comply with the obligations under Section 106 of the National Historic Preservation Act (NHPA). In addition, NUREG-1555 (NRC 2000) provides guidance to staff on how to conduct historic and cultural resource analysis in its environmental reviews.
In the context of NHPA, the NRC has determined that the area of potential effect (APE) for a license renewal action is the area at the power plant site and its immediate environment that may be affected by post-license renewal and land-disturbing activities associated with the 2-75
Affected Environment proposed action (NRC 2011e). The APE may extend beyond the immediate environs in instances where post-license renewal and land-disturbing activities or refurbishment activities specifically related to license renewal may potentially have an effect on historic properties (NRC 2011e).
Cultural Background. Substantial archaeological records indicate that there was prehistoric occupation of the STP area. During the Paleoindian era (pre-7800 B.C.), the earliest inhabitants of Texas were the Clovis and Folsom peoples, which are typically associated with the hunting of the extinct mammoth and bison, respectively. The Early Archaic era (7800 B.C. to 6000 B.C.)
represents a time when inhabitants became more settled, and numerous distinctive triangular points and barbed specimens are noted from this era. The Middle Archaic period (6000 B.C.
to 2500 B.C.) reflects a diversity of stone tools and shell middens, while the Late Archaic era (2500 B.C. to 700 B.C.) is marked by distinctive projectile points and stone tools. The Late Prehistoric era (700B.C. to 1500 A.D.) is noted for the introduction of the bow and arrow and pottery (NRC 2011b).
Hundreds of tribes inhabited Texas, and historians have a difficult time tracing their origin because there are few written records from this period (University of Texas at Austin 2011).
The historic period can be traced to the 1500s, when the Spanish and French explored the Texas Coast. With the arrival of the Europeans, there were many changes for the native peoples. Diseases destroyed many populations, and several tribes fled to and from the area that makes up the State of Texas today. Matagorda County was created in 1837, soon after Texas gained its independence from Mexico (NRC 2011b). Today, there are three indigenous groups living within the Texas boarders that are listed among the Nations many Federally recognized tribesthe Alabama-Coushatta Tribe in East Texas; the Ysleta del Sur Pueblo, or Tigua, in far West Texas; and the Kickapoo Traditional Tribe in southwest Texas along the Texas-Mexico border (THC 2011). Other recognized tribes maintain ties to their ancestors homelands in the State of Texas and monitor sites throughout the State that are important to their tribe and their history (THC 2011). Further cultural background is documented in the NRC EIS (2011b) for the review of the STP, Units 3 and 4, combined license application.
Historic and Archaeological Resources at the STP Site. This section discusses the known historic and archaeological resources at the STP site and in the surrounding area. The following information was used to identify the historic and archaeological resources at the STP site:
- original construction FES (NRC 1975);
- original ER (HL&P 1975), which included the Texas Archaeological Survey Report (Hall and Ford 1973);
- STP, applicants ER, operating license renewal stage, STP, Units 1 and 2 (STPNOC 2010b);
- audit report regarding STP LRAcultural resources (NRC 2011g);
- consultation with tribes.
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Affected Environment In the early 1970s, the Texas Archaeological Survey conducted cultural resources investigations of the STP site and surrounding area. The investigations included a literature review, a pedestrian survey, and limited subsurface testing (NRC 2011b; STPNOC 2010b, 2010d). The construction of STP, Units 1 and 2, was completed in the 1980s, and much of the site had been heavily disturbed by construction activities and the creation of the reservoir.
STP identified three cultural resource sites within 10 mi of the STP site. Cultural resources site 41MG48 is approximately 5 mi from the northeast boundary of the STP site and is described as a late 19th century artifact scatter associated with homesteading Artifacts consisted of ceramic, glass, and metal with manufacturing dates between 1890 and 1910. STP reported that a homestead was established in the 1890s and dissolved in 1946. Cultural resource investigations concluded that the site was not significant and that no further work on the site was needed.
The closest recorded site is 41MG49, and it is approximately 4 mi from the northeastern boundary of the STP site. Site 41MG49 was originally reported in the license renewal ER as having no site form record (STPNOC 2010b). In July 2011, STP revisited the information and discovered the missing site form record for site 41MG49 that described it as a shell midden with no associated artifacts(STPNOC 2011g). Cultural resource investigations concluded that the site was significant and should be studied further if the site were to be affected.
Site 41MG112 is approximately 5 mi from the northeastern boundary of the STP site and is described as a dismantled historic farmstead dating to the mid-20th century. Cultural resource investigations concluded that the site was not significant and that no further work on the site was needed (STPNOC 2011g). These three sites (41MG48, 41MG49, and 41MG112) are located outside of the. There are no recorded historic or archaeological resources on the STP site.
STP identified a potential historic gravesite in its ER (STPNOC 2010b) located on the southeast corner of the STP site. The NRC staff reviewed information during the environmental audit for cultural resources at the STP site and discussed the status and protection of the historic gravesite with STP environmental staff (NRC 2011g). STP staff had interviewed descendants of the former property owner and confirmed the presence of a historic grave from the late 1800s; however, this gravesite is not recorded and little is known about it (STPNOC 2011g).
2.3 Related Federal and State Activities The NRC reviewed the possibility that activities of other Federal agencies might impact the renewal of the operating license for STP. There are no Federal projects that would make it necessary for another Federal agency to become a cooperating agency in the preparation of this supplemental EIS. There are no known American Indian lands within 50 mi of STP.
Federally owned facilities within 50 mi of STP include (NRC 2011b):
- Big Boggyadministered by the FWSis a 5,000-ac national wildlife refuge that borders Matagorda Bay and is approximately 9 mi southeast of the STP site.
- San Bernardadministered by the FWSis a 45,311-ac national wildlife refuge that contains coastal prairies and salt marshes in southern Matagorda and Brazoria Counties.
The NRC is required under Section 102(2)(C) of NEPA to consult with and obtain the comments from any Federal agency that has jurisdiction by law or special expertise with respect to any environmental impact involved in the subject matter of the EIS. For example, during the course 2-77
Affected Environment of preparing the SEIS, the NRC consulted with the FWS and the NMFS. A complete list of key consultation correspondences is listed in Appendix D.
Regarding Coastal Zone Management Act (CZMA) compliance status, pursuant to Section 506.11(13) of Texas Administrative Code, STP license renewal falls within the definition of Federal agency action:
A federal license or permit that a federal agency may issue that represents the proposed federal authorization, approval, or certification needed by the applicant to begin an activity. An action to renew, amend, or modify an existing license or permit shall not be considered an action subject to the CMP [Coastal Management Program] if the action only extends the time period of the existing authorization without authorizing new or additional work or activities, would not increase pollutant loads to coastal waters or result in relocation of a wastewater outfall to a critical area, or is not otherwise directly relevant to the policies in
§501.14 of this title (relating to Policies for Specific Activities and Coastal Natural Resource Areas).
In addition, in a letter dated January 29, 2010, the Coastal Coordination Council that administers the CZMA compliance in Texas explained:
The project [STP] was undertaken before Texas had a federally approved [CMP]
and based on information provided in the [STPNOCs] letter dated December 2, 2009, it has been determined that there are no significant unresolved consistency issues. Therefore, pursuant to Section 506.11(13), this project is consistent with the CMP goals and policies.
Hence, for license renewal purpose, STPNOC has obtained and maintained a consistency certification in accordance with the CZMA.
2.4 References 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, Standards for protection against radiation.
10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, Domestic licensing of production and utilization facilities.
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.
10 CFR Part 61. Code of Federal Regulations, Title 10, Energy, Part 61, Licensing requirements for land disposal of radioactive waste.
10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, Packaging and transportation of radioactive material.
30 TAC 1-307. Texas Administrative Code, Title 30, Environmental Quality, Part 1, Texas Commission on Environmental Quality, Chapter 307, Texas Surface Water Quality Standards.
31 TAC 10-356. Texas Administrative Code, Title 31, Natural Resources and Conservation, Part 10, Texas Water Development Board, Chapter 356, Groundwater Management.
36 CFR Part 800. Code of Federal Regulations. Title 36, Parks, Forests, and Public Property, Part 800, Protection of historic properties.
2-78
Affected Environment 40 CFR Part 81. Code of Federal Regulations, Title 40, Protection of Environment, Part 81, Designation of areas for air quality planning purposes.
40 CFR Part 141. Code of Federal Regulations, Title 40, Protection of Environment, Part 141, National primary drinking water regulations.
40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, Environmental radiation protection standards for nuclear power operations.
50 CFR Part 10. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 10, General provisions.
50 CFR Part 22. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 22, Eagle permits.
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Subject:
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[STPNOC] South Texas Project Nuclear Operating Company. 2009a. Updated Final Safety Analysis Report Units 1 and 2. Bay City, TX: STPNOC. Revision 15. ADAMS No.
[STPNOC] South Texas Project Nuclear Operating Company. 2009b. Water Conservation Plan, STP Nuclear Operating Company, South Texas Project Electric Generating Station, Certificate of Adjudication 14-5437 A. May 1, 2009. Revision 2. ADAMS No. ML11256A058.
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[STPNOC] South Texas Project Nuclear Operating Company. 2010a. 2009 Annual Environmental Operating Report, South Texas Project Electric Generating Station. Bay City, TX: STPNOC. April 2010. ADAMS No. ML101260530.
[STPNOC] South Texas Project Nuclear Operating Company. 2010b. South Texas Project, Units 1 and 2, License Renewal Application. Bay City, TX: STPNOC. Appendix E, Environmental Report. September 2010. ADAMS No. ML103010263.
[STPNOC] South Texas Project Nuclear Operating Company. 2010c. South Texas Project, Units 3 and 4, Combined License Application. Bay City, TX: STPNOC. Part 2, Final Safety Analysis Report, Revision 4. ADAMS No. ML102860517.
[STPNOC] STP Nuclear Operating Company. 2010d. South Texas Project, Units 3 and 4, Combined License Application. Bay City, TX: STPNOC. Part 3, Environmental Report, Revision 4. ADAMS No. ML102860592.
[STPNOC] South Texas Project Nuclear Operating Company (STPNOC). 2010e. Letter from Mark McBurnett, STPNOC, to NRC Document Control Desk.
Subject:
Additional Information Regarding Draft Environmental Impact Statement. September 9, 2010. ADAMS No. ML102600127.
[STPNOC] South Texas Project Nuclear Operating Company. 2011a. 2010 Annual Environmental Operating Report, South Texas Project Electric Generating Station. Bay City, TX: STPNOC. April 2011. ADAMS Nos. ML111250423 and ML111250429.
[STPNOC] South Texas Project Nuclear Operating Company. 2011b. Letter from AW Harrison, Manager Licensing, to NRC Document Control Desk.
Subject:
Transmittal of documents to support review of the STP LRA. TAC Nos. ME 4938 and ME 5122. STP Letter No. NOC-AE-11002720. August 31, 2011. ADAMS Nos. ML11256A056 and ML11256A059.
[STPNOC] South Texas Project Nuclear Operating Company. 2011c. Letter from GT Powell, STPNOC, to NRC Document Control Desk.
Subject:
Response to RAI for the review of the STP LRA. July 5, 2011. ADAMS No. ML11193A016.
[STPNOC] South Texas Project Nuclear Operating Company. 2011d. Letter from GT Powell, Vice President, STPNOC, to NRC Document Control Desk.
Subject:
Response to RAI for the STP LRA. TAC Nos. ME4938 and ME5122. STP Letter No. NOC-AE-11002719.
September 6, 2011. ADAMS No. ML11255A211.
[STPNOC] South Texas Project Nuclear Operating Company. 2011e. Letter from GT Powell, Vice President, STPNOC, NRC Document Control Desk.
Subject:
Response to RAI for the review of the STP LRA. TAC Nos. ME4938 and ME5122. STP Letter No. NOC-AE-11002723.
September 12, 2011. ADAMS No. ML11259A014.
[STPNOC] South Texas Project Nuclear Operating Company. 2011f. Letter from GT Powell, STPNOC, to NRC Document Control Desk.
Subject:
Response to RAI for the review of the STP LRA. October 18, 2011. ADAMS No. ML11298A085.
[STPNOC] South Texas Project Nuclear Operating Company. 2011g. Letter from GT Powell, Vice President, STPNOC, NRC Document Control Desk.
Subject:
response to RAI for the review of the LRA. July 5, 2011. ADAMS No. ML11193A074.
[STPNOC] South Texas Project Nuclear Operating Company. 2012a. South Texas Project, Units 1 and 2, Clarification of Information. Bay City, TX: STPNOC. January 10, 2012. ADAMS No. ML12011A188.
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Affected Environment
[STPNOC] South Texas Project Nuclear Operating Company. 2012b. Letter from GT Powell, Vice President, STPNOC, NRC Document Control Desk.
Subject:
response to RAI for the review of the LRA. March 12, 2012. ADAMS No. ML12079A014.
[STPNOC] South Texas Project Nuclear Operating Company. 2012c. Letter from SL Dannhardt, Manager, Environmental, STPNOC, NRC Document Control Desk.
Subject:
Renewal of the wastewater discharge permit. April 17, 2012. ADAMS No. ML12114A198.
[STPNOC] South Texas Project Nuclear Operating Company. 2012d. 2011 Annual Environmental Operating Report, South Texas Project Electric Generating Stations. Bay City, TX: STPNOC. April 2012. ADAMS Nos. ML12130A266 and ML12130A267.
[STPNOC] South Texas Project Nuclear Operating Company. 2013a. Letter from DW Rencurrel, Senior Vice President, STPNOC, NRC Document Control Desk.
Subject:
Update to license renewal application-environmental permits. January 21, 2013. ADAMS No. ML13032A074.
[STPNOC] South Texas Project Nuclear Operating Company. 2013b. 2012 Annual Environmental Operating Report, South Texas Project Electric Generating Stations. Bay City, TX: STPNOC. April 2013. ADAMS Nos. ML13148A039 and ML13148A040.
[TCEQ] Texas Commission on Environmental Quality. 2005. STPNOC TPDES Permit No. WQOOO 1908000, Permit to Discharge Wastes. July 21, 2005. ADAMS No. ML11256A057.
[TCEQ] Texas Commission on Environmental Quality. 2009. Letter from L Lancaster, Team Leader Application Review and Processing Team, TCEQ, to SL Dannhardt, STPNOC.
Subject:
Declaration of Administrative Completeness, STPNOC, Permit No. WQ0001908000 (EPA ID No. TX0064947) (RN102395654), Type of Authorization: Renewal. July 13, 2009. ADAMS No. ML11255A211.
[TCEQ] Texas Commission on Environmental Quality. 2011. Draft 2010 Texas Integrated Report for Clean Water Act Sections 305(b) and 303(d). March 8, 2011. Available at
<http://www.tceq.texas.gov/waterquality/ assessment/10twqi/10twqi> (accessed October 20, 2011).
Texas Historical Commission. 2011. Celebrate Native American Heritage in November.
Available at <http://www/thc/.state.tx.us/news/whatsnewstories/wnnamnth.shtml> (accessed October 28, 2011).
Texas Water Code, Title 2, Water Administration, Chapter 36, Groundwater Conservation Districts. Available at <http://www.twdb.state.tx.us/gwrd/gcd/gcdhome.htm> (accessed July 2012).
[TMMSN] Texas Marine Mammal Stranding Network. 2011. The Gulf of Mexicos Marine Mammals. January 2, 2011. Available at
<http://www.sci.tamucc.edu/tmmsn/29Species/marine.html> (accessed May 19, 2011).
[TPWD] Texas Parks and Wildlife Department. 2011a. Brazos Bend State Park. Available at
<http://www.tpwd.state.tx.us/spdest/findadest/parks/brazos_bend/> (accessed September 27, 2011).
[TPWD] Texas Parks and Wildlife Division. 2011b. Jaguarundi. Available at
<http://www.tpwd.state.tx.us/publications/pwdpubs/media/pwd_bk_w7000_0013_jaguarundi.
pdf> (accessed September 7, 2011).
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Affected Environment
[TPWD] Texas Parks and Wildlife Division. 2011c. Letter from A Turner, Wildlife Habitat Assessment Program, to B Pham, Branch Chief, NRC.
Subject:
Reply to request for species list for South Texas license renewal. April 20, 2011. ADAMS No. ML11119A009.
[TPWD] Texas Parks and Wildlife Department. 2011d. Mad Island. Available at
<http://www.tpwd.state.tx.us/huntwild/hunt/wma/find_a_wma/list/?id=39> (accessed September 27, 2011).
[TPWD] Texas Parks and Wildlife Division. 2011e. Ocelot (Leopardus pardalis). Available at
<http://www.tpwd.state.tx.us/huntwild/wild/species/ocelot/> (accessed 12 April 2013).
[TPWD] Texas Parks and Wildlife Division. 2011f. Rare, Threatened, and Endangered Species of Texas for Bexar, Brazoria, Colorado, DeWitt, Fayette, Gonzales, Guadalupe, Jackson, Lavaca, Matagorda, Wharton, and Wilson Counties. Available at
<http://gis.tpwd.state.tx.us/TpwEndangeredSpecies/DesktopDefault.aspx> (accessed May 19, 2011).
[TPWD] Texas Parks and Wildlife Division. 2013a. Rare, Threatened, and Endangered Species of Texas for Brazoria, Matagorda, and Wharton Counties. Available at
<http://www.tpwd.state.tx.us/gis/ris/es/> (accessed March 8, 2013).
[TPWD] Texas Parks and Wildlife Division. 2013b. Whooping Crane (Grus americana).
Available at <http://www.tpwd.state.tx.us/huntwild/wild/species/whooper/> (accessed 12 April 2013).
[TSHA] Texas State Historical Association. 2011. Texas Almanac: Population History of Counties from 1850-2010. Available at <http://www.texasalmanac.com/topics/population>
(accessed January 2011).
[TSWGW] Texas Saltwater and Fishing Guides Web. 2005. King Mackerel (Kingfish).
Available at <http://www.txsaltwaterfishingguides.com/FishFacts/kingfish.htm> (accessed September 9, 2011). ADAMS No. ML100600370.
[TWDB] Texas Water Development Board. 2006. Aquifers of the Gulf Coast of Texas. Austin, TX: TWDB. Report 365. February 2006. Available at
<http://www.twdb.state.tx.us/publications/reports/GroundWaterReports/GWReports/R365/
AGCindex.htm> (accessed August 31, 2011).
[TWDB] Texas Water Development Board. 2007. State Water PlanWater for Texas 2007.
Austin, TX: TWDB Document No. GP-8-1. Volume 1. January 2007. Available at
<http://www.twdb.state.tx.us/wrpi/swp/swp.asp> (accessed August 31, 2011).
[TXDOT] Texas Department of Transportation. 2011. District Traffic Maps2010. Available at <http://ftp.dot.state.tx.us/pub/txdot-info/tpp/traffic_counts/2010/ykm_base.pdf> (accessed April 2011).
University of Texas at Austin. 2011. Texas Beyond History. Available at
<http://www/texasbeyondhistory.net/faq/index.html#9> (accessed October 28, 2011).
[USACE] U.S. Army Corps of Engineers. 2009. Letter from K Jaynes, Compliance Section Chief, Galveston District, to R Kiesling, STPNOC.
Subject:
Jurisdictional wetlands on the South Texas site. May 14, 2009. ADAMS No. ML11256A057.
[USCB] U.S. Census Bureau. 2010. American FactFinder, Census 2000 and 2006-2008, 3-Year Estimate, American Community Survey, State and County QuickFacts on Brazoria and Matagorada Counties. Housing Characteristics for 2000 and 2006-2008, 3-Year Estimate.
Profile of Selected Economic Characteristics: 2000 and 2010. Available at
<http://factfinder.census.gov and http://quickfacts.census.gov> (accessed January 2011).
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Affected Environment
[USDA NASS] U.S. Department of Agriculture National Agricultural Statistics Service. 2009.
2007 Census of Agriculture, Volume 1, Chapter 2, Table 1 and Table 7. December 2009.
Available at
<http://www.agcensus.usda.gov/Publications/2007/Full_Report/Volume_1,_Chapter_2_County_
Level/Texas/index.asp> (accessed June 2011).
[USGS] U.S. Geological Survey. 2008. Geologic Hazards Team Interactive Map Server, National Seismic Hazard Maps2008. April 23, 2008. Available at <http://gldims.cr.usgs.gov>
(accessed September 20, 2011).
[USGS] U.S. Geological Survey. 2011a. Circular Area Earthquake Search, NEIC: Earthquake Search Results, U.S. Geological Survey Earthquake Database. (search parameters:
Significant U.S. Earthquakes (1569-1989) Database, Latitude 28.7951 N, Longitude -96.04900 W, Radius 550 km). October 4, 2010. Available at
<http://earthquake.usgs.gov/earthquakes/eqarchives/epic/epic_circ.php> (accessed September 20, 2011).
[USGS] U.S. Geological Survey. 2011b. Circular Area Earthquake Search, NEIC: Earthquake Search Results, U.S. Geological Survey Earthquake Database. (search parameters:
USGS/NEIC (PDE) 1973 Database, Latitude 28.7951 N, Longitude -96.04900 W, Radius 200 km). October 4, 2010. Available at
<http://earthquake.usgs.gov/earthquakes/eqarchives/epic/epic_circ.php> (accessed September 20, 2011).
[USGS] U.S. Geological Survey. 2011c. Texas Earthquake Information, Seismicity Map of Texas, Seismic Hazard Map of Texas. Available at
<http://earthquake.usgs.gov/earthquakes/states/index.php?regionID=43> (accessed September 20, 2011).
[USGS] U.S. Geological Survey. 2011d. USGS Surface-Water Annual Statistics for the Nation, USGS 08162500, Colorado River Near Bay City, TX. Available at
<http://waterdata.usgs.gov/nwis/annual/?referred_module=sw&site_no=08162500&por_
08162500_1=1460,00060,1,1948,2011&year_type=W&format=html_table&date_format=YYYY-MM-DD&rdb_compression=file&submitted_form=parameter_selection_list> (accessed August 31, 2011).
Wai CN, Huntsman G. 2006a. Epinephelus drummondhayi. Available at
<http://www.iucnredlist.org/apps/redlist/details/7854/0> (accessed June 28, 2011).
Wai CN, Huntsman G. 2006b. Hyporthodus nigritus. Available at
<http://www.iucnredlist.org/apps/redlist/details/7860/0> (accessed June 28, 2011).
[WEG] Wild Earth Guardians. Petition to list the saltmarsh topminnow (Fundulus jenkinsi) under the U.S. Endangered Species Act. September 3, 2010. Available at
<http://sero.nmfs.noaa.gov/pr/esa/Candiate%20Spp/Saltmarsh%20Topminnow%20Petition-1.
pdf> (accessed June 28, 2011).
Wiken E, Nava FJ, Griffith G. 2011. North American Terrestrial EcoregionsLevel III.
Montreal, Canada: Commission for Environmental Cooperation. 149 p. Available at
<ftp://ftp.epa.gov/wed/ecoregions/pubs/NA_TerrestrialEcoregionsLevel3_Final-2june11_CEC.
pdf> (accessed September 12, 2011).
Wilber, D. 1989. Reproductive biology and distribution of stone crabs (Xanthidae, menippe) in the hybrid zone on the northeastern Gulf of Mexico. Marine Ecology Progress Series 52(1989):235-244.
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Affected Environment Young, SC, Kelly, V, Budge, T, Deeds, N. 2007. FINAL Development of the LSWP Groundwater Flow Model for the Chicot and Evangeline Aquifers in Colorado, Wharton, and Matagorda Counties. Austin, TX: URS Corporation, INTERA, and Baer Engineering and Consulting. Available at
<http://www.lcra.org/library/media/public/docs/lswp/findings/URS_Mitigation_report_final.pdf>.
ADAMS No. ML100471604.
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3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT Facility owners or operators may need to undertake or, for economic or safety reasons, may choose to perform refurbishment activities in anticipation of license renewal or during the license renewal term. The major refurbishment class of activities characterized in the Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS) (NRC 1996) is intended to encompass actions that typically take place only once in the life of a nuclear plant, if at all. Examples of these activities include, but are not limited to, replacement of boiling-water reactor recirculation piping and pressurized-water reactor steam generators. These actions may have an impact on the environment beyond those activities occurring during normal operations for which the activities require evaluation, depending on the type of action and the plant-specific design. Table 3-1 lists the environmental issues associated with refurbishment that the U.S. Nuclear Regulatory Commission (NRC) staff (the staff) determined to be Category 1 issues in the GEIS.
Table 3-1. Category 1 Issues Related to Refurbishment Issue GEIS Section(s)
Surface water quality, hydrology, and use (for all plants)
Impacts of refurbishment on surface water quality 3.4.1 Impacts of refurbishment on surface water use 3.4.1 Aquatic ecology (for all plants)
Refurbishment 3.5 Groundwater use and quality Impacts of refurbishment on groundwater use and quality 3.4.2 Land use Onsite land use 3.2 Human health Radiation exposures to the public during refurbishment 3.8.1 Occupational radiation exposures during refurbishment 3.8.2 Socioeconomics Public services: public safety, social services, and tourism and 3.7.4; 3.7.4.3; 3.7.4.4; 3.7.4.6 recreation Aesthetic impacts (refurbishment) 3.7.8 Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 Table 3-2 lists environmental issues related to refurbishment that the NRC staff determined to be plant-specific or inconclusive in the GEIS. These issues are Category 2 issues. The definitions of Category 1 and 2 issues can be found in Section 1.4 of this supplemental environmental impact statement (SEIS).
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Environmental Impacts of Refurbishment Table 3-2. Category 2 Issues Related to Refurbishment 10 CFR 51.53(c)(3)(ii)
Issue GEIS Section(s) Subparagraph Terrestrial resources Refurbishment impacts 3.6 E Threatened or endangered species (for all plants)
Threatened or endangered species 3.9 E Air quality Air quality during refurbishment 3.3 F (non-attainment and maintenance areas)
Socioeconomics Housing impacts 3.7.2 I Public services: public utilities 3.7.4.5 I Public services: education (refurbishment) 3.7.4.1 I Offsite land use (refurbishment) 3.7.5 I Public services, transportation 3.7.4.2 J Historic and archaeological resources 3.7.7 K Environmental justice Environmental justice(a) Not addressed Not addressed (a)
Guidance related to environmental justice was not in place at the time the NRC prepared the GEIS and the associated revision to 10 CFR Part 51. If an applicant plans to undertake refurbishment activities for license renewal, the applicants Environmental Report (ER) and the staffs SEIS must address environmental justice.
Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 Table B.2 of the GEIS identifies systems, structures, and components (SSCs) that are subject to aging and might require refurbishment to support continued operation during the license renewal period of a nuclear facility. In preparation for its license renewal application, South Texas Project Nuclear Operating Company (STPNOC) performed an evaluation of these SSCs pursuant to Section 54.21 of Title 10, Energy, of the Code of Federal Regulations (10 CFR 54.21) to identify the need to undertake any major refurbishment activities that would be necessary to support the continued operation of South Texas Project (STP) during the proposed 20-year period of extended operation.
In the ER, STPNOC indicated that, in accordance with 10 CFR Part 54, STPNOC has submitted an integrated plant assessment (IPA) addressing the aging management of SSC for license renewal. The IPA does not identify the need to undertake any major refurbishment activities that are necessary to support continued operation of STP during the period of extended operation (STPNOC 2010). Furthermore, STPNOC indicated that it has replaced the steam generator and reactor heads to meet the operational needs under the current license.
Therefore, the staff does not assess refurbishment activities in this SEIS.
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Environmental Impacts of Refurbishment 3.1 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.
[NRC] U.S. Nuclear Regulatory Commission. 1975. Final Environmental Statement Related to The Proposed South Texas Project, Units 1 and 2. Washington, DC: NRC. NUREG-75/019.
March 1975. ADAMS No. ML11174A118
[NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG-1437. May 1996.
ADAMS Nos. ML040690705 and ML040690738.
[NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3, Transportation, Table 9.1, Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC:
NRC. NUREG-1437, Volume 1, Addendum 1. August 1999. ADAMS No. ML04069720.
[STPNOC] South Texas Plant Nuclear Operating Company. 2010b. South Texas Project, Applicants Environmental ReportOperating License Renewal Stage, South Texas Project Units 1 & 2. September 2010. ADAMS No. ML103010263.
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4.0 ENVIRONMENTAL IMPACTS OF OPERATION This chapter addresses potential environmental impacts related to the period of extended operation of South Texas Project (STP). These impacts are grouped and presented according to resource. Generic issues (Category 1) rely on the analysis presented in the Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants (NRC 1996, 1999, 2013d), unless otherwise noted. Site-specific issues (Category 2) have been analyzed for STP. However, some issues are not applicable to STP because of site characteristics or plant features. Section 1.4 of this supplemental environmental impact statement (SEIS) provides an explanation of the criteria for Category 1 and Category 2 issues, as well as the definitions of SMALL, MODERATE, and LARGE. In addition, as described in Section 1.4, the U.S. Nuclear Regulatory Commission (NRC) has published a final rule (78 FR 37282, June 20, 2013) revising its environmental protection regulation, Title 10 of the Code of Federal Regulations (10 CFR) Part 51, Environmental protection regulations for domestic licensing and related regulatory functions. The final rule consolidates similar Category 1 and 2 issues, changes some Category 2 issues into Category 1 issues, and consolidates some of those issues with existing Category 1 issues. The revised rule also adds new Category 1 and 2 issues. These issues are discussed in Section 4.11.
4.1 Land Use Onsite land use issues that could be affected by license renewal are listed in Table 4-1. As discussed in the GEIS, onsite land use and powerline right-of-way (ROW) conditions are expected to remain unchanged during the license renewal term at all nuclear plants; thus, impacts would be SMALL. These issues, therefore, were classified as Category 1 issues.
Section 2.2.1 of this SEIS describes the land use conditions at STP.
The NRC staff reviewed and evaluated South Texas Project Nuclear Operating Companys (STPNOCs) Environmental Report (ER) (STPNOC 2010b), scoping comments, and other available data on STP, Units 1 and 2, were reviewed and evaluated for new and significant information. The review included an audit conducted by the NRC staff at the STP site. No new and significant information was identified during this review that would change the conclusions presented in the GEIS. Therefore, for these Category 1 issues, impacts during the renewal term are not expected to exceed those discussed in the GEIS.
Table 4-1. Land Use Issues Issue GEIS Section Category Onsite land use 4.5.3 1 Powerline ROW 4.5.3 1 Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 4.2 Air Quality Section 2.2.2 of this SEIS describes the meteorology and air quality in the vicinity of the STP site.
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Environmental Impacts of Operation The air quality issue applicable to STP during the renewal term is discussed below and listed in Table 4-2. The GEIS did not identify any Category 2 issues related to air quality. The NRC staff did not identify any new and significant information during the review of the applicants ER (STPNOC 2010b), the staffs site audit, the scoping process, or the evaluation of other available information. Therefore, there are no impacts related to these issues beyond those discussed in the GEIS. For these issues, the GEIS concluded that the impacts are SMALL, and additional site-specific mitigation measures are unlikely to be sufficiently beneficial to warrant implementation.
Table 4-2. Air Quality Issues Issue GEIS Section Category Air quality effects of transmission lines 4.5.2 1 Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 4.3 Surface Water Resources The surface water use, hydrology, and surface water quality issues potentially applicable to STP, Units 1 and 2, are discussed in the following sections and listed in Table 4-3. Surface water-related aspects and conditions relevant to STP, Units 1 and 2, are described in Sections 2.1.7.1 and 2.2.4 of this SEIS.
Table 4-3. Surface Water Resources Issues Issues GEIS Section Category Altered current patterns at intake & discharge structures 4.2.1.2.1 1 Altered salinity gradients 4.2.1.2.2 1 Discharge of chlorine or other biocides 4.2.1.2.4 1 Discharge of sanitary wastes & minor chemical spills 4.2.1.2.4 1 Discharge of other metals in wastewater 4.2.1.2.4 1 Water use conflicts (plants with cooling towers & cooling ponds using 4.3.2.1 2 makeup water from a small river with low flow)
Source: STPNOC 2010b, 2011b and Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 4.3.1 Generic Surface Water Issues NRC did not identify any new and significant information with regard to Category 1 (generic) surface water issues based on review of the ER (STPNOC 2010b), the public scoping process, or as a result of the environmental site audit. The NRC staff also reviewed other sources of information such as various permits and data reports. As a result, no information or impacts related to these issues were identified that would change the conclusions presented in the GEIS. Therefore, it is expected that there would be no impacts related to these Category 1 issues during the renewal term beyond those discussed in the GEIS. For these surface water issues, the GElS concludes that the impacts are SMALL.
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Environmental Impacts of Operation 4.3.2 Surface Water Use ConflictsPlants Using Makeup Water from a Small River with Low Flow For nuclear power plants using cooling towers or cooling ponds that are supplied with makeup water from a small river, the potential impact on the flow of the river and related impacts on instream and riparian ecological communities is considered a Category 2 issue; thus, it requires a plant-specific assessment. The requirement for this assessment is specified by 10 CFR 51.53(c)(3)(ii)(A), which also defines a small river as one whose annual flow rate is less than 3.15x1012 ft3/yr (9x1010 m3/yr) or 100,000 cfs (2,820 m3/s). In evaluating the potential impacts resulting from surface water use conflicts associated with license renewal, the NRC staff uses as its baseline the existing surface water resource conditions described in Sections 2.1.7.1 and 2.2.4.1 of this SEIS. These baseline conditions encompass the existing hydrologic (flow) regime of the surface water(s) potentially affected by continued operations as well as the magnitude of surface water withdrawals for cooling and other purposes (as compared to relevant appropriation and permitting standards). The baseline also considers other downstream uses and users of surface water.
STP, Units 1 and 2, has a closed-cycle heat-dissipation system that uses a cooling pond, the main cooling reservoir (MCR), with makeup water supplied from a small river, the lower Colorado River, with a mean annual discharge equivalent to 82.6x109 ft3/yr (23.4x108 m3/yr) or 2,620 cfs (74.1 m3/s). Therefore, an assessment of the impact of the proposed action on the flow of the river is required.
In the State of Texas, water use is regulated by the Texas Water Code. Surface water belongs to the State (Water Code, Title 2, Subtitle B, Chapter 11, Section 11.021). The right to use surface waters of the State can be acquired in accordance with the provisions of the Texas Water Code, Chapter 11. Because the Colorado River Basin is currently heavily appropriated (used or obligated for use), future water users in this basin would likely obtain surface water by purchasing or leasing existing appropriations. The Texas Water Development Board (TWDB) uses 16 planning regions, the Regional Water Planning Areas (or regions), to plan and finance water supply projects. The regions prepare plans within their areas that are compiled into the State Water Plan. The most recent plan was adopted by the TWDB in November 2006 (TWDB 2007). For this SEIS, the staff reviewed the best available information for its analysis.
Currently, the State of Texas is in the 2011 to 2016 planning cycle. The regions have compiled the 2011 Regional Water Plans. The 2012 State Water Plan has been released for public comment (TWDB 2011). The STP site is located in the Lower Colorado Regional Water Planning Group (LCRWPG), or Region K.
STPNOC owns water rights from the lower Colorado River to operate power reactors on the STP site. The waters of the Colorado River for STPNOCs use are adjudicated (administered or allotted) via a water right secured in 1989 (STPNOC 2010b). An agreement between the Lower Colorado River Authority (LCRA) and STPNOC specifies the conditions related to STPNOCs withdrawal (diversion) of water from the Colorado River. STPNOC is allowed to withdraw 102,000 ac-ft/yr (126 million m3/yr) from the Colorado River at a maximum withdrawal rate of 1,200 cfs (34.4 m3/s) or 540,000 gpm. However, STPNOC is limited to withdrawing 55 percent of the river flow that exceeds 300 cfs (8.5 m3/s) or 135,000 gpm (STPNOC 2009a; TCEQ 2009a). In other words, STPNOC is limited in its ability to withdraw water from the Colorado River during low flow conditions (i.e., 55 percent of the river flow at the volumetric flow rate that exceeds 300 cfs).
STPNOCs historical withdrawals of surface water from the Colorado River for plant operations are summarized in Table 4-4.
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Environmental Impacts of Operation Table 4-4. Surface Water Withdrawals and Usage for Calendar Years 2003-2010 for STP, Units 1 and 2 Calendar Year Water Withdrawal (ac-ft) (a) Water Use (ac-ft) 2003 0 27,800 2004 62,374 37,963 2005 5,694 35,383 2006 50,012 37,912 2007 58,740 39,403 2008 10,303 38,186 2009 72,464 38,008 2010 43,213 37,893 (a)
To convert ac-ft to m3, multiply by 1,233.5. To convert ac-ft to gal., multiply by 325,851.
Source: STPNOC 2010b, 2011b Between 2003 and 2010, STPNOC withdrew an average of 37,850 ac-ft/yr (46.7 million m3/yr) from the Colorado River and consumed an average of 36,569 ac-ft/yr (45.1 million m3/yr) to support the operations of STP, Units 1 and 2. For a given year, withdrawals from the lower Colorado River can be significantly less or more than corresponding water use because of rules for water withdrawal specified in the LCRA-STPNOC contract (right to purchase or use), which are based on river flow and meteorological conditions that affect evaporation from the MCR. In 2003, STPNOC withdrew no water from the Colorado River but consumptively used 27,800 ac-ft (34.3 million m3). The following year, STPNOC had to withdraw 62,374 ac-ft (76.9 million m3) of river water to cover the 37,963 ac-ft (46.8 million m3) of consumption and to replenish the MCR storage (the MCR functions and specifications are described in Section 2.1.6). The average, minimum, and maximum yearly withdrawals from the lower Colorado River over the 2003 to 2010 period are 36, 0, and 71 percent of the STPNOC annual water rights of 102,000 ac-ft (126 million m3).
The LCRWPG adopted its 2011 Region Plan in July 2010 (LCRWPG 2010). The LCRWPG estimated that the total water demand in Region K would increase from 1,086,692 ac-ft/yr (1.34 billion m3/yr) in 2010 to 1,382,534 ac-ft/yr (1.71 billion m3/yr) in 2060, mainly due to a projected doubling of the population of Region K over the timeframe. The LCRWPG estimated that the water available to Region K would decline from 1,331,715 ac-ft/yr (1.64 billion m3/yr) in 2010 to 1,289,453 ac-ft/yr (1.59 billion m3/yr) in 2060. The LCRWPG estimated that region-wide water shortages would be 297,000 and 367,000 ac-ft/yr (366 and 453 million m3/yr) in 2030 and 2060, respectively (LCRWPG 2010). To estimate shortages, the LCRWPG used the following conservative assumptions:
- Available water would be that during a historical drought of record.
- All water rights would be used fully and simultaneously.
- Interruptible water from LCRA and municipal return flows to the Colorado River would not be available.
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Environmental Impacts of Operation These assumptions are conservative because they minimize water availability and maximize water use, thereby maximizing potential shortages.
The region plans to address shortages by using a variety of strategies. These water management strategies include use of municipal return flows, conservation, reuse, new water storage facilities, aquifer storage of surface water, new groundwater supply development, saltwater desalination, and intra-region transfer of water from areas with surplus. The LCRWPG estimated that the implementation of all water management strategies could yield an additional 349,862 to 610,750 ac-ft/yr (432 to 754 million m3/yr) to meet the estimated shortages (LCRWPG 2010).
During the past 5 years, withdrawals from the lower Colorado River to support the operations of STP, Units 1 and 2, have averaged 46,946 ac-ft/yr (57.9 million m3/yr), which is equivalent to 2.5 percent of the mean annual discharge of 2,620 cfs (74.1 m3/s) or approximately 1.89 million ac-ft/yr (2.3 billion m3/yr) for the river. The average withdrawal for STP, Units 1 and 2, is 3.5 and 3.6 percent of the water available to Region K in 2010 and 2060, respectively.
The 2060 projection is based on the assumption that no implementation of any strategies to augment (or to change) regional water supply would have taken place. STPNOCs water right of 102,000 ac-ft/yr (126 million m3/yr) is accounted for in the Region K plan. The LCRWPG has evaluated several strategies that can be used to meet shortages that may occur during conditions similar to the drought of record when all existing water rights are fully and simultaneously used. Therefore, NRC concludes that continued operation of STP, Units 1 and 2, as supported by the currently held water rights, would have no substantial effect on water supplies in the region. NRC further concludes that the impact on surface water resources and downstream water availability in the lower Colorado River from continued withdrawals during the license renewal term would be SMALL.
4.4 Groundwater Resources The groundwater use and quality issues applicable to STP, Units 1 and 2, are discussed in the following sections and listed in Table 4-5 for Category 1 (generic) and Category 2 (site-specific) issues. Groundwater resources-related aspects and conditions relevant to STP, Units 1 and 2, are described in Sections 2.1.7.2 and 2.2.5 of this SEIS.
Table 4-5. Groundwater Resources Issues Issues GEIS Section Category Groundwater use conflicts (potable and service water & dewatering; 4.8.1.1, 4.8.1.2 2 plants that use >100 gpm)
Groundwater use conflicts (plants using cooling towers withdrawing 4.8.1.3 2 makeup water from a small river)
Groundwater quality degradation (saltwater intrusion) 4.8.2.1 1 Groundwater quality degradation (cooling ponds in salt marshes) 4.8.3 1 4.4.1 Generic Groundwater Issues Section 2.2.5 of this SEIS discusses groundwater use and quality at STP. NRC did not identify any new and significant information with regard to Category 1 (generic) groundwater issues based on review of the ER (STPNOC 2010b), the public scoping process, or as a result of the 4-5
Environmental Impacts of Operation environmental site audit. The NRC staff also reviewed other sources of information, such as applicable permits and data reports, as listed in the reference section of this SEIS chapter. The staff provides a list of STP permits for operation (status of compliance) in Appendix C. As a result, no information or impacts related to these issues were identified that would change the conclusions presented in the GEIS. Therefore, it is expected that there would be no impacts related to these Category 1 issues during the renewal term beyond those discussed in the GEIS. For these groundwater issues, the GElS concludes that the impacts are SMALL.
4.4.2 Groundwater Use Conflicts This section presents the NRC staffs review of plant-specific (Category 2) groundwater use conflict issues, as listed in Table 4-5.
4.4.2.1 Plants Using Greater Than 100 gpm of Groundwater For nuclear power plants that pump more than 100 gpm (380 L/min) of groundwater from onsite wells, the potential groundwater use conflict with nearby groundwater users is considered a Category 2 issue that requires a plant-specific assessment, as specified in 10 CFR 51.53(c)(3)(ii)(C). In evaluating the potential impacts resulting from groundwater use conflicts associated with license renewal, the NRC staff uses as its baseline the existing groundwater resource conditions described in Sections 2.1.7.2 and 2.2.5.1 of this SEIS. These baseline conditions encompass the existing hydrogeologic framework and conditions (including aquifers) potentially affected by continued operations as well as the nature and magnitude of groundwater withdrawals for cooling and other purposes (as compared to relevant appropriation and permitting standards). The baseline also considers other downgradient or in-aquifer uses and users of groundwater.
As described in Section 2.1.7.2, onsite groundwater production at STP has averaged 768 gpm (2,910 L/min) or 1,239 ac-ft/yr (1.5 million m3/yr) annually over the 10-year period from 2001 through 2010. STP has a permit for five production wells completed in the Deep Chicot Aquifer to withdraw at a combined rate of approximately 1,860 gpm (7,040 L/min) or 3,000 ac-ft/yr (3.7 million m3/yr). Of the five production wells, wells 5, 6, and 7 (as described in Section 2.1.7.2) feed a common header (a single collection point) that delivers water to be chlorinated, filtered, and stored for use by the service water system and the fire protection system. Each of these three wells has a design capacity of 500 gpm (1,890 L/min) at a depth of 700 ft (210 m). The service water system includes the demineralizer system and the potable water supply for the plant. The common header supplied by the three production wells is also the primary source for makeup water to the essential cooling pond (ECP). Well 8, with a design capacity of 250 gpm (950 L/min) at a depth of 600 ft (180 m), supplies the Nuclear Support Center chill water for the building cooling tower. The Nuclear Training Facility (NTF) well, with a design capacity of 200 gpm (760 L/min) and a depth of 600 ft (180 m), provides fire protection water to the NTF (STPNOC 2010b).
Because the annual average withdrawal rate from these sources for service water and fire protection water is greater than 100 gpm (380 L/min), this is a Category 2 issue for the STP site.
All five STP production wells (5, 6, 7, 8, and NTF) are located relatively near the STP site boundary, as shown in Figure 2-1. Coastal Plains Groundwater Conservation District (CPGCD) rules require that wells of 7-in. (18-cm) diameter or greater completed on adjacent lands with different owners must be spaced a minimum of 2,500 ft (760 m) from any other permitted or registered well (CPGCD 2010). Therefore, drawdown at 2,500 ft (760 m) well spacing is relevant to the evaluation of potential conflicts with neighboring wells.
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Environmental Impacts of Operation The applicant performed an analysis of drawdown using the Theis non-equilibrium well equations (E.E. Johnson, Inc. 1966). Using representative hydraulic properties, the applicant calculated drawdowns of 20.0 and 20.7 ft (6.1 and 6.3 m) in the Deep Chicot Aquifer after 40 and 60 years, respectively, for a neighboring well located 2,500 ft (760 m) from an STP production well pumped at 500 gpm (1,890 L/min) (STPNOC 2011c). The projected change in drawdown during the additional 20 years of operation is less than 1 ft (0.3 m). The NRC staff checked and confirmed the applicants drawdown estimates, as presented in Table 4-6. To more completely evaluate the potential change in drawdown, the NRC staff also calculated drawdown at distances of 1 and 5 mi (1.6 and 8 km).
Table 4-6. Projected Drawdown and Change in Drawdown in Feet for the Deep Chicot Aquifer for Selected Distances Aquifer Drawdown ft (m) Change in Drawdown Distance (a) 40 years 60 years ft (m) 2,500 ft (760 m) 20 ft (6.1 m) (b) 20.7 ft (6.3 m) (b) 0.7 ft (0.2 m) 1 mi (1.6 km) 17.4 ft (5.3 m) 18.1 ft (5.5 m) 0.7 ft (0.2 m) 5 mi (8 km) 11.8 ft (3.6 m) 12.5 ft (3.8 m) 0.7 ft (0.2 m)
(a)
All projections assume a saturated hydraulic conductivity of 33,245 gallons per day per foot (gpd/ft), coefficient of storage of 0.00022 (dimensionless), and a pumping rate of 500 gpm (1,890 L/min).
(b)
This is based on STPNOC 2011c. Remaining drawdown values are based on NRC staff analyses.
The STP ER for proposed Units 3 and 4 reproduced a map showing the potentiometric surface (the water level that would rise in a well) in the Deep Aquifer in Matagorda County in 1967 (STPNOC 2010c). It shows the potentiometric head (hydraulic pressure) to be between 0 and 10 ft (3 m) below mean sea level (MSL) at the STP site. The Deep Aquifer potentiometric surface in 2005 reveals the potentiometric head on the site boundary near wells 5 and 6 to be as great as 55 ft (17 m) below MSL. Well 5 was completed in 1975, and well 6 was completed in 1977. By 2005, these wells had been in service for approximately 30 years, and drawdown was approximately 50 ft (15 m) below MSL. Piezometers completed in the Deep Chicot Aquifer at the site (STPNOC 2010c) indicate a steady response pumping activity since the late 1990s, with one piezometer relatively near production well 5 showing a near constant piezometric head of 50 ft (15 m) below MSL. The elevation of the upper surface of the Deep Chicot Aquifer is between 250 to 300 ft (76 to 91 m) below ground surface or approximately 220 to 270 ft (67 to 83 m) below MSL. Thus, the steady drawdown observed at the site ensures ample confining pressure remains in the Deep Chicot Aquifer. The drawdown observed suggests that a well located near the STP site boundary and one of the STP production wells could require a pumping lift (differential pressure applied by a pump) of approximately 50 ft (15 m) over conditions in 1967. This is the additional vertical distance that water would have to be pumped to the surface. However, the majority of this drawdown and associated pumping lift has been identified as regional drawdown resulting from groundwater development to the north of the STP site, as reflected in historical well and piezometer water well mapping (STPNOC 2009c).
The NRC staffs analysis of drawdown using representative hydraulic properties and review of field data reveals that drawdown near STP production wells could influence the pumping lift of groundwater wells on neighboring properties. However, the drawdown at STP production wells from 40 years of pumping is estimated to be approximately 20 ft (6.1 m), and continued operation for an additional 20 years beyond the current license period would increase drawdown 4-7
Environmental Impacts of Operation by less than 1 ft (0.3 m). This finding is influenced by local and regional groundwater use regulation as discussed above and in Section 2.2.5. The projected increase in drawdown of less than 1 ft (0.3 m) is a negligible impact on neighboring wells and landowners. Therefore, the NRC staff concludes that groundwater use conflicts from STP groundwater withdrawals during the license renewal term would be SMALL.
4.4.2.2 Plants Using Cooling Towers or Cooling Ponds and Withdrawing Makeup Water from a Small River Nuclear power plants using cooling towers or cooling ponds that are supplied with makeup water from a small river (as defined in Section 4.3.2) require a plant-specific assessment due to the potential impact on alluvial aquifers. The requirement for this assessment is specified by 10 CFR 51.53(c)(3)(ii)(A). This potential impact to groundwater is considered a Category 2 issue. The GEIS established this groundwater aspect as Category 2 because consumptive use of water withdrawn from a small river could adversely affect groundwater aquifer recharge. Low river flow conditions are of particular interest. For this groundwater use conflicts-related issue, the NRC staff uses the same baseline as noted in Section 4.4.2.1.
STP, Units 1 and 2, is dependent on the lower Colorado River as the primary water source for the 7,000-ac (2,830-ha) MCR. Systems that have a groundwater source (e.g., service water, fire protection) also discharge to the MCR. The lower Colorado River meets the NRC definition of a small river. As noted in Section 2.2.5.1, the Shallow Chicot Aquifer discharges to the Colorado River southeast of the STP site. There is a relatively narrow band of an alluvial aquifer separating the Shallow Chicot Aquifer from the Colorado River. With the rise and fall of the Colorado River, the alluvial aquifer experiences bank storage. This refers to a condition such that when groundwater in the alluvial aquifer is higher than the river stage, the alluvial aquifer discharges to the river. Similarly, when river stage is higher than groundwater in the alluvial aquifer, the alluvial aquifer is recharged by the river. In general, the lower Colorado River is a gaining stream (sustained by groundwater discharges) near the STP site. This is because the Shallow Chicot Aquifer discharges to the alluvial aquifer, and the alluvial aquifer discharges to the Colorado River. During high river stage and local to the river shore, the groundwater elevation would increase in the alluvial and Shallow Chicot Aquifer, resulting in recharge to the aquifers. During low river stage, the Shallow Chicot Aquifer and the alluvial aquifer would resume discharging to the river.
Near the STP site, the Shallow Chicot Aquifer is used primarily for livestock watering because of its low yields to wells and relatively poor quality. The Deep Chicot Aquifer is separated hydraulically from the Shallow Chicot Aquifer by a 100- to 150-ft (30- to 46-m) thick confining unit, and it is the primary source of groundwater for the region due to high aquifer yields and good quality.
STPNOC is limited in its ability to divert water from the lower Colorado River during periods of low flow and can do so only after confirming the Colorado River flow at the U.S. Geological Survey (USGS) Bay City gaging station supports the withdrawal of surface water in accordance with STPNOCs Certificate of Adjudication for water use, as discussed in Section 2.1.7.1 and Section 4.3.2 (STPNOC 2009d, 2010b).
In summary, the following staff findings are relevant to the issue of groundwater use conflicts on alluvial aquifers from STP continued operations:
- The alluvial aquifer is limited to a relatively narrow band between the Colorado River and the Shallow Chicot Aquifer.
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Environmental Impacts of Operation
- The Colorado River is normally a gaining stream with the alluvial aquifer and Shallow Chicot Aquifer discharging to the river. During periods of low river flow, the alluvial aquifer and Shallow Chicot Aquifer would discharge to the river (the normal situation for a gaining stream).
- The Shallow Chicot Aquifer is used for watering livestock and other low-yield, poor-quality applications and would not be substantially influenced by the bank storage effects of alluvial aquifer recharge and discharge.
- The Deep Chicot Aquifer is the primary groundwater supply in the region, and it discharges to the lower Colorado River estuary and Matagorda Bay approximately 5 mi (8 km) downstream of STP (discussed in Section 2.2.5).
- STP is limited through its Certificate of Adjudication and management plan regarding diversion of lower Colorado River water during low flow (discussed in Section 2.1.7.1 and Section 4.3.2).
Based on the information above, the NRC staff concludes that continued withdrawals of surface water (the Colorado River) for the operation of STP, Units 1 and 2, during low-flow periods would have a SMALL impact on recharge to the alluvial aquifer during the license renewal term.
4.4.3 Groundwater Quality As described in Section 4.4.1, the NRC staff did not identify any new and significant information with regard to Category 1 (generic) groundwater issues. As part of its assessment, the staff specifically reviewed information relating to the current state of knowledge regarding groundwater quality downgradient of the MCR and underlying the STP protected area, as summarized in this section. In evaluating the potential impacts on groundwater quality associated with license renewal, the NRC staff uses as its baseline the existing groundwater conditions described in Section 2.2.5.2 of this SEIS. These baseline conditions encompass the existing quality of groundwater potentially affected by continued operations (as compared to relevant state or U.S. Environmental Protection Agency (EPA) primary drinking water standards (DWS)) as well as the current and potential onsite and offsite uses and users of groundwater for drinking and other purposes. The baseline also considers other downgradient or in-aquifer uses and users of groundwater.
Elevated concentrations of tritium have been observed in groundwater adjacent to the MCR and in groundwater underlying the protected area of STP, Units 1 and 2, as described in Section 2.2.5.2. The MCR is unlined and water from the reservoir seeps into the Upper Shallow Aquifer. Systems within the protected area have released liquids containing tritium to groundwater.
Regarding non-radioactive contaminants in the MCR, total dissolved solids (TDS) is an indicator contaminant. The NRC staff anticipates that seepage from the MCR to the Upper Shallow Aquifer would initially have the same TDS concentration as the MCR. STPNOCs estimate of the median TDS concentration in the MCR from operation of STP, Units 1 and 2, is approximately 2,000 mg/L (NRC 2011b). Locally, groundwater from the Shallow Aquifer is described as being slightly saline because TDS concentrations are above 1,000 mg/L (i.e., slightly saline waters have TDS ranges of 1,000 to 3,000 mg/L). Onsite wells completed in the Shallow Chicot Aquifer have an average TDS concentration of 1,200 mg/L (STPNOC 2010c). Accordingly, the Shallow Aquifer is used locally to water livestock, and it is not a freshwater supply. The NRC staff concludes that given a long-term local increase of TDS concentration to 2,000 mg/L, the groundwater TDS concentration would remain in the range 4-9
Environmental Impacts of Operation associated with slightly saline waters. Thus, the potential future TDS level is consistent with the existing groundwater quality and its current use as a source of water for livestock. Any impacts from this change in groundwater quality would be localized because the groundwater plumes originating from the MCR are local to the STP site and the region immediately downgradient of the site to the lower Colorado River.
Regarding radioactive contaminants in the MCR, tritium is an indicator contaminant. Tritium releases occur to the Upper Shallow Chicot Aquifer from the MCR via seepage through the reservoir floor. Historical monitoring data for the MCR water (inside the MCR) show a peak tritium concentration of 17,410 picocuries per liter (pCi/L) in 1996 and values less than 14,000 pCi/L since then (STPNOC 2010b, 2010c). A relief well (no. 701) monitored since 1995 showed a peak tritium concentration of 7,672 pCi/L in 1998 and values less than 7,000 pCi/L since then. Tritium activity in an onsite monitoring well (MW-251) completed in the Shallow Chicot Aquifer showed a peak in year 2000 of approximately 8,000 pCi/L and lower values before and after (NRC 2011b; STPNOC 2010a, 2013b). However, in mid-2012, a spike to 8,600 pCi/L was observed in MW-251 before levels declined once again (STPNOC 2013b).
Monitoring continues to show that levels of tritium in the Shallow Chicot Aquifer around the MCR originate from the liquids discharged to the MCR and are below the EPA primary DWS of 20,000 pCi/L (40 CFR Part 141). The staff also concludes that tritium concentrations in the Shallow Chicot Aquifer, resulting from seepage from the MCR, are bounded by the tritium concentration in the MCR waters. Thus, the observed peak tritium concentration of 17,410 pCi/L, and more recent levels of 14,000 pCi/L, ensures that tritium concentrations in groundwater downgradient of the MCR will be below the EPA primary DWS. Further, as noted in Section 2.2.5.2, the Deep Chicot Aquifer is separated from the Shallow Chicot Aquifer by a zone of predominantly clay material 100 to 150 ft (30 to 46 m) thick. The Deep Chicot Aquifer is the primary source of groundwater for the region, and tritium has not been detected in the Deep Chicot Aquifer (MACTEC 2009).
As a result of STPNOCs participation in the Nuclear Energy Institutes (NEI) Groundwater Protection Initiative (NEI 2007), data exist on tritium levels in groundwater, and a report was issued that compiled all information about groundwater and releases to groundwater in the STP, Units 1 and 2, protected area (MACTEC 2009). A peak tritium concentration around 15,000 pCi/L was observed in the Upper Shallow Chicot Aquifer beneath the protected area in 2006. Sampling at the location of that peak concentration has shown a continuous decline in tritium concentration with a concentration of 678 pCi/L observed in 2012. All measured tritium levels in groundwater within the protected area are below the EPA primary DWS (i.e., 20,000 pCi/L) (see Section 2.2.5.2).
Three possible sources of tritium in groundwater within the protected area have been identified as seepage from the MCR, leaks of the TDS pipeline system, and discharge to the ground from the turbine steam trap drains or steam condensate lines. Tritium levels in groundwater originating in the MCR are bounded, as described above, and will be less than the EPA primary DWS. STPNOC has noted that the TDS pipeline system and the steam condensate line releases could have a maximum tritium concentration of less than 90,000 pCi/L (STPNOC 2011c). Releases to groundwater in the vicinity of the Units 1 and 2 reactors move downward from the Upper into the Lower Shallow Chicot Aquifer and then laterally to the east and southeast in the Lower Shallow Chicot Aquifer to the STP site boundary (NRC 2011b). As described in Section 2.2.5.2, the groundwater travel time from the protected area to the STP site boundary east of the protected area is approximately 100 years. This represents over eight half-lives of tritium decay; therefore, releases at the maximum level would decay to concentrations below the EPA primary DWS before leaving the STP site. The NRC staff has 4-10
Environmental Impacts of Operation evaluated the releases inside the protected area, as well as relevant groundwater monitoring data. The staff concludes that no release is occurring from an unidentified pathway (based on accounting of releases from available records), and there is no substantial adverse impact on drinking water (the staff evaluates human health issues in Section 4.8).
In addition to the foregoing, the following staff findings are relevant to the issue of groundwater quality impacts:
- Groundwater in the Shallow Chicot Aquifer will remain slightly saline and suitable to its current use for watering livestock.
- Tritium levels in the Shallow Chicot Aquifer resulting from seepage from the MCR will not exceed the EPA primary DWS.
- Tritium has not been detected in the Deep Chicot Aquifer, which is the primary groundwater source in the region.
- Tritium levels in the Shallow Chicot Aquifer resulting from leaks and discharges inside the STP protected area are currently below the EPA DWS, and long-term tritium levels leaving the STP site from such releases would be below the EPA DWS.
In conclusion, based on this informationincluding the staffs review of seepage from the MCR and the review of releases of liquids containing tritium within the protected area of STP, Units 1 and 2the NRC staff concludes that groundwater contaminant plumes have not altered current groundwater use in the region downgradient of the STP site. The staff further concludes that groundwater-quality impacts would remain SMALL during the license renewal term.
4.5 Aquatic Resources Sections 2.1.6 and 2.2.5 describe the STP cooling system and aquatic environment.
Section 2.2.7.1 describes the protected aquatic resources that could occur in the vicinity of STP and associated transmission lines. Category 1 and Category 2 issues related to aquatic resources applicable to STP are discussed below and listed in Table 4-7.
Table 4-7. Aquatic Resource Issues Issues GEIS Section Category For all plants Accumulation of contaminants in sediments or biota 4.2.1.2.4 1 Entrainment of phytoplankton & zooplankton 4.2.2.1.1 1 Cold shock 4.2.2.1.5 1 Thermal plume barrier to migrating fish 4.2.2.1.6 1 Distribution of aquatic organisms 4.2.2.1.6 1 Premature emergence of aquatic insects 4.2.2.1.7 1 Gas supersaturation (gas bubble disease) 4.2.2.1.8 1 Low dissolved oxygen in the discharge 4.2.2.1.9 1 4-11
Environmental Impacts of Operation Issues GEIS Section Category Losses from predation, parasitism, & disease among organisms 4.2.2.1.10 1 exposed to sublethal stresses Stimulation of nuisance organisms 4.2.2.1.11 1 For Plants with Cooling Pond Heat-Dissipation Systems Entrainment of fish & shellfish in early life stages 4.1.2 2 Impingement of fish & shellfish 4.1.3 2 Heat shock 4.1.4 2 4.5.1 Generic Aquatic Ecology Issues The NRC staff did not identify any new and significant information related to the Category 1 issues listed above during the review of STPNOCs ER, the site audit, or the scoping process that would change the conclusions presented in the GEIS (the NRC staff also reviewed other sources of information, such as applicable permits and data reports, as listed in the reference section of this SEIS chapter). Therefore, there is no impact related to these issues beyond those discussed in the GEIS. For these issues, the GEIS concluded that the impacts are SMALL.
4.5.2 Entrainment and Impingement Entrainment and impingement of aquatic organisms are site-specific (Category 2) issues for assessing the impacts of license renewal at plants with cooling pond heat-dissipation systems.
Entrainment is the taking in of organisms with a plants cooling water intake. The organisms involved are generally of small size, dependent on the screen mesh size, and include phyto-and zooplankton, fish eggs and larvae, shellfish larvae, and many other forms of aquatic life.
Impingement is the entrapment of organisms against the cooling water intake screens.
A particular species can be subject to both impingement and entrainment if some individuals are impinged on screens while others pass through and are entrained (EPA 1977). Section 316(b) of the Clean Water Act (CWA) (33 United States Code (U.S.C.) §1326(b)) requires that [a]ny standard established pursuant to Section 1311 of this title or Section 1316 of this title and applicable to a point source shall require that the location, design, construction, and capacity of cooling water intake structures reflect the best technology available for minimizing adverse environmental impact.
At STP, organisms maybe impinged or entrained at two locations. Organisms that inhabit the lower Colorado River may be impinged or entrained when water is drawn through the reservoir makeup pumping facility (RMPF) from the Colorado River into the MCR. Organisms that inhabit the MCR may be impinged or entrained when water is drawn through the cooling water intake structure (CWIS) from the MCR to the cooling water system.
The adverse environmental impacts of cooling water intakes occur through both impingement and entrainment. Heat, physical stress, or chemicals used to clean the cooling system may kill or injure the entrained organisms. Exhaustion, starvation, asphyxiation, descaling, and physical stresses may kill or injure impinged organisms. STPNOC survey data in the MCR indicate that entrained organisms from the lower Colorado River can survive the stresses of the intake 4-12
Environmental Impacts of Operation system at the RMPF and colonize the MCR (ENSR 2008a, 2008b). However, entrainment and colonization of the MCR removes these organisms from the rest of the ecosystem in the region.
Entrained organisms that pass through the CWIS into the plants cooling system are subject to mechanical, thermal, and toxic stresses. Therefore, survival is unlikely.
This section uses a retrospective assessment of the present and past impacts to the (terrestrial or aquatic) ecosystem resulting from plant operation in order to provide a prospective assessment for the future impacts over the license renewal term (i.e., the remainder of the present term plus an additional 20 years). The timeframe and geographic extent of the assessment are two related parts of the scoping process that bounds the impact analysis. The timeframe defines how far back and how far forward the analysis will extend. In assessing the level of impact, the staff looks at the projected effects in comparison to a baseline condition.
In agreement with National Environmental Policy Act (NEPA) guidance (CEQ 1997a), the baseline of the assessment is the condition of the resource without the action (i.e., under the no-action alternative). Under the no-action alternative, the plant would shut down, and the resource would conceptually return to its condition without the plant, which is not necessarily the same as the condition before the plant was constructed. The timeframe of analyses for ecological resources extends far enough into the past to understand trends and to determine whether the resource is stable, which the NRC definitions of impact levels require. For assessing direct and indirect impacts, the geographic boundaries depend on the biology of the species under consideration.
Because impingement and entrainment are fundamentally linked, the NRC staff determined that effects of each should be assessed using an integrated approach. The NRC staff employed a weights-of-evidence (WOE) approach to evaluate the effects of impingement and entrainment on the aquatic resources in the lower Colorado River and the MCR. NRC employed this approach because EPA recommends a WOE approach for ecological risk assessments (EPA 1998). WOE is a useful tool due to the complex nature of assessing risk (or impact), and NRC has employed this approach in other evaluations of the effects of nuclear power plant cooling systems on aquatic communities (NRC 2010, 2011i).
Menzie et al. (1996) defines WOE as the process by which multiple measurement endpoints are related to an assessment endpoint to evaluate whether significant risk of harm is posed to the environment. In this modified WOE approach, the NRC staff examined five lines of evidence to determine if operation of the STP cooling system has the potential to cause adverse impacts to fish and shellfish near STP. The first line of evidence is impingement and entrainment studies at the RMPF during the initial filling and subsequent intermittent withdraw of water from the Colorado River to the MCR (McAden 1984, 1985). The second line of evidence is impingement and entrainment studies at the CWIS from 2007 through 2008 during the withdraw of water from the MCR through the circulating water system for STP, Units 1 and 2 (ENSR 2008a). The third line of evidence includes engineering designs and operational procedures to limit impingement and entrainment. The fourth line of evidence includes reviews by other regulatory agencies, such as EPA and the Texas Commission on Environmental Quality (TCEQ). The fifth line of evidence includes survey data of fish and shellfish populations prior to and during operations within the Colorado River.
Line of Evidence Number 1: Impingement and Entrainment Studies on the Colorado River The NRC staff evaluated the potential impacts from impingement and entrainment during water withdrawal from the Colorado River by examining impingement and entrainment studies from 1983 to 1984. McAden et al. (1984, 1985) conducted studies at the RMPF when STPNOC 4-13
Environmental Impacts of Operation initially filled the MCR with Colorado River water. NRC (1986) assessed the environmental impacts of impingement and entrainment for the initial operating license for STP, Units 1 and 2.
McAden et al. (1984, 1985) conducted studies to estimate entrainment impacts by collecting surface plankton samples in front of the RMPF. McAden used a hand-towed 0.5-m (20-in. mouth diameter) ichthyoplankton net with 0.5-mm (0.02-in.) square mesh and swept the hand tow parallel to the front wall of the pump structure. The most commonly collected species included the zoeae and juveniles of Harris mud crabs (Rhithropanopeus harrisii), river shrimp (Macrobrachium ohione), and white shrimp (Litopenaeus setiferus), as shown in Table 4-8.
McAden collected the eggs and larvae of two fish speciesbay anchovy (Anchoa mitchilli) and mosquito fish (Gambusia affinis). McAden also conducted plankton tows in the Colorado River near the RMPF. The most commonly collected species of fish eggs and larvae included bay anchovy, Gulf menhaden (Brevoortia patronus), and Atlantic croaker (Micropogonias undulatus).
Section 2.2.5.1 provides addition details regarding fish egg and larvae sampling in the Colorado River.
Based on the entrainment study by McAden et al. (1984, 1985), NRC (1986) estimated that entrainment losses would be approximately 10 percent of the organisms passing the RMPF.
This value represents the loss of organisms in the influence of the tidal flow in the river and does not represent the entire populations of those species in the lower Colorado River.
NRC (1986) determined that the systems along the Texas Gulf coasts and the area influenced by the RMPF are not unique. In addition, NRC (1986) determined that species commonly caught in near the RMPF by McAden are ubiquitous (widespread or common) and abundant along the Texas and Gulf coasts. The reproductive potential (fecundity) for these species is high; therefore, the larvae entrained are a small portion of the total larvae produced by adult females for most species (NRC 2011b). In addition, most makeup water withdrawal would occur during high river flow conditions, which is when the salinity and concentrations of estuarine and marine organisms would be lowest. Therefore, NRC (1986) concluded that entrainment losses for the species collected by McAden (1984, 1985) would not constitute a significant impact to their respective populations.
ENSR Corporation (2008a) indicates that many individuals of numerous species survived entrainment at the RMPF and inhabit the MCR. While these organisms survived entrainment, the entrainment, overall, has led to a loss of the organisms in the Colorado River, and these organisms no longer contribute to the riverine ecosystem.
Table 4-8. Number (per 100 m3) of Macrozooplankton and Ichthyoplankton Collected in Plankton Samples in Front of the RMPF from 1984 and 1985
% of Common Name Scientific Name Aug-83(a) Sept-83(b) Sept-84(c) Total Total bay anchovy Anchoa mitchilli 51.3 0 0 51.3 1 bivalves-juveniles Pelecypoda 10.3 28.3 0 38.6 1 blue crab-juvenile Callinectes sapidus 62.8 14.1 0 76.9 2 crabs-megalopa Callinectes spp. 115 0 0 115 3 glass shrimp Palaemonetes paludosus 0 14.9 0 14.9 <1 Harris mud crab Rhithropanopeus harrisii 184.9 1,461.4 695.9 2,342.2 60 4-14
Environmental Impacts of Operation
% of Common Name Scientific Name Aug-83(a) Sept-83(b) Sept-84(c) Total Total mosquito fish Gambusia affinis 23.3 14.9 0 38.2 1 ghost shrimp Callianassa spp. 0 0 51.4 51.4 1 river shrimp Macrobrachium ohione 609.3 29 0 638.3 16 white shrimp Litopenaeus setiferus 222.2 312.8 0 535 14 unidentified fish spp. 0 0 12.9 12.9 <1 Total 1,279.1 1,875.4 760.2 3,914.7 (a)
Samples collected on August 9-10, 1983, at 1100, 1640, 2230, and 0450 (b)
Samples collected on September 15-16, 1983, at 1100, 1705, 2250, and 0545 (c)
Samples collected on September 6, 1984, at 0020, 0500, 1030, and 1615 Source: McAden 1984, 1985 McAden et al. (1984, 1985) also conducted impingement studies by washing all organisms off two intake screen and filtering them through a dip net with a 0.25-in (6.4-mm) mesh. Each sample period was 30 minutes. McAden (1984, 1985) collected three samples within 24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> during each week that pumping occurred. The most commonly impinged species included blue crab (61 percent), river shrimp (18 percent), and white shrimp (10 percent), as shown in Table 4-9. Impinged fish included one crevalle jack (Caranx hippos), one green sunfish (Lepomis cyanellus), and one inland silverside (Menidia beryllina). Because the impingement study collected so few fish, NRC (1986) predicted the most likely fish to be impinged based on size (which is related to swim speed) and the density and abundance of the species near the RMPF.
NRC (1986) predicted Gulf menhaden to be the most commonly impinged species (65 percent),
followed by Atlantic croaker (16 percent), bay anchovy (10 percent), and striped mullet (8 percent). NRC (1986) concluded that impingement losses would have a minor effect on the biota of the Colorado River because the commonly impinged species are ubiquitous, abundant habitat for these species occurs along the Texas and Gulf coasts, and the design elements of the RMPF would reduce impingement losses.
STPNOC has not conducted impingement and entrainments studies on the Colorado River since its 1983 to 1984 study (STPNOC 2010b, 2010c). Since 1984, the U.S. Army Corps of Engineers (USACE) completed the mouth of the Colorado River project, increasing the flow between the Colorado River and Matagorda Bay (USACE 2005; Wilber and Bass 1998). As discussed below in the aquatic survey section (line of evidence number 5), the diversity of aquatic species and the presence of estuarine-marine species has increased since the 1970s.
However, ENSR (2008b) found that the majority of the species most likely to be impinged (e.g., Gulf menhaden, Atlantic croaker, and striped mullet) continue to be the most common species of fish collected around the RMPF and would likely continue to be the most common species impinged during the license renewal term.
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Environmental Impacts of Operation Table 4-9. Invertebrates and Fish Impinged at the RMPF during 1983-1984 Studies
% of Common Name Scientific Name July-83(a) Aug-83(b) Sept-83(c) Sept-84(d) Total Total blue crab Callinectes sapidus 69 44 4 6 123 61 crevalle jack Caranx hippos 1 0 0 0 1 <1 Palaemonetes glass shrimp paludosus 14 1 0 0 15 7 Palaemonetes grass shrimp kadiakensis 1 1 0 0 2 1 green sunfish Lepomis cyanellus 1 0 0 0 1 <1 inland silverside Menidia beryllina 1 0 0 0 1 <1 Farfantepenaeus pink shrimp brasiliensis 0 0 0 1 1 <1 Palaemonidae shrimp Palaemonidae spp. 2 0 0 0 2 1 Macrobrachium river shrimp ohione 28 4 1 4 37 18 white shrimp Litopenaeus setiferus 0 3 13 4 20 10 Total 117 53 18 15 203 (a) Samples collected on July 13-14, 1983, at 1329, 2100, and 0511; July 21-22, 1983, at 1315, 2110, 0505; and July 27-28, 1983, at 1400, 2230, and 0626.
(b) Samples collected on August 9-10, 1983, at 1300, 2100, and 0500.
(c) Samples collected on September 15-16, 1983, at 1414, 2205, and 0615.
(d) Samples collected on September 5-6, 1984, at 1910, 0300, and 1104.
Source: McAden 1984, 1985 Line of Evidence Number 2: Impingement and Entrainment Studies on the Main Cooling Reservoir STP conducted impingement and entrainment studies at the CWIS on the MCR in May 2007 through April 2008 (ENSR 2008a). The objective of the study was to characterize the aquatic species within the MCR, and to evaluate impingement and entrainment impacts to establish, to the extent possible, relationships between the presence of aquatic organisms and the current (STP, Units 1 and 2) intake design and operating parameters (ENSR 2008a).
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Environmental Impacts of Operation ENSR (2008a) collected entrainment samples over a 24-hour period, twice per month from May through September and once per month from October through April. ENSR collected entrainment samples by placing 0.363-mm (0.014-in.) plankton nets behind the trash bars at the CWIS. ENSR pumped water from a depth of approximately 12 ft (3.7 m) through a buffering chamber at flows up to 10,800 gallons per hour or 180 gpm. ENSR operated the pumps four times per day, for approximately 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br /> per event, for a volume of 100 m3 (3,500 ft3) of water per 24-hour period.
ENSR (2008a) collected 207,696 organisms representing nine different fish families and 12 different classes of invertebrates (Table 4-10). The most commonly impinged taxa included Harris mud crab (68 percent) and unidentified decapod zoea (or free swimming larvae)
(15 percent). Ichthyoplankton, or fish eggs and larvae, comprised less than 1 percent of all entrained organisms. ENSR reported the highest entrainment rates from April through June and the lowest from December through March. Entrainment of threadfin shad and mud crabs was highest in late spring and summer, and entrainment of silversides was highest in summer.
Table 4-10. Aquatic Species Collected during Entrainment Sampling in the MCRs CWIS for Units 1 and 2, 2007-2008 Common Name Taxon Total Number % of Total Finfish anchovy Anchoa spp. 30 <1 clupeid Clupeidae 544 <1 fish egg 418 <1 goby Gobiidae 61 <1 perch-like fish Perciformes 6 <1 naked goby Gobiosoma bosc 5 <1 needlefish Belonidae 3 <1 silversides Atherinidae 201 <1 wrasse Labridae 3 <1 Invertebrates amphipod Amphipoda 145 <1 bivalve Mollusca 1 <1 brachyuran decapod (zoea) Brachyura 353 <1 copepod Copepoda 6,588 3 decapod (mud crabs) Panopeidae 10,798 5 decapod (zoea) Decapoda 31,919 15 fish lice Copepoda 399 <1 harpacticoid copepod Copepoda 12,212 6 Harris mud crab Rhithropanopeus harrisii 140,192 68 4-17
Environmental Impacts of Operation Common Name Taxon Total Number % of Total insect Insecta 24 <1 midge Diptera 110 <1 mite or ticks Acari 12 <1 mysid shrimp Mysida 2,660 1 polychaete Annelida 4 <1 seed shrimp Ostracoda 78 <1 shrimp Caridea 1 <1 tongue biters Isopoda 16 <1 water flea Cladocera 800 <1 unidentified 113 <1 Total 207,696 Source: ENSR 2008a ENSR (2008a) collected impingement samples over a 24-hour period, twice per month from May through September and once per month from October through April. ENSR collected samples by placing a metal-framed net fitted with a 0.25-in. (6.4-mm) nylon mesh net within the sluiceway that connects the CWIS screen wash system and the debris basket.
ENSR (2008a) collected a total of 3,982 organisms representing 25 finfish and 7 invertebrate species (Table 4-11). The most commonly impinged species includes threadfin shad (Dorosoma petenense) (42 percent), blue crab (24 percent), mud crab (24 percent), Atlantic croaker (5 percent), and white shrimp (3 percent). Blue crab impingement was highest during the months of May, June, and July, and threadfin shad impingement was highest during the months of January and March. ENSR did not report any other temporal trends for individual species or all species combined.
Table 4-11. Aquatic Species Collected during Impingement Sampling in the MCRs CWIS for Units 1 and 2, 2007-2008 Common Name Scientific Name Total Number % of Total Finfish American eel Anguilla rostrata 1 <1 Atlantic croaker Micropogonias undulatus 182 5 bay anchovy Anchoa mitchilli 3 <1 bay whiff Citharichthys spilopterus 2 <1 black drum Pogonias cromis 2 <1 blue catfish Ictalurus furcatus 6 <1 bluegill Lepomis macrochirus 9 <1 4-18
Environmental Impacts of Operation Common Name Scientific Name Total Number % of Total channel catfish Ictalurus punctatus 4 <1 common carp Cyprinus carpio carpio 2 <1 freshwater drum Aplodinotus grunniens 5 <1 freshwater goby Ctenogobius shufeldti 2 <1 gizzard shad Dorosoma cepedianum 2 <1 goby Gobiidae spp. 8 <1 Gulf menhaden Brevoortia patronus 2 <1 inland silverside Menidia beryllina 5 <1 ladyfish Elops saurus 1 <1 naked goby Gobiosoma bosc 13 <1 needlefish Strongylura exilis 2 <1 rough silverside Membras martinica 2 <1 sand seatrout Cynoscion arenarius 3 <1 sharptail goby Oligolepis acutipennis 2 <1 sheepshead Archosargus probatocephalus 1 <1 speckled worm eel Myrophis punctatus 1 <1 spot croaker Leiostomus xanthurus 1 <1 threadfin shad Dorosoma petenense 1,668 42 Invertebrates blue crab Callinectes sapidus 944 24 brown shrimp Farfantepenaeus aztecus 10 <1 grass shrimp Paleemonetes pugio 33 <1 lesser blue crab Callinectes similis 3 <1 Harris mud crab Rhithropanopeus harrisii 953 24 river shrimp Macrobrachium ohione 3 <1 white shrimp Litopenaeus setiferus 106 3 Other flat-headed snake Tantilla gracilis 1 <1 Total 3,982 4-19
Environmental Impacts of Operation Common Name Scientific Name Total Number % of Total Source: ENSR 2008a Line of Evidence Number 3: Engineered Design and Operational Conditions EPA recently published a proposed rule that describes multiple approaches to reduce impingement and entrainment mortality at existing cooling water intake structures. These approaches include flow reduction, or reducing the total amount of water withdrawn; intake velocity; technologies to exclude organisms and to collect and return organisms to the water body; and intake location and timing of withdrawals (76 FR 22174). The RMPF on the Colorado River and the CWIS on the MCR incorporate several of these approaches.
Flow Reduction. Reducing the intake flow reduces the amount of water withdrawn from water bodies to be cycled through the cooling system, which likely reduces the amount of aquatic organisms that would be drawn through the intake structure and subject to impingement and entrainment. STP uses a cooling pond-based heat-dissipation system that withdraws and discharges cooling water to the MCR. The MCR is similar to a closed-cycle cooling system since the water in the reservoir continues to circulate from the MCR, into the plant, and back again. STP intermittently draws water from the Colorado River to compensate for water loss from evaporation and seepage from the MCR. Depending on the quality of the makeup water, closed-cycle recirculating cooling water systems can reduce consumptive water use by 96 to 98 percent of the amount that the facility would use if it employed a once-through cooling system (69 FR 41576).
Reduced Intake Velocity. Water velocity associated with the intake structure greatly influences the rate of impingement and entrainment. The higher the approach or through-screen velocity or both, the greater the number of organisms impinged or entrained. At an approach velocity of 0.5 ft/s (0.15 m/s) or less, most fish can swim away and escape from the intake current (66 FR 65274). The maximum design approach velocity in front of the traveling screens at the RMPF is approximately 0.5 ft/s, based on a maximum pumping rate of approximately 538,000 gpm (2,040 m3/min) (STPNOC 2008a, 2008c, 2010c).
Technologies to exclude organisms and to collect and return organisms to the water body. The RMPF has several technologies that help exclude organisms from becoming impinged or entrained. The RMPF has coarse trash racks with 4-in. (10-cm) spacing between bars, which would impede larger organisms from entering the intake system (STPNOC 2010c). After passing through trash racks, water flows through traveling screens with a 3/8 in. (9.5 mm) mesh (STPNOC 2010c). The space between the trash racks and the traveling screens allow fish to swim downstream and exit the intake structure (STPNOC 2010c). Fish collected or washed from the traveling screens can also return to the river via a sluice and fish bypass pipe. The discharge point of the fish bypass system is at the downstream end of the intake structure, approximately 2 ft (0.6 m) below normal water elevation (STPNOC 2010c).
During high-flow conditions, the accumulation of debris on the traveling screens is too high to open the fish bypass system, and screenwash discharge is directed to the sluice trench catch baskets rather than back to the river. Generally, the fish bypass system is closed when river flows are greater than 4,000 cfs (100 m3/s), and the system is occasionally closed when flows are greater than 2,000 cfs (60 m3/s), which has occurred from 2001 to 2006, 7 percent of the time (STPNOC 2008a, 2008c, 2010c). Operators at the RMPF are required to monitor for increased impingement rates on the traveling screens, and operators evaluate relevant factorssuch as river flow, salinity, and observations of impingementto determine whether pumping should continue (STPNOC 2008a, 2008c, 2010c).
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Environmental Impacts of Operation Intake Location and Time of Withdrawals. Location of the intake system is another design factor that can affect impingement and entrainment because water drawn from areas with lower biological productively is less likely to include organisms that could be impinged or entrained.
The RMPF is located on the Colorado River, which is designated as a tidal stream and includes essential fish habitat (EFH) for Federally managed fish and shellfish species (GMFMC 2004).
Locating intake systems in such areas with sensitive biological productivity can negatively affect aquatic life (69 FR 41576). However, the area of the river where the RMPF is situated has fewer organisms and less species richness than the downstream segment of the river, closer to the GIWW (ENSR 2008b).
STPNOC designed the RMPF to position the traveling intake screens parallel to the flow in the river, or flush to the river bank with no projecting structures that create eddies and countercurrents that would cause entrapment (NRC 1986; STPNOC 2010c). Most organisms likely to be entrained or entrapped would occur in higher densities in the main river channel.
They are less likely to be removed from the river by an intake facility sited on the shoreline (NRC 2011b). Entrapment of aquatic organisms in a restricted area (e.g., in the sedimentation basin between the RMPF intake screens and the pumps and in the MCR) can lead to congregation of the organisms, and, if environmental conditions change, the organisms may be harmed. Under such conditions, entrapment can increase impingement of aquatic organisms.
Operational procedures for the RMPF also minimize impingement and entrainment because STPNOC intermittently draws water from the Colorado River for Units 1 and 2, and pumping occurs during periods of lower biological productivity. For example, STPNOC (2010b) noted that most withdrawals would occur during periods of high river flow. Pumping at high-flow conditions minimizes impacts to aquatic organisms in the water column because the organisms are likely to remain in the river flow and unlikely to be caught in the influence of the water being pumped into the RMPF located on the shoreline (STPNOC 2008a, 2008c, 2010b, 2010c). In addition, periods of high river flow (fall through spring) generally correlate with lower biological productivity when less young and estuarine-marine organisms are present (NRC 1986; STPNOC 2010b). During the 2007 to 2008 aquatic ecology studies in the Colorado River, fish density (as expressed in the catch per unit effort) was lowest during high river flow conditions and when salinity was lowest (ENSR 2008b; STPNOC 2008a, 2008c). Salinity can be an indicator of an influx of estuarine species moving up the river from the GIWW.
Line of Evidence 4: Other Regulatory Reviews Section 316(b) of the CWA requires that the location, design, construction, and capacity of cooling water intake structures reflect the best technology available for minimizing adverse environmental impacts. As part of STPNOCs original National Pollutant Discharge Elimination System (NPDES) permit application, in a letter dated June 28, 1982, STPNOC provided EPA with detailed information on the design and operation of the RMPF (STPNOC 2010b). Based on this information, EPA concluded that the intake structure is approved by Best Available Technology in accordance with Section 316(b) of the CWA (EPA 1985).
TCEQ has administered STPNOCs Texas Pollutant Discharge Elimination System (TPDES) permit since 1998, when EPA delegated authority to the State of Texas to administer the States permit program. STPNOC submitted a TPDES permit renewal application by letter dated May 24, 2007. Included in this application was a description of how the cooling water system is a closed-cycle recirculating system and, as such, meets the best available technology standard for minimizing adverse environmental impacts (STPNOC 2010b). For example, STPNOC noted that the MCR recycles water for heat-dissipation and is not a water of the U.S. or a water of the State. TCEQ Water Quality Division concurred that the STP cooling system operates as a 4-21
Environmental Impacts of Operation closed-cycle recirculating system and that the MCR is not a water of the State (TCEQ 2007).
Neither EPA nor the State of Texas has requested additional studies from STPNOC in regards to a 316(b) determination (STPNOC 2010b).
Line of Evidence Number 5: STP Survey Data on the Colorado River Impingement and entrainment from current operations of the RMPF have removed individuals from the Colorado River ecosystem. One method to determine the impacts to aquatic resources from operation of the RMPF is to compare the species abundance and diversity prior to and during operations. ENSR (2008b) compared the aquatic community in the Colorado River using the results of field studies from 1974 (HPLC 1974), 1983 and 1984 (McAden 1984, 1985), and 2007 through 2008 (ENSR 2008b). The 1970s studies were conducted in support of the construction permit for STP, Units 1 and 2. McAden (1984, 1985) conducted studies in support of the operating license for STP, Units 1 and 2. ENSR (2008b) sampled portions of the Colorado River in support of the combined license (COL) for proposed Units 3 and 4.
Section 2.2.5.1 provides additional details of these studies. Because the sampling locations and gear types varied with each study, it can be difficult to determine whether changes over time are due to plant operations, other anthropogenic or environmental changes, or study methods.
ENSR (2008b) compared species richness from trawl surveys conducted in 1974, 1983, and 2007 through 2008. Species richness was generally higher in 2007 through 2008 compared to earlier surveys (ENSR 2008b), as shown in Figure 4-1. For example, species richness in Segment C, which is closest to the RMPF, increased from 12 in the 1974 study to 24 in 2007 through 2008 study. Because STPNOC gathered data for only 2 or 3 years in each segment of the river, it is unclear whether the change in diversity is part of a long-term temporal change or whether the physical conditions in the river (e.g., lower salinity in the 1970s), or another variable, contributed to the different levels of diversity in 1974 compared to 2007 and 2008.
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Environmental Impacts of Operation Figure 4-1. Species Richness of Aquatic Species Captured in Trawl Surveys from 1974, 1983, and 2007 through 2008 40 35 30 Species Richness 25 1974 1983 20 2007-2008 15 10 5
0 Segment A Segment B Segment C River Segment ENSR (2008b) calculated the Jaccard coefficients of community similarity to determine similarities between the samples collected over time in similar reaches of the lower Colorado River based on the presence or absence of taxa. For this measure, as the coefficient approaches 1.0, the more taxa in the two samples are the same. Conversely, as the coefficient approaches zero, the samples have fewer taxa in common. For samples collected in the area closest to the RMPF (Segment C), the Jaccard coefficient was 0.36, when comparing 2007 to 2008 samples to 1974 samples, and 0.37, when comparing 2007 to 2008 samples to 1983 to 1984 samples. Similar comparisons with seine data resulted in coefficient values of 0.31 (for 1974) and 0.33 (for 1983 to 1984). ENSR (2008b) also compared trawl data throughout all river segments for 1974 and 2007 to 2008 data, which resulted in a Jaccard coefficient of 0.44. These results suggest low to moderate similarity of the species collected in 1974 and 1983 through 1984 compared to 2007 through 2008.
The results of ENSR (2008b) suggest that the current aquatic community is different and may be slightly more diverse than the aquatic community inhabiting the Colorado River during the start of operations for STP, Units 1 and 2. ENSR (2008b) observed changes in diversity near the RMPF as well as further downstream, which would be less likely to be impacted by STP operations. The increase in flow between the Colorado River and Matagorda Bay has likely contributed to the changes in community structure and the increase in species diversity of aquatic species by providing passage for saltwater and estuarine species from the lower Colorado River to Matagorda Bay (NRC 2011b). Based on the information from the latest survey data and what is known about the design of the RMPF, the operation of the RMPF does not appear to have noticeably altered populations of the species currently found in the river.
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Environmental Impacts of Operation Conclusion The NRC staff examined five lines of evidence to determine if impingement and entrainment have the potential to cause adverse impacts to fish and shellfish near STP. The first line of evidence includes impingement and entrainment studies at the RMPF during the initial filling and subsequent intermittent withdraw of water from the Colorado River to the MCR (McAden 1984, 1985). The second line of evidence includes impingement and entrainment studies at the CWIS from 2007 through 2008 during the withdraw of water from the MCR through the circulating water system (ENSR 2008a). The third line of evidence includes engineering designs and operational procedures to limit impingement and entrainment. The fourth line of evidence includes reviews by other regulatory agencies, such as EPA and the TCEQ. The fifth line of evidence includes survey data of fish and shellfish populations prior to and during operations within the Colorado River.
STPNOC conducted limited studies of impingement, entrainment, and aquatic monitoring at the RMPF in the lower Colorado River. However, in considering the best available information for the staffs analysis, the results and conclusions of earlier impingement and entrainment studies and evaluations, such as McAden (1983, 1984) and NRC (1986), are likely still applicable because the most commonly impinged species are still common in the area near the RMPF (ENSR 2008b). Additionally, the design features of the RMPF that minimize losses of organisms would not change during the period of extended operations. In addition, EPA (1985) has concluded that the design of the RMPF reflects best available technology for minimizing adverse environmental impacts. Based on the information from current and historical surveys, impingement and entrainment studies, and the design of the RMPF and the cooling system, operation of the STP cooling system does not appear to have noticeably altered populations of the species currently found in the river. Therefore, the NRC staff concludes that the impact from entrainment and impingement by the STP cooling water system on aquatic resources is SMALL.
4.5.3 Thermal Shock For plants with cooling pond heat-dissipation systems, NRCs GElS (1996) lists the effects of heat shock as an issue requiring plant-specific, Category 2, evaluation before license renewal.
The NRC (1996) made impacts on fish and shellfish resources resulting from heat shock a site-specific issue because of continuing concerns about thermal discharge effects and the possible need to modify thermal discharges in the future in response to changing environmental conditions.
Information considered in this analysis includes STPNOCs TDPES permit, modeling of the thermal plume, the type of cooling system (cooling pond heat-dissipation system in this case),
and other information. To perform this evaluation, the NRC staff (a) reviewed the STPNOCs ER (STPNOC 2010b), STPNOCs TPDES permit (TCEQ 2005), and thermal plume modeling results (NRC 2011b) and (b) performed an audit at the STP site.
As described in Section 2.2.3, STP discharge to the Colorado River is permitted under its TPDES permit (TCEQ 2005). The permit allows the average daily discharge to be 144 million gallons per day (gpd). The TPDES permit also limits the daily average temperature to 95 °F and the daily maximum temperature to 97 °F. TCEQ based these limits on site-specific (or segment-specific) TCEQ water quality rise standards for Segment 1401, Colorado River Tidal, at Title 30, Chapter 307.10, Appendix A, pursuant to the Texas Administrative Code. The TPDES permit also prohibits discharges that would exceed 12.5 percent of the flow of the Colorado River at the discharge point or when the flow in the Colorado River adjacent to STP is less than 800 cfs. An EPA online database indicated that STP has had no CWA formal 4-24
Environmental Impacts of Operation enforcement actions or violations related to discharge temperature in the last 5 years (STPNOC 2011c). Neither EPA nor TCEQ has required STPNOC to seek a 316(a) variance or conduct studies in support of a 316(a) variance (STPNOC 2010b).
STPNOC operating procedures limit the blowdown flow rates and the number of discharge ports to be used during discharge events (STPNOC 2010b). For example, operators may open two to seven blowdown valves, depending on the blowdown rate (STPNOC 2010b). STPNOC procedures prescribe a range of allowable blowdown rates, from 80 to 308 cfs, depending on the Colorado River flow (STPNOC 2010b).
NRC (2011b) modeled the potential thermal plume from discharges to the Colorado River based on the continued operations of STP, Units 1 and 2, as well as the operation of proposed Units 3 and 4. While this SEIS solely pertains to continued operation of STP, Units 1 and 2, the results of NRCs (2011b) modeling study are presented for the following reasons:
- During operations of Units 3 and 4, discharge from all four units would mix in the MCR, and STPNOC would operate a single outfall to discharge water from the MCR (STPNOC 2010c).
- The same TPDES permit would cover Units 1 through 4 (STPNOC 2010c).
- Modeling the thermal plume based on four-unit operation bounds the potential impacts from continued operations of STP, Units 1 and 2.
NRC (2011b) determined that the maximum thermal plume dimensions would occur during the greatest difference in temperatures between the MCR water and the water in the river (20.4 °F),
highest MCR discharge rate through seven ports (44 cfs per port, for a total of 308 cfs discharge rate), and the minimal flow in the Colorado River where the discharge would be equal to 12.5 percent of the total flow in the river (2,464 cfs). NRC (2011b) modeled these conditions using a CORMIX (U.S. EPA computer code) mixing-zone model to determine the likely water temperature increases, the likely duration and frequency of discharge, and the dimensions of the thermal plume. The model indicated that a portion of the Colorado River would remain at ambient water temperature, allowing mobile aquatic organisms to avoid the thermal plume by passing the plume on the bottom of the river and throughout much of the water column. For example, during the maximum expected thermal plume dimensions, the thermal plume that is 5 °F (2.8 °C) above ambient conditions reaches the bottom of the river from the last port of the discharge pipe to 120 ft (37 m) downstream, and the plume extends approximately 25 percent across the width of the river. In that part of the river, the benthic invertebrate species (e.g., grass (Palaemonetes pugio), white, and brown shrimp) would be able to move along the bottom of the river on the far side of the discharge structure without passing through the elevated temperature plume. Approximately 120 ft (37 m) downstream of the last port of the discharge pipe, the positive buoyancy of the warmer water causes the plume to rise to the surface of the river. NRC (2011b) predicted the surface of the river to have an elevated temperature across the entire width of the river from approximately 1,060 ft (323 m) from the last port of the discharge pipe to about 4,400 ft (1,341 m) downstream from the ports. As the plume rises to the surface and extends from bank to bank, however, a portion of the water column would remain at ambient river temperatures and would allow mobile organismssuch as foraging fish (e.g., Gulf menhaden, black drum (Pogonias cromis), spotted seatrout (Cynoscion nebulosus), striped mullet)to move up and downstream.
Less mobile organisms would not be able to swim away to avoid the thermal plume, such as eggs, larvae, and mollusks. The most common juvenile and adult species collected in Segment B, where the plume could reach across the river at the surface, include Gulf 4-25
Environmental Impacts of Operation menhaden, grass shrimp, black drum, white shrimp, and striped mullet (ENSR 2008b). The overall impact to these species from the effects of the thermal plume would be unlikely to noticeably alter these populations because these organisms have a high fecundity, and the number of organisms lost would be insignificant compared to their population in the lower Colorado River.
NRCs (2011b) simulation models the discharge plume based on four-unit operations, which would likely be larger and occur more often than the discharge from continued operations of STP, Units 1 and 2. For example, STPNOC has discharged to the Colorado River once during the operation of STP, Units 1 and 2, in 1997, as part of a system test (STPNOC 2010b). For four-unit operations, STPNOC estimated that water from the MCR would be discharged to the Colorado River as frequently as once every 11 days and could be continuous for as much as 75 days (NRC 2011b). NRC (2011b) determined that STPNOCs discharge operating policy would rarely result in discharges from the MCR that would create a thermal plume during times when river water quality is poor.
The STP cooling system also limits thermal impacts to the MCR and the Colorado River. STP uses a cooling pond-based heat-dissipation system that withdraws and discharges cooling water to the MCR. The MCR is similar to a closed-cycle cooling system since the water in the reservoir continues to circulate from the MCR, into the plant, and back again. STP discharges to the Colorado River to maintain water chemistry and quality within the MCR. Because the water within the MCR is reused, discharges are generally less frequent than other types of cooling systems, such as once-through cooling systems.
After reviewing the status of STPNOCs TPDES permit, modeling of the thermal plume, and the type of cooling system at STP, the NRC staff concludes that the level of thermal impacts to the aquatic community due to renewing the STP operating license is SMALL. The thermal plume is unlikely to noticeably impact aquatic resources near STP for the following reasons:
- STPNOCs TPDES permits limit the amount and timing of discharges.
- Modeling studies indicate that mobile aquatic species could avoid the thermal plume by swimming at a lower depth or different side of the river.
- Species or life-stages that are less mobile organisms would not be able to swim away to avoid the thermal plume, such as eggs, larvae, and mollusks.
However, most species observed in this area generally have high fecundity, and the number of organisms lost would be insignificant compared to their population in the lower Colorado River.
- Cooling water is not regularly discharged into the Colorado River since STP uses a cooling pond-based heat-dissipation system that reuses water from the MCR.
4.5.4 Mitigation The design of the RMPF and operating procedures mitigate potential impingement, entrainment, and thermal shock to aquatic organisms in the lower Colorado River as follows:
- Flow ReductionSTPNOC reduces the flow rate, or amount of water withdrawn from the Colorado River, by reusing water in the MCR.
- Reduced Intake VelocityAt an approach velocity of 0.5 ft/s or less, most fish can swim away and escape from the intake current (66 FR 65274). The 4-26
Environmental Impacts of Operation maximum design approach velocity in front of the traveling screens at the RMPF is approximately 0.5 ft/s, based on a maximum pumping rate of approximately 538,000 gpm (STPNOC 2008, 2010c).
- Technologies to Exclude Organisms and to Collect and Return Organisms to the Water BodyThe RMPF has coarse trash racks, traveling screens, and a fish bypass system (STPNOC 2010c).
- Intake LocationThe RMPF is situated in a portion of the lower Colorado River that has lower density of many fish and invertebrates and overall lower species richness than further downstream, closer to the GIWW (ENSR 2008b).
- Time of WithdrawsOperational procedures for the RMPF also minimize impingement and entrainment because STPNOC intermittently draws water from the Colorado River for Units 1 and 2, and pumping occurs during periods of lower biological productivity (e.g., periods of high river flow and lower salinity).
Additional details regarding these mitigation measures are described above, in Section 4.5.1.
4.6 Terrestrial Resources The issues related to terrestrial resources applicable to STP are listed in Table 4-12. The NRC staff did not identify any new and significant information during the review of STPNOCs ER, the staffs site audit, the scoping process, or the evaluation of other available information (e.g.,
applicable permits and data reports as listed in the reference section of this SEIS chapter).
Therefore, there is no impact related to these issues beyond those discussed in the GEIS. For these issues and consistent with the GEIS, the NRC staff concludes that the impacts to terrestrial resources are SMALL.
Table 4-12. Terrestrial Resources Issues Identified in the GEIS Issue GEIS Section Category Cooling tower impacts on crops & ornamental vegetation 4.3.4 1 Cooling town impacts on native plants 4.3.5.1 1 Bird collisions with cooling towers 4.3.5.2 1 Powerline ROW management (cutting herbicide application) 4.5.6.1 1 Bird collisions with powerlines 4.5.6.1 1 Impacts of electromagnetic fields on flora & fauna (plants, agricultural 4.5.6.3 1 crops, honeybees, wildlife, livestock)
Floodplains & wetland on powerline ROW 4.5.7 1 Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 4-27
Environmental Impacts of Operation 4.7 Protected Species and Habitats Section 2.2.7 of this SEIS describes protected species and habitats in the vicinity of the STP site. Table 4-13 lists the one Category 2 issue related to protected species and habitats that is applicable to STP.
Table 4-13. Protected Species Issues Identified in the GEIS Issue GEIS Section Category Threatened or endangered species 4.1 2 Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 This site-specific, or Category 2 issue, requires consultation with the appropriate agencies to determine whether threatened or endangered species are present and whether they would be adversely affected by continued operation of STP during the license renewal term. In the case of STP, the U.S. Fish and Wildlife Service (FWS) is responsible for terrestrial and freshwater species listed under the Endangered Species Act (ESA), the Bald and Golden Eagles Act, and the Migratory Bird Treaty Act (MBTA). The National Marine Fisheries Service (NMFS) is responsible for marine and anadromous species listed under the ESA and the Magnuson-Stevens Fishery Conservation and Management Act (MSA) and those species that have been designated as NMFS Species of Concern. The Texas Parks and Wildlife Division is responsible for species protected by the State of Texas Statutes. Descriptions of protected species and habitats appear in Section 2.2.8. In its assessment, the NRC defined the action area in Section 2.2.8.
4.7.1 Species and Habitats Protected Under the Endangered Species Act Chronology of Endangered Species Act Section 7 Consultation The NRC staff corresponded with both the FWS and NMFS to determine impacts to Federally listed species and to decide whether to initiate Section 7 consultation as a result of the proposed STP license renewal. The NRC developed a list of Federally listed species within the vicinity of STP and requested concurrence on this list in a February 16, 2011, letter (NRC 2011f). The FWS responded to this request on June 2, 2011, with an updated list and recommendations concerning specific species (FWS 2011b). Specific species for which FWS had concerns are discussed in Section 2.2.8.1.
The NRC sent a similar letter to the NMFS on February 16, 2011 (NRC 2011h). The NMFS responded to this letter in an e-mail dated March 3, 2011 (NMFS 2011c) and provided the NRC with a list of Federally listed species under its jurisdiction in Texas. Following the issuance of the draft SEIS, the NRC sent letters to the FWS and NMFS on December 10, 2012 (NRC 2012c, 2012d), requesting concurrence with the staffs effect determinations for Federally listed species in accordance with 50 CFR 402(j).
For species under NMFSs jurisdiction, the NRC staff concluded that there would be no effect on these species (see below). Per an e-mail dated January 29, 2013 (NMFS 2013), NMFS does not typically concur or not concur with no effect determinations by the staff. Thus, for species under NMFSs jurisdiction, no further consultation is required, and the NRC has fulfilled its obligations under Section 7 of the ESA for species under NMFSs jurisdiction.
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Environmental Impacts of Operation For species under FWSs jurisdiction, the FWS Clear Lake Ecological Services Office contacted the NRC, by phone on January 31, 2013, to discuss NRCs letter and to request additional maps of the transmission lines from the NRC. The NRC provided the requested information via e-mail later that day (NRC 2013a). On February 5, 2013, the FWS Clear Lake Ecological Services Office and the NRC spoke again by phone, and the FWS Clear Lake Ecological Services Offices noted that it was preparing additional information requests that it would send the NRC.
These requests were sent in an e-mail dated March 14, 2013 (FWS 2013d). The NRC has updated its protected species analysis in this SEIS as a result of the information provided in FWSs March 14, 2013, e-mail. Informal Section 7 consultation with the FWS continues at this time.
Species and Habitats Under NMFS Jurisdiction Section 2.2.8 discusses species and habitats protected under the ESA and within NMFSs jurisdiction that occur in Matagorda County and have the potential to occur in the action area (as defined in Section 2.2.8). The NRC staff identified seven listed species. However, the staff determined that none of these species occur within the action area. Therefore, the NRC concludes that the proposed STP license renewal would have no effect on these species (see Table 4-14).
The NRC staff did not identify any candidate or proposed species or proposed or designated critical habitat under NMFSs jurisdiction within the action area. Thus, the proposed STP license renewal would have no effect on any candidate or proposed species or proposed or designated critical habitat under NMFSs jurisdiction.
Table 4-14. ESA Effect Determinations for Federally Listed Species Under NMFS Jurisdiction ESA Effect Species Justification for Determination Determination Fish smalltooth sawfish no effect The species does not occur in the action area.
(Pristis pectinata)
Mammals West Indian manatee no effect The species does not occur in the action area.
(Trichechus manatus)
Reptiles loggerhead sea turtle no effect The species does not occur in the action area.
(Caretta caretta) green sea turtle no effect The species does not occur in the action area.
(Chelonia mydas) leatherback sea turtle no effect The species does not occur in the action area.
(Dermochelys coriacea) hawksbill sea turtle no effect The species does not occur in the action area.
(Eretmochelys imbricata)
Kemps ridley sea turtle no effect The species does not occur in the action area.
(Lepidochelys kempii) 4-29
Environmental Impacts of Operation Species and Habitats Under FWS Jurisdiction Section 2.2.8 discusses species and habitats protected under the ESA and within FWSs jurisdiction that occur in Matagorda County and have the potential to occur in the action area.
The NRC staff identified 11 listed species, of which the staff determined that 8 do not occur in the action area and, thus, would not be affected by the proposed STP license renewal. The remaining three species are discussed below in more detail. Table 4-14a summarizes the NRC staffs effect determinations for listed and candidate species.
Table 4-14a. ESA Effect Determinations for Federally Listed and Candidate Species Under NMFSs Jurisdiction ESA Effect Justification for Determination Species Determination Birds The species may occur in the action may affect, but is area. However, the proposed action Spragues pipit not likely to would not affect habitat use, prey (Anthus spragueii) adversely affect availability, or breeding or nesting behavior.
piping plover The species does not occur in the action no effect (Charadrius melodus) area.
The species may occur in the action northern aplomado falcon may affect, but is area. However, the proposed action (Falco femoralis not likely to would not affect habitat use, prey septentrionalis) adversely affect availability, or breeding or nesting behavior.
whooping crane The species does not occur in the action no effect (Grus americana) area.
eskimo curlew The species does not occur in the action no effect (Numenius borealis) area.
Mammals red wolf The species does not occur in the action no effect (Canis rufus) area.
ocelot The species does not occur in the action no effect (Leopardus pardalis) area.
Louisiana black bear The species does not occur in the action no effect (Ursus americanus luteolus) area.
Mollusks smooth pimpleback The species does not occur in the action no effect (Quadrula houstonensis) area.
Texas fawnsfoot The species does not occur in the action no effect (Truncilla macrodon) area.
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Environmental Impacts of Operation ESA Effect Justification for Determination Species Determination Reptiles The species is known to occur in the action area. It is listed as threatened American alligator not applicable only because its appearance is similar to (Alligator mississipiensis) another species; therefore, it is not subject to Section 7 consultation.
The STP site is in close proximity to four units of designated piping plover (Charadrius melodus) critical habitat, the closest of which lies 7 mi (11 km) south of the STP site boundary along the shoreline of West Matagorda Bay. Because continued operation and maintenance of the STP site would involve no onsite or offsite disturbances, the proposed license renewal would result in no direct or indirect effects to piping plover critical habitat. Thus, the NRC staff concludes that the proposed license renewal would have no effect on designated piping plover critical habitat.
The NRC staff did not identify any proposed critical habitat during its review.
The NRC staff did not identify any Federally proposed species or proposed critical habitat within the action area during its review. Additionally, in its correspondence with NRC, the FWS did not identify any proposed species or proposed critical habitat. Thus, the NRC staff concludes that the proposed license renewal would have no effect on Federally proposed species or proposed critical habitat.
Spragues Pipit (Anthus spragueii). The Spragues pipit may occur in areas of suitable habitat, such as mixed grasslands and pastureland, within the action area. If Spragues pipit occupies any habitat within the action area, the NRC staff assumes that the species would continue to occupy the area as during the current operating license term. Continued operation and maintenance of the STP site during the proposed license renewal term will not involve any construction, ground-disturbing activities, or changes to existing land use conditions in either natural or developed areas. Thus, continued operation of STP would not affect habitat or prey availability. Noise levels and human activity would remain similar to current operations and would not cause any additional disturbances that would cause pipits to avoid or abandon habitat within the action area. The Spragues pipit winters in Texas, so the proposed license renewal would not affect breeding or young-rearing. The NRC staff did not identify any direct or indirect adverse effects to the Spragues pipit that would result from continued operation during the proposed license renewal term. Furthermore, the continued operation of STP during the proposed license renewal term would preserve the existing habitats on the STP site. Therefore, this could result in beneficial effects to the species.
Though the Spragues pipit may occur in the action area, the NRC staff has not identified any records or studies to date that confirm that the Spragues pipit inhabits the action area, and it has not found any information that indicates that adverse effects to the species would occur as a result of the proposed license renewal term. However, if the species was observed on the STP site, the NRC has measures in place to ensure that it would be notified so that the NRC staff could determine the appropriate course of action, such as possibly reinitiating Section 7 consultation under the ESA with the FWS at that time. STPs operating license, Appendix B, Environmental Protection Plan, Section 4.1 (NRC 1988, 1989) requires STPNOC to report to the NRC within 24 hours1 days <br />0.143 weeks <br />0.0329 months <br /> any occurrence of a species protected by the ESA on the STP site.
Additionally, the NRCs regulations containing notification requirements require that operating nuclear power reactors report to the NRC within 4 hours0.167 days <br />0.0238 weeks <br />0.00548 months <br /> any event or situation, related 4-31
Environmental Impacts of Operation toprotection of the environment, for which a news release is planned or notification to other government agencies has been or will be made (10 CFR 50.72(b)(2)(xi)). Such notifications include reports regarding Federally listed species, as described in Section 3.2.12 of NUREG-1022, Event Reporting Guidelines for 10 CFR 50.72 and 50.73 (NRC 2013b).
The NRC staff concludes that the proposed license renewal may affect, but is not likely to adversely affect, the Spragues pipit.
Northern Aplomado Falcon (Falco femoralis septentrionalis). The northern aplomado falcon may occur in areas of suitable habitat, such as scrub shrub, mixed grasslands, and pastureland, within the action area. If northern aplomado falcons occupy any habitat within the action area, the NRC staff assumes that the species would continue to occupy the area as during the current operating license term. Continued operation and maintenance of the STP site during the proposed license renewal term will not involve any construction, ground-disturbing activities or changes to existing land use conditions in either natural or developed areas. Thus, continued operation of STP would not affect habitat or prey availability. Noise levels and human activity would remain similar to current operations and would not cause any additional disturbances that would cause individuals to avoid or abandon habitat within the action area. In its Federal Register notice documenting the establishment of an experimental population of northern aplomado falcons in New Mexico and Arizona, the FWS noted that the species appears to be relatively tolerant of human presence (71 FR 42298). Nesting pairs have been observed to tolerate approach within 100 m (328 ft) of their nests by researchers, have nested within 100 m (328 ft) of highways in eastern Mexico, and are frequently found nesting in association with managed livestock pastureland in Mexico and Texas (71 FR 42298).
The NRC staff did not identify any direct or indirect adverse effects to the northern aplomado falcon that would result from continued operation during the proposed license renewal term.
Furthermore, the continued operation of STP during the proposed license renewal term would preserve the existing habitats on the STP site. Therefore, this could result in beneficial effects to the species.
Though the northern aplomado falcon may occur in the action area, the NRC staff has not identified any records or studies to date that confirm that the species inhabits the action area, and it has not found any information that indicates that adverse effects to the species would occur as a result of the proposed license renewal term.
The NRC staff concludes that the proposed license renewal may affect, but is not likely to adversely affect, the northern aplomado falcon.
American Alligator (Alligator mississipiensis). American alligators inhabit Kelly Lake, Little Robins Slough, site wetlands, and the various dikes associated with the MCR. Continued operation and maintenance of the STP site during the proposed license renewal term will not involve any construction, ground-disturbing activities, or changes to existing land use conditions in either natural or developed areas. Water use and quality would also not change significantly during the proposed license renewal term. Therefore, the proposed license renewal would not affect habitat or prey availability or create any changes that would alter the behavior of alligators on the site. However, the American alligator is threatened due to similarity of appearance with the American crocodile (Crocodylus acutus), which does not occur in the action area. The American alligator is not biologically endangered or threatened and is not subject to Section 7 consultation (FWS 2012), so an ESA affect determination does not apply to this species.
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Environmental Impacts of Operation 4.7.2 Species Designated as NMFS Species of Concern Though some of the species of concern listed in Section 2.2.8.2 occur in Matagorda Bay, none of the species of concern in the vicinity of STP occur in the Colorado River and would, therefore, not be impinged or entrained by STP cooling water intake or otherwise affected by the proposed license renewal. The NRC staff concludes that there is no adverse impact to any NMFS species of concern.
4.7.3 Species Protected Under the Bald and Golden Eagles Protection Act Though bald eagles occur throughout the STP region, no known nests are in close proximity to any of the STP buildings, parking lots, or other structures that could be disturbed by ongoing human activity. Because the proposed license renewal does not involve construction or land disturbances, no bald eagle habitat would be affected by the proposed license renewal. The NRC staff concludes that there is no adverse impact to the bald eagle.
4.7.4 Species Protected Under the Migratory Bird Treaty Act As discussed in Section 2.2.8.4, a variety of migratory birds inhabit the STP site and surrounding region. Because the proposed license renewal does not involve construction or land disturbances, no migratory birds would be affected by the proposed license renewal. The NRC staff concludes that there is no adverse impact to migratory birds.
4.7.5 Species Protected Under the Marine Mammal Protection Act Section 2.2.8.5 discusses marine mammals in the vicinity of STP. None of these species occur in the Colorado River and would, therefore, not be impinged or entrained by STP cooling water intake or otherwise affected by the proposed license renewal. The NRC staff concludes that there is no adverse impact to any marine mammals.
4.7.6 Species Protected Under the Magnuson-Stevens Act Section 2.2.8.6 identifies species with EFH with the potential to occur in the vicinity of STP. Of these species, ENSR (2008) collected the mangrove snapper and brown shrimp, white shrimp have been collected during ecological studies associated with STP, and white and brown shrimp have been collected during impingement or entrainment samples.
The NRC prepared an EFH assessment (NRC 2011c) as part of the review of the Units 3 and 4 COL application review. The NRC staff included the Colorado River, Matagorda Bay, and the Gulf of Mexico in the scope of its analysis because construction activities for the proposed Units 3 and 4 would include barge traffic. In that EFH assessment, the NRC concluded that the proposed Units 3 and 4 would have minimal adverse effects on EFH. The NMFS concurred with this determination in April 2010 (NMFS 2010). Because the area that would be affected by the proposed license renewal is smaller than the affected area for the proposed STP, Units 3 and 4, and would not require any construction or changes to current operation, the NRC staff concludes that the NRCs EFH assessment for the proposed STP, Units 3 and 4 (NRC 2011c),
bounds the analysis for the proposed license renewal of STP, and that there are no adverse impacts to any EFH species.
Following the issuance of the draft SEIS, the NRC forwarded a copy of the draft SEIS to NMFS and requested EFH consultation per 50 CFR 600.920 in a letter dated December 11, 2012 (NRC 2012b). The NRC followed up with this request via e-mail on February 25, 2013 4-33
Environmental Impacts of Operation (NRC 2013c). By e-mail dated March 1, 2013, NMFS stated that it concurs with NRCs conclusion that the continued operation of STP would not adversely affect EFH. NMFS also confirmed that no further EFH consultation is required for the proposed STP license renewal (NMFS 2013b).
4.7.7 Species Protected Under State of Texas Statutes Section 2.2.8.7 discusses species protected under Texass State Statutes. Some State-listed species may occur along the transmission line corridors. However, the minimal transmission line maintenance associated with the STP transmission lines is unlikely to affect any State-listed species. Because the transmission line corridors are well-established, continued maintenance will also not reduce or affect the amount or quality of available habitat. The NRC staff concludes that there are no adverse impacts to any State-listed species.
4.7.8 Conclusion The conclusions for species and habitat protected by each Act are stated above in terms appropriate to those Acts.
4.8 Human Health The human health issues applicable to STP are discussed below and listed in Table 4-15 for Category 1, Category 2, and uncategorized issues.
Table 4-15. Human Health Issues.
Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 contains more information on these issues.
Issue GEIS Section Category (a)
Radiation exposures to the public during refurbishment 3.8.1 1 Occupational radiation exposures during refurbishment 3.8.2(a) 1 Microbiological organisms (occupational health) 4.3.6 1 Microbiological organisms (public health, for plants using lakes or canals or cooling towers or cooling ponds that discharge to a small 4.3.6 2 river)
Noise 4.3.7 1 Radiation exposures to public (license renewal term) 4.6.2 1 Occupation radiation exposures (license renewal term) 4.6.3 1 Electromagnetic fieldsacute effects (electric shock) 4.5.4.1 2 Electromagnetic fieldschronic effects 4.5.4.2 Uncategorized 4-34
Environmental Impacts of Operation Issue GEIS Section Category (a)
Issues apply to refurbishment, an activity that STP does not plan to undertake.
Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 4.8.1 Generic Human Health Issues Category 1 issues applicable to STP in regard to human health impacts are listed in Table 4-15.
STPNOC stated in its ER that it was not aware of any new and significant human health issues associated with the renewal of the STP operating license. The staff has not identified any new and significant information related to human health issues associated with the operation of STP, Units 1 and 2, during the period of license renewal as a result of its independent review of STPNOCs ER, the site audit, and the scoping process. The NRC staff also reviewed other sources of information, such as data reports, as listed in the reference section of this SEIS chapter. Therefore, the NRC staff concludes that, for Category 1 human health issues, there would be no impact from nonradiological issues to the public or to workers during the renewal term beyond those discussed in the GEIS.
4.8.2 Radiological Impacts of Normal Operations Category 1 issues applicable to STP in regard to radiological impacts are listed in Table 4-15.
Regarding the potential for new and significant radiological information, STPNOC evaluated the issue of tritium contained in groundwater on the plant site and concluded that the tritium in groundwater would not preclude the waters current or future use; therefore, the issue is not new and significant. The staff discusses groundwater monitoring for radioactivity in Sections 2.2.5.2 and 4.4.3 and later in this section. In its radiological evaluation, the NRC staff determined that the issue is not new and significant.
The staff has not identified any new and significant information related to human health issues associated with radiation exposures during its independent review of STPNOCs ER, the site audit, and the scoping process. Therefore, the NRC staff concludes that there would be no impact from radiation exposures to the public or to workers during the renewal term beyond those discussed in the GEIS.
The findings in the GEIS are as follows:
- Radiation exposures to public (license renewal term)Based on information in the GEIS, the NRC found that radiation doses to the public will continue at current levels associated with normal operations.
- Occupational exposures (license renewal term)Based on information in the GEIS, the NRC found that projected maximum occupational doses during the license renewal term are within the range of doses experienced during normal operations and normal maintenance outages and would be well below regulatory limits.
According to the GEIS, the impacts to human health are SMALL, and additional plant-specific mitigation measures are unlikely to be sufficiently beneficial to warrant implementation. There are no Category 2 issues related to radiological impacts of routine operations.
The information presented below is a discussion of selected radiological programs conducted at STP.
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Environmental Impacts of Operation South Texas Project Radiological Environmental Monitoring Program. STP conducts a Radiological Environmental Monitoring Program (REMP) to assess the radiological impact, if any, to its employees, the public, and the environment from the operations at STP, Units 1 and 2. The REMP measures the aquatic, terrestrial, and atmospheric environment for radioactivity, as well as the ambient radiation. In addition, the REMP measures background radiation (i.e., cosmic sources, global fallout, and naturally occurring radioactive material, including radon). The REMP supplements the radioactive effluent monitoring program by verifying that any measurable concentrations of radioactive materials and levels of radiation in the environment are not higher than those calculated using the radioactive effluent release measurements and transport models.
An annual radiological environmental operating report is issued, which contains a discussion of the results of the monitoring program. The report contains data on the monitoring performed for the most recent year. The REMP collects samples of environmental media to measure the radioactivity levels that may be present. The media samples are representative of the radiation exposure pathways that may impact the public.
The STP REMP is made up of four categories based on the exposure pathways to the public airborne, waterborne, ingestion, and direct radiation. The air is sampled in areas around STP by measuring the levels of radioactive iodine and particulate matter on filters. For the waterborne pathway, the water samples are taken from surface water, groundwater, and drinking water. Also included in this pathway are sediment samples taken from the MCR and the Colorado River. The ingestion pathway samples local broadleaf vegetation, agricultural products, and food products. The direct exposure pathway measures environmental radiation doses using thermoluminescent dosimeters.
In addition to the REMP, STP has an onsite Groundwater Protection Program designed to monitor the onsite plant environment for detection of leaks from plant systems and pipes containing radioactive liquid (STPNOC 2010b). Additional information on the Groundwater Protection Program is contained later in this section and in the Groundwater Quality section in Chapter 2 (Section 2.2.5.2) of this document.
The staff reviewed the STP annual radiological environmental operating reports for 2006 through 2010 to look for any significant impacts to the environment or any unusual trends in the data (STPNOC 2007a, 2008d, 2009a, 2010a, 2011a). A 5-year period provides a data set that covers a broad range of activities that occur at a nuclear power plant such as refueling outages, non-refueling outage years, routine operation, and years where there may be significant maintenance activities. In addition, data from the applicants current 2012 REMP report was reviewed and added to this final SEIS (STPNOC 2013a, 2013b). Based on the staffs review, no adverse trends (i.e., steadily increasing buildup of radioactivity levels) were observed, and the data showed that there was no measurable impact to the environment from operations at STP.
Tritium Groundwater Monitoring. Nuclear industry events involving tritium prompted STP to sample groundwater in the shallow aquifer near the nuclear plants in 2005.
In 2007, the NEI established a standard for monitoring and reporting radioactive isotopes in groundwater. This standard is contained in NEI 07-07, Industry Ground Water Protection InitiativeFinal Guidance Document (NEI 2007). STPNOC implemented the recommendations of this industry standard and has broadened the Groundwater Monitoring Program to include samples collected near the nuclear plants. Results of STPNOCs Groundwater Monitoring Program are contained in the annual REMP report submitted to the NRC in May of each year.
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Environmental Impacts of Operation These reports are available for review by the public through the Agencywide Documents Access and Management System (ADAMS) electronic reading room available through the NRC Web site.
In the 2010 REMP report, STPNOC reported that tritium was detected on site. The applicants evaluation shows that the positive results are likely due to the wells location in an area that is influenced by the MCR. Other positive samples appear to be the result of discharges to the ground involving water previously considered non-radioactive since only trace quantities of tritium were measured. All groundwater sample containing tritium were below the EPAs DWS of 20,000 pCi/l (740 Becquerels per liter). Also, the data showed no impact to sources of drinking water. The water samples from the onsite drinking water source (a deep aquifer) and offsite sampling of the Colorado River showed only natural background radiation levels (STPNOC 2011a). The 2012 REMP report showed that tritium levels were generally stable in 2012 and remained below the EPAs DWS.
Based on its review of the applicants monitoring reports, including the 2012 data, the staff concludes that there are no significant impacts to human health associated with tritium in the groundwater at the STP site. The applicants Groundwater Protection Program will monitor the groundwater and report the results in its annual radiological environmental monitoring report.
Also, NRC inspectors will periodically review STPNOCs Groundwater Protection Program to ensure the program continues to be effective.
Texas Department of State Health Services Environmental Monitoring Program. The Texas Department of State Health Services (DSHS) performs its own independent environmental monitoring around the STP site and other nuclear facilities (i.e., research reactors, commercial users of radioactive material, and the U.S. Department of Energys (DOEs) Pantex facility) located in Texas. All analyses of environmental media (i.e., soil, air, water, and vegetation) are performed by its Laboratory Services Section. The States radiation branch performs the monitoring of direct radiation from a facility using TLDs.
The staff reviewed the States environmental summary reports for 2005 through 2009 (the most recent report available at the time of the staffs review) (TDSHS 2012). In each of the reports, the State concluded that the sample data indicated no release of radioactive material to the environment that exceeded the regulatory or license limits of the DSHS or any other agency such as the NRC or the DOE. For this final SEIS, the staff searched for a more current report than the 2009 report reviewed in the draft SEIS and did not find a more current report.
South Texas Project Radioactive Effluent Release Program. All nuclear plants were licensed with the expectation that they would release radioactive material to both the air and water during normal operation. However, NRC regulations require that radioactive gaseous and liquid releases from nuclear power plants must meet radiation dose-based limits specified in 10 CFR Part 20 and the as low as is reasonably achievable (ALARA) criteria in Appendix I to 10 CFR Part 50. Regulatory limits are placed on the radiation dose that members of the public can receive from radioactive effluents released by a nuclear power plant. In addition, nuclear power plants are required by 10 CFR 50.36(a) to submit an annual report to the NRC, which lists the types and quantities of radioactive effluents released into the environment. The radioactive effluent release reports are available for review by the public through the ADAMS electronic reading room available through the NRC Web site.
The NRC staff reviewed the annual radioactive effluent release reports for 2006 through 2010 (STPNOC 2007b, 2008e, 2009b, 2010d, 2011d). In addition, data from the applicants current 2012 radioactive effluent release report were reviewed and included in this final SEIS (STPNOC 2013a, 2013b). The NRC staffs review focused on the calculated doses to a 4-37
Environmental Impacts of Operation member of the public from radioactive effluents released from STP. The doses were compared to the radiation protection standards in 10 CFR 20.1301 and the ALARA dose design objectives in Appendix I to 10 CFR Part 50.
Dose estimates for members of the public are calculated based on radioactive gaseous and liquid effluent release data and atmospheric and aquatic transport models. The 2012 annual radioactive material release report (STPNOC 2013a, 2013b) contains a detailed presentation of the radioactive discharges and the resultant calculated doses. The following summarizes the calculated dose to a member of the public located outside the STP site boundary from radioactive gaseous and liquid effluents released during 2012:
- The total-body dose to an offsite member of the public from STP Unit 1 radioactive liquid effluents was 9.25x10-3 mrem (9.25x10-5 mSv) and 4.48x10-4 mrem (4.48x10-6 mSv) for Unit 2, which is well below the 3 mrem (0.03 mSv) dose criterion in Appendix I to 10 CFR Part 50.
- The organ (liver) dose to an offsite member of the public from STP Unit 1 radioactive liquid effluents was 9.28x10-3 mrem (9.28x10-5 mSv) and 4.52x10-4 mrem (4.52x10-6 mSv), which is well below the 10 mrem (0.10 mSv) dose criterion in Appendix I to 10 CFR Part 50.
- The air dose at the site boundary from gamma radiation in gaseous effluents from STP Unit 1 was 1.89x10-3 mrad (1.89x10-5 mGy) and 4.93x10-4 mrad (4.93x10-6 mGy) for Unit 2, which is well below the 10 mrad (0.1 mGy) dose criterion in Appendix I to 10 CFR Part 50.
- The air dose at the site boundary from beta radiation in gaseous effluents from Unit 1 was 6.99x10-4 mrad (6.99x10-6 mGy) and 2.28x10-4 mrad (2.28x10-6 mGy) for Unit 2, which is well below the 20 mrad (0.2 mGy) dose criterion in Appendix I to 10 CFR Part 50.
- The dose to an organ (bone) from radioactive iodine, radioactive particulates, and carbon-14 from Unit 1 was 3.29x10-1 mrem (3.29x10-3 mSv) and 3.28x10-1 mrem (3.28x10-3 mSv) for Unit 2, which is well below the 15 mrem (0.15 mSv) dose criterion in Appendix I to 10 CFR Part 50.
The highest dose from direct radiation to an offsite member of the public was 7.0x10-3mrem (7.0x10-5 mSv). This dose is based on a conservative assumption that an individual is located at the STP site fence east of the two reactor units for the entire year.
- The total-body dose from radioactive gaseous and liquid effluents combined with the dose from direct radiation from STP, Units 1 and 2, equals the maximum dose from all pathways to an offsite member of the public. The total annual dose is 2.3x10-2 mrem (2.3x10-4 mSv), which is well below the 25 mrem (0.25 mSv) dose standard in EPAs 40 CFR Part 190.
The staffs review of the STP Radioactive Effluent Control Program showed that radiation doses to members of the public were controlled within Federal radiation protection standards contained in Appendix I to 10 CFR Part 50, 10 CFR Part 20, and 40 CFR Part 190.
The applicant has no plans to conduct refurbishment activities during the license renewal term; however, routine plant refueling and maintenance activities currently performed will continue during the license renewal term. Based on the past performance of the radioactive waste system to maintain the dose from radioactive effluents to be ALARA, similar performance is 4-38
Environmental Impacts of Operation expected during the license renewal term. Continued compliance with regulatory requirements is expected during the license renewal term; therefore, the impacts from radioactive effluents would be SMALL.
4.8.3 Microbiological Organisms For power plants that use a cooling pond, lake, or canal or that discharge to a small river, the effects of microbiological organisms on human health are listed as a Category 2 issue and require plant-specific evaluation for license renewal review. This issue is applicable to STP because the facility uses a cooling pond, as defined in the GElS (NRC 1996). The cooling pond (MCR) discharges to Colorado River that has the mean annual average flow of approximately 2,629 cfs (NRC 2011b). This meets the definition of a small river. The MCR is within the confine of the STP security perimeter and is not available for public use.
The Category 2 designation is based on the potential for public health impacts associated with thermal enhancement of Naegleria fowleri, a pathogenic amoeba, and other enteric pathogens that could not be assessed generically. The NRC noted that impacts of nuclear plant thermal discharges are considered to be of small significance if they do not enhance the presence of microorganisms that are detrimental to water quality and public health (NRC 1996).
Microbiological organisms that grow at temperatures above 45 °C to 50 °C (113 °F to 122 °F) are termed thermophilic, or heat-loving, organisms (Brock 1974). STP has TPDES permit (No. WQ0001908000) to discharge to the Colorado at the daily average temperature limit of 95 °F and daily maximum temperature limit of 97 °F (STPNOC 2010). These limits are below the temperature at which thermophilic microorganisms grow and thrive (113 °F to 122 °F).
Hence, the potential of waterborne disease outbreak due to discharge from the MCR to the Colorado River is remote.
Furthermore, the TPDES permit limits the discharge to less than 12.5 percent of the river flow and may not exceed 200 million gpd. It is likely that the discharge would occur during high river flow periods, which are reported by the STPNOC to be during the winter and spring when the river temperature is at low level.
The staff asked the Texas Department of Health about any concerns the department might have relative to the microorganisms in the MCR that could cause waterborne disease outbreak in the area (NRC 2012a). The department responded that it did not have any records of such outbreak, and it is not aware of any potential concerns about outbreaks associated with the operation of STP during the extended period of operation.
The staff concludes that the potential impacts to public health from microbiological organisms, resulting from operation of the STP cooling water discharge system to the aquatic environment on or near the site, are SMALL, and no further mitigations are warranted.
4.8.4 Electromagnetic FieldsAcute Effects Based on the GEIS, the NRC found that electric shock resulting from direct access to energized conductors or from induced charges in metallic structures has not been found to be a problem at most operating plants and, generally, is not expected to be a problem during the license renewal term. However, site-specific review is required to determine the significance of the electric shock potential along the portions of the transmission lines that are within the scope of this SEIS.
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Environmental Impacts of Operation In the GEIS (NRC 1996), the NRC found that without a review of the conformance of each nuclear plant transmission line with National Electrical Safety Code (NESC) criteria, it was not possible to determine the significance of the electric shock potential (IEEE 2002). Evaluation of individual plant transmission lines is necessary because the issue of electric shock safety was not addressed in the licensing process for some plants. For other plants, land use in the vicinity of transmission lines may have changed, or power distribution companies may have chosen to upgrade line voltage. To comply with 10 CFR 51.53(c)(3)(ii)(H), the applicant must provide an assessment of the impact of the proposed action on the potential shock hazard from the transmission lines if the transmission lines that were constructed for the specific purpose of connecting the plant to the transmission system do not meet the recommendations of the NESC for preventing electric shock from induced currents. The NRC uses the NESC criteria as its baseline to assess the potential human health impact of the induced current from an applicants transmission lines. As discussed in the GEIS, the issue of electric shock is of small significance for transmission lines that are operated in adherence with the NESC criteria.
STPNOC analyzed its transmission lines to identify the limiting case for each line where the potential exists for the highest current-induced shock. STPNOC calculated the electric field strength and induced current for each of the lines using a computer code called ACDCLINE, produced by the Electric Power Research Institute. The input parameters included the design features of each of the limiting-case transmission lines, and a tractor-trailer was assumed to be the maximum vehicle size under the lines. STPNOC reported in its ER and in two supplemental letters (STPNOC 2011c, 2011f) that there are three transmission lines (i.e., two Hill County lines and one Skyline line) that exceed the NESC 5 milliampere (mA) criterion for preventing electric shock from induced currents. However, STPNOC states that the configuration of these lines has changed since the original plant construction. These lines are no longer directly connected with STP. A substation was constructed at Elm Creek. The original Hill County and Skyline transmission lines are now looped into the Elm Creek substation before proceeding to the Hill County and Skyline substations. The lines pass through land that is primarily agricultural and rangeland, with some forest land and lesser land-use categories. The areas are mostly remote, with low population densities. The lines cross numerous county, State, and U.S. highways.
As reported by STPNOC in its ER, the service providers for the STP transmission lines have surveillance and maintenance procedures that periodically examine the lines to ensure they remain within their design criteria. These procedures include routine aerial inspections that include checks for encroachments, broken conductors, broken or leaning structures, and signs of trees burning, any of which would be evidence of clearance problems. Ground inspections include examination for clearance, integrity of structures, and surveillance for dead or diseased trees that might fall on the transmission lines. Problems noted during any inspection are reported for follow-up corrective action. STPNOC has considered potential mitigation measures to reduce or avoid adverse impacts from electric shock from its transmission lines, with a combination of options, as follows:
- re-examining the induced current calculations for selected transmission lines (for accuracy and possible safety margin identification),
- raising the transmission towers at the potentially affected road-transmission line intersections,
- modifying the double-circuit lines to reduce the current-induced shock potential, or
- placing caution signs under the transmission lines.
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Environmental Impacts of Operation Based on information provided by STPNOC and potential mitigation measures (to reduce or avoid adverse impacts) considered by the applicant, the staff concludes that potential impact from acute electric shock during the renewal period would be SMALL to MODERATE. This conclusion is based on the fact that the three transmission lines exceed the NESC 5 mA criterion by a small percentage, the locations where the lines exceed the standard are in remote locations or are on private property, and the applicant, in accordance with 10 CFR 51.53(c)(3)(iii), has considered potential mitigation measures to reduce or avoid adverse impacts from electric shock.
4.8.5 Electromagnetic FieldsChronic Effects In the GEIS, the effects of chronic exposure to 60 Hz electromagnetic fields from powerlines were not designated as Category 1 or 2 and will remain uncategorized until a scientific consensus is reached on the health implications of these fields.
The potential effects of chronic exposure from these fields continue to be studied and are not known at this time. The National Institute of Environmental Health Sciences (NIEHS) directs related research through the DOE.
The NIEHS report (NIEHS 1999) contains the following conclusion:
The NIEHS concludes that ELF EMF (extremely low frequency electromagnetic field) exposure cannot be recognized as entirely safe because of weak scientific evidence that exposure may pose a leukemia hazard. In our opinion, this finding is insufficient to warrant aggressive regulatory concern. However, because virtually everyone in the United States uses electricity and therefore is routinely exposed to ELF EMF, passive regulatory action is warranted such as continued emphasis on educating both the public and the regulated community on means aimed at reducing exposures. The NIEHS does not believe that other cancers or non cancer health outcomes provide sufficient evidence of a risk to currently warrant concern.
This statement is not sufficient to cause the staff to change its position with respect to the chronic effects of electromagnetic fields. The staff considers the GEIS finding of UNCERTAIN still appropriate and will continue to follow developments on this issue.
4.9 Socioeconomics The socioeconomic issues applicable to STP, Units 1 and 2, are shown in Table 4-16 for Category 1, Category 2, and one uncategorized issue (environmental justice). Section 2.2.8 of this SEIS describes the socioeconomic conditions near STP, Units 1 and 2.
Table 4-16. Socioeconomics during the Renewal Term Issues GEIS Section Category Housing impacts 4.7.1 2 Public services: public safety, social services, & tourism & 4.7.3, 4.7.3.3, 4.7.3.4, 1
recreation 4.7.3.6 Public services: public utilities 4.7.3.5 2 Public services: education (license renewal) 4.7.3.1 1 4-41
Environmental Impacts of Operation Issues GEIS Section Category Offsite land use (license renewal term) 4.7.4 2 Public Services: transportation 4.7.3.2 2 Historic & archaeological resources 4.7.7 2 Aesthetic impacts (license renewal term) 4.7.6 1 Aesthetic impacts of transmission lines (license renewal term) 4.5.8 1 Environmental justice Not addressed(a) Uncategorized (a) Guidance for implementing Executive Order 12898 and conducting an environmental justice impact analysis was not available prior to the completion of the GEIS. This issue must be addressed in plant-specific reviews.
4.9.1 Generic Socioeconomic Issues The STPNOC ER, scoping comments, other available data records on STP, Units 1 and 2, were reviewed and evaluated for new and significant information. The review included a data gathering site visit to STP, Units 1 and 2 (the NRC staff also reviewed other sources of information such as applicable permits and data reports as listed in the reference section of this SEIS chapter). No new and significant information was identified during this review that would change the conclusions presented in the GEIS. Therefore, for these Category 1 issues, impacts during the renewal term are not expected to exceed those discussed in the GEIS. For STP, Units 1 and 2, the NRC staff incorporates the GEIS conclusions by reference. Impacts for Category 2 issues and the uncategorized issue (environmental justice) are discussed in Sections 4.9.2 through 4.9.7.
4.9.2 Housing Appendix C of the GEIS (NRC 1996) presents a population characterization method based on two factorssparseness and proximity. Sparseness measures population density within 20 mi (32 km) of the site, and proximity measures population density and city size within 50 mi (80 km). Each factor has categories of density and size. A matrix is used to rank the population category as low, medium, or high as shown in Figure C.1 of the GEIS.
According to the 2000 Census, an estimated 35,291 people lived within 20 mi (32 km) of STP, Units 1 and 2, which equates to a population density of 36 persons per square mile (STPNOC 2010). This translates to a Category 1, most sparse, population density using the GEIS measure of sparseness (less than 40 persons per square mile and no community with 25,000 or more people within 20 mi). An estimated 255,118 people live within 50 mi (80 km) of STP, Units 1 and 2, with a population density of 32 persons per square mile (STPNOC 2010).
Applying the GEIS proximity measures, STP is classified as proximity Category 1 (no city with 100,000 or more persons and less than 50 persons per square mile within 50 mi). Therefore, according to the sparseness and proximity matrix presented in the GEIS, rankings of sparseness Category 1 and proximity Category 1 result in the conclusion that the STP is located in a low population area.
Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, states that impacts on housing availability are expected to be of SMALL, MODERATE, or LARGE. MODERATE or LARGE housing impacts of the workforce associated with refurbishment may be associated with plants located in 4-42
Environmental Impacts of Operation sparsely populated areas or in areas with growth control measures that limit housing development. Because (a) STPNOC has no planned refurbishment activities and (b) Brazoria County and Matagorda County are not subject to growth-control measures that would limit housing development, any changes in employment at STP would have little noticeable effect on housing availability in these counties. Since STPNOC has no plan to add non-outage employees during the license renewal period, employment levels at STP would remain relatively constant with no additional demand for permanent housing during the license renewal term.
Based on this information, there would be no impact on housing during the license renewal term beyond what has already been experienced. Therefore, the NRC staff concludes that the impacts would be SMALL.
4.9.3 Public ServicesPublic Utilities Impacts on public utility services (e.g., water, sewer) are considered SMALL if the public utility has the ability to respond to changes in demand and would have no need to add or modify facilities. Impacts are considered MODERATE if service capabilities are overtaxed during periods of peak demand. Impacts are considered LARGE if additional system capacity is needed to meet ongoing demand.
Analysis of impacts on the public water systems considered both plant demand and plant-related population growth. Section 2.1.7 of this SEIS describes the permitted withdrawal rate and actual use of water for reactor cooling at STP, Units 1 and 2.
Since STPNOC has no plans to add non-outage employees during the license renewal period, employment levels at STP would remain relatively unchanged with no additional demand for public water services. Public water systems in the region are adequate to meet the demands of residential and industrial customers in the area. Therefore, there would be no impact to public water services during the license renewal term beyond what is currently being experienced.
Therefore, the NRC staff concludes that the impacts would be SMALL.
4.9.4 Public ServicesTransportation Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 states that:
Transportation impacts (level of service) of highway traffic generated...during the term of the renewed license are generally expected to be of SMALL significance.
However, the increase in traffic associated with additional workers and the local road and traffic control conditions may lead to impacts of MODERATE or LARGE significance at some sites.
The regulation in 10 CFR 51.53(c)(3)(ii)(J) requires all applicants to assess the impacts of highway traffic generated by the proposed project on the level of service of local highways during the term of the renewed license. Since STPNOC has no plans to add non-outage employees during the license renewal period, traffic volume and levels of service on roadways in the vicinity of STP, Units 1 and 2, would not change. Therefore, there would be no transportation impacts during the license renewal term beyond those already being experienced. Therefore, the NRC staff concludes that the impacts would be SMALL.
4.9.5 Offsite Land Use Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 notes that significant changes in land use may be associated with population and tax revenue changes resulting from license renewal. Section 4.7.4 of the GEIS defines the magnitude of land-use changes as a result of 4-43
Environmental Impacts of Operation plant operation during the license renewal term as SMALL when there will be little new development and minimal changes to an areas land-use pattern, as MODERATE when there will be considerable new development and some changes to the land-use pattern, and LARGE when there will be large-scale new development and major changes in the land-use pattern.
Tax revenue can affect land use because it enables local jurisdictions to provide the public services (e.g., transportation and utilities) necessary to support development. Section 4.7.4.1 of the GEIS states that the assessment of tax-driven land-use impacts during the license renewal term should consider the size of the plants tax payments relative to the communitys total revenues, the nature of the communitys existing land-use pattern, and the extent to which the community already has public services in place to support and guide development. If the plants tax payments are projected to be small relative to the communitys total revenue, tax driven land-use changes during the plants license renewal term would be SMALL, especially where the community has pre-established patterns of development and has provided public services to support and guide development. Section 4.7.2.1 of the GEIS states that if tax payments by the plant owner are less than 10 percent of the taxing jurisdictions revenue, the significance level would be SMALL. If tax payments are 10 to 20 percent of the communitys total revenue, new tax-driven land-use changes would be MODERATE. If tax payments are greater than 20 percent of the communitys total revenue, new tax-driven land-use changes would be LARGE. This would be especially true where the community has no pre-established pattern of development or has not provided adequate public services to support and guide development.
As discussed in Sections 4.9.2, 4.9.3, and 4.9.4, it is not expected that there would be any change in the staffing levels at STP or increased demand for additional housing, public services related to public utilities, and transportation during the license renewal period. Therefore, the NRC staff concludes that the impacts would be SMALL.
4.9.5.1 Population-Related Impacts Since STPNOC has no plans to add non-outage employees during the license renewal period, there would be no plant operations-driven population increase in the vicinity of STP, Units 1 and 2. Therefore, there would be no population-related offsite land use impacts during the license renewal term beyond those already being experienced. Therefore, the NRC staff concludes that the impacts would be SMALL.
4.9.5.2 Tax Revenue-Related Impacts As discussed in Chapter 2, STPNOC pays property taxes for STP, Units 1 and 2, to Matagorda County, Matagorda County Hospital District, Navigation District #1, Drainage District #3, Palacios Seawall District, and the Coastal Plains Groundwater District. Since STPNOC started making property tax payments to local jurisdictions, population levels and land use conditions in Matagorda County has remained relatively unchanged (STPNOC 2010); therefore, tax revenue from STP, Units 1 and 2, has had little or no effect on land use conditions within the county.
Since employment levels at STP, Units 1 and 2, would remain relatively unchanged with no increase in the assessed value of STP, Units 1 and 2, annual property tax payments would also be expected to remain relatively unchanged throughout the license renewal period. Based on this information, there would be no tax-revenue-related offsite land use impacts during the license renewal term beyond those already being experienced. Therefore, the NRC staff concludes that the impacts would be SMALL.
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Environmental Impacts of Operation 4.9.6 Historic and Archaeological Resources The National Historic Preservation Act (NHPA) requires Federal agencies to consider the effects of their undertakings on historic properties. Historic properties are defined as resources that are eligible for listing on the National Register of Historic Places (NRHP). The criteria for eligibility are listed in 36 CFR 60.4 and include association with significant events in history; association with the lives of persons significant in the past; embodiment of distinctive characteristics of type, period, or construction; and sites or places that have yielded or are likely to yield important information. The historic preservation review process (Section 106 of NHPA) is outlined in regulations issued by the Advisory Council on Historic Preservation (ACHP) in 36 CFR Part 800.
In accordance with 36 CFR 800.8(c), the NRC has elected to use the NEPA process to comply with the obligations found under Section 106 of the NHPA.
The issuance of a renewed operating license for a nuclear power plant is a Federal action that could affect historic properties on or near the nuclear plant site and transmission lines. In accordance with the provisions of the NHPA, the NRC is required to make a reasonable effort to identify historic properties included in or eligible for inclusion in the NRHP in the area of potential effect (APE). The APE for license renewal is the nuclear power plant site, transmission lines, and immediate environs. If historic properties are present, the NRC is required to contact the State Historic Preservation Office (SHPO), assess the potential impact, and resolve any possible adverse effects of the undertaking (license renewal) on historic properties. NRC is also required to notify the SHPO if historic properties would not be affected by license renewal or if no historic properties are present. The SHPO is part of the Texas Historical Commission (THC) in the State of Texas. This section provides the NRCs assessment of effects from the proposed license renewal action for STP, Units 1 and 2.
Section 2.2.10 of this SEIS provides specific historic and cultural information near the STP site.
On March 17, 2009, STP initiated informal consultation with the THC regarding the renewal of operating licenses for STP, Units 1 and 2. STP concluded in its letter to THC that there would be no effect on historic properties from license renewal and associated operation and maintenance activities (STPNOC 2010b). The THC responded to STP on October 26, 2009, with a determination of No Historic Properties Affected, Project May Proceed (STPNOC 2010b). The THC response is in the form of a stamp on the last page of the STP letter that was sent to the THC, which STP included in its ER for license renewal (STPNOC 2010b).
Prior to the site audit in May 2011, NRC contacted the THC concerning license renewal for STP.
The staff and THC concluded there was no need to meet during the environmental audit to discuss cultural resources (NRC 2011a). The THC determined that there were no known issues with license renewal for STP and referred the NRC to the THC response to STP on October 26, 2009, with the determination of No Historic Properties Affected, Project May Proceed (STPNOC 2010b).
In accordance with 36 CFR 800.8(c), on January 27, 2011, and February 17, 2011, respectively, the NRC initiated consultations on the proposed action by writing to the ACHP and SHPO (NRC 2011d, 2011e). In February 2011, the NRC initiated consultation with six Federally recognized tribes: the Yselta del Sur Pueblo Tribe, Alabama-Cousahatta Tribe, Kiowa Tribe of Oklahoma, the Comanche Nation, Tonkawa Tribe of Oklahoma, and Kickapoo Traditional Council (Appendix D contains a copy of these letters for reading convenience). Also in February 2011, the NRC initiated consultation with four additional tribes: the Apalachicola Band of Creek Indians, Lipan Apache Band of Texas, Pamaque Clan of Coahuila Y Tejas, and the Tap Pilam-Coahuiltecan Nation (Appendix D contains a copy of these letters). In its letters, the 4-45
Environmental Impacts of Operation NRC provided information about the proposed action and the definition of APE. In addition, the NRC indicated that the NHPA review would be integrated with the NEPA process, in accordance with 36 CFR 800.8. NRC invited participation in the identification and possible decisions concerning historic properties and invited participation in the scoping process. Four tribesthe Apalachicola Band of Creek Indians, the Kickapoo Traditional Council, the Tonkawa Tribe of Oklahoma, and the Tap Pilam-Coahuiltecan Nationresponded to the NRC with scoping comments. These comments included concerns with potential accidents, requests to re-survey the STP site, requests for notification if historic and cultural resources of cultural significance were discovered on the STP site, and statements of no concern with the undertaking. NRC responded to the tribes in October 2011 and has taken the comments into consideration while preparing this SEIS (Appendix D lists copies of these letters).
As described in Section 2.2.10, there are no recorded archaeological sites or historic structures on the STP site. STPNOC has identified a potential historic gravesite located on the southeast boundary of the STP site within the APE. STP staff interviewed descendants of the former property owner and confirmed the presence of a grave from the late 1800s; however, little is known about the gravesite, and it is not a recorded historic and archaeological resource. The NRC staff has confirmed that there are no planned ground-disturbing activities near the gravesite and it would be protected from any operation and maintenance activities associated with the license renewal term as the activities would occur several miles from the [grave]site and would be conducted in accordance with STP environmental compliance procedures (STPNOC 2011g).
STPNOC has no planned refurbishment activities associated with license renewal at the STP site (STPNOC 2011g). A review of operation and maintenance activities that occur in and around the STP site indicates that these activities are limited to the use of existing roads and previously disturbed areas and are subject to STP environmental compliance procedures (applicable to any future potential land disturbing constructions at STP).
For the purposes of NHPA Section 106 consultation, the NRC staff concludes a finding of no effect to historic properties (36 CFR Section 800.4(d)(1)) based on the following:
- historic and cultural resources located within the APE,
- tribal input,
- STP environmental compliance procedures,
- there will be no refurbishment or ground-disturbing activities associated with the relicensing of STP, Units 1 and 2,
- SHPO finding of No Historic PropertiesAffected, Project May Proceed, and
- the NRC staffs cultural resource analysis and consultation.
For the purposes of the NRC staffs NEPA analysis, in consideration of the conclusion reached in the NHPA Section 106 consultation, the NRC staff concludes that potential impacts on historic and cultural resources related to STP license renewal would be SMALL.
4.9.7 Environmental Justice Under Executive Order (EO) 12898 (59 FR 7629), Federal agencies are responsible for identifying and addressing, as appropriate, disproportionately high and adverse human health and environmental impacts on minority and low-income populations. In 2004, the NRC issued a 4-46
Environmental Impacts of Operation Policy Statement on the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions (69 FR 52040), which states, The Commission is committed to the general goals set forth in EO 12898, and strives to meet those goals as part of its NEPA review process.
The Council on Environmental Quality (CEQ) provides the following information in Environmental Justice: Guidance Under the National Environmental Policy Act (CEQ 1997b):
Disproportionately High and Adverse Human Health Effects.
Adverse health effects are measured in risks and rates that could result in latent cancer fatalities, as well as other fatal or nonfatal adverse impacts on human health. Adverse health effects may include bodily impairment, infirmity, illness, or death. Disproportionately high and adverse human health effects occur when the risk or rate of exposure to an environmental hazard for a minority or low-income population is significant (as employed by NEPA) and appreciably exceeds the risk or exposure rate for the general population or for another appropriate comparison group.
Disproportionately High and Adverse Environmental Effects.
A disproportionately high environmental impact that is significant (as employed by NEPA) refers to an impact or risk of an impact on the natural or physical environment in a low-income or minority community that appreciably exceeds the environmental impact on the larger community. Such effects may include ecological, cultural, human health, economic, or social impacts. An adverse environmental impact is an impact that is determined to be both harmful and significant (as employed by NEPA). In assessing cultural and aesthetic environmental impacts, impacts that uniquely affect geographically dislocated or dispersed minority or low-income populations or American Indian tribes are considered.
The environmental justice analysis assesses the potential for disproportionately high and adverse human health or environmental effects on minority and low-income populations that could result from the operation of STP during the license renewal term. In assessing the impacts, the following definitions of minority individuals and populations and low-income population were used (CEQ 1997b):
Minority individuals.
Individuals who identify themselves as members of the following population groups: Hispanic or Latino, American Indian or Alaska Native, Asian, Black or African American, Native Hawaiian or Other Pacific Islander, or two or more races, meaning individuals who identified themselves on a Census form as being a member of two or more races, for example, Hispanic and Asian.
Minority populations.
Minority populations are identified when (1) the minority population of an affected area exceeds 50 percent or (2) the minority population percentage of the affected area is meaningfully greater than the minority population percentage in the general population or other appropriate unit of geographic analysis.
Low-income population.
Low-income populations in an affected area are identified with the annual statistical poverty thresholds from the Census Bureaus Current Population Reports, Series P60, on Income and Poverty.
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Environmental Impacts of Operation Minority Population. According to 2010 Census data, 45.9 percent of the total population (approximately 110,201 persons) residing within a 50-mi (80-km) radius of STP identified themselves as minority individuals. The largest minority group was Hispanic or Latino (of any race) (approximately 82,000 persons or 33.9 percent), followed by Black or African American (approximately 23,000 persons or 9.6 percent) (CAPS 2011).
According to 2010 Census data, minority populations in the socioeconomic ROI (Matagorda and Brazoria Counties) comprised 47.4 percent of the total two-county population as shown in Table 2-17 (USCB 2011). Figure 4-2 shows minority population block groups using 2010 Census data for race and ethnicity within a 50-mi (80-km) radius of STP.
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Environmental Impacts of Operation Figure 4-2. 2010 Census Minority Block Groups Within a 50-mi Radius of STP Source: USCB 2012.
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Environmental Impacts of Operation Census block groups were considered minority population block groups if the percentage of the minority population within any block group exceeded 45.9 percent (the percent of the minority population within the 50-mi radius of STP). A minority population exists if the percentage of the minority population within the block group is meaningfully greater than the minority population percentage in the 50-mi radius. Minority population block groups are concentrated in the Bay City area, El Campo, Freeport, Palacios, and Port Lavaca. Smaller concentrations of minority population block groups are found in Angelton and Wharton. The nearest minority population (i.e., percentage is meaningfully greater than the percentage in the 50-mi radius) to STP is located in Matagorda, Texas. In Matagorda, according to the 2010 Census, approximately 15 percent of the Matagorda population identified themselves as minority.
Low-Income Population. According to 2006 through 2010 American Community Survey 5-year estimates, an average of 11.4 percent of families and 14.2 percent of individuals residing in nine countiesall or parts of which are located within a 50-mi radius of STP (Brazoria, Calhoun, Colorado, Fort Bend, Jackson, Lavaca, Matagorda, Victoria, and Wharton)were identified as living below the Federal poverty threshold in 2010 (USCB 2010). The 2010 Federal poverty threshold was $22,314 for a family of four.
According to 2006 through 2010 American Community Survey 5-year estimates, the median household income for Texas was $49,646, with 16.8 percent of the State population and 13 percent of families living below the Federal poverty threshold in 2010 (USCB 2011).
Brazoria County had a lower median household income average ($43,258) and lower percentages of individuals (10.6 percent) and families (8.2 percent) living below the poverty level when compared to the State average. Matagorda County had a lower household income average ($48,508) compared to the State average and higher than Brazoria County, but a higher percentage of individuals (18.6 percent) and families (21.6 percent) living below the poverty level when compared to Brazoria County and the State (USCB 2011).
Figure 4-3 shows low-income census block groups within a 50-mi (80-km) radius of STP.
Census block groups were considered low-income population block groups if the percentage of individuals living below the Federal poverty threshold within any block group exceeded the percent of the individuals living below the Federal poverty threshold within the 50-mi radius of STP. Similar to the locations of minority population block groups, the majority of low-income population block groups are located in the Bay City area, Freeport, Palacios, Port Lavaca, and Wharton. Smaller concentrations of minority population block groups are located near Angelton.
The nearest low-income population to STP is located in Matagorda, Texas.
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Environmental Impacts of Operation Figure 4-3. Census 2010 Low-Income Block Groups Within a 50-mi Radius of STP Source: USCB 2012 4-51
Environmental Impacts of Operation Analysis of Impacts. The NRC addresses environmental justice matters for license renewal in the following ways:
- identifying the location of minority and low-income populations that may be affected by the continued operation of the nuclear power plant during the license renewal term,
- determining whether there would be any potential human health or environmental effects to these populations and special pathway receptors, and
- determining if any of the effects may be disproportionately high and adverse.
Figure 4-2 and Figure 4-3, above, identify the location of minority and low-income populations residing within a 50-mi (80-km) radius of STP. This area of impact is consistent with the impact analysis for public and occupational health and safety, which also focuses on populations within a 50-mi (80-km) radius of the nuclear plant. Chapter 4 presents the assessment of environmental and health impacts for each resource area. With the exception of the electromagnetic fields/acute effects issue, which the NRC staff concluded has a potential impact level of SMALL to MODERATE, the NRC staff concluded that the impact from all the other environmental issues would be SMALL.
Potential impacts to minority and low-income populations (including migrant workers or Native Americans) would mostly consist of socioeconomic and radiological effects; however, radiation doses from continued operations during the license renewal term are expected to continue at current levels and would remain below regulatory limits. Chapter 5 of this SEIS discusses the environmental impacts from postulated accidents that might occur during the license renewal term, which include both design-basis and severe accidents. In both cases, the NRC has generically determined that impacts associated with design-basis accidents are SMALL because nuclear plants are designed and operated to successfully withstand such accidents, and the probability-weighted consequences of severe accidents are SMALL.
Therefore, based on this information and the analysis of human health and environmental impacts presented in Chapters 4 and 5 of this SEIS, there would be no disproportionately high and adverse impacts to minority and low-income populations from the continued operation of STP during the license renewal term.
As part of addressing environmental justice concerns associated with license renewal, the NRC also assessed the potential radiological risk to special population groups (such as migrant workers or Native Americans) from exposure to radioactive material received through their unique consumption and interaction with the environment patterns. These include subsistence consumption of fish, native vegetation, surface waters, sediments, and local produce; absorption of contaminants in sediments through the skin; and inhalation of airborne radioactive material released from the plant during routine operation. This analysis is presented below.
Subsistence Consumption of Fish and Wildlife. The special pathway receptors analysis is an important part of the environmental justice analysis because consumption patterns may reflect the traditional or cultural practices of minority and low-income populations in the area, such as migrant workers or Native Americans.
Section 4-4 of EO 12898 (1994) directs Federal agencies, whenever practical and appropriate, to collect and analyze information on the consumption patterns of populations that rely principally on fish or wildlife or both for subsistence and to communicate the risks of these consumption patterns to the public. In this SEIS, the NRC considered whether there were any 4-52
Environmental Impacts of Operation means for minority or low-income populations to be disproportionately affected by examining impacts to American Indians, Hispanics, migrant workers, and other traditional lifestyle special pathway receptors. Special pathways take into account the levels of radiological and nonradiological contaminants in native vegetation, crops, soils and sediments, groundwater, surface water, fish, and game animals on or near STP.
The following is a summary discussion of the NRCs evaluation from Section 4.8.2 of the REMP that assesses the potential impacts for subsistence consumption of fish and wildlife near the STP site.
STPNOC has an ongoing, comprehensive REMP to assess the impact of STP operations on the environment. To assess the impact of nuclear power plant operations, samples are collected annually from the environment and analyzed for radioactivity. A nuclear power plant effect would be indicated if the radioactive material detected in a sample was significantly larger than background levels. Two types of samples are collected. The first type, control samples, is collected from areas that are beyond the measurable influence of the nuclear power plant or any other nuclear facility. These samples are used as reference data to determine normal background levels of radiation in the environment. These samples are then compared with the second type of samples, indicator samples, collected near the nuclear power plant. Indicator samples are collected from areas where any contribution from the nuclear power plant will be at its highest concentration. These samples are then used to evaluate the contribution of normal nuclear power plant operations to radiation or radioactivity levels in the environment. An effect would be indicated if the radioactivity levels detected in an indicator sample was significantly larger than the control sample or background levels.
Samples of environmental media are collected from the aquatic and terrestrial pathways in the vicinity of STP. The aquatic pathways include surface water, groundwater, drinking water, fish, crab, shrimp, oyster, and shoreline sediment. The terrestrial pathways include airborne particulates, food products (i.e., leafy vegetables such as cabbage and various edible greens, are collected from gardens and farms in the vicinity of STP), beef, poultry, wild animal meat (i.e., waterfowl, deer, rabbits, and alligator), and broadleaf vegetation. In 2010, analyses performed on samples of environmental media showed no significant or measurable radiological impact above background levels from normal STP operations (STPNOC 2011). For this final SEIS, the NRC staff reviewed the results of STPs REMP data for 2012 and concluded that there were no significant of measurable radiological impacts above background levels from normal STP operations (STPNOC 2013b)
Conclusion. Based on the radiological environmental monitoring data from STP, the NRC finds that no disproportionately high and adverse human health impacts would be expected in special pathway receptor populations in the region as a result of subsistence consumption of water, local food, fish, and wildlife.
4.10 Evaluation of New and Potentially Significant Information The staff has not identified new and significant information on environmental issues related to operation during the renewal term. The staff also determined that information provided during the public comment period did not identify any new issue that requires site-specific assessment.
The staff reviewed the discussion of environmental impacts associated with operation during the renewal term in the GElS and has conducted its own independent review, including public involvement process (e.g., public meetings) to identify issues with new and significant information.
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Environmental Impacts of Operation New and significant information is information that identifies a significant environmental issue not covered in the GEIS and codified in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, or information that was not considered in the analyses summarized in the GEIS and that leads to an impact finding that is different from the finding presented in the GEIS and codified in 10 CFR Part 51.
In accordance with 10 CFR 51.53(c), the ER submitted by the applicant must provide an analysis of the Category 2 issues in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B.
Additionally, it must discuss actions to mitigate any adverse impacts associated with the proposed action and environmental impacts of alternatives to the proposed action. In accordance with 10 CFR 51.53(c)(3), the ER does not need to contain an analysis of any Category 1 issue unless there is significant new information on a specific issue.
The NRC also has a process for identifying new and significant information. That process is described in NUREG-1555, Supplement 1, Standard Review Plans for Environmental Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal (NRC 1999b, 2013e).
The search for new information includes:
- review of an applicants ER and the process for discovering and evaluating the significance of new information,
- review of public comments,
- review of environmental quality standards and regulations,
- coordination with Federal, State, and local environmental protection and resource agencies, and
- review of the technical literature.
New information discovered by the staff is evaluated for significance using the criteria set forth in the GEIS. For Category 1 issues where new and significant information is identified, reconsideration of the conclusions for those issues is limited in scope to the assessment of the relevant new and significant information; the scope of the assessment does not include other facets of an issue that are not affected by the new information.
4.11 Environmental Issues Contained in the Revised 10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions As described in Section 1.4 of this SEIS, the NRC has published a final rule (78 FR 37282, June 20, 2013) revising its environmental protection regulation, 10 CFR Part 51, Environmental protection regulations for domestic licensing and related regulatory functions. The final rule consolidates similar Category 1 and 2 issues, changes some Category 2 issues into Category 1 issues, and consolidates some of those issues with existing Category 1 issues. The revised rule also adds new Category 1 and 2 issues. The new Category 1 issues include geology and soils, exposure of terrestrial organisms to radionuclides, exposure of aquatic organisms to radionuclides, human health impact from chemicals, and physical occupational hazards.
Radionuclides released to groundwater, effects on terrestrial resources (non-cooling system impacts), minority and low-income populations (i.e., environmental justice), and cumulative impacts were added as new Category 2 issues. Except for cumulative impacts, this section addresses the direct and indirect effects associated with these new Category 1 and Category 2 4-54
Environmental Impacts of Operation issues. The cumulative impacts assessment is presented in Section 4.12. Table 4-16a shows the newly revised 10 CFR Part 51 issues.
Table 4-16a. Newly Revised 10 CFR Part 51 Issues Issues GEIS Section Category Geology and soils 4.4 1 Radionuclides released to groundwater 4.5.1.2 2 Exposure of terrestrial organisms to radionuclides 4.6.1.1 1 Exposure of aquatic organisms to radionuclides 4.6.1.2 1 Human health impacts from chemicals 4.9.1.1.2 1 Physical occupational hazards 4.9.1.1.5 1 Environmental justice (minority & low-income populations) 4.10 2 Cumulative Impacts 4.13 2 Terrestrial Resources 4.6.1.1 2 Source: NRC 2013d; 78 FR 37282.
4.11.1 Geology and Soils With respect to the geologic environment of a plant site, the final rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new Category 1 issue, Geology and soils. This new issue has an impact level of SMALL. This new Category 1 issue considers geology and soils from the perspective of those resource conditions or attributes that can be affected by continued operations during the renewal term. An understanding of geologic and soil conditions has been well established at all nuclear power plants and associated transmission lines during the current licensing term, and these conditions are expected to remain unchanged during the 20-year license renewal term for each plant. The impact of these conditions on plant operations and the impact of continued power plant operations and refurbishment activities on geology and soils are SMALL for all nuclear power plants and not expected to change appreciably during the license renewal term. Operating experience shows that any impacts to geologic and soil strata would be limited to soil disturbance from construction activities associated with routine infrastructure renovation and maintenance projects during continued plant operations. Implementing best management practices would reduce soil erosion and subsequent impacts on surface water quality. Information in plant-specific SEISs prepared to date and reference documents has not identified these impacts as being significant.
Section 2.2.3 of this SEIS describes the local and regional geologic environment relevant to STP. The staff did not identify any new and significant information with regard to this Category 1 (generic) issue based on review of the STPNOCs ER, the public scoping process, or as a result of the environmental site audit. As discussed in Chapter 3 of this SEIS and as identified in the STPNOCs ER (STPNOC 2010b), STPNOC has no plans to conduct major refurbishment or replacement actions associated with license renewal to support the continued operation of STP. Furthermore, STPNOC anticipates no major changes including construction or other ground-disturbing activities, and the staff anticipates that ongoing maintenance activities would primarily be confined to previously disturbed areas or existing ROWs. Based on 4-55
Environmental Impacts of Operation this information, it is expected that any incremental impacts on geology and soils during the license renewal term would be SMALL.
4.11.2 Radionuclides Released to Groundwater With respect to groundwater quality, the final rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new Category 2 issue, Radionuclides released to groundwater, with an impact level range of SMALL to MODERATE, to evaluate the potential impact of discharges of radionuclides from plant systems into groundwater. This new Category 2 issue has been added to evaluate the potential impact to groundwater quality from the discharge of radionuclides from plant systems, piping, and tanks. The staff evaluates this issue for STP in Section 4.4.3 of this SEIS. Based on its review, the staff concludes the impacts are SMALL.
4.11.3 Exposure of Aquatic Organisms and Terrestrial Resource to Radionuclides With respect to the aquatic and terrestrial organisms, the final rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding two new Category 1 issues, Exposure of aquatic organisms to radionuclides and Exposure of terrestrial organisms to radionuclides, among other changes. These new Category 1 issues consider the impacts to aquatic and terrestrial organisms from exposure to radioactive effluents discharged from a nuclear power plant during the license renewal term. An understanding of the radiological conditions in the aquatic and terrestrial environment from the discharge of radioactive effluents within NRC regulations has been well established at nuclear power plants during their current licensing term. Based on this information, the staff concluded that the doses to aquatic and terrestrial organisms (i.e., biota) are expected to be well below exposure guidelines developed to protect these organisms and assigned an impact level of SMALL.
The staff has not identified any new and significant information related to the exposure of aquatic organisms to radionuclides during its independent review of STPNOCs ER, the site audit, and the scoping process. Section 2.1.2 of this SEIS describes the applicants Radioactive Waste Management Program to control radioactive effluent discharges to ensure that they comply with NRC regulations in 10 CFR Part 20. Section 4.8.2 of this SEIS contains the staffs evaluation of the STPNOCs radioactive effluent and radiological environmental monitoring programs. STPNOCs radioactive effluent and radiological environmental monitoring programs provide further support for the conclusion that the impacts of aquatic and terrestrial organisms from radionuclides are SMALL.
The staff concludes that there would be no impacts to aquatic and terrestrial organisms (biota) from radionuclides beyond those impacts contained in Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 of the revised rule; therefore, the impacts to aquatic and terrestrial organisms from radionuclides are SMALL.
4.11.4 Effects on Terrestrial Resources (Non-cooling System Impacts)
With respect to the terrestrial organisms, the final rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by expanding the Category 2 issue, Refurbishment impacts, among others, to include normal operations, refurbishment, and other supporting activities during the license renewal term. This issue remains a Category 2 issue with an impact level range of SMALL to LARGE; however, the revised rule renames this issue Effects on terrestrial resources (non-cooling system impacts).
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Environmental Impacts of Operation Section 2.2.7 describes the terrestrial resources on and in the vicinity of the STP site, and Section 2.2.8 describes protected species and habitats. Prior to plant construction, much of the 12,220-ac (4,945-ha) STP site was cropland and rangeland. Approximately 8,000 ac (3,200 ha) of the site were disturbed and modified by plant construction and related activities.
As detailed in Section 2.2.1 of this SEIS, the STP operations area consisting of the reactor buildings and support facilities totals approximately 111 ac (45 ha), with the MCR encompassing 7,000 ac (2,833 ha). Another 1,700 ac (688 ha) is natural lowland habitat. The rest of the site is mostly undeveloped land; a portion of which, east of the MCR, is leased for cattle grazing. As discussed in Chapter 3 of this SEIS and according to the applicants ER (STPNOC 2010b),
STPNOC has no plans to conduct refurbishment or replacement actions associated with license renewal to support the continued operation of STP. Further, as previously discussed in Section 4.7, STPNOC anticipates that continued operations and maintenance will not involve any new construction or other ground-disturbing activities, including changes to existing land use conditions in either natural or developed areas. Based on the staffs independent review, the staff concurs that any operation and maintenance activities that STPNOC might otherwise undertake during the renewal term, such as maintenance and repair of plant infrastructure (e.g.,
roadways, piping installations, onsite transmission lines, fencing, and other security infrastructure), likely would be confined to previously disturbed areas of the plant site.
Therefore, the staff expects non-cooling system impacts on terrestrial resources during the license renewal term to be SMALL.
4.11.5 Human Health Impacts From Chemicals and Physical Occupational Hazards With respect to the human health, the final rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding two new Category 1 issues, Human health impact[s] from chemicals and Physical occupational hazards. The first issue considers the impacts from chemicals to plant workers and members of the public. The second issue only considers the nonradiological occupational hazards of working at a nuclear power plant. An understanding of these nonradiological hazards to nuclear power plant workers and members of the public have been well established at nuclear power plants during those plants current licensing terms. The impacts from chemical hazards are expected to be minimized through the applicants use of good industrial hygiene practices as required by permits and Federal and State regulations (e.g., in compliance with the Occupational Safety and Health Administrations regulation on chemical hazard and the use of the Material Data Sheet for the respective facilities). Also, the impacts from physical hazards to plant workers will be of small significance if workers adhere to safety standards and use protective equipment as required by Federal and State regulations (e.g., Occupational Safety and Health Administration rules for industrial safety such as mitigation measures for asphyxiation concerns, working in an enclosed space, or with overhead loads). The impacts to human health for each of these new issues from continued plant operations are SMALL.
The staff has not identified any new and significant information related to these nonradiological issues during its independent review of STPNOCs ER, the site audit, the scoping process, and comments on the draft SEIS. Therefore, the staff concludes that there would be no impact to human health from chemicals or physical hazards (i.e., industrial hazard) beyond those impacts described in Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 of the revised rule and; therefore, the impacts are SMALL.
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Environmental Impacts of Operation 4.11.6 Environmental Justice With respect to environmental justice concerns, the final rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new Category 2 issue, Minority and low-income populations, to evaluate the impacts of continued operations and any refurbishment activities during the license renewal term on minority populations and low-income populations living in the vicinity of the plant. Environmental justice was listed in Table B-1 as a concern, prior to this revised rule, but was not evaluated in the 1996 GEIS; therefore, it is addressed in each SEIS.
Consistent with this requirement, the staff evaluates this issue in Section 4.9.7 of this SEIS.
4.11.7 Cumulative Impacts With respect to cumulative impacts, the final rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new Category 2 issue, Cumulative impacts, to evaluate the potential cumulative impacts of license renewal. The staff evaluates this issue in Section 4.12 of this SEIS.
4.12 Cumulative Impacts As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental protection regulation, 10 CFR Part 51. With respect to cumulative impacts, the final rule amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new Category 2 issue, Cumulative impacts, to evaluate the potential cumulative impacts of license renewal.
The staff considered potential cumulative impacts in the environmental analysis of continued operation of STP nuclear plant during the 20-year license renewal period. Cumulative impacts may result when the environmental effects associated with the proposed action are overlaid or added to temporary or permanent effects associated with other past, present, and reasonably foreseeable actions. Cumulative impacts can result from individually minor, but collectively significant, actions taking place over a period of time. It is possible that an impact that may be SMALL by itself could result in a MODERATE or LARGE cumulative impact when considered in combination with the impacts of other actions on the affected resource. Likewise, if a resource is regionally declining or imperiled, even a SMALL individual impact could be important if it contributes to or accelerates the overall resource decline.
For the purposes of this cumulative analysis, past actions are those before the receipt of the license renewal application. Present actions are those related to the resources at the time of current operation of the power plant, and future actions are those that are reasonably foreseeable through the end of plant operation including the period of extended operation.
Therefore, the analysis considers potential impacts through the end of the current license terms as well as the 20-year renewal license term. The geographic area over which past, present, and reasonably foreseeable actions would occur is dependent on the type of action considered and is described below for each resource area.
The staff describes the incremental impacts of the proposed action (i.e., STP license renewal) in Sections 4.1-4.9 of this SEIS. To evaluate cumulative impacts, the incremental impacts of the proposed action are combined with other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person who undertakes such actions. The staff used the information provided in the ER; responses to requests for additional information; information from other Federal, State, and local agencies; scoping comments; and information gathered during the audit at the STP site to identify other past, present, and 4-58
Environmental Impacts of Operation reasonably foreseeable actions. To be considered in the cumulative analysis, the staff determined if the project would occur within the noted geographic areas of interest and within the period of extended operation, if it was reasonably foreseeable, and if there would be potential overlapping effect with the proposed project. For past actions, consideration within the cumulative impacts assessment is resource and project specific. In general, the effects of past actions are included in the description of the affected environment in Chapter 2, which serves as the baseline for the cumulative impacts analysis. However, past actions that continue to have an overlapping effect on a resource potentially affected by the proposed action are considered in the cumulative analysis.
Other actions and projects were identified during this review and considered in the staffs independent analysis of the potential cumulative effects. Examples of other actions and projects that were considered in this analysis include the following:
- proposed STP, Units 3 and 4,
- White Stallion Energy Center (WSEC),
- LCRA-San Antonio Water System (SAWS) Project,
- Mary Rhodes Pipeline Phase II, and
- Brazos Bend State Park, Mad Island Marsh Preserve, Mad Island Wildlife Management Area, Big Boggy National Wildlife Refuge, and the Texas Prairie Wetland Project.
The complete description of each of the projects and actions that were considered are listed in the discussions of the following sections.
4.12.1 Land Use As discussed in Section 4.1 of this SEIS, onsite land use and powerline ROW conditions are not expected to change during the license renewal term for STP. Therefore, activities associated with continued reactor operations during the license renewal term are not expected to change the use and management of STPNOCs lands on the STP site. Therefore, cumulative impacts of land use are SMALL.
4.12.2 Air Quality This section addresses the direct and indirect effects of license renewal on air quality resources when added to the aggregate effects of other past, present, and reasonably foreseeable future actions. The geographic area considered in the cumulative air quality analysis is the county of the proposed action because air quality designations for criteria air pollutants are generally made at the county level. Counties are further grouped together based on a common air shedknown as an air quality control region (AQCR)to provide for the attainment and maintenance of the National Ambient Air Quality Standards (NAAQS). The STP site is located in Matagorda County, Texas, which is part of the Metropolitan Houston-Galveston Intrastate AQCR (40 CFR 81.38). Additional counties in this AQCR include Austin, Brazoria, Chambers, Colorado, Fort Bend, Galveston, Harris, Liberty, Montgomery, Walker, Waller, and Wharton Counties.
In evaluating the potential impacts on air quality associated with license renewal, the NRC staff uses as its baseline the existing air quality conditions described in Section 2.2.2 of this SEIS.
These baseline conditions encompass the existing air quality conditions (EPAs NAAQS county 4-59
Environmental Impacts of Operation designations) potentially affected by air emissions from continued operations. Section 2.2.2 summarizes the air quality designation status for Matagorda County as well as other counties in the Metropolitan Houston-Galveston Intrastate AQCR. As noted in Section 2.2.2, EPA regulates six criteria pollutants under the NAAQS. These pollutants are carbon monoxide, lead, nitrogen dioxide, ozone, sulfur dioxide, and particulate matter. Matagorda County is designated as unclassified or in attainment for all NAAQS criteria pollutants. All other counties in this AQCR are designated as unclassified or in attainment with respect to the NAAQS criteria pollutants, except Brazoria County, which is classified nonattainment/severe relative to the 8-hour ozone standard.
Criteria pollutant air emissions from the STP site are presented in Section 2.2.2.1. These emissions are principally from standby diesel generators and conform to Texas State air emission requirements in 30 TAC 101.10 (Texas Administrative Code). Continued operations of the STP site would result in annual air emissions comparable to those noted in Section 2.2.2.1.
Assuming an average annual emission rate of 58.62 tons per year of total emissions from all sources, an additional 20 years of operation would result in approximately 1,172.4 tons (1,066.9 metric tons) of total emissions from all sources. There is no planned site refurbishment associated with license renewal; therefore, there are no additional air emissions beyond those noted in Section 2.2.2.1 for normal operations.
Foreseeable projects that could contribute meaningfully to cumulative impacts to air quality include the construction and operation of STP, Units 3 and 4, and the construction and operation of the WSEC, a 1,320 mW coal and petroleum coke plant located about 5 mi (8 km) northeast of the STP site (MCEDC 2011).
In September 2007, STPNOC submitted COL applications to the NRC for two new nuclear units on the STP site. If approved, STPNOC would construct the new units adjacent to the currently operating Units 1 and 2. Construction activities would cause some localized temporary air-quality effects because of emissions and fugitive dust from operation of the earth-moving and material-handling equipment. Emissions from workers vehicles and motorized construction equipment exhaust would be temporary. NRC assumed that construction crews would use dust-control practices to control and reduce fugitive dust. STPNOC proposed such activities during construction of proposed Units 3 and 4 (STPNOC 2010b). Section 111.145 of TCEQs regulations requires dust suppression control during the construction of facilities and parking lots. Construction activities and their effect on air quality will be similar for the WSEC coal plant.
It is unlikely that construction of the two projects would overlap because WSEC is scheduled to begin construction in 2012, 2 years earlier than the proposed construction of proposed Units 3 and 4.
During operations, two new nuclear plants would have similar air emissions, primarily from backup diesel generators, to those of existing STP, Units 1 and 2. Because air emissions would be similar for the new nuclear plants, the NRC expects similar air permitting conditions and regulatory requirements as that for Units 1 and 2. In STPNOCs ER for Units 3 and 4, STPNOC stated that [a]ir emissions sources would be managed in accordance with Federal, Texas, and local air quality control laws and regulations. Likewise, NRC assumes that the WSEC facility would be operated in accordance with Federal, Texas, and local air quality control laws and regulations. Effluents from power plants such as the WSEC are typically released through stacks and with significant vertical velocity. Section 8.3.1 of this SEIS characterizes the impacts for the emissions from similar plants as being clearly noticeable, but given existing regulatory regimens, permit requirements, and emissions controls, the coal-fired plant would not destabilize air quality.
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Environmental Impacts of Operation Potential cumulative effects of global climate change (GCC) and increases in average annual temperatures, higher probabilities of extreme heat events, higher occurrences of extreme rainfall (intense rainfall or drought), and changes in the wind patterns could affect concentrations of the air pollutants and their long-range transport because their formation partially depends on the temperature and humidity and is a result of the interactions between hourly changes in the physical and dynamic properties of the atmosphere, atmospheric circulation features, wind, topography, and energy use (IPCC 2010).
The NRC staff examined the cumulative effects of the continued operation of STP, Units 1 and 2, the construction and operation of STP, Units 3 and 4, and the construction and operation of the WSEC coal plant. The cumulative impacts on criteria pollutants from emissions of effluents from the STP site and the WSEC would be noticeable, principally as a result of the contribution of WSEC, but not destabilizing. The NRC staff concludes that cumulative impacts from other past, present, and reasonably foreseeable future actions on air quality resources in the geographic areas of interest would be MODERATE.
4.12.3 Water Resources This section addresses the direct and indirect effects of license renewal on water resources when added to the aggregate effects of other past, present, and reasonably foreseeable future actions. As described in Sections 4.3 and 4.4, the incremental impacts on water resources from continued operations during the proposed license renewal term would be SMALL. This analysis considers two primary geographic areas of interest. For the lower Colorado River, the geographic area of interest is the drainage basin of the Colorado River and Matagorda Bay, encompassed by Region K (i.e., the LCRA) of the Texas statewide water plan (LCRWPG 2010).
For cumulative impacts on groundwater resources, the geographic area of interest generally focuses on the CPGCD and potentially affected aquifer systems. The CPGCD has the same boundaries as Matagorda County.
For the Shallow Chicot Aquifer, which could be affected by seepage and spills, the area of interest extends from recharge areas in Matagorda County to downgradient discharge areas along the Colorado River. For the Deep Chicot Aquifer, the area of interest extends from recharge areas in Wharton County to Matagorda Bay.
The Colorado River and Chicot aquifers are hydraulically connected. As such, this review focused on the projects and activities that would use groundwater or could affect the Chicot aquifers beneath the STP site or would withdraw or discharge water to the Colorado River within their respective geographic areas.
For the purposes of this analysis, it is notable that State-designated River Authorities, such as the LCRA (Section 2.2.4.1), act as managers and suppliers of surface water while Groundwater Conservation Districts act as managers and permitting authorities for groundwater within their respective areas. Overall water resources planning at the regional level is performed by the designated regions, and the TWDB brings the Regional Water Plans together to adopt the State Water Plan. Regional and State-level water planning consider demands, supplies, and future development of both surface and groundwater resources across the State of Texas (NRC 2011b).
4.12.3.1 Cumulative Impacts on Surface Water Resources In addition to continued operation of STP, Units 1 and 2, the NRC staff identified several other past, present, and foreseeable projects (NRC 2011b). These projects include the proposed STP, Units 3 and 4, the WSEC, the LCRA-SAWS Project, and the Mary Rhodes Pipeline 4-61
Environmental Impacts of Operation Phase II Project, in addition to the existing water use for municipal, irrigation, industrial, and instream uses. NRC and USACE (2011b) also considered potential effects of GCC on water supply in Region K, in which STP, Units 1 and 2, is located.
The projected average long-term consumptive surface water use of proposed STP, Units 3 and 4, would be 37,430 ac-ft/yr (46.2 million m3/yr) at 100 percent load factor (NRC 2011b).
The projected consumptive use for STP, Units 3 and 4, is approximately 2.6 percent of the estimated water available to users in the Matagorda County portion of Region K in the 2030 to 2060 timeframe, which is estimated to be 145,540 ac-ft/yr (179.5 million m3/yr)
(LCRWPG 2010). Because the incremental water use of proposed STP, Units 3 and 4, is a small percentage of the water available to the local region and would not require additional allocation over the current water right held by STPNOC, the NRC staff concludes that the incremental impact of water use for STP, Units 3 and 4, on the Colorado River would be minimal.
Although its future is uncertain because of continuing legal action, a water-sharing project between the LCRA and the SAWS, involving Regions K and L, could affect water resources in the region. An off-channel storage reservoir in Wharton County is proposed. The planned project would provide 377,000 ac-ft/yr (465 million m3/yr) of water to Regions K and L, and Region L would receive 150,000 ac-ft/yr (185 million m3/yr) from Region K starting in the 2020 decade (NRC 2011b). The LCRWPG has considered the effects of the LCRA-SAWS Project while estimating the water availability in its 2011 Region Water Plan (LCRWPG 2010).
The WSEC is a 1,320-MW power plant, proposed to be located in Matagorda County near Farm-to-Market (FM) Road 2668, 1 mi (1.6 km) south of the Port of Bay City, approximately 5 mi (8 km) northeast of the STP site. On October 13, 2008, proponents for WSEC applied to LCRA for a new firm water supply of 22,000 ac-ft/yr (27 million m3/yr), with the total diversion from the Colorado River estimated at 29,750 ac-ft/yr (37 million m3/yr), accounting for delivery losses (NRC 2011b). The total WSEC withdrawal would be about 2 percent of the estimated water available to Matagorda County users in the 2030 to 2060 timeframe (LCRWPG 2010). Because the incremental water withdrawal for WSEC is a small percentage of the water available to the local region, the NRC staff concludes that the impact of WSEC withdrawal on the regions water supply would be minimal.
The City of Corpus Christi has a water right amounting to 35,000 ac-ft/yr (43 million m3/yr) from the Colorado River (NRC 2011b). Water planning of the City of Corpus Christi indicates that the city may start to use its currently unused water rights from the Colorado River by 2020 or sooner, depending on demand (City of Corpus Christi 2011). Although the City of Corpus Christi does not currently use its water rights from the Colorado River, these rights are accounted for in Region K water availability planning. To use its water rights from the Colorado River, the City of Corpus Christi would build Phase II of Mary Rhodes Pipeline from Bay City to Lake Texana to tie into the existing Phase I of the pipeline that delivers water from Lake Texana to the city (NRC 2011b). The City of Corpus Christi water right would represent approximately 2.4 percent of the estimated water available to Matagorda County users in the 2030 to 2060 timeframe (LCRWPG 2010). Because the incremental water withdrawal by the City of Corpus Christi is a small percentage of the water available to the local region, the NRC staff concludes that the impact of the City of Corpus Christi withdrawal on the regions water supply would be minimal.
Freshwater inflow needs for Matagorda Bay represent the only use of lower Colorado River waters downstream of the STP site (NRC 2011b). The LCRA, TCEQ, Texas Parks and Wildlife Department, and the TWDB estimated Matagorda Bay freshwater inflow needs (LCRA et 4-62
Environmental Impacts of Operation al. 2006). LCRA et al. (2006) estimated a target for freshwater inflow that would optimize productivity of selected estuarine species and the critical freshwater inflow that would promote repopulation of finfish and shellfish following a dry period. The average target freshwater inflow was established at 118,975 ac-ft/mo (146.7 million m3/mo) or 1,972 cfs (55 m3/s). The critical freshwater inflow was established at 36,000 ac-ft/mo (44 million m3/mo) or 597 cfs (17 m3/s).
Recommendations made in LRCA et al. (2006) with regard to inflow needs continue to be reviewed by the TCEQ, and, if formally established, they could make the cited volume of surface water discharge unavailable for other uses (NRC 2011b).
NRC and USACE (NRC 2011b) considered the U.S. Global Change Research Programs (USGCRPs) most recent compilation of the state of knowledge relative to GCC effects (USGCRP 2009). NRC and USACE reviewed forecasted increases in temperature and decreases in precipitation for the Colorado River watershed reported by USGCRP (2009) and determined that GCC could affect water supply in the Colorado River Basin by reducing surface runoff and increasing evapotranspiration during the period of STP, Units 1 and 2, extended operations. The USGCRP has identified that the region is likely to experience water conflicts by 2025 because of increasing population and potential endangered species needs (USGCRP 2009). The NRC and USACE (NRC 2011b) concluded that while the GCC-related changes may not be insignificant nationally or globally, their impact on STP regional water resources would not be destabilizing. Thus, the NRC staff concludes that GCC effects would not substantially add to regional surface water cumulative impacts during the license renewal term for STP, Units 1 and 2.
Historically, the waters of the Colorado River Basin have been extensively used, and the region has surface water planning, allocation, and development systems in place to manage the use of its limited surface water resources. The cumulative impact on surface water use in Region K relative to the unaltered conditions prior to these uses, from past and present diversions and reasonably foreseeable future projects, would noticeably alter but not destabilize the surface water resource. Nevertheless, due to the potential impacts associated with water use conflicts and maintenance of Colorado River flows to Matagorda Bay, the NRC staff concludes that cumulative impacts on surface water resources during the license renewal term would be MODERATE.
4.12.3.2 Cumulative Impacts on Groundwater Resources Water drawn from the Shallow Chicot Aquifer in the vicinity of the STP site is slightly saline, and, consequently, it is used primarily for livestock watering. Offsite livestock wells are located close to the STP site boundary, and four are located on leased grazing land within the STP site (i.e., between the MCR and the Colorado River) (see Section 2.2.5.1). No groundwater is withdrawn from the Shallow Chicot Aquifer for use by STP, Units 1 and 2. STP operation does result in seepage from the MCR entering the Upper Shallow Aquifer, and the MCR water carries with it the constituents contained in plant cooling water (e.g., tritium, TDS) (NRC 2011b; STPNOC 2010b). Operation of the plant has also resulted in leaks and releases to the Shallow Aquifer within the protected area (e.g., the TDS line leaks and steam condensate discharge)
(MACTEC 2009). These releases have not substantially affected the groundwater quality within the STP site, and impacts on groundwater quality off site would be less. Specifically, for the Shallow Chicot Aquifer, tritium levels remain below the EPA primary DWS, and TDS concentrations remain within the range defining a slightly saline groundwater. Because of the reasons presented above, the NRC staff concludes that cumulative impacts on groundwater use and quality during the license renewal term, related to the Shallow Chicot Aquifer, would be SMALL.
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Environmental Impacts of Operation In contrast, water drawn from the Deep Chicot Aquifer is of higher quality. Aside from the existing STP-owned groundwater wells completed in the Deep Chicot Aquifer that supply STP, Units 1 and 2, the closest wells to the STP site completed in the Deep Chicot Aquifer are the public water supply wells in the communities of Selkirk and Exotic Isle, which are located adjacent to the STP site eastern boundary (see Section 2.2.5). Wells for these communities are approximately 1 mi (1.6 km) from the nearest STP production well and 3.75 mi (6 km) from STP, Units 1 and 2. Review of other existing or planned projects in the surrounding area indicates groundwater use by Equistar Chemicals LPs Matagorda facility, the OXEA Corporation Bay City Plant, and the municipal water supply for Bay City. The shortest distance from this group of facilities to STP is approximately 5 mi (8 km) (NRC 2011b).
Groundwater used at STP, Units 1 and 2, is from the Deep Chicot Aquifer. Public water supplies and other large-scale industrial users also draw from this aquifer. As noted in Section 4.4.2.1, there has been a regional drawdown in the Deep Aquifer in the vicinity of the STP site. By 1980, a regional drawdown of approximately 35 ft (11 m) was attributed to groundwater development to the north of the STP site (STPNOC 2009a). Proposed STP, Units 3 and 4, would also use the groundwater from the production wells at the STP site.
Groundwater use by STP, Units 1 and 2, is 768 gpm (2,910 L/min) for normal operations (see Section 2.1.7.2). Groundwater use by the proposed STP, Units 3 and 4, is 975 gpm (3,690 L/min) for normal operations. These rates represent 2.4 and 3.1 percent, respectively, of the annual rate of groundwater use permitted by the CPGCD in Matagorda County during the 2008 to 2010 permit period (NRC 2011b). Based on the best available information, other than the proposed STP, Units 3 and 4, there are no other foreseeable nearby new projects with a substantial demand for groundwater. The aquifer drawdown projections from STP well pumping for selected distances are shown in Table 4-6 and discussed in Section 4.4.2.1. Potential impacts of drawdown from STP operations on other groundwater users, and from other users pumping on STP, would be minimal because the Deep Chicot Aquifer remains confined, and changes in pumping lift over the 20-year renewal period would not be substantial.
Because of higher groundwater use in the past, subsidence has been an issue in the STP region. The USGS (Ryder and Ardis 2002) has described subsidence in Matagorda County as less than 1 ft (0.3 m) since 1900 over most of the region, with somewhat higher subsidence of 1.5 ft (0.46 m) noted in western Matagorda County. STPNOC has observed a subsidence rate of less than 0.1 in. (0.25 cm) to about 0.2 in. (0.50 cm) per year during construction and through STP, Units 1 and 2, operations in 1993 (STPNOC 2008b). The updated final safety analysis report (UFSAR) for STP, Units 1 and 2, projected regional subsidence from 1973 through 2020 to be between 2.5 and 3 ft (0.76 and 0.9 m) based on a projected regional groundwater decline of 87 ft (26.5 m) and subsidence coefficients derived from regional observations (STPNOC 2009c). To minimize the potential for subsidence, STPNOC spaced its main production wells (i.e., wells 5, 6, and 7) over 5,000 ft (1,520 m) apart and distributes the pumping rates among them. All groundwater users in Matagorda County operate their wells under the rules of the CPGCD (2009). The purpose of the CPGCD is to provide for conserving, preserving, protecting, and recharging the groundwater to control subsidence and prevent the waste and pollution of the groundwater resource. Groundwater use under the rules of the CPGCD minimizes the potential for excessive drawdown, saltwater intrusion, or land subsidence impacts to arise and affect neighboring groundwater users (CPGCD 2009). Current observations of drawdown are consistent with the drawdown projected in the UFSAR for STP, Units 1 and 2, and subsidence projections are consistent with observations. These potential impacts are greatest on site where they are monitored. As noted in Section 4.3.2.1, drawdown at STP production wells is currently in equilibrium with the surrounding groundwater aquifer, and continued operation of STP wells for an additional 20 years beyond the current license would 4-64
Environmental Impacts of Operation increase drawdown by less than 1 ft (0.3 m). Additional subsidence resulting from this change in drawdown during the license renewal term would be minimal.
Operation of STP, Units 1 and 2, does not adversely affect groundwater quality in the Deep Chicot Aquifer because of the low-conductivity layer between 100 and 150 ft (30 and 46 m) thick that separates and isolates the Shallow Chicot Aquifer from the Deep Chicot Aquifer. Similarly, because of the hydraulic isolation of the Deep Chicot Aquifer from the Shallow Chicot Aquifer and any releases at the land surface, other nearby groundwater users are also not adversely affecting groundwater quality in the Deep Chicot Aquifer. Groundwater drawdown at the STP production wells is great enough to reverse the regional gradient and draw groundwater in the Deep Chicot Aquifer from beneath the STP site into the production wells. Thus, if any releases from the plant were to move from the Shallow to the Deep Chicot Aquifer, the contamination would likely be drawn to and intercepted by STP groundwater production wells (NRC 2011b).
With regard to the Deep Chicot Aquifer, because of the reasons presented above, the NRC staff concludes that cumulative impacts on groundwater use and quality during the license renewal term would be SMALL.
4.12.4 Aquatic Resources This section addresses the direct and indirect effects of license renewal on aquatic resources when added to the aggregate effects of other past, present, and reasonably foreseeable future actions. The geographic area considered in this analysis includes the STP site and the portion of the lower Colorado River basin within influence of STP operations, including Matagorda Bay.
In agreement with NEPA guidance, the baseline is the condition of the resource without the action (i.e., under the no-action alternative). Under the no-action alternative, the plant would shut down, and the resource would conceptually return to its condition without the plant, which is not necessarily the same as the condition before the plant was constructed. The baseline condition or benchmark for assessing cumulative impacts on aquatic resources takes into account the preoperational environment, as recommended by EPA (1999) for its review of NEPA documents:
Designating existing environmental conditions as a benchmark may focus the environmental impact assessment too narrowly, overlooking cumulative impacts of past and present actions or limiting assessment to the proposed action and future actions. For example, if the current environmental condition were to serve as the condition for assessing the impacts of relicensing a dam, the analysis would only identify the marginal environmental changes between the continued operation of the dam and the existing degraded state of the environment. In this hypothetical case, the affected environment has been seriously degraded for more than 50 years with accompanying declines in flows, reductions in fish stocks, habitat loss, and disruption of hydrologic functions. If the assessment took into account the full extent of continued impacts, the significance of the continued operation would more accurately express the state of the environment and thereby better predict the consequences of relicensing the dam.
Sections 2.2.5 and 2.2.7 of this SEIS present an overview of the history and factors that led to the current condition of the aquatic features on the STP site, the Colorado River, and Matagorda Bay. Since the 1920s, development and redirection of the lower Colorado River has affected the water quality, water chemistry, and aquatic resources. These alterations have increased the freshwater input to Matagorda Bay and marine and estuarine inputs to the lower Colorado River, resulting in a change in salinity. Anthropogenic activities has decreased available habitat for some species and increased available habitat for others. For example, construction and 4-65
Environmental Impacts of Operation development projects have reduced the area available for aquatic organisms to navigate through the Colorado River and Matagorda Bay due to erosion, habitat modification, and habitat fragmentation. Overall, species richness and diversity have increased in the lower Colorado River near STP (from the GIWW to navigation mile marker 8) based on surveys in 2007 to 2008 compared to similar surveys in 1983 to 1984 (ENSR 2008b; NRC 1986, 2011b; STPNOC 2010b). The change in the aquatic community could be due to differences in study methods (e.g., differences in sampling protocol over time), environmental conditions (e.g., variance in weather conditions during the two sampling efforts), or from human activities (e.g., the river diversion projects that has increased the marine and estuarine flow into the lower Colorado River).
Many natural and anthropogenic activities can influence the current and future aquatic biota in the area surrounding STP. Potential biological stressors include continued entrainment, impingement, and potential heat shock from STP, Units 1 and 2 (if the license renewal is granted), as described in Section 4.5, construction and operation of STP, Units 3 and 4, other water use projects, urbanization, fishing, and GCC, as described below.
Construction and Operations of STP, Units 3 and 4. In 2007, STPNOC submitted an application to the NRC to construct and operate two additional nuclear reactors on the STP site, referred to in this SEIS as STP, Units 3 and 4. In 2011, NRC published its final EIS evaluating the environmental impacts of the proposed construction and operations of Units 3 and 4 (NRC 2011b). This project would have overlapping impacts with the continued operations of Units 1 and 2. For example, all four units would draw water from the MCR, which need to be filled higher than current levels (STPNOC 2010c). STPNOC would draw the additional makeup water from the Colorado River through the RMPF. Species impinged and entrained would be similar to those impinged and entrained during operations of Units 1 and 2. Past impingement and entrainment studies and NRC evaluations of such studies concluded that impacts to the important species would be insignificant and minor, primarily because the density of organisms in the vicinity is rather low and the species are ubiquitous in the region (McAden 1984, 1985; NRC 1986, 2011b). Additionally, the design and operation of the RMPF minimize impacts on aquatic biota, as described in Section 4.5.2. Therefore, impacts from operation of the RMPF (impingement, entrainment, and entrapment) for four units are unlikely to destabilize aquatic resources in the lower Colorado River.
Operation of the four units would also affect aquatic resources in the MCR. Higher intake levels to provide cooling water for four units would increase impingement and entrainment at the CWISs in the MCR. The two discharges from the four units would increase the water temperature in the MCR. Aquatic organisms in the MCR would either avoid or acclimate to the new conditions. Because the aquatic community in the MCR is isolated from the onsite water bodies and the Colorado River, these impacts would not noticeably alter the aquatic resources within the geographic area of interest.
Operation of two additional units would increase the frequency and duration of discharges from the MCR into the Colorado River. STPNOC would manage discharges, as needed, based on water quality in the MCR and TPDES permit conditions (STPNOC 2010b). Chemical releases from discharging into the Colorado River are expected to be below the criteria for protection of aquatic life (TCEQ 2005). NRC (2011b) determined that under certain conditions, such as poor river water quality, the size and configuration of the thermal plume could impede passage of the aquatic organisms in the Colorado River, including species that are of commercial and recreational importance and species that are Federally managed and have designated EFH.
NRC (2011b) concluded that the foraging behavior and high fecundity of such aquatic 4-66
Environmental Impacts of Operation organisms suggest that the effects from the thermal plume would not noticeably alter or destabilize the populations or aquatic community in the lower Colorado River.
NRC (2011b) concluded that the impacts to aquatic resources from other construction and operational activities of all four units would not noticeably alter or destabilize aquatic resources.
These impacts include additional seepage from the MCR that could influence flow to Little Robbins Slough and wetlands, increased non-permeable surfaces (e.g., parking lots and buildings) that would change the flow of stormwater into the drainages on site, maintenance dredging in the Colorado River, shoreline restoration activities along the Colorado River, and disturbances from vessel traffic to marine mammals (NRC 2011b).
Other Water Use Projects. Future projects near STP that would withdraw or redirect significant quantities of the Colorado River include the proposed LCRA-SAWS Project, WSEC, and municipal use (TWDB 2006; WSEC 2011).
The LCRA-SAWS Project is projected to generate 150,000 ac-ft of new water supplies by 2060 through conjunctive use of groundwater from the Gulf Coast Aquifer and surface water supplies from the Colorado River (TWDB 2006). LCRA-SAWS (2009) will evaluate impacts to aquatic habitat in the Colorado River with and without the proposed project. WSEC, a proposed coal-fired generating plant, would withdraw approximately 22,000 ac-ft per year of water from the lower Colorado River (WSEC 2011). LCRA included water use from WSEC growth in its water supply resource plan for Region K, Matagorda County. Other sources of water use included in water supply estimates include increases in municipal use due to population, manufacturing, mining, irrigation, transfer of water via the proposed Mary Rhodes Pipeline II, and other categories (TWBD 2006). From 2010 to 2040, the plan estimates an annual increase of 12 percent without the WSEC Project and 80 percent with the WSEC Project (LCRA 2008).
These projects have the potential to change the freshwater contribution in the river within the vicinity of STP by redirecting the flow or by withdrawing a significant amount of freshwater.
Changes in flow of saltwater into the river could change the habitat (or salinity) for many species. In response, estuarine-marine species would likely become more abundant if the salinity increases whereas freshwater species would likely become more abundant if the salinity decreases. The Colorado River diversion project, which increased the flow between the Colorado River and Matagorda Bay, resulting in an increase in salinity near the STP site, likely influenced the shift in aquatic communities near STP towards estuarine-marine species (ENSR 2008b; NRC 1975, 1986, 2011b).
Urbanization and Development. Residential or industrial development in the vicinity of STP site can affect aquatic resources. Increased urbanization and population growth, while projected to be low in comparison to other locations in Texas (NRC 2011b), would still lead to increased development along the shores of the Colorado River that can contribute to cumulative impacts in the lower Colorado River basin through habitat loss and nonpoint source pollution. Future activities could lead to increased water needs, nonpoint and point source water pollution, vessel traffic on the waterways, and maintenance dredging.
Proposed future power generation facilities to support increased energy usage, including WSEC and the Victoria County Station, may require the development of new transmission systems in the geographic area of interest. The WSEC may be required to add additional transmission capabilities within the vicinity for its power transmission, but that information is currently not available to evaluate (WSEC 2011). If WSEC or Victoria County Station build new transmission corridors, they would likely have a minor effect on aquatic species assuming the owners consider aquatic resource when routing transmission lines and employ best management practices (BMPs) during construction and maintenance activities.
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Environmental Impacts of Operation STPNOC would use existing transmission corridors to support power transmission from proposed Units 3 and 4 and during the period of extended operations for Units 1 and 2.
STPNOC (2010b, 2010c) would employ vegetation maintenance and control along existing and future corridors, which would not be expected to increase and contribute to cumulative effects (NRC 2011b).
Fishing. Commercial and recreational fishing in the Colorado River and Matagorda Bay would likely continue to increase in the future. The region is recognized for recreational fishing of many species, and fishing would likely increase with increased urbanization in the vicinity.
Matagorda Bay is one of the recognized regions in Texas for commercial fishing, primarily associated with the shrimp industry (TPWD 2002), although these fisheries are not significant contributors to employment in the region (NRC 2011b). In efforts to improve the fisheries in the area, TPWD has designated the most eastern half of the eastern arm of Matagorda Bay as a finfish and shellfish nursery, closing the area to commercial fishing and commercial harvesting of oysters (LCRA et al. 2006). A freshwater inflow needs study for Matagorda Bay has identified several alternatives associated with water management strategies designed to improve commercial fishing opportunities (LCRA et al. 2006). If management strategies do not improve sustainability of fisheries, increased fishing pressures could result in overall decreased biological productivity for the Colorado River and Matagorda Bay.
Climate Change. In addition to direct anthropogenic activities, GCC could impose additional stressors on aquatic communities. The presence of natural environmental stressors (e.g., short-or long-term changes in precipitation or temperature) would contribute to the cumulative environmental impacts to the Colorado River and Matagorda Bay. GCC could lead to decreased precipitation, increased sea levels, varying freshwater inflow, increased temperatures, increased storm surges, greater intensity of coastal storms, and increased nonpoint source pollution from runoff during these storms (GCRP 2009; Montagna et al. 1995; Nielsen-Gammon 1995). Such changes could directly affect habitat for aquatic communities by altering the flow of freshwater, water quality, salinity, and dissolved oxygen levels. Habitat alterations could result in changes to community structure, species abundance, and species diversity. These kinds of changes occurred in the vicinity of STP with the diversion of the Colorado River into the Gulf and Matagorda Bay since the 1920s (NRC 2011b).
GCC could also slow efforts to restore nursery habitats in Matagorda Bay. The Colorado River diversion project increased the flow of freshwater into the bay in an effort to improve habitat for wetlands, oyster reefs, and other nursery grounds (USACE 2009). However, LCRA et al. (2006) indicated slower than expected results and showed that more freshwater inflow into the bay is needed to increase biological productivity in the bay. The effects of rising sea level, which would increase salinity in the bay, would likely be counterproductive to the current efforts to increase freshwater flows into the Bay. Changes in water quality in Matagorda Bay and the lower Colorado River could create areas that are hypoxic (low in dissolved oxygen) and lead to further stress on aquatic communities (Montagna et al. 1995). These stressors would result in shifts in species ranges, habitats, and migratory behaviors and also alter ecosystem processes (GCRP 2009).
Conclusion. Past, present and reasonably foreseeable future activities exist in the geographic area of interest that could contribute to cumulative effects to aquatic ecological resources.
Future development of industries that compete for water in the Colorado River, such as WSEC, as well as management of water budgets across the State of Texas through diversion projects like the LCRA-SAWS Project and the Mary Rhodes Pipeline Phase II Project, would likely affect aquatic resources in the lower Colorado River. Such actions in combination with other direct and indirect anthropogenic and natural environmental stressors, including GCC, would 4-68
Environmental Impacts of Operation cumulatively lead to effects on the aquatic communities that would noticeably alter important attributes such as species range, habitat availability, ecosystem processes, migratory corridors and behavior, species diversity, and species abundance. The NRC staff concludes that cumulative impacts from past, present, and reasonably foreseeable actions to aquatic resources in the geographic area of interest would be MODERATE.
4.12.5 Terrestrial Resources Historic Conditions. Section 2.6 discusses the ecoregion in which the STP site liesthe Western Gulf Coastal Plainwhich is dominated by tallgrass and shortgrass prairie.
Historically, these prairies covered about 6.5 million ac (2.6 million ha) within Texas. During the past century, urban and industrial development and agricultural expansions have fragmented the natural habitat. In the late 1800s, ranchers introduced large numbers of cattle to the region.
Livestock grazing continues to be a major land use, but the majority of land has been altered for cultivation of rice, sugarcane, forage, and grain. By the 1980s, Diamond and Smeins (1984) estimated that less than one percent of Texass native coastal prairie grasslands remained in a relatively pristine state.
The Texas Gulf coasts historically contained abundant and diverse wetlands. Approximately 30 percent of the coastal prairies along the Texas Gulf coasts were once wetlands (TPWD 2010). Human activities, including landscape alteration for agricultural, industrial, or urban uses, continue to significantly threaten remaining wetland habitats (TPWD 2005). In addition, decreased precipitation, sea-level rise, more frequent high-intensity storm surges, and increased temperatures resulting from GCC have contributed to wetland losses (GCRP 2009).
Nonetheless, rice fields, prairie wetlands, and coastal marshes continue to provide important habitat for waterfowl and many other wildlife species. TPWD (2005) identified the Gulf coasts and associated grassland prairies, wetlands, marshes, and agriculture as one of the most important wintering areas for North Americas waterfowl populations.
On the immediate site, STPNOC cleared land for, built, and filled the 7,000-ac (2,800-ha) MCR and cleared an additional 300 ac (120 ha) for the facilitys buildings, parking lots, roads, and other infrastructure.
In the region surrounding the STP site, construction of many industrial facilities and wastewater treatment plants have resulted in the loss of terrestrial habitat. These facilities include:
- the Formosa Plastics Corporation plant,
- the Texas Liquid Fertilizer Company,
- the Alcoa aluminum plant,
- the Equistar Chemical LPs Matagorda facility, and
- the OXEA Corporations chemical plant.
Other Projects. Many projects near the STP site could affect the terrestrial environment in the future. These projects are discussed in this section.
Chemicals Inc. has a specialty chemical plant near STP. The plants 107.5-ac (44-ha) site is located about 5 mi (8 km) south of Bay City (Chemicals Inc. 2011).
About 5 mi (8 km) northeast of the STP site, a 1,200-ac (490-ha) tract of land is the site for the WSEC, a 1,320-net-mW coal and petroleum coke plant (MCEDC 2011). The TCEQ granted the project its air quality permit in September 2010. The status of the facilitys wastewater permit is 4-69
Environmental Impacts of Operation uncertain. Coal-fired plants are a major source of air pollution in the U.S. because they release sulfur dioxide, nitrogen oxides, mercury, carbon dioxide, and particulates. Nitrous oxides and sulfur dioxides combine with water to form acid rain, which can lead to erosion and changes in soil pH levels. Mercury deposits onto soil and surface water, which may then be taken up by terrestrial and aquatic plant or animal species and poses the risk of bioaccumulation.
In September 2007, STPNOC submitted COL applications to the NRC for two new nuclear units on the STP site. If approved, STPNOC would construct the new units adjacent to the currently operating Units 1 and 2. As a result, about 540 ac (220 ha) would be disturbed. Of this, the new reactors, the associated buildings and infrastructure, and a new heavy haul road would occupy 300 ac (120 ha), and the remaining 240 ac (100 ha) would only be temporarily disturbed for temporary buildings, construction equipment storage, and material laydown (NRC 2011b).
The majority of land that would be disturbed is currently maintained or mowed grasslands, shrub-scrub habitat, or used for existing industrial activities. The new units would require additional transmission lines to transfer power to the regional electric grid. However, STPNOC would not create any new or expand any existing transmission line corridors (NRC 2011b). In the NRCs EIS regarding the proposed new STP units, the NRC (2011b) concluded that impacts to the terrestrial environment would be SMALL for this proposed action.
Development of the proposed Mary Rhodes Pipeline Phase II Project would likely also contribute to regional habitat loss and fragmentation. Potential cumulative impacts resulting from construction and operation of the proposed water transport line would be similar to those impacts from constructing and maintaining new transmission line corridors and include habitat fragmentation, creation of early successional habitat, and displacement of certain wildlife species.
For projects listed above, construction and operation would impact wildlife by increasing noise and traffic, which could alter behavior or cause a shift in habitat use in undisturbed land bordering construction areas. Birds in the immediate area would be more likely collide with tall structures and construction equipment. However, construction impacts would be short-term and relatively minor. Hence, the impacts would not destabilize the environment.
Urbanization and Habitat Fragmentation. As the region surrounding the STP site becomes more developed, habitat fragmentation will increase. Species that require larger ranges, especially predators, will likely suffer reductions in their populations. In contrast, herbivores will experience less predation pressure, and their populations are likely to increase. Edge species will likely benefit from the fragmentation, while species that require interior forest or swamp habitat will likely suffer. The transmission line corridors established for STP transmission lines represent habitat fragmentation, though many of these corridors pass through cultivated land that has already been converted from its native habitat or shrub-scrub habitat, which was minimally altered during transmission line construction. Habitat fragmentation of surrounding areas may increase the value of the network of wetlands within the Texas Prairie Wetlands Project110 ac of which is set aside on the STP sitebecause this land will not experience fragmentation or other human-induced impacts.
Parks and Wildlife Preserves. The FWS and State have set many lands in the STP region aside as parks, preserves, or management areas. These include:
- Brazos Bend State Park,
- Mad Island Marsh Preserve,
- Mad Island Wildlife Management Area, 4-70
Environmental Impacts of Operation
- Big Boggy National Wildlife Refuge, and
Section 2.2.6 of this SEIS describes these parks and preserves in more detail. These areas will continue to provide valuable habitat to native wildlife, migratory birds, and native prairie and marsh vegetation. Both the National Wildlife Refuge Network and the Texas Prairie Wetland Project are ongoing efforts. In the future, FWS and Ducks Unlimited will continue to acquire lands for these projects.
Conclusion. The NRC staff examined the cumulative effects of the construction of STP, neighboring energy projects, continued urbanization and habitat fragmentation, and nearby parks and wildlife preserves. The NRC staff concludes that the minimal terrestrial impacts on the continued STP operations would not contribute to the overall decline in the condition of terrestrial resources. The NRC staff believes that the cumulative impacts of other and future actions during the term of license renewal on terrestrial habitat and associated species, when added to past, present, and reasonably foreseeable future actions, would be MODERATE.
4.12.6 Human Health Radiological Impacts. The radiological dose limits for protection of the public and workers have been developed by the NRC and EPA to address the cumulative impact of acute and long-term exposure to radiation and radioactive material. These dose limits are codified in 10 CFR Part 20 and 40 CFR Part 190. For the purpose of this analysis, the area within a 50-mi (80.4-km) radius of STP was included. The REMP conducted by STPNOC in the vicinity of the STP site measures radiation and radioactive materials from all sources (i.e., hospitals and other licensed users of radioactive material); therefore, the monitoring program measures cumulative radiological impacts. Within the 50-mi (80-km) radius of the STP site, there are currently no other nuclear power reactors or uranium fuel cycle facilities.
Radioactive effluent and environmental monitoring data for the 5-year period from 2006 to 2010 and, for this final SEIS, data from the 2012 reports were reviewed as part of the cumulative impacts assessment. In Section 4.8.1 of this SEIS, the NRC staff concluded that impacts of radiation exposure to the public and workers (occupational) from operation of STP during the renewal term are SMALL. The NRC and the State of Texas would regulate any future actions in the vicinity of the STP site that could contribute to cumulative radiological impacts.
As stated in its ER, the applicant stores its spent nuclear fuel in its spent fuel pool. The applicant estimates that there is adequate capacity in its spent fuel pool to store spent fuel until 2025. For reactor operations past that date, STPNOC plans to install a dry fuel storage system at the STP site for the storage of its spent fuel. The installation and monitoring of this facility will be governed by NRC requirements in 10 CFR Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste. Radiation from this projected storage facility as well as from the operation of STP, Units 1 and 2, are required to be within the radiation dose limits in 10 CFR Part 20, 40 CFR Part 190, and 10 CFR Part 72. The NRC performs periodic inspections of every licensed dry fuel storage facility to verify its compliance with all licensing and regulatory requirements. Currently, the applicant has not submitted an application to the NRC for the dry fuel storage system, so no further information is available.
In September 2007, STPNOC applied to the NRC for a COL pursuant to the requirements of 10 CFR Part 52 for the construction and operation of two additional reactors at the STP site.
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Environmental Impacts of Operation STPNOC submitted information on the site and surrounding area to NRC in its application for the COL. The NRC reviewed the COL application and issued the final EIS (NRC 2011b), which analyzed the impacts on the surrounding communities and natural resources to determine if the STP site is suitable to support two additional reactor units (proposed Units 3 and 4). The NRC also evaluated the cumulative impacts of the operation of four reactor units and considered the possible life extension of STP, Units 1 and 2, for 20 years. In the final EIS, the NRC staff concludes that cumulative radiological impacts would be SMALL.
In addition, pursuant to 10 CFR Part 20 and 40 CFR Part 190, the cumulative radiological impacts from STP, Units 1 and 2, the possible projected dry fuel storage system, and two additional reactor units are required to meet the acceptable radiation dose limits (protecting human health) specified in these regulations. EPA regulation (40 CFR 190) limits the total dose to an offsite individual near STP from all uranium fuel cycle facilities and all pathways, located at STP. Furthermore, the STP REMP would monitor the buildup of radioactivity in the environment to effectively ensure that the levels remain acceptable. Based on this information, the staff concludes that cumulative radiological impacts would be SMALL.
Electromagnetic Fields Impacts. For electromagnetic fields impacts on human health, the staff determined that not all of the STP transmission lines are operating within design specifications and meet current NESC criteria. In Section 4.8.4, the NRC staff determined that the potential impacts from STP transmission lines were SMALL to MODERATE. However, STP addressed the issue of acute shock by providing the staff with potential actions it is considering to mitigate the impacts. Therefore, the staff concludes that the transmission lines are not expected to significantly affect the overall potential for electric shock from induced currents within the analyzed area of interest.
With respect to the effects of chronic exposure to ELF-EMF, as discussed in Section 4.8.5, the GEIS finding of uncertain is appropriate to STP.
For the reasons listed above, the staff concludes that the cumulative impacts of continued operation of the STP transmission lines and other transmission lines in the affected area would be SMALL to MODERATE.
Microorganisms Impacts. In the environmental review for the proposed Units 3 and 4, the NRC staff determined that other projects (e.g., the Mary Rhodes Pipeline Phase II Project) would use or divert river water upstream of STP. These projects, depending on the magnitude and without mitigation measures, could reduce freshwater river flow and increase the ambient river water temperature (Neuces River Authority 2001; TWDB 2006b; WSEC 2009). Therefore, this cumulative effect on Colorado River conditions could be favorable for an increased presence of thermophilic microorganisms and, subsequently, increase the risk of public exposure to potential harmful microorganisms (thermophilic). However, based on past data on waterborne diseases from recreational water activities in Texas and the discharging limits on STP, cumulative impacts to human health due to exposure to microorganisms in the Colorado River would likely be minimal (CDC 2009; TDSHS 2010). Hence, the staff concludes that cumulative impacts to human health due to exposure to microorganisms in the Colorado River would be SMALL.
4.12.7 Socioeconomics This section addresses socioeconomic factors that have the potential to be directly or indirectly affected by changes in operations at STP, Units 1 and 2, in addition to the aggregate effects of other past, present, and reasonably foreseeable future actions. The primary geographic area of interest considered in this cumulative analysis is Brazoria and Matagorda Counties, where approximately 84 percent of STP employees reside (see Table 2-12). This is where the 4-72
Environmental Impacts of Operation economy, tax base, and infrastructure would most likely be affected since STP workers and their families reside, spend their income, and use their benefits within these counties.
As discussed in Section 4.9 of this SEIS, continued operation of STP, Units 1 and 2, during the license renewal term would have no impact on socioeconomic conditions in the region beyond those already experienced. Accordingly, the NRC concluded that the impacts would be SMALL.
Since STPNOC has no plans to hire additional workers during the license renewal term, overall expenditures and employment levels at STP, Units 1 and 2, would remain relatively unchanged with no additional demand for permanent housing and public services. In addition, since employment levels and tax payments would not change, there would be no population or tax revenue-related land use impacts. Based on this information and other information presented in Chapter 4 of this SEIS, there would be no additional contributory effect on socioeconomic conditions in the future from the continued operation of STP, Units 1 and 2, during the license renewal term beyond what is currently being experienced. The only cumulative contributory effects would come from the other reasonably foreseeable future planned activities at STP, such as the construction and operation of Units 3 and 4.
The NRC completed an environmental review for the construction and operation of STP, Units 3 and 4 (STPNOC 2011b). The potential socioeconomic impacts of the construction and operation of the proposed Units 3 and 4, in addition to the contributory effects of the continued operations of Units 1 and 2, are addressed in the Final EIS (NUREG-1937, Environmental Impact Statement for Combined Licenses (COLs) for South Texas Project Electric Generating Station, Units 3 and 4). The NRC concluded that the impacts would be both adverse and beneficial and could range from SMALL to LARGE in the immediate vicinity of STP.
Therefore, the cumulative impact of the continued operation of STP, Units 1 and 2, when combined with the construction and operation of Units 3 and 4 would be SMALL to LARGE.
There would be a major increase in the demand for temporary (rental) housing and public and business services in the vicinity of the STP site by thousands of construction workers during the years of construction. In addition, during periods of peak construction, there would be a major increase in the volume of construction vehicles and commuter worker traffic, especially during shift changes, on roads in the immediate vicinity of the STP site. Impacts would also occur to local economies in the immediate vicinity of STP due to increased sales, use, and property, and corporate taxes attributable to construction and operation of STP, Units 3 and 4. There would be a noticeable increase in the demand for permanent housing and public services, such as schools, police and fire, and public water and electric services by workers and their families during the years of power plant operations. In addition, there would be a noticeable increase in the number of commuter vehicles during shift changes and refueling outages on roads in the immediate vicinity of the STP site. The specific impact of this action will also depend on the final design, characteristics, and construction practices that would be used by STPNOC and its contractors (STPNOC 2011b).
Environmental Justice. The environmental justice cumulative impact analysis assesses the potential for disproportionately high and adverse human health and environmental effects on minority and low-income populations that could result from past, present, and reasonably foreseeable future actions including STP operations during the renewal term. Adverse health effects are measured in terms of the risk and rate of fatal or nonfatal adverse impacts on human health. Disproportionately high and adverse human health effects occur when the risk or rate of exposure to an environmental hazard for a minority or low-income population is significant and exceeds the risk or exposure rate for the general population or for another appropriate comparison group. Disproportionately high environmental effects refer to impacts or risk of impact on the natural or physical environment in a minority or low-income community that are 4-73
Environmental Impacts of Operation significant and appreciably exceed the environmental impact on the larger community. Such effects may include biological, cultural, economic, or social impacts. Some of these potential effects have been identified in resource areas presented in Chapter 4 of this SEIS. Minority and low-income populations are subsets of the general public residing in the area, and all would be exposed to the same hazards generated from STP operations.
Based on the information discussed in this section, and the analysis of human health and environmental impacts presented in Chapters 4 and 5, it is unlikely there would be any disproportionately high and adverse contributory effect on minority and low-income populations from the continued operation of STP and other reasonably foreseeable future actions during the license renewal term. Therefore, the cumulative impacts on environmental justice during the license renewal term would be SMALL.
4.12.8 Historic and Archaeological Resources This section addresses the direct and indirect effects of license renewal on historic and cultural resources when added to the aggregate effects of other past, present, and reasonably foreseeable future actions. The geographic area considered in this analysis is the APE associated with the proposed undertaking, as described in Section 2.2.9.
Before construction of STP, the area was largely undisturbed and contained archaeological sites. In the early 1970s, the Texas Archaeological Survey conducted cultural resources investigations of the STP site and surrounding area. The investigations included a literature review, a pedestrian survey, and limited subsurface testing (NRC 2011b; STPNOC 2010b, 2010c). The construction of STP was completed in the 1980s, and much of the site had been heavily disturbed by construction activities including the construction of the MCR. Section 2.2.10 presents an overview of the existing historic and archaeological resources located on the STP site. As described in Section 4.9.6, no cultural resources would be affected by relicensing activities associated with the STP site.
Past land development has resulted in impacts on, and the loss of cultural resources near and at, the STP site. The impacts from other past, present, and reasonably foreseeable projects were reviewed to analyze overlapping impacts that might affect cultural resources. Direct impacts would occur if archaeological sites in the APE are physically removed or disturbed. The following projects are located within the geographic area considered for cumulative impacts:
- construction and operation of STP, Units 3 and 4,
- transmission lines, and
- future urbanization.
Construction and operation of STP, Units 3 and 4, transmission lines, and future urbanization have the potential to result in impacts on cultural resources through inadvertent discovery during ground-disturbing activities. However, based on the best available information, there are no known historic or archaeological resources on the STP site. In addition, STPNOC has environmental compliance procedures in place for cultural resource protection and inadvertent discovery and has stated the construction and operation activities would not affect the unrecorded gravesite on the STP site (STPNOC 2011g). Future urbanization near STP would be required to comply with applicable State and Federal laws regarding protection of cultural and archaeological resources, and any impacts would be mitigated accordingly.
Based on this information, the NRC staff finds that the continued operation of STP during the license renewal term would not incrementally contribute to cumulative impacts on historic and 4-74
Environmental Impacts of Operation archaeological resources within STP and in the surrounding area. Therefore, the cumulative impacts on historic and archaeological resources during the license renewal term would be SMALL.
4.12.9 Summary of Cumulative Impacts The staff considered the potential impacts resulting from the operation of STP during the period of extended operation and other past, present, and reasonably foreseeable future actions near STP. The preliminary determination is that the potential cumulative impacts would range from SMALL to MODERATE, depending on the resource. Table 4-17 summarizes the cumulative impacts on resources areas.
Table 4-17. Summary of Cumulative Impacts on Resource Areas Resource Area Cumulative Impact The NRC staff examined the cumulative effects of the continued operation of STP, Units 1 and 2, the construction and operation of STP, Units 3 and 4, and the construction and operation of the nearby WSEC coal plant. The cumulative impacts on criteria pollutants from emissions of effluents from the STP site and Air quality the WSEC would be noticeable (but not destabilizing), principally as a result of the contribution of WSEC. In addition, cumulative effects of GCC would contribute to the degradation of air quality resources in the geographic areas of interest (i.e., AQCR). For these reasons, the cumulative impacts on air quality during the license renewal term would be MODERATE.
Waters of the Colorado River Basin have been extensively used, and the region has surface water planning, allocation, and development systems in place to manage the use of its limited surface water resources. Nevertheless, because of the potential impacts associated with water use conflicts and maintenance of Colorado River flows to Matagorda Bay, the cumulative impacts on surface water Water resources resources during the license renewal term would be MODERATE.
Because of the effective controls by the CPGCD on water use and because the STP operational leaks have not substantially affected the groundwater quality within the STP site, the cumulative impacts on groundwater resources during the license renewal term would be SMALL.
Future development of industries that compete for water in the Colorado River, such as WSEC, as well as management of water budgets across the State of Texas through diversion projects like the LCRA-SAWS Project and the Mary Rhodes Pipeline Phase II Project would likely affect aquatic resources in the lower Colorado River. Such actions, in combination with other direct and indirect Aquatic ecology anthropogenic and natural environmental stressorsincluding GCCwould cumulatively lead to effects on the aquatic communities that would noticeably alter important attributes, such as species range, habitat availability, ecosystem processes, migratory corridors and behavior, species diversity, and species abundance. For these reasons, the cumulative impacts on aquatic ecology during the license renewal term would be MODERATE.
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Environmental Impacts of Operation Resource Area Cumulative Impact The staff examined the cumulative effects of the construction at STP (e.g., proposed STP, Units 3 and 4), neighboring projects, continued urbanization and habitat fragmentation, and nearby parks and wildlife preserves. The staff Terrestrial ecology concludes that the minimal terrestrial impacts on the continued STP operations would not contribute to the overall decline in the condition of terrestrial resources.
For these reasons, the cumulative impacts on terrestrial ecology during the license renewal term would be MODERATE.
The radiological dose limits for protection of the public and workers have been developed by the NRC and EPA to address the cumulative impact of acute and long-term exposure to radiation and radioactive material. The NRC and the State of Texas would regulate any future actions in the vicinity of the STP site that Human health could contribute to cumulative radiological impacts. In addition, the cumulative radiological impacts from operation of STP, Units 1 and 2, the projected dry fuel storage system, and two additional reactor units would be required to meet the radiation dose limits in 10 CFR Part 20 and 40 CFR Part 190. For these reasons, cumulative radiological impacts during the license renewal term would be SMALL.
As discussed in Section 4.12.7, if STPNOC receives NRC approval for the proposed new reactors and decides to construct one or two new nuclear power plants, the socioeconomic impacts of this action during construction could be SMALL to LARGE in the immediate vicinity of STP. The potential environmental Socioeconomics impacts of the new reactor units are addressed in the final EIS (NUREG-1937) prepared by the NRC staff for the construction and operation of the new reactors.
As discussed in Section 4.12.7, there would also be no disproportionately high and adverse impacts to minority and low-income populations from the continued operation of STP during the license renewal term.
Historic & As described in Sections 4.9.6 and 4.12.8, the continued operation of STP during archaeological the license renewal term would not incrementally contribute to the cumulative resources impacts on historic and archaeological resources within STP and in the surrounding area. Therefore, the cumulative impacts on historic and archaeological resources during the license renewal term would be SMALL.
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Request for concurrence on the effects of the proposed South Texas Project license renewal on threatened and endangered species. December 10, 2012. ADAMS No. ML12285A415.
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NUREG-1437, Revision 1, Volumes 1, 2, and 3. June 2013. ADAMS Accession Nos.
ML13106A241, ML13106A242, and ML13106A244.
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South Texas Project, Units 3 and 4, Docket Nos.52-012 and 52-013, Response to RAIs. July 2, 2008. ADAMS No. ML081970465.
[STPNOC] South Texas Project Nuclear Operating Company. 2008c. Letter from S Head, STPNOC, to NRC Document Control Desk.
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Response to RAIs. December 18, 2008.
ADAMS No. ML090860873.
[STPNOC] South Texas Project Nuclear Operating Company. 2008d. South Texas Project, Units 1 and 2. 2007 Annual Environmental and Annual Radiological Environmental Operating Reports. Wadsworth, TX. ADAMS No. ML081280093.
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[STPNOC] South Texas Project Nuclear Operating Company. 2011a. South Texas Project, Units 1 and 2. 2010 Annual Environmental and Annual Radiological Environmental Operating Reports. Wadsworth, TX. ADAMS No. ML111250429.
[STPNOC] South Texas Project Nuclear Operating Company. 2011b. Letter from AW Harrison, Manager Licensing, to NRC Document Control Desk.
Subject:
Transmittal of documents to support review of the STP LRA. TAC Nos. ME 4938 and ME 5122. STP Letter No. NOC-AE-11002720. August 31, 2011. ADAMS Nos. ML11256A056 and ML11256A059.
[STPNOC] South Texas Project Nuclear Operating Company. 2011c. Letter from G.T. Powell, Vice President, STPNOC, to NRC Document Control Desk.
Subject:
Response to RAI for the STP LRA. TAC Nos. ME4938 and ME5122. STP Letter No. NOC-AE-11002719.
September 6, 2011. ADAMS No. ML11255A211.
[STPNOC] South Texas Project Nuclear Operating Company. 2011d. South Texas Project, Units 1 and 2. Radioactive Effluent Release Report for 2010. Wadsworth, TX. ADAMS No. ML11124A121.
[STPNOC] South Texas Project Nuclear Operating Company. 2011e. Letter from GT Powell, Vice President, STPNOC, to U.S. Nuclear Regulatory Commission, Document Control Desk.
Subject:
Response to RAI for the STP LRA. TAC Nos. ME4938 and ME5122. STP Letter No.
NOC-AE-11002723. September 12, 2011. ADAMS No. ML11259A014.
[STPNOC] South Texas Project Nuclear Operating Company. 2011f. Letter from D.W.
Rencurrel, Senior Vice President, STPNOC, to U.S. Nuclear Regulatory Commission, Document Control Desk.
Subject:
Response to Requests for Additional Information for the South Texas Project License Renewal Application (TAC Nos. ME4938 and ME5122) (STP Letter Number NOC-AE-1002761). November 17, 2011. ADAMS No. ML11333A094.
[STPNOC] South Texas Project Nuclear Operating Company. 2011g. Letter from G.T. Powell, Vice President, STPNOC, to U.S. Nuclear Regulatory Commission, Document Control Desk.
Subject:
Response to Requests for Additional Information for the South Texas Project License Renewal Application (TAC Nos. ME4938 and ME5122) (STP Letter Number NOC-AE-1 1002691). July 5, 2011. ADAMS No. ML11193A074.
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5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS This chapter describes the environmental impacts from postulated accidents that might occur during the period of extended operation. The term accident refers to any unintentional event outside normal plant operations that results in a release, or the potential for a release, of radioactive materials into the environment. Two classes of postulated accidents are evaluated in the generic environmental impact statement (GEIS)design-basis accidents (DBAs) and severe accidents (Table 5-1).
Table 5-1. Issues Related to Postulated Accidents Two issues related to postulated accidents are evaluated under the National Environmental Protection Act (NEPA) in the license renewal reviewDBAs and severe accidents.
Issues Category DBAs 1 Severe accidents 2 5.1 Design Basis Accidents In order to receive U.S. Nuclear Regulatory Commission (NRC) approval to operate a nuclear power facility, an applicant for an initial operating license must submit a safety analysis report (SAR) as part of its application. The SAR presents the design criteria and design information for the proposed reactor and comprehensive data on the proposed site. The SAR also discusses various hypothetical accident situations and the safety features that are provided to prevent and mitigate accidents. The NRC staff (the staff) reviews the application to determine if the plant design meets the NRCs regulations and requirements and includes, in part, the nuclear plant design and its anticipated response to an accident.
DBAs are those accidents that both the applicant and the staff evaluate to ensure that the plant can withstand normal and abnormal transients and a broad spectrum of postulated accidents, without undue hazard to the health and safety of the public. Many of these postulated accidents are not expected to occur during the life of the plant but are evaluated to establish the design basis for the preventive and mitigative safety systems of the nuclear power plant. The acceptance criteria for DBAs are described in Title 10 of the Code of Federal Regulations (CFR) Part 50 (10 CFR Part 50) and 10 CFR Part 100.
The environmental impacts of DBAs are evaluated during the initial licensing process, and the ability of the plant to withstand these accidents is demonstrated to be acceptable before issuance of the operating license. The results of these evaluations are found in applicant documentation such as the applicants final safety analysis report (FSAR), the staffs safety evaluation report (SER), the final environmental statement (FES), and Section 5.1 of this supplemental environmental impact statement (SEIS). An applicant is required to maintain the acceptable design and performance criteria throughout the life of the nuclear power plant, including the period of extended operation. The consequences for these events are evaluated for the hypothetical maximum exposed individual; as such, changes in the plant environment will not affect these evaluations. Because of the requirements that continuous acceptability of the consequences and aging management programs (AMPs) be in effect for the period of extended operation, the environmental impacts, as calculated for DBAs, should not differ significantly from initial licensing assessments over the life of the plant, including the period of extended operation. Accordingly, the design of the plant, relative to DBAs during the period of extended 5-1
Environmental Impacts of Postulated Accidents operation, is considered to remain acceptable; therefore, the environmental impacts of those accidents were not examined further in the GEIS.
The Commission has determined that the environmental impacts of DBAs are of SMALL significance for all nuclear power plants because the plants were designed to successfully withstand these accidents. Therefore, for the purposes of license renewal, DBAs are designated as a Category 1 issue. The early resolution of the DBAs (i.e., successfully withstand these accidents) makes them a part of the current licensing basis (CLB) of the plant. The CLB of the plant is to be maintained by the applicant under its current license; therefore, in accordance with 10 CFR 54.30, it is not subject to review under license renewal.
No new and significant information related to the South Texas Project (STP) was identified during the review of the South Texas Project Nuclear Operating Company, LLC (STPNOC)
Environmental Report (ER) (STPNOC 2010), site audit (NRC 2011), the scoping process (NRC 2012), or evaluation of other available information (including comments on the draft SEIS). Therefore, there are no impacts related to these issues beyond those discussed in the GEIS.
5.2 Severe Accidents Severe nuclear accidents are those that are more severe than DBAs because they could result in substantial damage to the reactor core, whether or not there are serious offsite consequences. In the GEIS, the staff assessed the impacts of severe accidents during the period of extended operation, using the results of existing analyses and site-specific information to conservatively predict the environmental impacts of severe accidents for each plant during the period of extended operation.
Severe accidents initiated by external phenomena (e.g., tornadoes, floods, earthquakes, fires, and sabotage) have not traditionally been discussed in quantitative terms in FESs and were not specifically considered for the STP site in the GEIS (NRC 1996). However, the GEIS did evaluate existing impact assessments, including beyond design basis earthquakes, at existing plantsperformed by NRC and by the industry at 44 nuclear plants in the U.S. In addition, the GEIS for license renewal performed a discretionary analysis of sabotages of plant systems in connection with license renewal. In the GEIS, the Commission concludes that the risk from sabotage and beyond design-basis earthquakes at existing plants is small and that the risks from other external events are adequately addressed by a generic consideration of internally initiated severe accidents (NRC 1996).
Based on information in the GEIS, the Commission found that:
The probability weighted consequences of atmospheric releases, fallout onto open bodies of water, releases to groundwater, and societal and economic impacts from severe accidents are small for all plants. However, alternatives to mitigate severe accidents must be considered for all plants that have not considered such alternatives.
The staff identified no new and significant information related to postulated accidents (DBAs and severe accidents) during the review of the STP ER (STPNOC 2010), site audit (NRC 2011), the scoping process (NRC 2012), or evaluation of other available information. Therefore, there are no impacts related to these issues beyond those discussed in the GEIS. However, in accordance with 10 CFR 51.53(c)(3)(ii)(L), the staff has reviewed severe accident mitigation alternatives (SAMAs) for STP. The results of the review are discussed in Section 5.3.
5-2
Environmental Impacts of Postulated Accidents 5.3 Severe Accident Mitigation Alternatives Section 10 CFR 51.53(c)(3)(ii)(L) requires that license renewal applicants consider alternatives to mitigate severe accidents if the staff has not previously evaluated SAMAs for the applicants plant in an environmental impact statement (EIS) or related supplement or in an environmental assessment. The purpose of this consideration is to ensure that plant changes (e.g., hardware, procedures, and training) with the potential for improving severe accident safety performance are identified and evaluated. SAMAs have not been previously considered for STP; therefore, the remainder of Chapter 5 addresses those alternatives.
5.3.1 Overview of Severe Accident Mitigation Alternative Process This section presents a summary of the SAMA evaluation for STP conducted by STPNOC, and the staffs review of that evaluation. The staff performed its review with contract assistance from Pacific Northwest National Laboratory. The staffs review is available in full in Appendix F of this SEIS, and the STPNOCs SAMA evaluation is available in full in Attachment F of STPNOCs ER (LRA Appendix E).
STPNOC conducted the SAMA evaluation for STP with a four-step approach. In the first step, STPNOC quantified the level of risk associated with potential reactor accidents using the plant-specific probabilistic risk assessment (PRA) and other risk models.
In the second step, STPNOC examined the major risk contributors and identified possible ways (SAMAs) of reducing that risk. Common ways of reducing risk are changes to components, systems, procedures, and training.
In the third step, STPNOC estimated the benefits and the costs associated with each of the candidate SAMAs. Estimates were made of how much each SAMA could reduce risk. Those estimates were developed in terms of dollars, in accordance with NRC guidance for performing regulatory analyses. STPNOC also estimated the costs of implementing the candidate SAMAs.
Finally, in the fourth step, STPNOC compared the cost and benefit of each of the remaining SAMAs to determine whether the SAMA was cost beneficial, meaning the benefits of the SAMA were greater than the cost (a positive cost benefit).
5.3.2 Estimate of Risk STPNOC submitted an assessment of SAMAs for STP as part of the ER (STPNOC 2010). This assessment was based on the most recent STP PRA available at that time, a plant-specific offsite consequence analysis performed using the MELCOR Accident Consequence Code System 2 (MACCS2) computer code, and insights from the STP individual plant examination (IPE) and individual plant examination of external events (IPEEE) (HL&P 1992).
Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA analysis. The first is the STP Level 1 and Level 2 PRA model, which is an updated version of the IPE (HL&P 1992) which, in turn, was an update of the earlier model completed for the purpose of supporting changes in certain STP technical specifications (NRC 1994). The second is a supplemental analysis of offsite consequences and economic impacts (essentially a Level 3 PRA model) developed specifically for the SAMA analysis. The SAMA analysis is based on the most recent STP Level 1 and Level 2 PRA model available at the time of the ER, referred to as the STP_REV6 model. The scope of the Level 1 model includes internal and external initiating events.
5-3
Environmental Impacts of Postulated Accidents The following results are based upon the STP model of record (STP_REV6), as presented in the ER (STPNOC 2010). The impact of the sensitivity analysis to updated fire and seismic data on the total core damage frequency (CDF) is provided in Appendix F, Sections F.2.2 (risk estimates) and F.6.2 (cost-benefit evaluation) of this SEIS.
The STP CDF is approximately 6.4x10-6 per year for both internal and external events as determined from quantification of the Level 1 PRA model. The CDF is based on the risk assessment for internally initiated events, which includes internal flooding, and external events, which includes fire, seismic events, external flooding, and tornado events. The internal events CDF is approximately 3.9x10-6 per year, and the external events CDF is approximately 2.5x10-6 per year. The external events CDF includes contributions of approximately 1.0x10-6 per year due to fire events, 7.3x10-8 per year due to seismic events, and 1.4x10-6 per year due to other external events (STPNOC 2010).
When determined from the sum of the containment event tree (CET) sequences, or Level 2 PRA model, the CDF is approximately 6.2x10-6 per year (within acceptable approximation) for both internal and external events. The 6.2x10-6 value derived from the CET was used as the baseline CDF in the SAMA evaluations (STPNOC 2010).
The breakdown of CDF by initiating event is provided in Table 5-2, Table 5-3, Table 5-4, and Table 5-5 for internal, fire, seismic, and other external events, respectively (STPNOC 2011).
5-4
Environmental Impacts of Postulated Accidents Table 5-2. STP Core Damage Frequency for Internal Events
% Contribution % Contribution CDF Initiating event (a) to internal events to total CDF (per year)
CDF(b, c)
Loss of all offsite power 9.6x10-7 25 15 Loss of 345 kV offsite power 6.3x10-7 16 10 Steam generator tube rupture (SGTR) 4.4x10-7 11 7 Excessive loss-of-coolant accident (LOCA) 3.2x10-7 8 5 Steam line break outside containment 2.8x10-7 7 4 Loss of electrical auxiliary building heating, 2.6x10-7 7 4 ventilation, and air conditioning (HVAC)
Turbine trip 1.8x10-7 5 3 Partial loss of main feedwater 1.5x10-7 4 2 Reactor coolant pump (RCP) seal LOCA 1.5x10-7 4 2 Interfacing system LOCA 1.3x10-7 3 2 Loss of DC busses 9.7x10-8 2 2 Small LOCAs 7.5x10-8 2 1 Reactor trip 6.5x10-8 2 1 Other internal events 3.6x10-7 9 6 Total CDF (internal events) 3.9x10-6 100 64 (a)
The impact of the sensitivity analysis to updated fire and seismic data on the total CDF is not included in these results. Section F.2.2 provides a discussion of these impacts.
(b)
Obtained from CDF given in ER Table F.2-1 (STPNOC 2010) divided by the total internal events CDF of
-6 3.89x10 .
(c)
May not total to 100 percent due to round off.
5-5
Environmental Impacts of Postulated Accidents Table 5-3. STP Core Damage Frequency for Fire Events CDF % Contribution to % Contribution to Fire initiator description (a) (per year) fire CDF(b, c) total CDF Fire zone 047 scenario X 4.0x10-7 39 6 Fire zone 071 scenario X 2.1x10-7 21 3 Fire zone 047 scenario B 1.8x10-7 18 3 Control room fire scenario 18 1.2x10-7 12 2 Fire zone 047 scenario BC 6.4x10-8 6 1 Control room fire scenario 23 2.6x10-8 3 0.4
-8 Fire zone 147 scenario O 1.1x10 1 0.2 Control room fire scenario 10 1.0x10-9 <1 <0.1 Total CDF (fire events) 1.0x10-6 100 16 (a)
The impact of the sensitivity analysis to updated fire and seismic data on the total CDF is not included in these results. Section F.2.2 provides a discussion of these impacts.
(b)
Obtained from CDF given in ER Table F.2-1 (STPNOC 2010) divided by fire events CDF of 1.02x10-6.
(c)
May not total to 100 percent due to round off.
Table 5-4. STP Core Damage Frequency for Seismic Events CDF % Contribution to % Contribution to Initiating event(a) (per year) total CDF seismic CDF (b, c)
Seismic event, 0.4g acceleration 4.1x10-8 55 0.6 Seismic event, 0.6g acceleration 2.1x10-8 28 0.3 Seismic event, 0.2g acceleration 9.8x10-9 13 0.2 Seismic event, 0.1g acceleration 2.1x10-9 3 <0.1 Total CDF (seismic events) 7.3x10-8 100 1.1 (a)
The impact of the sensitivity analysis to updated fire and seismic data on the total CDF is not included in these results. Section F.2.2 provides a discussion of these impacts.
(b)
Obtained from CDF given in ER Table F.2-1 (STPNOC 2010) divided by seismic events CDF of 7.31x10-8.
(c)
May not total to 100 percent due to round off.
5-6
Environmental Impacts of Postulated Accidents Table 5-5. STP Core Damage Frequency for Other External Events
% Contribution % Contribution CDF Initiating event (a) to other external to total CDF (per year) events CDF (b, c)
Tornado induced failure of switchyard and 1.1x10-6 79 17 essential cooling pond (ECP)
Essential cooling water (ECW) failure due to 2.9x10-7 21 5 breach of main cooling reservoir (MCR)
External flooding scenarios 2-6 9.5x10-9 <1 0.2 Flood induced loss of offsite power (LOOP) 2.1x10-9 <1 <0.1 Total CDF (other external events) 1.4x10-6 100 22 (a)
The impact of the sensitivity analysis to updated fire and seismic data on the total CDF is not included in these results. See Section F.2.2 for a discussion of these impacts.
(b)
Obtained from CDF given in ER Table F.2-1 (STPNOC 2010) divided by other external events CDF of 1.41 x 10-6.
(c)
May not total to 100 percent due to round off.
As shown in Table 5-2, internal events contribute about 61 percent of the total CDF. The two LOOP eventsLoss of All Offsite Power and Loss of 345 kV Offsite Powerare the largest contributors to the internal event CDF.
As shown in Table 5-5, the CDF for other external events make up the next largest contributor (about 22 percent) of the total CDF. The Tornado Induced Failure of Switchyard and Essential Cooling Pond (ECP) and Essential Cooling Water (ECW) Failure due to Breach of Main Cooling Reservoir (MCR) are the largest contributors in this group.
As shown in Table 5-3, fire events make up the next largest contributor (about 16 percent) of the total CDF. The Fire Zone 047 Scenario X and Fire Zone 071 Scenario X are the largest contributors. Seismic events make up a small contribution of about 1 percent to the total STP CDF. Station blackout contributes about 35 percent (2.2x10-6 per year) of the total CDF while anticipated transients without scram (ATWS) contribute about 4 percent (2.8x10-7 per year) to the total CDF (STPNOC 2011).
In the ER, STPNOC estimated the dose to the population within 80 km (50 mi) of the STP site to be approximately 0.0174 person-Sievert (Sv) (1.74 person-roentgen equivalent man (rem)) per year. The breakdown of the total population dose by containment release mode is summarized in Table 5-6. Large early releases, with induced SGTR and interfacing systems loss of coolant accident (ISLOCA), are the dominant contributors to the population dose risk at STP. Small early releases with pre-existing small containment failure and late releases with no sprays are also significant contributors to the population dose risk.
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Environmental Impacts of Postulated Accidents Table 5-6. Breakdown of Population Dose by Containment Release Mode Population dose (person-rem (b)
Containment release mode (a) per year) % Contribution Large early releases (<3 hrs) 0.68 39 Small early releases (<3 hrs) 0.59 34 Late releases (>3 hrs) 0.42 24 Intact containment 0.05 3 Total 1.74 100 (a)
The impact of the sensitivity analysis to updated fire and seismic data on the release category frequency is not included in these results. Section F.2.2 provides a discussion of these impacts.
(b)
One person-rem=0.01 person-Sv The staff has reviewed STPNOCs data and evaluation methods and concludes that the quality of the risk analyses is adequate to support an assessment of the risk reduction potential for candidate SAMAs. Accordingly, the staff based its assessment of offsite risk on the CDFs and offsite doses reported by STPNOC.
5.3.3 Potential Plant Improvements STPNOCs process for identifying potential plant improvements (SAMAs) consisted of the following elements:
- review of the dominant cutsets and most significant basic events from the current, plant-specific PRA,
- review of SAMA candidates identified for license renewal applications for representative PWR plants, and
- review of other industry documentation discussing potential plant improvements.
Based on this process, an initial set of 21 candidate SAMAs, referred to as Phase I SAMAs, were identified. In Phase I of the evaluation, STPNOC performed a qualitative screening of the initial list of SAMAs and eliminated SAMAs from further consideration using the following criteria:
- The SAMA has already been implemented at STP or would achieve results that have already been achieved at STP by other means.
- The SAMA has estimated implementation costs that would exceed the dollar value associated with eliminating all severe accident risk at STP.
Based on this screening, 16 SAMAs were eliminated, leaving 5 SAMAs for further evaluation. A detailed cost-benefit analysis was performed for each of the 5 SAMAs in the Phase II analysis.
STPNOC calculated the risk reduction that would be attributable to each candidate SAMA (assuming SAMA implementation) and re-quantified the risk value. The difference between the base risk value and the SAMA-reduced risk value is the averted risk, or the value of implementing the SAMA. STPNOC used this information in conjunction with the cost estimates 5-8
Environmental Impacts of Postulated Accidents for implementing each SAMA to perform a detailed cost-benefit comparison. STPNOC performed additional analyses to evaluate how the SAMA results would change if certain key parameters were changed, including re-assessing the cost-benefit calculations using the 95th percentile level of the failure probability distributions. The results of the uncertainty analysis are discussed in the ER, Attachment F, Section F.7. Based on the results of this SAMA analysis, none of the SAMAs have a positive net value, even when the 95th percentile PRA results were considered. Therefore, no SAMAs are being considered for implementation as part of license renewal (STPNOC 2010). The staffs concerns regarding SAMAs were provided to STPNOC in RAIs (NRC 2011). The staffs RAIs did not result in the identification of any potentially cost-beneficial SAMAs (STPNOC 2011). STPNOCs SAMA analyses and the NRCs review are discussed in more detail in the following sections.
The NRC staff concludes that STPNOC used a systematic and comprehensive process for identifying potential plant improvements for STP and that the set of SAMAs evaluated in the ER, together with those evaluated in response to the NRC staffs inquiries, is reasonably comprehensive and, therefore, is acceptable.
5.3.4 Evaluation of Risk Reduction and Costs of Improvements STPNOC estimated the costs of implementing the 21 SAMAs through the development of site-specific cost estimates and use of other applicants estimates for similar improvements.
The costs were developed on a site basis (i.e., two units). If the cost estimate was for a single unit, based on other applicants estimates for similar improvements, then the cost estimate was multiplied by two to derive the costs on a site basis. The site-specific cost estimates conservatively did not include contingency costs associated with unforeseen implementation obstacles or the cost of replacement power during extended outages required to implement the modifications (STPNOC 2010). The cost estimates that were based on other applicants estimates did not account for inflation, which is considered another conservatism.
STPNOC performed additional analyses to evaluate the impact of parameter choices and uncertainties on the results of the SAMA assessment. In this process, one additional SAMA was identified for detailed cost-benefit analysis.
The staff reviewed STPNOCs basis for calculating the risk reduction for the various plant improvements and concludes that the rationale and assumptions for estimating risk reduction are reasonable and generally conservative (i.e., the estimated risk reduction is higher than what would actually be realized). Accordingly, the staff based its estimates of averted risk for the various SAMAs on STPNOCs risk reduction estimates.
5.3.5 Cost-Benefit Comparison The methodology used by STPNOC to perform the Cost-Benefit Comparison in the Phase II analysis was based on NRCs guidance for performing a cost-benefit analysis (i.e., NUREG/BR-0184, Regulatory Analysis Technical Evaluation Handbook (NRC 1997)). The guidance involves determining the net value for each SAMA. If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the benefit associated with the SAMA, and it is not considered cost beneficial. Revision 4 of NUREG/BR-0058 states that two sets of estimates should be developed, one at a 3 percent discount rate and one at a 7 percent discount rate (NRC 2004). STPNOC provided a base set of results using the 7 percent discount rate and a sensitivity study using the 3 percent discount rate. These results are presented in Table 5-7 as the total benefit baseline and total benefit baseline with uncertainty. Table 5-7 lists (a) the assumptions considered to estimate the risk reduction for each of the evaluated SAMAs, (b) the estimated risk reduction in terms of percent reduction in CDF and population 5-9
Environmental Impacts of Postulated Accidents dose, and (c) the estimated total benefit (present value) of the averted risk. The estimated benefits reported in Table 5-7 reflect the combined benefit in both internal and external events.
There are six SAMAs listed in Table 5-7. The associated initiated events for these six SAMAs are:
- cable spreading room fire,
- SGTR,
- loss of reactor coolant system (RCS) water seal,
- loss of standby diesel generator (SBDG) HVAC, and
- loss of essential cooling water intake structure (ECWIS) HVAC, respectively.
The staff reviewed the bases for the applicants cost estimates. For certain improvements, the staff also compared the cost estimates to estimates developed elsewhere for similar improvements, including estimates developed as part of other applicants analyses of SAMAs for operating reactors. The staff reviewed the costs and has found them to be reasonable and generally consistent with estimates provided in support of other plants analyses. The staff agrees that the costs of the SAMAs evaluated would be higher than the associated benefits when they are considered independently.
Table 5-7. Phase II SAMA List (Cost-Benefit) for STP
% Risk reduction Total benefit ($)
Population Baseline Baseline with Cost ($)
CDF(b) dose (% dose (internal uncertainty(b)
SAMA(a) Assumptions reduction) + external)
(c) 3b Install fire Eliminate failure of the <1 <1 3K 4K 800K wrap on positive PDP due to a fire in displacement the cable spreading pump (PDP) room.
cables in cable spreading room.
4Develop Eliminate failure of the 2 10 27K 43K 100K procedures to operator action to isolate component isolate CCW.
cooling water (CCW) inside containment.
5-10
Environmental Impacts of Postulated Accidents
% Risk reduction Total benefit ($)
Population Baseline Baseline with Cost ($)
CDF(b) dose (% dose (internal uncertainty(b)
SAMA(a) Assumptions reduction) + external) 10Enhance Reassign a portion of 0 2 3K 5K 100K procedures to the SGTR CDF ensure the steam contribution for the generators (SGs) large early release are filled or category (7.48E-06 maintain filled in per year) and late SGTR events to release category scrub fission (1.35E-07 per year) to products. the small early release category and intact containment release category, respectively.
12Enhance Reassign the induced 0 0 <1K <1K 100K procedures to SGTR CDF prevent clearing of contribution (2.4E-09 RCS cold leg per year) for water seals. sequences in which offsite power is available from the large early release category to the intact containment release category.
13Develop Eliminate failure of the <1 0 1K 2K 100K procedures to operator action to open doors or use provide SBDG room portable fans for cooling.
alternate SBDG room cooling.
15Develop Eliminate failure of the 1 2 8K 12K 100K emergency operator action to procedures for provide ECWIS room alternate ECWIS cooling.
room cooling.
(a)
SAMAs in bold are potentially cost beneficial.
(b)
Baseline benefits increased by a factor of 1.6 to account for uncertainties, which is discussed further in Section F.6.2.
(c)
SAMA 3b retained for Phase II analysis based on results of uncertainty analysis, which is discussed further in Section F.6.2.
5.3.6 Conclusions The NRC staff reviewed the STPNOCs analysis. The staff concludes that the methods used and the implementations of those methods were sound. The treatment of SAMA benefits and costs supports the general conclusion that the SAMA evaluations performed by STPNOC are reasonable and sufficient for the license renewal submittal.
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Environmental Impacts of Postulated Accidents The staff agrees with STPNOCs conclusion that none of the candidate SAMAs are potentially cost beneficial. This conclusion is based on the generally conservative treatment of costs and benefits. This conclusion is consistent with the low residual level of risk indicated in the STP PRA and the fact that STPNOC has already implemented the plant improvements identified from the IPE and IPEEE.
5.4 References 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, Domestic Licensing of Production and Utilization Facilities.
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.
10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, Reactor Site Criteria.
[HL&P] Houston Lighting and Power Company. 1992. South Texas Project Electric Generating Station Level 2 Probabilistic Safety Assessment and Individual Plant Examination.
August 1992. (ADAMS Nos. ML0617001702, ML0617001790, ML0617001850).
[NRC] U.S. Nuclear Regulatory Commission. 1994. Letter from Suzanne C. Black, Director, to William T. Cottle, Houston Lighting & Power Company.
Subject:
Issuance of Amendment Nos. 59 and 47 to Facility Operating License Nos. NPF-76 and NPF-80 and Related Relief RequestSouth Texas Project, Units 1 and 2 (TAC Nos. M76048 and M76049).
February 17, 1994. ADAMS No. ML021300134.
[NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC. NRC NUREG-1437. May 1996.
ADAMS Nos. ML040690705 and ML040690738.
[NRC] U.S. Nuclear Regulatory Commission. 1997. Regulatory Analysis Technical Evaluation Handbook. Washington, DC. NRC. NUREG/BR-0184. January 1997. ADAMS No. ML050190193.
[NRC] U.S. Nuclear Regulatory Commission. 2004. Regulatory Analysis Guidelines of the U.S.
Nuclear Regulatory Commission. Washington, DC. NRC NUREG/BR-0058, Rev. 4. July 2000.
ADAMS No. ML003738939.
[NRC] U.S. Nuclear Regulatory Commission. 2011. Summary of site audit related to the review of the license renewal application for South Texas Project, Units 1 and 2. August 4, 2011.
ADAMS No. ML11196A005.
[NRC] U.S. Nuclear Regulatory Commission. 2012. Environmental Impact Statement Scoping Process, Summary Report, South Texas Project, Units 1 and 2, Bay City, TX. Washington, DC.
NRC. 2012. ADAMS No. ML11153A082.
[STPNOC] South Texas Project Nuclear Operating Company. 2010. South Texas Project, Applicants Environmental ReportOperating License Renewal Stage, South Texas Project Units 1 & 2. September 2010. ADAMS No. ML103010263.
[STPNOC] South Texas Project Nuclear Operating Company. 2011. Letter from G.T. Powell, STPNOC, to U.S. Nuclear Regulatory Commission Document Control Desk,
Subject:
South Texas Project Units 1 and 2, Docket Nos. STN 50-498, STN 50-499, Response to Request for 5-12
Environmental Impacts of Postulated Accidents Additional Information on South Texas Project License Renewal Application (TAC No. ME4938).
July 5, 2011. ADAMS No. ML11193A016.
[STPNOC] South Texas Project Nuclear Operating Company. 2011b. Letter from G.T. Powell, STPNOC, to U.S. Nuclear Regulatory Commission Document Control Desk,
Subject:
South Texas Project Units 1 and 2, Docket Nos. STN 50-498, STN 50-499, Response to Request for Additional Information on South Texas Project License Renewal Application (TAC No. ME4938).
August 23, 2011. ADAMS No. ML11250A067.
[STPNOC] South Texas Project Nuclear Operating Company. 2012b. Letter from D.W.
Rencurrel, STPNOC, to U.S. Nuclear Regulatory Commission Document Control Desk,
Subject:
South Texas Project Units 1 and 2, Docket Nos. STN 50-498, STN 50-499, Clarification to Supplemental Response to Request for Additional Information on South Texas Project License Renewal ApplicationSAMA (TAC Nos. ME4938 and ME5122). February 16, 2012. ADAMS No. ML12053A259.
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6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE, WASTE MANAGEMENT, AND GREENHOUSE GAS EMISSIONS This chapter addresses issues related to the uranium fuel cycle, solid waste management, and greenhouse gas (GHG) emissions during the proposed 20-year period of extended operation.
6.1 The Uranium Fuel Cycle The uranium fuel cycle includes uranium mining and milling, the production of uranium hexafluoride, isotopic enrichment, fuel fabrication, reprocessing of irradiated fuel, transportation of radioactive materials, and management of low-level wastes and high-level wastes related to uranium fuel cycle activities. The generic potential impacts of the radiological and nonradiological environmental impacts of the uranium fuel cycle and transportation of nuclear fuel and wastes are described in detail in NUREG-1437, Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants (NRC 1996, 1999) based, in part, on the generic impacts given in Table S-3, Table of Uranium Fuel Cycle Environmental Data, located at Title 10, Part 51.51, of the Code of Federal Regulations (10 CFR 51.51), and in 10 CFR 51.52(c), Table S-4, Environmental Impact of Transportation of Fuel and Waste to and from One Light-Water-Cooled Nuclear Power Reactor.
In the GEIS, the U.S. Nuclear Regulatory Commission (NRC) staff identified nine Category 1 issues related to the fuel cycle and waste management, which appear in Table 6-1. There are no Category 2 issues related to the fuel cycle and waste management.
Table 6-1. Issues Related to the Uranium Fuel Cycle and Waste Management Issues GEIS Sections Category Offsite radiological impacts (individual effects from other than the disposal of spent fuel & 6.1; 6.2.1; 6.2.2.1; 6.2.2.3; 6.2.3; 6.2.4; 6.6 1 high-level waste)
Offsite radiological impacts (collective effects) 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6 1 Offsite radiological impacts (spent fuel and 6.2.2.1; 6.2.2.2; 6.2.3; 6.2.4 1
high-level waste disposal)
Nonradiological impacts of the uranium fuel 6.1; 6.2.2.6; 6.2.2.7; 6.2.2.8; 6.2.2.9; 6.2.3; 6.2.4; 1
cycle 6.6 6.1; 6.2.2.2;6.4.2; 6.4.3; 6.4.3.1; 6.4.3.2; 6.4.3.3; 6.4.4; 6.4.4.1; 6.4.4.2; 6.4.4.3; 6.4.4.4; 6.4.4.5; Low-level waste storage & disposal 1 6.4.4.5.1; 6.4.4.5.2; 6.4.4.5.3; 6.4.4.5.4; 6.4.4.6;6.6 6.4.5.1; 6.4.5.2; 6.4.5.3; 6.4.5.4; 6.4.5.5; 6.4.5.6; Mixed waste storage & disposal 1 6.4.5.6.1; 6.4.5.6.2; 6.4.5.6.3; 6.4.5.6.4; 6.6 6.1; 6.4.6; 6.4.6.1; 6.4.6.2; 6.4.6.3; 6.4.6.4; Onsite spent fuel 1 6.4.6.5; 6.4.6.6; 6.4.6.7; 6.6 Nonradiological waste 6.1; 6.5; 6.5.1; 6.5.2; 6.5.3; 6.6 1 Transportation 6.1; 6.3.1; 6.3.2.3; 6.3.3; 6.3.4; 6.6, Addendum 1 1 6-1
Environmental Impacts of the Uranium Fuel Cycle, Waste Management, and Greenhouse Gas Emissions The NRC staffs evaluation of the environmental impacts associated with spent nuclear fuel is addressed in two issues in Table 6-1, Offsite radiological impacts (spent fuel and high-level waste disposal) and Onsite spent fuel. However, as explained later in this section, the scope of the evaluation of these two issues in this supplemental environmental impact statement (SEIS) has been revised. The issue, Offsite radiological impacts (spent fuel and high-level waste disposal), from Table 6-1, is not evaluated in this SEIS. In addition, the issue, Onsite spent fuel only evaluates the environmental impacts during the license renewal term.
For the term of license renewal, the NRC staff did not identify any new and significant information related to the remaining uranium fuel cycle and waste management issues listed in Table 6-1 during its review of the STP Nuclear Operating Company (STPNOC) Environmental Report (STPNOC 2010), the site visit, and the scoping process. Therefore, there are no impacts related to these issues beyond those discussed in the GEIS. For these Category 1 issues, the GEIS concludes that the impacts are SMALL, except for the issue, Offsite radiological impacts (collective effects), which the NRC has not assigned an impact level. This issue assesses the 100-year radiation dose to the U.S. population (i.e., collective effects or collective dose) from radioactive effluents released as part of the uranium fuel cycle for a nuclear power plant during the license renewal term compared to the radiation dose from natural background exposure. It is a comparative assessment for which there is no regulatory standard to base an impact level.
For the offsite radiological impacts resulting from spent fuel and high-level waste disposal and the onsite storage of spent fuel, which will occur after the reactors have been permanently shut down, the NRCs Waste Confidence rule represented the Commissions generic determination that spent fuel can continue to be stored safely and without significant environmental impacts for a period of time after the end of the licensed life for operation. This generic determination meant that the NRC did not need to consider the storage of spent fuel after the end of a reactors licensed life for operation in National Environmental Policy Act (NEPA) documents that support its reactor and spent fuel storage application reviews.
The NRC first adopted the Waste Confidence rule in 1984. The NRC amended the rule in 1990, reviewed it in 1999, and amended it again in 2010 (49 FR 34694; 55 FR 38474; 64 FR 68005; and 75 FR 81032 and 81037). The Waste Confidence rule is codified in 10 CFR 51.23.
On December 23, 2010, the Commission published in the Federal Register a revision of the Waste Confidence rule to reflect information gained from experience in the storage of spent fuel and the increased uncertainty in the siting and construction of a permanent geologic repository for the disposal of spent fuel and high-level waste (75 FR 81032 and 81037). In response to the 2010 Waste Confidence rule, the states of New York, New Jersey, Connecticut, and Vermont along with several other partieschallenged the Commissions NEPA analysis in the decision, which provided the regulatory basis for the rule. On June 8, 2012, the United States Court of Appeals, District of Columbia Circuit in New York v. NRC, 681F.3d 471 (D.C. Cir. 2012) vacated the NRCs Waste Confidence rule after finding that it did not comply with NEPA.
In response to the courts ruling, the Commission, in CLI-12-16 (NRC 2012a), determined that it would not issue licenses that rely upon the Waste Confidence rule, until the issues identified in the courts decision are appropriately addressed by the Commission. In CLI-12-16, the Commission also noted that the decision not to issue licenses only applies to final license issuance; all licensing reviews and proceedings should continue to move forward.
In addition, the Commission directed, in SRM-COMSECY-12-0016 (NRC 2012b), that the NRC staff proceed with a rulemaking that includes the development of a generic environmental impact statement (EIS) to support a revised Waste Confidence rule and to publish both the EIS 6-2
Environmental Impacts of the Uranium Fuel Cycle, Waste Management, and Greenhouse Gas Emissions and the revised rule in the Federal Register within 24 months (by September 2014). The Commission indicated that both the EIS and the revised Waste Confidence rule should build on the information already documented in various NRC studies and reports, including existing environmental assessments that the NRC developed as part of the 2010 Waste Confidence rule. The Commission directed that any additional analyses should focus on the issues identified in the courts decision. The Commisssion also directed that the NRC staff provide ample opportunity for public comment on both the draft EIS and the proposed Waste Confidence rule.
The revised rule and supporting EIS are expected to provide the necessary NEPA analyses of waste confidence-related human health and environmental issues. As directed by the Commission, the NRC will not issue a renewed license before the resolution of waste confidence-related issues. This will ensure that there would be no irretrievable or irreversible resource commitments or potential harm to the environment before waste confidence impacts have been addressed.
If the results of the Waste Confidence rule and supporting EIS identify information that requires a supplement to this SEIS, the NRC staff will perform any appropriate additional NEPA review for those issues before the NRC makes a final licensing decision.
6.2 Greenhouse Gas Emissions This section discusses the potential impacts from GHGs emitted from the nuclear fuel cycle.
The GEIS does not directly address these emissions, and its discussion is limited to an inference that substantial carbon dioxide emissions may occur if coal- or oil-fired alternatives to license renewal are carried out.
6.2.1 Existing Studies Since the development of the GEIS, the relative volumes of GHGs emitted by nuclear and other electricity generating methods have been widely studied. However, estimates and projections of the carbon footprint of the nuclear power lifecycle vary depending on the type of study done.
Additionally, considerable debate also exists among researchers on the relative effects of nuclear and other forms of electricity generation on GHG emissions. Existing studies on GHG emissions from nuclear power plants generally take two different forms:
(1) qualitative discussions of the potential to use nuclear power to reduce GHG emissions and mitigate global warming, and (2) technical analyses and quantitative estimates of the actual amount of GHGs generated by the nuclear fuel cycle or entire nuclear power plant life cycle and comparisons to the operational or life cycle emissions from other energy generation alternatives.
Qualitative Studies. The qualitative studies consist primarily of broad evaluations, large-scale public policy evaluations, or investment evaluations of whether an expansion of nuclear power is likely to be a technically, economically, or politically workable means of achieving global GHG reductions. Studies found by the staff during the subsequent literature search include the following:
- Evaluations to determine if investments in nuclear power in developing countries should be accepted as a flexibility mechanism to assist industrialized nations in achieving their GHG reduction goals under the Kyoto 6-3
Environmental Impacts of the Uranium Fuel Cycle, Waste Management, and Greenhouse Gas Emissions Protocols (IAEA 2000; NEA 2002; Schneider 2000). Ultimately, the parties to the Kyoto Protocol did not approve nuclear power as a component under the clean development mechanism (CDM) due to safety and waste disposal concerns (NEA 2002).
- Analyses developed to assist governments, including the U.S. Government, in making long-term investment and public policy decisions in nuclear power (Hagen et al. 2001; Keepin 1988; MIT 2003).
Although the qualitative studies sometimes reference and critique the existing quantitative estimates of GHGs produced by the nuclear fuel cycle or life cycle, their conclusions generally rely heavily on discussions of other aspects of nuclear policy decisions and investment such as safety, cost, waste generation, and political acceptability. Therefore, these studies are typically not directly applicable to an evaluation of GHG emissions associated with the proposed license renewal for a given nuclear power plant.
Quantitative Studies. A large number of technical studies, including calculations and estimates of the amount of GHGs emitted by nuclear and other power generation options, are available in the literature and were useful to the staffs efforts in addressing relative GHG emission levels.
Examples of these studies includebut are not limited toMortimer (1990),
Andseta et al. (1998), Spadaro (2000), Storm van Leeuwen and Smith (2008), Fritsche (2006),
Parliamentary Office of Science and Technology (POST) (2006), Atomic Energy Authority (AEA) (2006), Weisser (2006), Fthenakis and Kim (2007), and Dones (2007).
Comparing these studies and others like them is difficult because the assumptions and components of the lifecycles the authors evaluate vary widely. Examples of areas in which differing assumptions make comparing the studies difficult include the following:
- energy sources that may be used to mine uranium deposits in the future,
- reprocessing or disposal of spent nuclear fuel,
- current and potential future processes to enrich uranium and the energy sources that will power them,
- estimated grades and quantities of recoverable uranium resources,
- estimated grades and quantities of recoverable fossil-fuel resources,
- estimated GHG emissions other than carbon dioxide, including the conversion to carbon dioxide equivalents per unit of electric energy produced,
- performance of future fossil-fuel power systems,
- projected capacity factors for alternatives means of generation, and
- current and potential future reactor technologies.
In addition, studies may vary with respect to whether all or parts of a power plants lifecycle are analyzed (i.e., a full lifecycle analysis will typically address plant construction, operations, resource extraction (for fuel and construction materials), and decommissioning, whereas a partial lifecycle analysis primarily focuses on operational differences).
In the case of license renewal, a GHG analysis for that portion of the plants lifecycle (operation for an additional 20 years) would not involve GHG emissions associated with construction because construction activities have already been completed at the time of relicensing. In addition, the proposed action of license renewal would also not involve additional GHG 6-4
Environmental Impacts of the Uranium Fuel Cycle, Waste Management, and Greenhouse Gas Emissions emissions associated with facility decommissioning because that decommissioning must occur whether the facility is relicensed or not. However, in some of the above-mentioned studies, the specific contribution of GHG emissions from construction, decommissioning, or other portions of a plants lifecycle cannot be clearly separated from one another. In such cases, an analysis of GHG emissions would overestimate the GHG emissions attributed to a specific portion of a plants lifecycle. Nonetheless, these studies supply some meaningful information with respect to the relative magnitude of the emissions among nuclear power plants and other forms of electric generation, as discussed in the following sections.
In Table 6-2, Table 6-3, and Table 6-4, the staff presents the results of the above-mentioned quantitative studies to supply a weight-of-evidence evaluation of the relative GHG emissions that may result from the proposed license renewal as compared to the potential alternative use of coal-fired, natural gas-fired, and renewable generation. Most studies from Mortimer (1990) onward suggest that uranium ore grades and uranium enrichment processes are leading determinants in the ultimate GHG emissions attributable to nuclear power generation. These studies show that the relatively lower order of magnitude of GHG emissions from nuclear power, when compared to fossil-fueled alternatives (especially natural gas), could potentially disappear if available uranium ore grades drop sufficiently while enrichment processes continued to rely on the same technologies.
Summary of Nuclear Greenhouse Gas Emissions Compared to Coal. Considering that coal fuels the largest share of electricity generation in the U.S. and that its burning results in the largest emissions of GHGs for any of the likely alternatives to nuclear power generation, including South Texas Project (STP), most of the available quantitative studies focused on comparisons of the relative GHG emissions of nuclear to coal-fired generation. The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle (and, in some cases, the nuclear lifecycle), as compared to an equivalent coal-fired plant, are presented in Table 6-2.
The NRC staff considered the best available information for its independent analysis. Although the following chart does not include all existing studies, it gives an illustrative range of estimates developed by various sources.
Table 6-2. Nuclear Greenhouse Gas Emissions Compared to Coal Source GHG Emission Results Mortimer (1990) Nuclear230,000 tons CO2(a)
Coal5,912,000 tons CO2 Note: Future GHG emissions from nuclear to increase because of declining ore grade.
Andseta et al. (1998) Nuclear energy produces 1.4% of the GHG emissions compared to coal.
Note: Future reprocessing and use of nuclear-generated electrical power in the mining and enrichment steps are likely to change the projections of earlier authors, such as Mortimer (1990).
Spadaro (2000) Nuclear2.5-5.7 g Ceq/kWh Coal264-357 g Ceq/kWh Fritsche (2006) (Values Nuclear33 g Ceq/kWh estimated from graph in Coal950 g Ceq/kWh Figure 4) 6-5
Environmental Impacts of the Uranium Fuel Cycle, Waste Management, and Greenhouse Gas Emissions Source GHG Emission Results POST (2006) (Nuclear Nuclear5 g Ceq/kWh calculations from AEA 2006) Coal>1,000 g Ceq/kWh Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 6.8 g Ceq/kWh. Future improved technology and carbon capture and storage could reduce coal-fired GHG emissions by 90%.
Weisser (2006) (Compilation of Nuclear2.8-24 g Ceq/kWh results from other studies) Coal950-1,250 g Ceq/kWh (a)
6.2.1.2 Summary of Nuclear Greenhouse Gas Emissions Compared to Natural Gas The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle (and, in some cases, the nuclear lifecycle), as compared to an equivalent natural gas-fired plant, are presented in Table 6-3. In considering the best available information for its independent analysis, the staff noted that the following chart does not include all existing studies; however, it gives an illustrative range of estimates developed by various sources.
Table 6-3. Nuclear Greenhouse Gas Emissions Compared to Natural Gas Source GHG Emission Results Spadaro (2000) Nuclear2.5-5.7 g Ceq/kWh Natural Gas120-188 g Ceq/kWh Storm van Leeuwen & Smith Nuclear fuel cycle produces 20-33% of the GHG emissions compared (2008) to natural gas (at high ore grades).
Note: Future nuclear GHG emissions to increase because of declining ore grade.
Fritsche (2006) (Values Nuclear33 g Ceq/kWh estimated from graph in Cogeneration Combined Cycle Natural Gas150 g Ceq/kWh Figure 4)
POST (2006) (Nuclear Nuclear5 g Ceq/kWh calculations from AEA 2006) Natural Gas500 g Ceq/kWh Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 6.8 g Ceq/kWh. Future improved technology and carbon capture and storage could reduce natural gas GHG emissions by 90%.
Weisser (2006) (Compilation of Nuclear2.8-24 g Ceq/kWh results from other studies) Natural Gas440-780 g Ceq/kWh Dones (2007) Author critiqued methods and assumptions of Storm van Leeuwen and Smith (2005) and concluded that the nuclear fuel cycle produces 15-27% of the GHG emissions of natural gas.
Summary of Nuclear Greenhouse Gas Emissions Compared to Renewable Energy Sources.
The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle, as compared to equivalent renewable energy sources, are presented in Table 6-4. Calculation of 6-6
Environmental Impacts of the Uranium Fuel Cycle, Waste Management, and Greenhouse Gas Emissions GHG emissions associated with these sources is more difficult than the calculations for nuclear energy and fossil fuels because of the large variation in efficiencies due to their different sources and locations. For example, the efficiency of solar and wind energy is highly dependent on the location in which the power generation facility is installed. Similarly, the range of GHG emissions estimates for hydropower varies greatly, depending on the type of dam or reservoir involved (if used at all). Therefore, the GHG emissions estimates for these energy sources have a greater range of variability than the estimates for nuclear and fossil-fuel sources. As noted in Section 6.2.1.2, the following chart gives an illustrative range of estimates developed by various sources.
Table 6-4. Nuclear Greenhouse Gas Emissions Compared to Renewable Energy Sources Source GHG Emission Results Mortimer (1990) Nuclear230,000 tons CO2 Hydropower78,000 tons CO2 Wind power54,000 tons CO2 Tidal power52,500 tons CO2 Note: Future GHG emissions from nuclear are expected to increase because of declining ore grade.
Spadaro (2000) Nuclear2.5-5.7 g Ceq/kWh Solar PV27.3-76.4 g Ceq/kWh Hydroelectric1.1-64.6 g Ceq/kWh Biomass8.4-16.6 g Ceq/kWh Wind2.5-13.1 g Ceq/kWh Fritsche (2006) (Values Nuclear33 g Ceq/kWh estimated from graph in Solar PV125 g Ceq/kWh Figure 4) Hydroelectric50 g Ceq/kWh Wind20 g Ceq/kWh POST (2006) (Nuclear Nuclear5 g Ceq/kWh calculations from AEA 2006) Biomass25-93 g Ceq/kWh Solar PV35-58 g Ceq/kWh Wave/Tidal25-50 g Ceq/kWh Hydroelectric5-30 g Ceq/kWh Wind4.64-5.25 g Ceq/kWh Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 6.8 g Ceq/kWh.
Weisser (2006) (Compilation of Nuclear2.8-24 g Ceq/kWh results from other studies) Solar PV43-73 g Ceq/kWh Hydroelectric1-34 g Ceq/kWh Biomass35-99 g Ceq/kWh Wind8-30 g Ceq/kWh Fthenakis & Kim (2007) Nuclear16-55 g Ceq/kWh Solar PV17-49 g Ceq/kWh (a)
Conclusion. The sampling of data presented in Table 6-2, Table 6-3, and Table 6-4 demonstrates the challenges of any attempt to determine the specific amount of GHG emission attributable to nuclear energy production sources, as different assumptions and calculation 6-7
Environmental Impacts of the Uranium Fuel Cycle, Waste Management, and Greenhouse Gas Emissions methods will yield differing results. The differences and complexities in these assumptions and analyses will further increase when they are used to project future GHG emissions.
Nevertheless, several conclusions can be drawn from the information presented.
First, the various studies show a general consensus that nuclear power currently produces fewer GHG emissions than electrical generation based on fossil fuel. For example, the GHG emissions from a complete nuclear fuel cycle currently range from 2.5 to 55 grams of carbon equivalent per Kilowatt hour (g Ceq/kWh), as compared to the use of coal plants (264 to 1,250 g Ceq/kWh) and natural gas plants (120 to 780 g Ceq/kWh). The studies also give estimates of GHG emissions from five renewable energy sources based on current technology.
These estimates included solar-photovoltaic (17 to 125 g Ceq/kWh), hydroelectric (1 to 64.6 g Ceq/kWh), biomass (8.4 to 99 g Ceq/kWh), wind (2.5 to 30 g Ceq/kWh), and tidal (25 to 50 g Ceq/kWh). The range of these estimates is wide, but the general conclusion is that current GHG emissions from the nuclear fuel cycle are of the same order of magnitude as from these renewable energy sources.
Second, the studies show no consensus on future relative GHG emissions from nuclear power and other sources of electricity. There is substantial disagreement among the various authors about the GHG emissions associated with declining uranium ore concentrations, future uranium enrichment methods, and other factors, including changes in technology. Similar disagreement exists about future GHG emissions associated with coal and natural gas for electricity generation. Even the most conservative studies conclude that the nuclear fuel cycle currently produces fewer GHG emissions than sources based on fossil fuel and is expected to continue to do so in the near future. The primary difference between the authors is the projected cross-over date (the time at which GHG emissions from the nuclear fuel cycle exceed those sources based on fossil fuel) or whether cross-over will actually occur.
Considering the current estimates and future uncertainties, it appears that GHG emissions associated with the proposed STP relicensing action are likely to be lower than those associated with energy sources based on fossil fuel. The staff bases this conclusion on the following rationale:
- As shown in Table 6-2 and Table 6-3, the current estimates of GHG emissions from the nuclear fuel cycle are far below those for energy sources based on fossil fuel.
- License renewal of a nuclear power plant like STP may involve continued GHG emissions due to uranium mining, processing, and enrichment, but will not result in increased GHG emissions associated with plant construction or decommissioning (as the plant will have to be decommissioned at some point whether the license is renewed or not).
- Few studies predict that nuclear fuel cycle emissions will exceed those of fossil fuels within a timeframe that includes the STP periods of extended operation. Several studies suggest that future extraction and enrichment methods, the potential for higher-grade resource discovery, and technology improvements could extend this timeframe.
With respect to comparison of GHG emissions among the proposed STP license renewal action and renewable energy sources, it appears likely that there will be future technology improvements and changes in the type of energy used for mining, processing, and constructing facilities of all types. Currently, the GHG emissions associated with the nuclear fuel cycle and renewable energy sources are within the same order of magnitude. Because nuclear fuel 6-8
Environmental Impacts of the Uranium Fuel Cycle, Waste Management, and Greenhouse Gas Emissions production is the most significant contributor to possible future increases in GHG emissions from nuclear powerand because most renewable energy sources lack a fuel componentit is likely that GHG emissions from renewable energy sources would be lower than those associated with STP at some point during the period of extended operation.
The staff also supplies an additional discussion about the contribution of GHG to cumulative air quality impacts in Section 4.11.2 of this SEIS.
6.3 References 10 CFR 51. Code of Federal Regulations, Title 10, Energy, Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions.
10 CFR 54. Code of Federal Regulations, Title 10, Energy, Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants.
[AEA] AEA Technology. 2006. Carbon Footprint of the Nuclear Fuel Cycle, Briefing Note.
East Kilbride, UK: British Energy Group. March 2006. Available at
<http://www.british-energy.com/documents/carbon_footprint.pdf> (accessed on April 5, 2012).
Andseta S, Thompson MJ, Jarrell JP, Pendergast DR. 1998. CANDU Reactors and Greenhouse Gas Emissions. Proceedings of the 19th Annual Conference, Canadian Nuclear Society; 1998 October 18-21; Toronto, Ontario. Available at
<http://www.computare.org/Support%20documents/Publications/Life%20Cycle.htm> (accessed on April 5, 2012).
Dones R. 2007. Critical Note on the Estimation by Storm Van Leeuwen JW and Smith P of the Energy Uses and Corresponding CO2 Emissions for the Complete Nuclear Energy Chain.
Villigen, Switzerland: Paul Sherer Institute. April 2007. Available at
<http://gabe.web.psi.ch/pdfs/Critical%20note%20GHG%20PSI.pdf> (accessed on April 5, 2012).
Fritsche UR. 2006. Comparison of Greenhouse-Gas Emissions and Abatement Cost of Nuclear and Alternative Energy Options from a Life-Cycle Perspective. Freiburg, Germany:
Oko-Institut. January 2006. Available at <http://www.oeko.de/oekodoc/315/2006-017-en.pdf>
(accessed on April 5, 2012)
Fthenakis VM, Kim HC. 2007. Greenhouse-gas emissions from solar-electric and nuclear power: A life cycle study. Energy Policy 35(4):2549-2557.
[IAEA] International Atomic Energy Agency. 2000. Nuclear Power for Greenhouse Gas Mitigation under the Kyoto Protocol: The Clean Development Mechanism (CDM). Vienna, Austria: IAEA. November 2000. Available at
<http://www.iaea.org/Publications/Booklets/GreenhouseGas/greenhousegas.pdf> (accessed on April 5, 2012).
Mortimer N. 1990. World warms to nuclear power. SCRAM Safe Energy Journal Dec 89/Jan 90. Available at <http://www.no2nuclearpower.org.uk/articles/mortimer_se74.php>
(accessed on April 5, 2012).
[NEA and OECD] Nuclear Energy Agency and the Organization for Economic Co-operation and Development. 2002. Nuclear Energy and the Kyoto Protocol. Paris, France: OECD. Available at <http://www.nea.fr/ndd/reports/2002/nea3808-kyoto.pdf> (accessed on April 5, 2012).
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Environmental Impacts of the Uranium Fuel Cycle, Waste Management, and Greenhouse Gas Emissions
[NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, DC.
[NRC] U.S. Nuclear Regulatory Commission. Code Manual for MACCS2: Volume 1, Users Guide. Washington, DC. NRC. NUREG/CR-6613. May 1998. ADAMS No. ML063550020.
[NRC] U.S. Nuclear Regulatory Commission. 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, Washington, DC.
[NRC] U.S. Nuclear Regulatory Commission. 2012a. Commission, Memorandum and Order CLI-12-16, ADAMS No. ML12220A094.
[NRC] U.S. Nuclear Regulatory Commission. 2012b. SRM-COMSECY-12-0016-Approach for Addressing Policy Issues Resulting from Court Decision To Vacate Waste Confidence Decision and Rule, ADAMS No. ML12250A032.
[POST] Parliamentary Office of Science and Technology. 2006. Carbon footprint of electricity generation. Postnote 268. October 2006. Available at
<http://www.parliament.uk/documents/post/postpn268.pdf> (accessed on April 5, 2012).
Schneider M. 2000. Climate Change and Nuclear Power. Gland, Switzerland: WWF-World Wildlife Fund for Nature. April 2000. Available at
<http://assets.panda.org/downloads/fullnuclearreprotwwf.pdf> (accessed on April 5, 2012).
Spadaro JV, Langlois L, Hamilton B. 2000. Greenhouse Gas Emissions of Electricity Generation Chains: Assessing the Difference. Vienna, Austria: International Atomic Energy Agency. Available at
<http://www.iaea.org/Publications/Magazines/Bulletin/Bull422/article4.pdf>.
[STPNOC] STP Nuclear Operating (STPNOC). 2010. License Renewal Application, South Texas Project, Units 1 and 2, Appendix E, Applicants Environmental Report, Operating License Renewal Stage. ADAMS No. ML103010257.
Storm van Leeuwen JW, Smith P. 2008. Nuclear PowerThe Energy Balance. Chaam, Netherlands: Ceedata Consultancy. February 2008. Available at <http://www.stormsmith.nl/>
(accessed on April 5, 2012).
Weisser D. 2006. A guide to life-cycle greenhouse gas (GHG) emissions from electric supply technologies. Energy 32(9): 1543-1559. Available at
<http://www.iaea.org/OurWork/ST/NE/Pess/assets/GHG_manuscript_pre-print_
versionDanielWeisser.pdf> (accessed on April 5, 2012).
6-10
7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING Environmental impacts from the activities associated with the decommissioning of any reactor before or at the end of an initial or renewed license are evaluated in Supplement 1 of NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities Regarding the Decommissioning of Nuclear Power Reactors (NRC 2002). The U.S.
Nuclear Regulatory Commission (NRC) staffs (the staffs) evaluation of the environmental impacts of decommissioningpresented in NUREG-0586, Supplement 1notes a range of impacts for each environmental issue.
Additionally, the incremental environmental impacts associated with decommissioning activities resulting from continued plant operation during the renewal term are discussed in NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS) (NRC 1996, 1999). The GEIS includes a determination of whether the analysis of the environmental issue could be applied to all plants and whether additional mitigation measures would be warranted. Issues were then assigned a Category 1 or a Category 2 designation.
Section 1.4 of this supplemental environmental impact statement (SEIS) explains the criteria for Category 1 and Category 2 issues and defines the impact designations of SMALL, MODERATE, and LARGE. The staff analyzed site-specific issues (Category 2) for South Texas Project (STP) and assigned them a significance level of SMALL, MODERATE, or LARGE, or not applicable to STP because of site characteristics or plant features. There are no Category 2 issues related to decommissioning.
7.1 Decommissioning Table 7-1 lists the Category 1 issues in Table B-1 of Title 10 of the Code of Federal Regulations (CFR) Part 51, Subpart A, Appendix B, that are applicable to STP decommissioning following the renewal term.
Table 7-1. Issues Related to Decommissioning Issues GEIS Sections Category Radiation doses 7.3.1; 7.4 1 Waste management 7.3.2; 7.4 1 Air quality 7.3.3; 7.4 1 Water quality 7.3.4; 7.4 1 Ecological resources 7.3.5; 7.4 1 Socioeconomic impacts 7.3.7; 7.4 1 Decommissioning would occur whether STP were shut down at the end of its current operating license or at the end of the period of extended operation. There are no site-specific issues related to decommissioning.
A brief description of the staffs review and the GEIS conclusions, as codified in Table B-1, 10 CFR Part 51, for each of the issues follows:
7-1
Environmental Impacts of Decommissioning Radiation Doses. Based on information in the GEIS, the NRC noted that [d]oses to the public will be well below applicable regulatory standards regardless of which decommissioning method is used. Occupational doses would increase no more than 1 person-rem (1 person-mSv) caused by buildup of long-lived radionuclides during the license renewal term.
Waste Management. Based on information in the GEIS, the NRC noted that
[d]ecommissioning at the end of a 20-year license renewal period would generate no more solid wastes than at the end of the current license term. No increase in the quantities of Class C or greater than Class C wastes would be expected.
Air Quality. Based on information in the GEIS, the NRC noted that [a]ir quality impacts of decommissioning are expected to be negligible either at the end of the current operating term or at the end of the license renewal term.
Water Quality. Based on information in the GEIS, the NRC noted that [t]he potential for significant water quality impacts from erosion or spills is no greater whether decommissioning occurs after a 20-year license renewal period or after the original 40-year operation period, and measures are readily available to avoid such impacts.
Ecological Resources. Based on information in the GEIS, the NRC noted that
[d]ecommissioning after either the initial operating period or after a 20-year license renewal period is not expected to have any direct ecological impacts.
Socioeconomic Impacts. Based on information in the GEIS, the NRC noted that
[d]ecommissioning would have some short-term socioeconomic impacts. The impacts would not be increased by delaying decommissioning until the end of a 20-year relicense period, but they might be decreased by population and economic growth.
The staff has not found any new and significant information during its independent review of South Texas Project Nuclear Operating Companys (STPNOCs) Environmental Report (ER)
(STPNOC 2010), the site audit, the scoping process, or its evaluation of other available information (including comments on the draft SEIS). Therefore, the NRC staff concludes that there are no impacts related to these issues, beyond those discussed in the GEIS (NRC 1996, 1999). For all of these issues, the NRC staff concluded in the GEIS that the impacts are SMALL, and additional plant-specific mitigation measures are not likely to be sufficiently beneficial to be warranted.
7.2 References 10 CFR 51. Code of Federal Regulations, Title 10, Energy, Part 51, Environmental protection regulations for domestic licensing and related regulatory functions.
[NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG-1437. May 1996.
ADAMS Nos. ML040690705 and ML040690738.
[NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3, Transportation, Table 9.1, Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC:
NRC. NUREG-1437, Volume 1, Addendum 1. August 1999. ADAMS No. ML04069720.
[NRC] U.S. Nuclear Regulatory Commission. 2002. Final Generic Environmental Impact Statement on Decomissioning of Nuclear Facilities Regarding the Decommissioning of Nuclear 7-2
Environmental Impacts of Decommissioning Power Reactors. Washington, DC. NRC. NUREG-0586, Supplement 1. November 2002.
ADAMS No. ML023470304 and ML023500295.
[STPNOC] South Texas Plant Nuclear Operating Company. 2010. South Texas Project, Applicants Environmental ReportOperating License Renewal Stage, South Texas Project Units 1 & 2. September 2010. ADAMS No. ML103010263.
7-3
8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES The National Environmental Policy Act (NEPA) requires the consideration of a range of reasonable alternatives to the proposed action in an environmental impact statement (EIS). In this case, the proposed action is whether to issue renewed licenses for South Texas Project (STP), Units 1 and 2, which will allow the plant to operate for 20 years beyond the current license expiration dates. A license is just one of many authorizations that an applicant must obtain in order to operate its nuclear plant. Energy-planning decisionmakers and the owners of the nuclear power plant ultimately decide if the plant will operate. Economic and environmental considerations play a primary role in this decision. The U.S. Nuclear Regulatory Commissions (NRCs) responsibility is to ensure the safe operation of nuclear power facilities, not to formulate energy policy or encourage or discourage the development of alternative power generation (or replacement power alternatives).
The license renewal process is designed to assure safe operation of the nuclear power plant during the license renewal term. Under the NRCs environmental protection regulations in Title 10, Part 51, of the Code of Federal Regulations (10 CFR Part 51), which implement Section 102(2) of NEPA, renewal of a nuclear power plant operating license requires the preparation of an EIS.
To support the preparation of these EISs, the NRC prepared the Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, in 1996. The license renewal GEIS was prepared to assess the environmental impacts of continued nuclear power plant operations during the license renewal term. The intent was to determine which environmental impacts would result in essentially the same impact at all nuclear power plants and which ones could result in different levels of impacts at different plants and would require a plant-specific analysis to determine the impacts. For those issues that could not be generically addressed, the NRC develops a plant-specific supplemental environmental impact statement (SEIS) to the GEIS.
NRC regulations in 10 CFR 51.71(d) for license renewal require that a SEIS do the following:
Consider and weigh the environmental effects of the proposed action [license renewal]; the environmental impacts of alternatives to the proposed action; and alternatives available for reducing or avoiding adverse environmental effects.
While the GEIS reached generic conclusions regarding many environmental issues associated with license renewal, it did not determine which alternatives are reasonable or reach conclusions about site-specific environmental impact levels. As such, the NRC must evaluate environmental impacts of alternatives on a site-specific basis.
As stated in Chapter 1 of this SEIS, alternatives to renewing STPNOCs operating licenses must meet the purpose and need for the proposed action. They must provide an option that allows for power generation capability beyond the term of a current nuclear power plant operating license to meet future system generating needs, as such needs may be determined by State, utility, and, where authorized, Federal (other than NRC) [decisionmakers].
The NRC ultimately makes no decision about which alternative (or the proposed action) to carry out because that decision falls to the appropriate energy-planning decisionmakers.
8-1
Environmental Impacts of Alternatives Comparing the environmental effects of these alternatives will help the NRC decide if the adverse Alternatives Evaluated In-Depth:
environmental impacts of license renewal are great
- new nuclear, enough to deny the option of license renewal for
- natural gas-fired combined-cycle (NGCC),
energy-planning decisionmakers
- supercritical coal,
- combination alternative (NGCC, wind, and (10 CFR 51.95(c)(4)). If the NRC acts to issue a energy efficiency and conservation), and renewed license, all of the alternatives, including the
- purchased power.
proposed action, will be available to energy-planning Other Alternatives Considered:
decisionmakers. If NRC decides not to renew the license (or takes no action at all), then
- offsite nuclear-, gas-, or coal- generation,
- energy efficiency and conservation, energy-planning decisionmakers may no longer elect
- wind power, to continue operating STP and will have to resort to
- solar power, another alternativewhich may or may not be one of
- hydroelectric power, the alternatives considered in this sectionto meet
- wave and ocean energy, their energy needs now being satisfied by STP.
- geothermal power,
- municipal solid waste, In evaluating alternatives to license renewal, the NRC
- biomass, considered energy technologies or options currently
- biofuels, in commercial operation, as well as some
- oil-fired power, technologies not currently in commercial operation
- fuel cells, and
- delayed retirement.
but likely to be commercially available by the time the current STP operating licenses expire. The current operating licenses for STP, Units 1 and 2, will expire on August 20, 2027, and December 15, 2028, respectively. The NRCs analysis assumed that an alternative must be available (able to be constructed, permitted, and connected to the grid) by the time the current STP licenses expire.
NRC eliminated alternatives that cannot meet future system needs by providing the amounts of baseload power equivalent to the STP current generating capacity (2,500 megawatts electric (MWe)) and whose costs or benefits do not justify inclusion in the range of reasonable alternatives from detailed studies. NRC evaluated the remaining alternatives, which are discussed in-depth in this section. Each alternative eliminated from detailed study is briefly discussed, and a basis for its removal is provided at the end of this section. In total, 18 energy technology options and alternatives to the proposed action were considered (see text box) and then narrowed to the 5 alternatives considered in Sections 8.1 through 8.5. The no-action alternative is considered in Section 8.7.
The GEIS presents an overview of some energy technologies but does not reach any conclusions about which alternatives are most appropriate. Since 1996, many energy technologies have evolved significantly in capability and cost, while regulatory structures have changed to either promote or impede development of particular alternatives.
As a result, the analyses include updated information from the following sources:
- Energy Information Administration (EIA),
- other offices within the Department of Energy (DOE),
- U.S. Environmental Protection Agency (EPA),
- industry sources and publications, and
- information submitted by the applicant in the STP Nuclear Operating Companys (STPNOC) Environmental Report (ER).
8-2
Environmental Impacts of Alternatives The evaluation of each alternative considers the environmental impacts across several impact Energy Outlook categories: air quality, groundwater use and Each year, the EIApart of the DOEissues its quality, surface water use and quality, aquatic updated Annual Energy Outlook (AEO).
AEO 2011, affirms that natural gas, renewable, resources, terrestrial resources, human health, and coal are likely to fuel most new electrical land use, socioeconomics, transportation, capacity through 2035, with some growth in aesthetics, archaeological and historic resources, nuclear capacity (EIA 2011a), although all environmental justices, and waste management. A projections are subject to future developments in three-level standard of significanceSMALL, fuel price, electrical demand, and regulatory changes.
MODERATE, or LARGEis used to indicate the intensity of environmental effects for each Natural gas-fired plants account for 60 percent of capacity additions between 2010 and 2035 in alternative undergoing in-depth evaluation. The the AEO2011 Reference case, compared with order of presentation is not meant to imply 25 percent for renewables, 11 percent for coal-increasing or decreasing level of impact. Nor does fired plants, and 3 percent for nuclear.
it imply that an energy-planning decisionmaker Escalating construction costs have the largest would select one or another alternative. impact on capital-intensive technologies, including nuclear, coal, and renewables.
For each alternative where it is feasible to do so, However, Federal tax incentives, State energy the NRC considers the environmental effects of programs, and rising prices for fossil fuels increase the competitiveness of renewable and locating the alternative at the existing STP site, as nuclear capacity. In contrast, uncertainty about well as at an alternate site. Selecting the existing future limits on GHG [greenhouse-gas]
plant site allows for the maximum use of existing emissions and other possible environmental transmission and cooling system infrastructures regulations reduces the competitiveness of coal-fired plants. (EIA 2011a).
and minimizes the overall environmental impact.
In addition, to ensure that the alternatives analysis was consistent with State or regional energy policies, the NRC reviewed energy relevant statutes, regulations, and policies. The NRC also considered the current generation capacity mix and electricity production data within the ERCOT service area, in which STP, Units 1 and 2, are located. ERCOT is one of eight regional reliability councils in North America and operates under the reliability and safety standards set by the North American Electric Reliability Council (STPNOC 2010a). ERCOT is the independent system operator for the electric grid for most of Texas and manages the flow of electric power to approximately 23 million Texas customers, representing 85 percent of the States electric load and 75 percent of the States land area. ERCOT is unique because it is located entirely within the boundaries of the State of Texas. As such, the NRC considered the current generation capacity mix and electricity production data within the ERCOT service area in the evaluation of reasonable alternatives. In 2010, electric generators in ERCOT had an installed generating capacity of approximately 84,400 MWe. This capacity included units fueled by natural gas (57 percent), coal (23 percent), wind (12 percent), nuclear (6 percent), and other sources (2 percent). In 2010, the electric generators in ERCOT provided approximately 319 million megawatt-hours of electricity. Electricity produced was dominated by coal (40 percent) followed by natural gas (38 percent), nuclear (13 percent), wind (8 percent), and other sources (1 percent) (ERCOT 2011a).
Sections 8.1 through 8.5 describe the environmental impacts of alternatives to license renewal.
These alternatives include a new nuclear generation option in Section 8.1; a new NGCC in Section 8.2; a new coal-fired plant in Section 8.3; a combination alternative of NGCC, wind, and energy conservation and efficiency in Section 8.4; and purchased power in Section 8.5. In Section 8.6, alternatives considered but eliminated from detailed study are briefly discussed.
Finally, the environmental effects that may occur if the NRC takes no action and does not issue renewed licenses for STP are described in Section 8.7. Section 8.8 summarizes, in detail, the impacts of each of the alternatives considered.
8-3
Environmental Impacts of Alternatives 8.1 New Nuclear Generation In this section, the NRC staff evaluates the environmental impacts of a new nuclear generation option at the STP site.
The NRC considers the construction of two new nuclear plants to be a reasonable alternative to STP license renewal for Units 1 and 2 because nuclear generation currently provides baseload power in the ERCOT region, ERCOT expects additional nuclear generation in the future, and the technology to provide nuclear generation is readily available (ERCOT 2011a). In addition, on September 30, 2007, STPNOC submitted combined license (COL) applications to construct and operate two new advanced boiling water reactor (ABWR) nuclear plants (Units 3 and 4) on the STP site (NRC 2011). In its ER for Units 3 and 4, STPNOCs schedule included 5 years from when NRC issues its licenses to when commercial operations could begin (STPNOC 2010b). Therefore, there is sufficient time for STPNOC to prepare and submit an application and build and operate two new nuclear units before the licenses for Units 1 and 2 expire in 2027 and 2028, respectively. This section presents the environmental impacts of the new nuclear generation alternative, which includes constructing and operating two new nuclear plants at the STP site.
In evaluating the new nuclear alternative, based on best available information, the NRC presumed that new reactors would be installed on the STP site, allowing for the maximum use of existing ancillary facilities such as the transmission and cooling systems. The NRC further presumed that the new reactors would be two ABWR reactors similar to what the NRC analyzed in its environmental analysis for Units 3 and 4 in its final EIS (NRC 2011). As of September 2012, NRC is continuing to review the STP application for Units 3 and 4. While the licenses have not been granted as of September 2012, the NRC staff is using the results from its final EIS for Units 3 and 4 because it provides a site-specific analysis of two new nuclear plants at the STP site.
For the purpose of this analysis, each of the two ABWR reactors would have a net electrical output of approximately 1,300 MWe, which is slightly more than the generating capacity (2,500-MWe capacity) of STP, Units 1 and 2 (STPNOC 2010a). STPNOC (2010a) estimated that the power block and ancillary facilities (excluding the cooling-water system) for the new reactors would require approximately 540 ac (219 ha) and that sufficient contiguous acreage was available on the STP site. Because the heat-rejection demands are similar for Units 1 and 2 and proposed Units 3 and 4, the NRC estimated that the existing cooling system including the existing intake and discharge structures on the main cooling reservoir (MCR) and the Colorado Riverwould meet the heat-rejection demands of the two new reactors without any modifications. In STPNOCs ER for Units 3 and 4, STPNOC assumed minor modifications would be required to increase operations from two units to four units at the STP site. For the purposes of this analysis, the two new reactors would replace Units 1 and 2 rather than add two new units to the site; therefore, it is unlikely that modification would be required. Construction materials would be delivered via rail, truck, or barge. To accommodate such shipments, STPNOC would need to dredge near the current barge slip, and the rail spur would require upgrades (STPNOC 2010b).
NRC assumed that construction of two new nuclear units at the STP site would generally follow the same timeframe as that described in STPNOCs ER for the construction of Units 3 and 4.
This schedule included 12 months for site preparation, 45 months after NRC issues the licenses to complete construction and fuel loading, 6 months from fuel loading to initial power generation for Unit 3, and an additional 12 months for Unit 4 (STPNOC 2010b).
8-4
Environmental Impacts of Alternatives The NRC also considered the installation of multiple small and modular reactors at the STP site as an alternative to renewing the licenses for STP, Units 1 and 2. NRC established the Advanced Reactor Program in the Office of New Reactors due to considerable interest in small and modular reactors along with anticipated license applications by vendors. As of September 2012 (based on best available information), NRC has not received any applications.
Because there are no applications to construct and operate small modular reactors on a commercial scale, this analysis focused on nuclear generation by larger nuclear units.
8.1.1 Air Quality As discussed in Section 2.2.2.1, the STP site is located in central Matagorda County, Texas, at the southern edge of the Metropolitan Houston-Galveston Intrastate Air Quality Control Region (40 CFR 81.38). The Corpus Christi-Victoria Intrastate Air Quality Control Region (40 CFR 81.136) lies immediately south and west of Matagorda County. EPA has designated all of the counties in these Air Quality Control Regions adjacent to the STP site as in compliance with the National Ambient Air Quality Standards (40 CFR 81.344) except Brazoria County to the north; Brazoria County is classified Nonattainment/Severe relative to the 8-hour ozone standard (EPA 2011b).
Construction activities would cause some localized temporary air effects as a result of equipment emissions and fugitive dust from the operation of the earth-moving and material-handling equipment. Emissions from workers vehicles and motorized construction equipment exhaust would be temporary. Construction crews would use dust-control practices to control and reduce fugitive dust, as proposed for Units 3 and 4 (STPNOC 2010b), and because
§111.145 of the Texas Commission for Environmental Qualitys (TCEQ) regulations require dust suppression control during the construction of facilities and parking lots.
During operations, two new nuclear plants would have similar air emissions to those of existing STP, Units 1 and 2, and those expected from proposed Units 3 and 4; air emissions would be primarily from backup diesel generators. Because air emissions would be similar for the new nuclear plants, the NRC expects similar air permitting conditions and regulatory requirements as that for Units 3 and 4. In STPNOCs ER for Units 3 and 4, STPNOC stated that [a]ir emissions sources would be managed in accordance with Federal, Texas, and local air quality control laws and regulations. Permitting would likely include a prevention of significant deterioration (PSD) review and an operating permit from TCEQ.
STPNOC estimated air emissions during the operation of Units 3 and 4 as part of its COL application (NRC 2011; STPNOC 2010b). The largest stationary sources of emissions would be from three standby diesel generators and a single combustion turbine generator, each of which would be operated about 4 hours0.167 days <br />0.0238 weeks <br />0.00548 months <br /> per month. Table 8-1 lists the expected annual emissions from these sources. NRC assumed that there would be similar air emissions from two new nuclear units.
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Environmental Impacts of Alternatives Table 8-1. Expected Annual Emissions from the Largest Stationary Sources of Emissions Diesel Generators (lb/yr) Combustion Turbine (lb/yr)
Particulates 2,500 44 Sulfur Oxides 9,200 3,800 Carbon Monoxide 9,200 1,800 Hydrocarbons 6,100 120 Nitrogen Oxides 57,900 4,000 Source: STPNOC 2010b The operation of nuclear power plants involves the emission of some greenhouse gases, primarily carbon dioxide. NRC (2011) estimated that the total carbon footprint for actual plant operations of Units 3 and 4 for 40 years is on the order of 650,000 metric tons (MT)
(720,000 tons) of carbon dioxide equivalent (an emissions rate of about 16,000 MT (18,000 tons) annually, averaged over the period of operation). Periodic testing of diesel generators and other activities during plant operations accounts for about 60 percent of the total, or about 190,000 MT (210,000 tons) for each unit. Workforce transportation accounts for the most of the remaining 40 percent, or about 130,000 MT (140,000 tons) for each unit.
NRC (2011) based these carbon footprint estimates on information included in Appendix I of the final EIS and emissions data contained in the ER for Units 3 and 4 (STPNOC 2010b).
Equipment maintenance and measures taken to mitigate transportation impacts, such as properly maintained asphalt or concrete roads and appropriate speed limits (STPNOC 2010b),
would also reduce carbon dioxide emissions, while reducing other emissions. For example, STPNOC (2010b) states that fugitive dust generated by the commuting workforce would be minimized by properly maintaining hard-surfaced access roads and setting appropriate speed limits.
Subpart P of 40 CFR Part 51 contains the visibility protection regulatory requirements, including the review of new sources to be constructed in attainment or unclassified areas and that may affect visibility in any Federal Class I area. If a new nuclear plant were located close to a mandatory Class I area, additional air pollution control requirements may be required. As noted in Section 2.2.2.1, there are no Mandatory Class I Federal areas within 100 mi (161 km) of the STP site where visibility is an important value.
Because construction and operations of two new nuclear units at the STP site would not noticeably alter air quality, air quality impacts would be SMALL.
8.1.2 Surface Water Resources The NRC presumes that two new nuclear units would be designed to maximize use of existing facilities, including the existing intake and discharge structures on the MCR and the Colorado River. STPNOC did not propose using any surface water during the construction of Units 3 and 4 (NRC 2011); therefore, NRC expects that none would be used during construction for the new nuclear alternative.
Impacts to surface water quality could result from dredging activities in the Colorado River near the reservoir makeup pumping facility (RMPF) and the barge slip. Dredging can disturb sediments and potentially increase turbidity near and downstream of the dredged site. The NRC staff (NRC 2011) determined that the hydrological alterations resulting from site development would be localized and temporary. Permits and certifications from the U.S. Army 8-6
Environmental Impacts of Alternatives Corps of Engineers (USACE) and other agencies would require the implementation of best management practices (BMPs) to minimize impacts.
Runoff from construction areas would be controlled under a State-issued Texas Pollutant Discharge Elimination System (TPDES) general permit that would require implementation of a stormwater pollution prevention plan and associated BMPs to prevent or significantly mitigate soil erosion and contamination of stormwater runoff from construction activities. Runoff from construction areas would be limited to the duration of the construction.
During normal operations, STPNOC would intermittently withdraw and discharge water from and to the Colorado River to maintain the water quality and quantity in the MCR (NRC 2011). This would continue to occur in accordance with STPNOCs existing water rights and a new or revised State-issued TPDES permit, respectively, under this alternative. Water use would be similar to that of Units 1 and 2. The NRC staff (NRC 2011) estimated current water use for Units 1 and 2 during normal operations to be 3 percent of Texas Water Development Board (TWDB)-estimated Region K water supplies in 2010 (TWDB 2007). Therefore, the impact on surface water use in the Colorado River basin would be minimal.
In consideration of the information above, the impacts on surface water use and quality from construction and operations under the new nuclear generation alternative would be SMALL.
8.1.3 Groundwater Resources The NRC presumes that the two new nuclear units would use existing ancillary facilities at the STP site, including use of the onsite groundwater production wells. To build Units 3 and 4, STPNOC (2010b) proposed withdrawing groundwater from the Deep Aquifer during construction. The NRC staff (NRC 2011) determined that STPNOCs projected drawdown during building activities and the current presence of a sufficient confining head would maintain the Deep Aquifer as a confined aquifer. For construction of the new nuclear units under this alternative, it is assumed that STPNOCs existing wells would be used to supply the relatively small amounts of water (i.e., up to 491 gpm (1,860 L/min)) required for potable and sanitary uses, concrete production, dust suppression and soil compaction, and other uses during construction of the new units (NRC 2011).
Excavation for the new reactor foundations could extend to depths of approximately 70 ft (21 m) below ground surface (BGS), and dewatering of the Upper and Lower Shallow Chicot aquifers would be required. However, slurry walls and wells were proposed for use to minimize potential adverse effects from dewatering both on site and off site (NRC 2011). Further, application of BMPs in accordance with a State-issued National Pollutant Discharge Elimination System (NPDES) general permit, including appropriate waste management and spill prevention practices, would prevent or minimize any groundwater quality impacts during construction.
During operations of Units 3 and 4, STPNOC proposed to use groundwater for power block operational uses, fire protection systems, and potable and sanitary systems, and to use the existing onsite groundwater production wells at STP. However, one or more additional wells could also be installed to decrease pumping rates at existing wells and to better distribute drawdown impacts in the Deep Aquifer and ensure sufficient withdrawal capacity under STPNOCs existing groundwater permit (NRC 2011). Groundwater use for operation of the two replacement units was presumed to be somewhat higher than for existing STP, Units 1 and 2, but well within the groundwater operating permit held by STPNOC. The groundwater operating permit issued by the Coast Plains Groundwater Conservation District (see Section 2.1.7.2) is for approximately 1,860 gpm (7,040 L/min); STP, Units 1 and 2, use approximately 768 gpm (2,910 L/min) of groundwater; and the new units would require approximately 975 gpm (3,690 L/min) under normal operating conditions (NRC 2011). The NRC concludes that 8-7
Environmental Impacts of Alternatives groundwater use and quality impacts are likely to be similar to those observed for STP, Units 1 and 2.
Based on this information, the overall impact on groundwater use and quality from construction and operations under the new nuclear generation alternative would be SMALL.
8.1.4 Aquatic Ecology The NRC presumed that two new nuclear units would be designed to maximize use of existing facilities, including the existing intake and discharge structures on the MCR and the Colorado River.
Construction activities for two new reactors (such as construction of heavy haul roads and the power blocks) could affect drainage areas or other onsite aquatic features due to site runoff.
NRC assumed that STPNOC would install temporary and permanent erosion and sediment control measures to minimize the flow of disturbed soils into ditches and wetlands. Such BMPs would likely be described in a Texas Pollutant Discharge Elimination System (TPDES) general permit relating to stormwater discharges for construction activities.
To bring new materials to the site, NRC assumed construction crews would dredge near the barge slip on the Colorado River to transport some materials using barges, which are activities that STPNOC (2010b) proposed for the construction of Units 3 and 4. Permits and certifications from the USACE and other agencies would require the implementation of BMPs to minimize impacts. NRC (2011) determined that such activities would be temporary and unlikely to cause noticeable impacts to aquatic resources.
Plant operators would withdraw water from the Colorado River to maintain the proper water quality and quantity in the MCR during operations of two new ABWR units. Aquatic organisms would be impinged and entrained as water is drawn through the RMPF. Biota most vulnerable to entrainment and impingement would be the same as those described in Section 4.5 during the period of continued operations for Units 1 and 2. The low approach velocity at the RMPF (less than or equal to approximately 0.5 ft/s), the use of a pond-based heat-dissipation cooling system, the population status of biota most likely to be impinged and entrained, and the reproductive potential of fish and shellfish most vulnerable to impingement and entrainment would result in minimal adverse impacts to the aquatic ecosystem in the Colorado River near STP.
Plant operators would discharge water from the MCR to the Colorado River to maintain water quality within the MCR. Discharge impacts would be similar to those described in Section 4.5 for continued operations of STP, Units 1 and 2. Discharges are unlikely to noticeably impact aquatic resources near STP for the following reasons:
- STPNOCs TPDES permit would limit the amount and timing of discharges.
- Modeling studies indicate that mobile aquatic species could avoid the thermal plume by swimming at a lower depth or different side of the river (NRC 2011).
- Species or life-stages that are less mobile organisms would not be able to swim away to avoid the thermal plume, such as eggs, larvae, and mollusks.
However, most species observed in this area generally have high fecundity, and the number of organisms lost would be insignificant compared to their population in the lower Colorado River.
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Environmental Impacts of Alternatives
- Cooling water would not be regularly discharged into the Colorado River because STP uses a cooling pond-based heat-dissipation system that reuses water from the MCR.
The NRC staff determined that the impacts to aquatic resources on the STP site and in the Colorado River would be SMALL because modifications on site and to the river, such as dredging, would be temporary, and impingement, entrainment, and heat shock would not noticeably impact aquatic resources.
8.1.5 Terrestrial Ecology STPNOC (2010a) estimated that the power block and ancillary facilities (excluding the cooling-water system) for the new reactors would require approximately 540 ac (219 ha).
Construction activities, such as building the heavy haul road and new facilities, would permanently convert approximately 300 ac (121 ha) (STPNOC 2010b). Construction would likely affect a variety of habitats and land uses, including industrial land (buildings, parking areas, and mowed-maintained fields), drainage ditches, scattered small palustrine wetlands, scrub-shrub habitat, and mixed grassland habitat where abandoned farm lands previously existed prior to construction of Units 1 and 2 (NRC 2011; STPNOC 2010b). Most of these areas have been mildly to extensively disturbed during the construction and operations of Units 1 and 2 and other human activities. After the completion of the new units, plant operators would likely grade, landscape, and replant the areas used for temporary building support (STPNOC 2010b). The majority of permanently affected areas would be maintained land (e.g., mowed) or other industrial areas. NRC (2011) determined that the change in habitat availability would unlikely increase fragmentation of onsite habitats available for wildlife.
STPNOC would likely implement BMPs to minimize impacts to wetlands. STPNOC would be required to comply with the USACE 404 permits (NRC 2011).
Construction activities could also adversely affect onsite wildlife through noise, increased light pollution, and increased traffic. However, NRC (2011) determined that these impacts would be temporary and minor.
STPNOC (2010b) did not observe Federally or State-listed threatened or endangered species, critical habitat, or suitable habitats in the proposed disturbance area for Units 3 and 4.
NRC (2011) determined that the impacts to special status species from the construction and operation of Units 3 and 4 would be negligible.
Because many construction-related impacts would be temporary, and because the majority of long-term construction impacts would occur within previously disturbed areas, impacts on terrestrial resources would be SMALL.
8.1.6 Human Health The human health effects from two new nuclear power plants would be similar to those of the existing STP, Units 1 and 2, and the proposed Units 3 and 4 (NRC 2011). Human health issues related to construction would be equivalent to those associated with the construction of any major complex industrial facility and would be controlled to acceptable levels through the application of BMPs and STPNOCs compliance with Federal and State worker protection regulations. Human health impacts from operation of the new nuclear reactors would be equivalent to those associated with continued operation of the existing reactors and the proposed Units 3 and 4 (NRC 2011).
Both continuous and intermittent noise impacts can be expected at offsite locations, including at the closest residences. However, confining noise-producing activities to core hours of the day 8-9
Environmental Impacts of Alternatives (7:00 a.m. to 6:00 p.m.) and notifying potentially affected parties beforehand of such events would control noise impacts to acceptable levels. Noise impacts would be of short duration and would be SMALL.
Based on the above information, human health impacts for the construction and operation of two new nuclear units would be SMALL.
8.1.7 Land Use The GEIS generically evaluates the impacts of constructing and operating various replacement power plant alternatives on land use, both on and off each plant site. The analysis of land use impacts focuses on the amount of land area that would be affected by the construction and operation of a new nuclear power plant at the STP site.
STPNOC (2010a) estimated that the power block and ancillary facilities (excluding the cooling-water system) for the two new reactors would require approximately 540 ac (219 ha) and that sufficient contiguous acreage was available on the STP site. A sufficient amount of land is available on site, and most of the area is already in industrial use. Therefore, onsite land use impacts from the construction and operation of two new reactors at the STP site would be SMALL.
The amount of land required to mine uranium and fabricate nuclear fuel to support the new nuclear alternative would be similar to the amount of land required to support STP, Units 1 and 2, although an additional amount of land would be required to support uranium fuel requirements during the license renewal term. According to GEIS estimates, approximately 2,560 ac (1,036 ha) would be needed for the mining and processing of uranium fuel during the operating life of the new nuclear plant. Overall, offsite land use impacts from two new nuclear reactors would be SMALL.
8.1.8 Socioeconomics Socioeconomic impacts are defined in terms of changes to the demographic and economic characteristics and social conditions of a region. For example, the number of jobs created by the construction and operation of a power plant could affect regional employment, income, and expenditures.
Two types of jobs would be created by this alternative: (1) construction jobs, which are transient, short in duration, and less likely to have a long-term socioeconomic impact; and (2) power plant operation jobs, which have the greater potential for permanent, long-term socioeconomic impacts. Workforce requirements for the construction and operation of the new nuclear generation alternative were evaluated to measure their possible effects on current socioeconomic conditions.
STPNOC estimated a construction workforce of up to 5,950 (maximum) workers would be required to build Units 3 and 4 at the STP site (STPNOC 2010b). The relative economic impacts of this many workers on the local economy and tax base would vary, with the greatest impacts occurring in the communities where the majority of construction workers would reside and spend their income. As a result, local communities could experience a short-term economic boom from increased tax revenue and income generated by construction expenditures and the increased demand for temporary (rental) housing and business services. Some construction workers could relocate to Matagorda and surrounding counties in order to be closer to the construction work site. However, given the proximity of STP to the Houston metropolitan area, many construction workers could commute to the STP site, thereby lessening the need for 8-10
Environmental Impacts of Alternatives additional rental housing near STP. After completing the installation of the two new reactor units, local communities could experience a return to pre-construction economic conditions.
Based on this information, and given the magnitude of the estimated number of workers, socioeconomic impacts during construction in communities near the STP site could range from SMALL to LARGE.
STPNOC also estimated that STP, Units 3 and 4, would require 733 operations workers and an additional 1,100 workers during refueling outages (STPNOC 2010b). The number of operation workers would include some of the 1,378 workers from STP, Units 1 and 2. Socioeconomic impacts during operations could range from SMALL to MODERATE as the STP site transitions to the new reactor units. The potential reduction in overall employment at STP could affect property tax revenue and income in local communities and businesses. In addition, the permanent housing market could also experience increased vacancies and decreased prices if operations workers and their families move out of the region.
8.1.9 Transportation Transportation impacts associated with the construction and operation of a new two-unit nuclear power plant would consist of commuting workers and truck deliveries of construction materials and equipment to the power plant site. During periods of peak construction activity, up to 5,950 workers could be commuting daily to the STP site (STPNOC 2010b). Workers commuting to the STP site would primarily use two-lane roads. The volume of traffic on these roads, and especially Farm-to-Market (FM) 521, would increase substantially. In addition to commuting workers, trucks would be transporting construction materials and equipment to the worksite, further increasing the amount of traffic on local roads. The increase in vehicular traffic would peak during shift changes, resulting in temporary levels of service impacts and delays at intersections. Some power plant components and materials could also be delivered by train or barge (STPNOC 2010a). Train deliveries could cause additional traffic delays at railroad crossings. Based on this information, traffic-related transportation impacts during construction could range from MODERATE to LARGE.
Traffic-related transportation impacts would be greatly reduced after completing the installation of the two new reactor units. Transportation impacts would include daily commuting by the operating workforce, equipment and materials deliveries, and the removal of commercial waste material to offsite disposal or recycling facilities by truck. During reactor operations, the estimated number of operations workers commuting to and from STP would be 733 workers (STPNOC 2010b). Traffic-related transportation impacts would be less than current operations because the new units would employ approximately half as many workers as STP, Units 1 and 2. However, overall transportation impacts (related to plant operating workers and potential Units 1 and 2 decommissioning workers) would range from SMALL to MODERATE during power plant operations.
8.1.10 Aesthetics The analysis of aesthetic impacts focuses on the degree of contrast between the new nuclear alternative and the surrounding landscape and the visibility of the new power plant. The new power block would look very similar to the STP, Units 1 and 2, power block.
During construction, all of the clearing and excavation would occur on the STP site. These activities may be visible from offsite roads, particularly FM 521. Since the STP site already appears industrial, construction of the new units would appear similar to onsite activities during refueling outages.
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Environmental Impacts of Alternatives During reactor operations, the visual appearance of the STP site would not change since the power block for the new nuclear reactors would look virtually identical to the existing STP, Units 1 and 2, power block. Adding two new reactor units would increase the overall size of the existing STP facility if STP, Units 1 and 2, remained. Given the industrial appearance of the STP site and the similarity of the new units to the existing units, the new reactor units would blend in with the surroundings. In addition, the amount of noise generated during reactor operations would be the same as those generated during STP, Units 1 and 2, operations, which consists predominantly of the noise from routine industrial processes and communications. In general, aesthetic changes would be limited to the immediate vicinity of the STP site, and any impacts would be SMALL.
8.1.11 Historic and Archaeological Resources Cultural resources are the indications of human occupation and use of the landscape, as defined and protected by a series of Federal laws, regulations, and guidelines. Prehistoric resources are physical remains of human activities that predate written records; they generally consist of artifacts that may alone or collectively yield information about the past. Historic resources consist of physical remains that postdate the emergence of written records; in the U.S., they are architectural structures or districts, archaeological objects, and archaeological features dating from 1492 and later. Ordinarily, sites less than 50 years old are not considered historic, but exceptions can be made for such properties if they are of particular importance, such as structures associated with the development of nuclear power (e.g., Shippingport Atomic Power Station) or Cold War themes. American Indian resources are sites, areas, and materials important to American Indians for religious or heritage reasons. Such resources may include geographic features, plants, animals, cemeteries, battlefields, trails, and environmental features.
The cultural resource analysis encompassed the power plant site and adjacent areas that could potentially be disturbed by the construction and operation of replacement plant alternatives.
The potential for historic and archaeological resources can vary greatly depending on the location of the proposed site. To consider a projects effects on historic and archaeological resources, any affected areas would need to be surveyed to identify and record historic and archaeological resources, identify cultural resources (e.g., traditional cultural properties), and develop possible mitigation measures to address any adverse effects from ground-disturbing activities.
As described in Section 2.2.10, much of the STP site has been previously disturbed by the construction of STP, Units 1 and 2. In addition, in preparation for the COL application for Units 3 and 4, STPNOC conducted a cultural resources assessment of the STP site. STPNOC reviewed existing information for the STP site and the area within a 10-mi (16-km) radius.
STPNOC concluded that any cultural resource sites that may have existed on site would no longer retain their integrity because the area was heavily disturbed during the construction of Units 1 and 2 (STPNOC 2010b). In December 2006, STPNOC reported these findings to the SHPO at the Texas Historical Commission. The SHPO concurred that there would be no impacts to historic properties in January 2007 (STPNOC 2006; THC 2007).
There is a low potential for cultural resources to be located in previously undisturbed portions of the STP site. However, if the new nuclear units were to be sited within undisturbed areas or within areas of known cultural sensitivity (historic grave site located on the property and described in Section 2.2.10), these areas would need to be surveyed by a professional archaeologist to identify and develop possible mitigation measures to address any adverse effects from project activities. NRC assumes STPNOC would follow similar procedures to those described in the final EIS for STP, Units 3 and 4, if any historic or cultural resources were discovered during ground-disturbing activities associated with building the new units 8-12
Environmental Impacts of Alternatives (NRC 2011). In the final EIS for STP, Units 3 and 4, the staff concludes that the cumulative impacts to historic and archaeological resource would be SMALL.
The NRC staff determined that the impact of new nuclear plants at the STP site on historic and archaeological resources would be SMALL for the following reasons:
- NRC (2011) and STPNOC (2010a, 2010b) did not identify any cultural resources that could be affected by Units 3 and 4.
- The SHPO determined that construction for Units 3 and 4 would not affect cultural and historic resources.
- STPNOC has established environmental compliance procedures for new ground-disturbing activities.
8.1.12 Environmental Justice The environmental justice impact analysis evaluates the potential for disproportionately high and adverse human health and environmental effects on minority and low-income populations that could result from the construction and operation of a new power plant. Adverse health effects are measured in terms of the risk and rate of fatal or nonfatal adverse impacts on human health.
Disproportionately high and adverse human health effects occur when the risk or rate of exposure to an environmental hazard for a minority or low-income population is significant and exceeds the risk or exposure rate for the general population or for another appropriate comparison group. Disproportionately high environmental effects refer to impacts or risk of impact on the natural or physical environment in a minority or low-income community that are significant and appreciably exceed the environmental impact on the larger community. Such effects may include biological, cultural, economic, or social impacts. Some of these potential effects have been identified in resource areas discussed in this SEIS. For example, increased demand for rental housing during power plant construction could disproportionately affect low-income populations. Minority and low-income populations are subsets of the general public living near the STP site, and all are exposed to the same hazards generated from constructing and operating two new nuclear plants. Section 4.9.7, Environmental Justice, presents demographic information about minority and low-income populations residing in the vicinity of the STP site.
Potential impacts to minority and low-income populations from the construction and operation of a new nuclear power plant at the STP site would mostly consist of environmental and socioeconomic effects (e.g., noise, dust, traffic, employment, and housing impacts). Noise and dust impacts during construction would be short-term and primarily limited to onsite activities.
Minority and low-income populations residing along site access roads would be directly affected by increased commuter vehicle and truck traffic. However, because of the temporary nature of construction, these effects would only occur at certain hours of the day and are unlikely to be high and adverse. Increased demand for rental housing during construction could also affect low-income populations living near STP. However, given the proximity of STP to the Houston metropolitan area, many construction workers could commute to the STP site, thereby lessening the need for additional rental housing.
Based on this information, and the analysis of human health and environmental impacts presented in this SEIS, the construction and operation of a new nuclear power plant would not have disproportionately high and adverse human health and environmental effects on minority and low-income populations residing in the vicinity of the STP site.
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Environmental Impacts of Alternatives 8.1.13 Waste Management During the construction stage of the new nuclear plants, land clearing and other construction activities would generate waste that could be recycled, disposed of on site, or shipped to an offsite waste disposal facility. Because the new nuclear plants would be constructed on the previously disturbed STP site, the amounts of waste produced during land clearing would be reduced.
During the operational stage, normal plant operations, routine plant maintenance, and cleaning activities would generate nonradioactive waste as well as mixed waste, low-level waste, and high-level waste. Quantities of nonradioactive waste (discussed in Section 2.3.1 of this SEIS) and radioactive waste (discussed in Section 6.1 of this SEIS) generated by Units 1 and 2 would be comparable to that generated by the new nuclear plants.
According to the GEIS (NRC 1996), the generation and management of solid nonradioactive and radioactive waste during the period of renewed licenses are not expected to result in significant environmental impacts. Two new nuclear plants would generate waste streams similar to the two existing nuclear plants. Based on this information, waste impacts would be SMALL for two new nuclear plants located at the STP site.
8.1.14 Summary of Impacts of New Nuclear Generation Table 8-2 summarizes the environmental impacts of the new nuclear alternative compared to continued operation of STP.
Table 8-2. Summary of Environmental Impacts of the New Nuclear Alternative Compared to Continued Operation of STP, Units 1 and 2 Category New Nuclear Generation Continued STP Operation (proposed infrastructure)
Air quality SMALL SMALL Surface water SMALL SMALL Groundwater SMALL SMALL Aquatic resources SMALL SMALL Terrestrial resources SMALL SMALL Human health SMALL SMALL to MODERATE Land use SMALL SMALL Socioeconomics SMALL to LARGE SMALL Transportation MODERATE to LARGE SMALL Aesthetics SMALL SMALL Historic & archaeological SMALL SMALL Waste management SMALL SMALL 8.2 Natural Gas-Fired Combined-Cycle Generation In this section, the NRC staff evaluates the environmental impacts of natural gas-fired combined-cycle (NGCC) generation at the STP site.
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Environmental Impacts of Alternatives Natural gas accounted for 38 percent of all electricity generated in the ERCOT service area in 2010, accounting for the second greatest share of electrical power (ERCOT 2011a).
Development of new natural gas-fired plants may be affected by perceived or actual action to limit greenhouse gas emissions, although they produce markedly fewer greenhouse gases per unit of electrical output than coal-fired plants. Natural gas-fired plants are a feasible, commercially available option for providing electrical generating capacity beyond STPNOCs current license expiration. NRC examined NGCC because NGCC can operate with high thermal efficiency (approximately 60 percent for some units) and is capable of economically providing baseload power. Therefore, NRC considered NGCC generation a reasonable alternative to STP license renewal.
NGCC plants differ significantly from coal-fired boilers and existing nuclear plants. NGCC plants derive the majority of their electrical output from a gas-turbine cycle and then generate additional powerwithout burning any additional fuelthrough a second, steam-turbine cycle.
The first gas turbine stage (similar to a large jet engine) burns natural gas, which turns a driveshaft that powers an electric generator. The exhaust gas from the gas turbine is still hot enough to boil water to steam. Ducts carry the hot exhaust to a heat-recovery steam generator, which produces steam to drive a steam turbine and produce additional electrical power. The combined-cycle approach is significantly more efficient than any one cycle on its own; thermal efficiency can exceed 60 percent. Because the NGCC alternative derives much of its power from a gas turbine cycle, and because it wastes less heat than the existing STP units, it requires significantly less cooling water than the coal-fired alternative or the existing STP.
To replace the 2,500 MWe power that STP generates, NRC considered four hypothetical gas-fired units, each with a net capacity of 640 MWe. For purposes of this analysis, the hypothetical units would be similar to General Electrics (GEs) H-class gas fired combined-cycle units. While any number of commercially available combined-cycle units could be installed in a variety of combinations to replace the power currently produced by STP, GEs H-class units are highly efficient models that would be used to minimize environmental impacts. Other manufacturers, like Siemens, offer similarly high efficiency models.
GEs H-class combined-cycle generating units operate at a heat rate of 5,690 British thermal units per kilowatt hours (BTU/kWh), or nearly 60 percent thermal efficiency (GE 2011). As noted above, this NGCC alternative would require much less cooling water than STP because the NGCC units operate at a higher thermal efficiency and because they require much less water for steam cycle condenser cooling. Therefore, the NRC staff assumed that the existing cooling water system, including the intakes and discharges on the MCR and the Colorado River, would be sufficient for this alternative.
Construction of onsite visible structures would include the natural gas turbine buildings and heat-recovery steam generators (which may be enclosed in a single building), exhaust stacks, and, if necessary, equipment associated with a natural gas pipeline, such as a compressor station. The NGCC alternative at the STP site would use the existing STP transmission system.
Based on GEIS estimates, the plant would require approximately 312 ac (126 ha), which includes a new pipeline that would run approximately 2 mi (3 km) from the STP site to an existing pipeline.
This 2,560 MWe NGCC plant would consume 110 billion cubic feet (ft3) (3,111 million cubic meters (m3)) of natural gas annually, assuming an average heat content of 1,029 BTU/ft3 (EIA 2009). Natural gas would be extracted from the ground through wells, then treated to remove impurities (like hydrogen sulfide), and blended to meet pipeline gas standards before being piped through the state pipeline system to the plant site. This NGCC alternative would 8-15
Environmental Impacts of Alternatives produce relatively little waste, primarily in the form of spent catalysts used for emissions controls.
To build the NGCC plant, site crews would clear vegetation from the site, prepare the site surface, and begin excavation before other crews begin actual construction on the plant or any associated infrastructure, including the 2 mi (3 km) pipeline. The NGCC alternative at the STP site would use the existing STP transmission system. Construction materials would be delivered via rail spur, truck, or barge. For the proposed construction of Units 3 and 4, STPNOC proposed dredging near the current barge slip and upgrading the existing rail spur to accommodate shipments of construction materials (STPNOC 2010b). The NRC staff finds this to be reasonable and assumed that dredging and rail spur upgrades would be required for the NGCC alternative.
8.2.1 Air Quality As discussed in Section 2.2.2.1, the STP site is located in central Matagorda County, Texas, at the southern edge of the Metropolitan Houston-Galveston Intrastate Air Quality Control Region (40 CFR 81.38). The Corpus Christi-Victoria Intrastate Air Quality Control Region (40 CFR 81.136) lies immediately south and west of Matagorda County. EPA has designated all of the counties in these Air Quality Control Regions adjacent to the STP site as in compliance with the National Ambient Air Quality Standards (40 CFR 81.344) except Brazoria County to the north; Brazoria County is classified Nonattainment/Severe relative to the 8-hour ozone standard (EPA 2011b).
Construction activities would cause some localized temporary air quality effects because of emissions and fugitive dust from operation of earth-moving and material-handling equipment.
Emissions from workers vehicles and motorized construction equipment would be temporary.
NRC assumed that construction crews would use dust-control practices to control and reduce fugitive dust. STPNOC proposed such activities during construction of proposed Units 3 and 4 (STPNOC 2010b), and §111.145 of TCEQs regulations require dust suppression control during the construction of facilities and parking lots.
A new NGCC plant would qualify as a new major-emitting industrial facility and would be subject to PSD requirements under the Clean Air Act (CAA) (EPA 2011c). The NGCC plant would need to comply with the standards of performance for electric utility steam generating units set forth in 40 CFR Part 60 Subpart KKKK. The plant would also require an operating permit from TCEQ.
In STPNOCs ER for Units 3 and 4, STPNOC stated that [a]ir emissions sources would be managed in accordance with Federal, Texas, and local air quality control laws and regulations.
Likewise, NRC assumed that the NGCC plant would also operate in accordance with Federal, Texas, and local air quality control laws and regulations.
Subpart P of 40 CFR Part 51 contains the visibility protection regulatory requirements, including the review of new sources that would be constructed in the attainment or unclassified areas and may affect visibility in any Federal Class I area. If an NGCC alternative was located close to a mandatory Class I area, additional air pollution control requirements would be required. As noted in Section 2.2.2.1, there are no mandatory Class I Federal areas within 50 mi of the STP site.
The NRC projects the following emissions based on data published by the EIA, EPA, and on performance characteristics and emissions controls:
Environmental Impacts of Alternatives
- particulate matter 10 m or PM10373 tons (338 MT) per year.
8.2.1.1 Sulfur Oxide and Nitrogen Oxide A new NGCC plant would have to comply with Title IV of the CAA (42 USC 7651) reduction requirements for sulfur oxides and nitrogen oxides, which are the main precursors of acid rain and the major cause of reduced visibility. Title IV establishes maximum sulfur oxide and nitrogen oxide emission rates from existing plants and a system of sulfur oxide emission allowances that can be used, sold, or saved for future use by new plants. In addition, in August 2011, EPA published the Cross-State Air Pollution Rule, which included reductions of sulfur oxides and nitrogen oxides in Texas. According to the rule, NGCC plants would need to comply with the new reductions by 2012.
As stated above, the new NGCC alternative would produce 192 tons (174 MT) per year of sulfur oxides and 839 tons (761 MT) per year of nitrogen oxides based on the use of the dry low-nitrogen oxide combustion technology and use of the selective catalytic reduction (SCR) to significantly reduce nitrogen oxide emissions. The new plant would be subjected to the continuous monitoring requirements for sulfur oxides and nitrogen oxides, as specified in 40 CFR Part 75. The current State Implementation Plan (SIP) for Texas includes a cap and trade program for sulfur and nitrogen oxides. To operate the NGCC plant, sulfur dioxide allowance would need to be purchased from the open market or an existing fossil-fired plant would need to be shut down and those credits would need to be applied to the new plants (STPNOC 2010a). Thus, provided the plant operator is able to purchase sufficient allowances to operate, the NGCC alternative would not add to the net regional sulfur or nitrogen oxide emissions, although it might do so locally.
8.2.1.2 Greenhouse Gases The new plant would release greenhouse gases, such as carbon dioxide and methane. The plant would be subjected to the continuous monitoring requirements for carbon dioxide, as specified in 40 CFR Part 75. The NGCC plant would emit approximately 6.1 million tons (approximately 6.0 million MT) per year of carbon dioxide emissions.
On July 12, 2012, EPA issued a final rule tailoring the applicability criteria that determine which stationary sources and modification to existing projects become subject to permitting requirements for greenhouse emissions under the PSD and Title V Programs of the CAA (77 FR 41051). According to the Tailoring Rule, greenhouse gases are a regulated new source review pollutant under the PSD major source permitting program if the source is otherwise subject to PSD (for another regulated new source review pollutant) and has a greenhouse gas potential to emit equal to or greater than 75,000 tons (68,000 MT) per year of carbon dioxide equivalent (carbon dioxide equivalent adjusting for different global warming potentials for different greenhouse gases). Such sources would be subject to best available control technology (BACT), although EPA has yet to determine BACT for greenhouse gases.
EPA issued a Federal Implementation Plan (FIP) on May 3, 2011, to permit greenhouse gas-emitting sources in states that do not have measures to lower greenhouse gases in their SIP. Because Texas has not updated its SIP to include greenhouse gases, EPA will be the official permitting authority for greenhouse gas-emitting sources in Texas if the SIP is not updated before the NGCC plant begins operations.
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Environmental Impacts of Alternatives 8.2.1.3 Particulates The new NGCC alternative would produce 373 tons (338 MT) per year of TSP, all of which would be emitted as PM10. STPNOC (2010a) indicated that all PM10 emissions would be particulate matter, 2.5 m or PM2.5. DOE (2007) evaluated the emissions from a hypothetical 560 MWe NGCC unit using BACT to meet the emission requirements of the 2006 New Source Performance Standards. DOE concluded that emissions from particulates would be negligible because NGCC uses natural gas as fuel; therefore, NGCC plants would not require emissions controls equipment or features to reduce these emissions.
During the construction of an NGCC plant, onsite activities would also generate fugitive dust.
Vehicles and motorized equipment would create exhaust emissions during the construction process. These impacts would be intermittent and short-lived; however, to minimize dust generation, construction crews would use applicable dust-control measures, as described above.
8.2.1.4 Hazardous Air Pollutants In December 2000, EPA issued regulatory findings (65 FR 79825) on emissions of hazardous air pollutants (HAPs) from electric utility steam-generating units, which said that natural gas-fired plants emit HAPs such as arsenic, formaldehyde, and nickel and stated the following:
Also in the utility RTC (Report to Congress), the EPA indicated that the impacts due to HAP emissions from natural gas-fired electric utility steam generating units were negligible based on the results of the study. The Administrator finds that regulation of HAP emissions from natural gas-fired electric utility steam generating units is not appropriate or necessary.
As a result of EPAs conclusion, the NRC staff finds no significant air quality effects from HAPs.
8.2.1.5 Conclusion Based on this information, the overall air quality impacts of a new NGCC plant located at the STP site would be SMALL to MODERATE. Impacts would not be noticeable for sulfur and nitrogen oxides because the Texas SIP requires a Cap and Trade Program, and there would be no net increase in sulfur and nitrogen oxide emissions. Based on analyses from DOE (2007) and EPA (2000, 65 FR 79825), TSPs and HAPs would have negligible impacts. Greenhouse gas emissions would be noticeable; carbon dioxide emissions would be two orders of magnitude larger than the threshold in EPAs tailoring rule for greenhouse gas (75,000 tons or 68,000 MT) per year of carbon dioxide equivalent), which would trigger a regulated new source review.
8.2.2 Surface Water Resources STPNOC did not propose using any surface water during the construction of Units 3 and 4 (NRC 2011). As a new NGCC plant would occupy a much smaller footprint relative to new nuclear units, and its construction would entail less extensive excavation and earthwork, NRC expects that surface water would not be used during construction for the NGCC alternative.
Some temporary impacts to surface water quality may result from dredging activities in the Colorado River near the barge slip and from increased sediment loading in stormwater runoff from active construction areas. Due to the short-term nature of the dredging activities, the hydrologic alterations and sedimentation would be localized and temporary. Dredging would also be conducted under a permit from the USACE requiring the implementation of BMPs to minimize impacts. Runoff from construction areas would be controlled under a State-issued TPDES general permit that would require implementation of a stormwater pollution prevention 8-18
Environmental Impacts of Alternatives plan and associated BMPs to prevent or significantly mitigate soil erosion and contamination of stormwater runoff from construction activities.
For facility operations, the NGCC alternative would require much less cooling water than STP, Units 1 and 2, and consumptive water use would be much less. It is expected that use of the existing intake and discharge infrastructure on the MCR and the Colorado River would be sufficient to support this alternative. Surface water withdrawals would be subject to, and would remain well within, STPNOCs existing water rights, and effluent discharges and stormwater discharges associated with industrial activity would subject to a revised State-issued TPDES permit under this alternative.
In consideration of the above, the impacts on surface water use and quality from construction and operations under the NGCC alternative would be SMALL.
8.2.3 Groundwater Resources Construction-related ground disturbance and excavation work would be substantially less than that described for the new nuclear alternative. Although groundwater dewatering of foundation excavations for a new NGCC plant would likely be required, slurry walls and wells were proposed for use to minimize potential adverse effects from dewatering both on site and off site (NRC 2011). Application of BMPs in accordance with a state-issued NPDES general permit, including appropriate waste management and spill prevention practices, would prevent or minimize any groundwater quality impacts during construction.
STPNOC assumed that a fossil-fuel-fired generation facility would be located adjacent to the STP, Units 1 and 2, site to use the existing infrastructure, including continued use of existing onsite groundwater production wells at STP. Groundwater use for construction of a new NGCC plant would be substantially less than the volume required for new nuclear units under this alternative by virtue of the smaller footprint involved for excavation, earthwork, and structural work. This would encompass such uses as potable and sanitary uses, concrete production, dust suppression and soil compaction, and other uses.
For NGCC plant operations, NRC assumed that the NGCC alternative would entail the same relative ratio of groundwater use to surface water use as that used at STP, Units 1 and 2. This includes the use of groundwater for freshwater and service water makeup, potable and sanitary uses, and fire protection. Consequently, it is expected that total groundwater usage and associated aquifer effects would likely be much less under this alternative than those under current STP operations. This is because of the fewer number of auxiliary systems requiring groundwater and the much smaller workforce under the NGCC alternative.
Based on this information, the overall impact on groundwater use and quality from construction and operations under the NGCC alternative would be SMALL.
8.2.4 Aquatic Ecology Construction activities for the NGCC alternative (such as construction of heavy haul roads and the power blocks) could affect drainage areas or other onsite aquatic features. NRC assumed that the plant operator would install temporary and permanent erosion and sediment control measures to minimize the flow of disturbed soils into ditches and wetlands. Such BMPs would likely be described in a TPDES general permit relating to stormwater discharges for construction activities. To bring new materials to the site, NRC assumed the plant operator would dredge near the barge slip to transport some materials using barges. Permits and certifications from the USACE and other agencies would require the implementation of BMPs to minimize impacts.
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Environmental Impacts of Alternatives Due to the short-term nature of the dredging activities, the hydrological alterations to aquatic habitats would be localized and temporary.
During operations, the NGCC alternative would require less cooling water to be withdrawn from the Colorado River than STP, Units 1 and 2, requires. Therefore, the number of fish and other aquatic organisms affected by impingement and entrainment would be less for an NGCC alternative than for those associated with license renewal. The NGCC alternative would also discharge less thermal effluent because less cooling water would be required. STPNOCs TPDES permit limits the daily discharge to 144 million gpd and shall not exceed 12.5 percent of the flow of the Colorado River at the discharge point (TCEQ 2005). STPNOC has discharged to the Colorado River once during the operation of STP in 1997 as part of a system test (STPNOC 2010a). Because the thermal discharge would be smaller than STP, Units 1 and 2, the number of fish and other aquatic organisms affected by heat shock would be less for an NGCC alternative than for those associated with license renewal.
The NGCC plant emission has specific impacts to the aquatic ecology. The cooling system for a new NGCC plant would have similar chemical discharges as STP, but the air emissions from the NGCC plant would emit particulates that would settle onto the river surface and introduce a new source of pollutants that would not exist if STP continued operating. However, the flow of the Colorado River would dissipate pollutants, which would decrease the concentration of pollutants and minimize the exposure of fish and other aquatic organisms to pollutants.
Construction activities would require BMPs; dredging would be short-term; the surface water withdrawal and discharge for this alternative would be less than for STP, Units 1 and 2; and pollutants would dissipate within the Colorado River (minimizing exposure concentrations to aquatic resources). Therefore, impacts on aquatic ecology would be SMALL.
8.2.5 Terrestrial Ecology Constructing the NGCC alternative would require approximately 312 ac (126 ha), which includes a new pipeline that would run approximately 2 mi (3 km) from the STP site to an existing pipeline. These land disturbances form the basis for impacts on terrestrial ecology.
If the NGCC alternative was constructed at the STP site, construction would likely affect a variety of habitats and land uses, including industrial land (buildings, parking areas, and mowed-maintained fields), drainage ditches, scattered small palustrine wetlands, scrub-shrub habitat, and mixed grassland habitat where abandoned farm lands previously existed prior to construction of Units 1 and 2. Most of these areas have been mildly to extensively disturbed during the construction and operation of Units 1 and 2 and other human activities. After the completion of the new units, the plant operator would likely grade, landscape, and replant the areas used for temporary building support, which is similar to what STPNOC proposed to do after completion of proposed new nuclear Units 3 and 4 (STPNOC 2010b). The majority of permanently affected areas would be maintained (e.g., mowed) and industrial areas. The plant operator would likely implement BMPs to minimize impacts to wetlands, and the plant operator would be required to comply with the USACE 404 permits. Construction activities could also adversely affect onsite wildlife through noise, increased light pollution, and increased traffic.
However, these impacts would be temporary and minor.
Gas extraction and collection would also affect terrestrial ecology in offsite gas fields, although much of this land is likely already disturbed by gas extraction, and the incremental effects of this alternative on gas field terrestrial ecology are difficult to gauge.
Construction of the 2-mi (3-km) natural gas pipeline could also increase habitat fragmentation.
To the extent possible, STPNOC would route the pipeline through previously disturbed areas 8-20
Environmental Impacts of Alternatives (STPNOC 2010a). Threatened and endangered species may also be affected by construction of the natural gas pipeline. Long-linear projects, such as pipelines, can often be sited to avoid sensitive areas. Once construction is completed, impacts would be minimal, especially in previously disturbed areas.
Because many construction-related impacts would be temporary, and because the majority of long-term construction impacts would occur within previously disturbed areas, impacts on terrestrial resources would be SMALL.
8.2.6 Human Health An NGCC plant would emit criteria air pollutants, but generally in smaller quantities than a coal-fired plant (except nitrogen oxide, which requires additional controls to reduce emissions).
The human health effects of NGCC generation are generally low, although in Table 8-2 of the GEIS (NRC 1996), the NRC identified cancer and emphysema as potential health risks from natural gas-fired plants. Nitrogen oxide emissions contribute to ozone formation, which in turn contributes to human health risks. Emission controls on this NGCC alternative maintain nitrogen oxide emissions well below air quality standards established for the purposes of protecting human health, and emissions trading or offset requirements mean that overall nitrogen oxide in the region would not increase. Health risks to workers may also result from handling spent catalysts that may contain heavy metals.
Overall, human health risks to occupational workers and to members of the public from NGCC plant emissions sited at the STP site would likely be SMALL.
Noise during plant operations would be limited to industrial processes and communications.
Pipelines delivering natural gas fuel could be audible off site near compressor stations. Pipeline companies would need to adhere to local ordinances regarding maximum noise levels during construction and at compressor stations. Therefore, impacts from noise would likely be SMALL.
8.2.7 Land Use The GEIS generically evaluates the impact of constructing and operating various replacement power plant alternatives on land use, both on and off each plant site. The analysis of land use impacts focuses on the amount of land area that would be affected by the construction and operation of a four-unit NGCC plant at the STP site.
Based on scaled GEIS estimates and information provided by STPNOC in its ER, approximately 312 ac (126 ha) of land would be needed to support an NGCC alternative to replace STP. This amount of land use would include other plant structures and associated infrastructure, such as the new 2-mi (3-km) pipeline, and is unlikely to exceed 312 ac (126 ha), excluding land for natural gas wells and collection stations.
In addition to onsite land requirements, land would be required off site for natural gas wells and collection stations. Scaling from GEIS estimates, approximately 9,600 ac (3,885 ha) would be required for wells and collection stations to bring the gas to the plant. Gas well and collection stations could noticeably alter land use in those areas, although most of this land requirement would occur in areas where gas extraction already occurs.
The elimination of uranium fuel for STP could partially offset offsite land requirements. Scaling from GEIS estimates approximately 2,560 ac (1,036 ha) would not be needed for mining and processing uranium during the operating life of the plant. Overall land-use impacts from the natural gas alternative (considering the amount of additional offsite land needed for NGCC gas 8-21
Environmental Impacts of Alternatives pipeline infrastructure and gas well and collection station development) could range from SMALL to MODERATE.
8.2.8 Socioeconomics Socioeconomic impacts are defined in terms of changes to the demographic and economic characteristics and social conditions of a region. For example, the number of jobs created by the construction and operation of a power plant could affect regional employment, income, and expenditures. Two types of jobs would be created by this alternative: (1) construction-related jobs, which are transient, short in duration, and less likely to have a long-term socioeconomic impact; and (2) power plant operation jobs, which have the greater potential for permanent, long-term socioeconomic impacts. Workforce requirements for the construction and operation of the NGCC alternative were evaluated to measure their possible effects on current socioeconomic conditions.
Scaling from GEIS estimates, the construction workforce would peak at 3,200 workers.
STPNOC projected a maximum construction workforce of 2,028 workers (STPNOC 2010a).
STPNOCs estimate appears reasonable; therefore, it is used in this analysis. The relative economic impact of this many workers on the local economy and tax base would vary, with the greatest impacts occurring in the communities where the majority of construction workers would reside and spend their income. As a result, local communities could experience a short-term economic boom from increased tax revenue and income generated by construction expenditures and the increased demand for temporary (rental) housing and business services.
Some construction workers could relocate to Matagorda and surrounding counties in order to be closer to the construction work site. However, given the proximity of STP to the Houston metropolitan area, many construction workers could commute to the STP site, thereby lessening the need for additional rental housing near STP.
After completing the installation of the four-unit NGCC plant, local communities could experience a return to pre-construction economic conditions. Based on this information, and given the number of workers, socioeconomic impacts during construction in communities near the STP site could range from SMALL to MODERATE.
Scaling from GEIS estimates, the plant operation workforce would be 400 workers. STPNOC estimated a plant operations workforce of approximately 97 workers. The STPNOC estimate appears to be reasonable and is consistent with trends toward lowering labor costs by reducing the size of plant operations workforces. The amount of property taxes paid under the NGCC alternative may increase if additional land is required off site to support this alternative.
Socioeconomic impacts during operations could range from SMALL to MODERATE as the STP site transitions to the new NGCC power plant. The potential reduction in overall employment at STP could affect property tax revenue and income in local communities and businesses. In addition, the permanent housing market could also experience increased vacancies and decreased prices if operations workers and their families move out of the region.
8.2.9 Transportation Transportation impacts associated with construction and operation of a four-unit, NGCC plant would consist of commuting workers and truck deliveries of construction materials to the STP site. During periods of peak construction activity, up to 2,028 workers could be commuting daily to the site (STPNOC 2010a). Workers commuting to the STP site would primarily use two-lane roads. The volume of traffic on these roads, and especially FM 521, would increase substantially. In addition to commuting workers, trucks would be transporting construction materials and equipment to the worksite, thus increasing the amount of traffic on local roads.
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Environmental Impacts of Alternatives The increase in vehicular traffic would peak during shift changes, resulting in temporary levels of service impacts and delays at intersections. Pipeline construction and modification to existing natural gas pipeline systems could also have a temporary impact. Some power plant components and materials could also be delivered by train or barge. Train deliveries could cause additional traffic delays at railroad crossings. Based on this information, traffic-related transportation impacts during construction could range from SMALL to MODERATE.
Traffic-related transportation impacts would be greatly reduced after completing the installation of the new NGCC units. Transportation impacts would include daily commuting by the operating workforce, equipment and materials deliveries, and the removal of commercial waste material to offsite disposal or recycling facilities by truck. During operations, the estimated number of operations workers commuting to and from STP would be 97 workers (STPNOC 2010a). Since fuel is transported by pipeline, the transportation infrastructure would experience little to no increased traffic from plant operations. Traffic-related transportation impacts would be considerably less than current operations because the new NGCC power plant would employ far fewer workers than STP, Units 1 and 2. Overall, transportation impacts would be SMALL during plant operations.
8.2.10 Aesthetics The analysis of aesthetic impacts focuses on the degree of contrast between the NGCC alternative and the surrounding landscape and the visibility of the NGCC plant. During construction, all of the clearing and excavation would occur on the STP site. These activities may be visible from offsite roads, particularly FM 521. Since the STP site already appears industrial, construction of the NGCC power plant would appear similar to onsite activities during refueling outages.
The four NGCC units could be approximately 100 ft (30 m) tall, with two exhaust stacks up to 175 ft (53 m) tall. The facility would be visible off site during daylight hours, and some structures may require aircraft warning lights. The power plant would be smaller and less noticeable than STP, Units 1 and 2, which has a reactor building height of approximately 250 ft (76 m) (STPNOC 2010b). Noise generated during NGCC power plant operations would be limited to routine industrial processes and communications. Pipelines delivering natural gas fuel could be audible off site near gas compressor stations.
In general, given the industrial appearance of the STP site, the new NGCC power plant would blend in with the surroundings if the existing STP, Units 1 and 2, remains. Aesthetic changes would be limited to the immediate vicinity of the existing STP site, and any impacts would be SMALL.
8.2.11 Historic and Archaeological Resources The same considerations, discussed in Section 8.1.11, for the impact of the construction of a new nuclear plant on historic and archaeological resources apply to the construction activities that would occur on the STP site for an NGCC plant. As described in Section 2.2.10, much of the STP site has been previously disturbed by the construction of STP, Units 1 and 2. In addition, in preparation for the COL application for Units 3 and 4, STPNOC conducted a cultural resources assessment of the STP site. STPNOC reviewed existing information for the STP site and the area within a 10-mi (16-km) radius. STPNOC concluded that any cultural resource sites that may have existed on site would no longer retain their integrity because the area was heavily disturbed during the construction of Units 1 and 2 (STPNOC 2010b). In December 2006, STPNOC reported these findings to the SHPO at the Texas Historical Commission. The SHPO 8-23
Environmental Impacts of Alternatives concurred, in January 2007, that there would be no impacts to historic properties (STPNOC 2006; THC 2007).
There is a low potential for cultural resources to be located in previously undisturbed portions of the STP site. However, if the NGCC units were to be sited within undisturbed areas or within areas of known cultural sensitivity (historic grave site located on the property and described in Section 2.2.10), these areas would need to be surveyed by a professional archaeologist to identify and develop possible mitigation measures to address any adverse effects from project activities. NRC assumes the plant operator would follow similar procedures to those described in the final EIS for STP, Units 3 and 4 (NRC 2011), if the plant operator discovered any historic or cultural resources during ground-disturbing activities associated with building the new units.
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., the new 2-mi pipeline, roads, transmission corridors, rail lines, or other rights-of-way (ROWs)). In most cases, long-linear projects can be sited to avoid areas of greatest sensitivity.
The NRC staff determined that the impact of the NGCC alternative at the STP site on historic and archaeological resources would be SMALL for the following reasons:
- NRC (2011) and STPNOC (2010a, 2010b) did not identify any cultural resources that could be affected by Units 3 and 4.
- The SHPO determined that construction for Units 3 and 4 would not affect cultural and historic resources.
- Long-linear projects (e.g., pipelines) can usually be sited to avoid sensitive areas.
- NRC assumes that the plant operator would follow environmental compliance procedures for new ground-disturbing activities.
8.2.12 Environmental Justice The environmental justice impact analysis evaluates the potential for disproportionately high and adverse human health, environmental, and socioeconomic effects on minority and low-income populations that could result from the construction and operation of a new power plant. As previously discussed in Section 8.1.12, such effects may include human health, biological, cultural, economic, or social impacts. Some of these potential effects have been identified in resource areas discussed in this SEIS. For example, increased demand for rental housing during plant construction could disproportionately affect low-income populations. Minority and low-income populations are subsets of the general public living near the STP site, and all are exposed to the same hazards generated from constructing and operating a new NGCC plant.
Section 4.9.7, Environmental Justice, presents demographic information about minority and low-income populations residing in the vicinity of the STP site.
Potential impacts to minority and low-income populations from the construction and operation of a new NGCC plant at the STP site would mostly consist of environmental and socioeconomic effects (e.g., noise, dust, traffic, employment, and housing impacts). Noise and dust impacts during construction would be short-term and primarily limited to onsite activities. Minority and low-income populations residing along site access roads would be directly affected by increased commuter vehicle and truck traffic. However, because of the temporary nature of construction, these effects would only occur during certain hours of the day and are unlikely to be high and adverse. Increased demand for rental housing during construction could also affect low-income populations living near STP. However, given the proximity of STP to the Houston metropolitan 8-24
Environmental Impacts of Alternatives area, many construction workers could commute to the STP site, thereby lessening the additional need for rental housing.
Based on this information, and the analysis of human health and environmental impacts presented in this SEIS, the construction and operation of a new NGCC power plant would not have disproportionately high and adverse human health and environmental effects on minority and low-income populations residing in the vicinity of the STP site.
8.2.13 Waste Management During the construction stage of the NGCC generation alternative, land clearing and other construction activities would generate waste that could be recycled, disposed of on site, or shipped to an offsite waste disposal facility. Because the alternative would be constructed on or near the previously disturbed STP site, the amounts of waste produced during land clearing would be reduced.
During the operational stage, spent SCR catalysts, which are used to control nitrogen oxide emissions from the NGCC plants, would make up the majority of the waste generated by this alternative.
According to the GEIS (NRC 1996), an NGCC plant would generate minimal waste. Waste impacts would therefore be SMALL for an NGCC alternative located at the STP site.
8.2.14 Summary of Impacts for the NGCC Generation Alternative Table 8-3 summarizes the environmental impacts of the NGCC alternative compared to continued operation of STP.
Table 8-3. Summary of Environmental Impacts of the NGCC Alternative Compared to Continued Operation of STP Natural Gas Combined-Cycle Category Generation Continued STP Operation Air quality SMALL to MODERATE SMALL Surface water SMALL SMALL Groundwater SMALL SMALL Aquatic resources SMALL SMALL Terrestrial resources SMALL SMALL Human health SMALL SMALL to MODERATE Land use SMALL to MODERATE SMALL Socioeconomics SMALL to MODERATE SMALL Transportation SMALL to MODERATE SMALL Aesthetics SMALL SMALL Historic & archaeological SMALL SMALL Waste management SMALL SMALL 8-25
Environmental Impacts of Alternatives 8.3 Supercritical Coal-Fired Generation In this section, the NRC staff evaluates the environmental impacts of supercritical coal-fired generation at the STP site.
Coal-fired generation accounted for 40 percent of all electricity generated in the ERCOT service area in 2010, accounting for the greatest share of electrical power (ERCOT 2011a).
Furthermore, the EIA projects that coal-fired power plants will account for the greatest share of capacity additions through 2035more than natural gas, nuclear, or renewable generation options (EIA 2011a). Development of new coal-fired plants may be affected by perceived or actual action to limit greenhouse gas emissions. TCEQ has recently granted permits to several recently proposed coal-fired plants (TCEQ 2011). Supercritical coal-fired plants are feasible, commercially available options for providing electrical generating capacity beyond STPNOCs current license expiration. Therefore, NRC considered supercritical coal fired-generation a reasonable alternative to STP license renewal.
Supercritical technologies are increasingly common in new coal-fired plants. Supercritical facilities operate at higher temperatures and pressures than most existing coal-fired plants. At the critical point, there is no change of state when pressure is increased or if heat is added. For states above the critical point, the steam is supercritical. Operating at higher temperatures and pressures allows the supercritical coal-fired alternative to operate at a higher thermal efficiency than subcritical coal-fired power plants. While supercritical facilities are more expensive to construct, they consume less fuel for a given output, reducing environmental impacts. Based on technology forecasts from EIA, the NRC staff expects that a new, supercritical coal-fired plant would operate at a heat rate of 8,740 Btu/kWh (EIA 2011b).
In a supercritical coal-fired power plant, burning coal heats pressurized water. As the supercritical steam and water mixture moves through plant pipes to a turbine generator, the pressure drops. The mixture flashes to steam. The heated steam expands across the turbine stages, which then spin and turn the generator to produce electricity. After passing through the turbine, any remaining steam is condensed back to water in the plants condenser.
To replace the 2,500 MWe of power that STP generates, the NRC staff considered four hypothetical coal-fired units, each with a net capacity of 640 MWe. The hypothetical coal-fired plant would require a similar amount of water as STP, Units 1 and 2. Therefore, the NRC staff assumed that the existing cooling water system, including the intakes and discharges on the MCR and the Colorado River, would be sufficient for this alternative. The coal-fired alternative at the STP site would also use the existing STP transmission system.
The hypothetical 2,560 MWe power plant would consume 11.4 million tons (10.4 MT) of coal annually, based on an average heat content of 8,200 British thermal units per pound (Btu/lb)
(STPNOC 2010a). EPA (2011a) reported that the majority of coal plants within the ERCOT region use subbituminous coal. The other coal plants used lignite or combined subbituminous coal with lignite. While lignite is the most common type of coal found in Texas, NRC assumed that the hypothetical coal plant for this alternative would use subbituminous coal because when combusted, it releases lower levels of Federal CAA criteria pollutants, such as carbon dioxide, nitrous oxides, sulfuric oxides, and particulate matter (TCPA 2008).
Texas coal plants commonly use Power River Basin coal (STPNOC 2010a; TCPA 2008). Given current coal mining operations in Wyoming, the coal used in this alternative would likely be mined in surface mines, then mechanically processed and washed, before being transported likely by railto the power plant site. Limestone for scrubbers would also likely arrive by rail (STPNOC 2010a). This coal-fired alternative would produce roughly 446,000 tons (405,000 MT) of ash, and 43 percent (193,000 tons (175,000 MT)) of the ash would be recycled 8-26
Environmental Impacts of Alternatives for beneficial use (STPNOC 2010a). STPNOC (2010a) estimated that approximately 88,000 tons (80,000 MT) of scrubber sludge would be disposed of on site each year, which was based on an assumed annual lime usage of approximately 107,000 tons (97 MT).
Approximately 200 ac (81 ha) would be required to dispose of the ash and scrubber waste on site over a 40-year plant life (STPNOC 2010a).
Construction of onsite visible structures would include the boilers and heat-recovery steam generators (which may be enclosed in a single building), exhaust stacks, and an electrical switchyard. Based on GEIS estimates, the plant would require approximately 4,629 ac (1,873 ha) of land. STPNOC (2010a) estimates that 353 ac (143 ha) of land would be required.
This estimate appears reasonable; therefore, it is used for this analysis.
To build the coal-fired alternative, site crews would clear the plant site of vegetation, prepare the site surface, and begin excavation before other crews begin actual construction on the plant and any associated infrastructure. Construction materials would be delivered via rail spur, truck, or barge. For the proposed construction of Units 3 and 4, STPNOC proposed dredging near the current barge slip and upgrading the existing rail spur to accommodate shipments of construction materials (STPNOC 2010b). The NRC staff finds this to be reasonable and assumed that dredging and rail spur upgrades would be required for the coal-fired alternative.
The NRC also considered an integrated gasification combined cycle (IGCC) coal-fired plant.
IGCC is an emerging technology for generating electricity with coal that combines modern coal gasification technology with both gas turbine and steam turbine power generation. The technology is cleaner than conventional pulverized coal plants because major pollutants can be removed from the gas stream before combustion. The IGCC alternative also generates less solid waste than the pulverized coal-fired alternative. The largest solid waste stream produced by IGCC installations is slag, a black, glassy, sand-like material that is potentially a marketable byproduct. The other large-volume byproduct produced by IGCC plants is sulfur, which is extracted during the gasification process and can be marketed rather than placed in a landfill.
IGCC units do not produce ash or scrubber wastes. In spite of the preceding advantages, the NRC concluded in the final EIS for the proposed Units 3 and 4 (NRC 2011) that a new IGCC plant is not a reasonable alternative for the following reasons:
- IGCC plants are more expensive than comparable pulverized coal plants (NETL 2007).
- The few existing IGCC plants in the U.S. have considerably smaller capacity (approximately 250 MWe each) than STP, Units 1 and 2.
- System reliability of existing IGCC plants has been lower than pulverized coal plants.
- The existing IGCC plants have had an extended (though ultimately successful) operational testing period (NPCC 2005).
- A lack of overall plant performance warranties for IGCC plants has hindered commercial financing (NPCC 2005).
At present, the NRC continues to finds this determination reasonable. While the capacity of some of the proposed IGCC plants has grown slightly, most proposed IGCC plants are still considerable smaller than STP, Units 1 and 2. For example, on September 27, 2011, DOE approved a loan to Summit Texas Clean Energy, LLC, for a 400 MWe IGCC plant to be built west of Midland-Odessa, Texas (DOE 2011a). Although NRC considered an IGCC plant as an alternative for the Shearon Harris license renewal SEIS, whose license would also have expired in 2027, the Shearon Harris nuclear plant is much smaller than STP, Units 1 and 2 (955 MWe 8-27
Environmental Impacts of Alternatives as compared to 2,500 MWe) (NRC 2008). Because of the small capacity of proposed IGCC plants, the NRC did not find IGCC to be a reasonable alternative for STP, Units 1 and 2. For these reasons, IGCC plants are not considered further in this SEIS.
8.3.1 Air Quality Air quality impacts from coal-fired generation can be substantial because it emits a significant quantity of sulfur oxides, nitrogen oxides, particulates, carbon monoxide, and HAPs such as mercury; however, many of these pollutants can be effectively controlled by various technologies.
As discussed in Section 2.2.2.1, STP is located in central Matagorda County, Texas, at the southern edge of the Metropolitan Houston-Galveston Intrastate Air Quality Control Region (40 CFR 81.38). The Corpus Christi-Victoria Intrastate Air Quality Control Region (40 CFR 81.136) lies immediately south and west of Matagorda County. EPA has designated all of the counties in these Air Quality Control Regions adjacent to the STP site as in compliance with the National Ambient Air Quality Standards (40 CFR 81.344) except Brazoria County to the north; Brazoria County is classified Nonattainment/Severe relative to the 8-hour ozone standard (EPA 2011b).
Construction activities would cause some localized temporary air-quality effects because of emissions and fugitive dust from operation of the earth-moving and material-handling equipment. Emissions from workers vehicles and motorized construction equipment exhaust would be temporary. NRC assumed that construction crews would use dust-control practices to control and reduce fugitive dust. STPNOC proposed such activities during construction of proposed Units 3 and 4 (STPNOC 2010b), and §111.145 of TCEQs regulations require dust suppression control during the construction of facilities and parking lots.
A new coal-fired plant would qualify as a new major-emitting industrial facility and would be subject to PSD requirements of the CAA (EPA 2011c). The coal-fired plant would need to comply with the standards of performance for electric utility steam generating units set forth in 40 CFR Part 60 Subpart Da and GG. The plant would also require an operating permit from TCEQ. In STPNOCs ER for Units 3 and 4, STPNOC stated that [a]ir emissions sources would be managed in accordance with Federal, Texas, and local air quality control laws and regulations. Likewise, NRC assumed that the coal-fired plant would be operated in accordance with Federal, Texas, and local air quality control laws and regulations.
Subpart P of 40 CFR Part 51 contains the visibility protection regulatory requirements, including the review of new sources that would be constructed in the attainment or unclassified areas and may affect visibility in any Federal Class I area. If a coal-fired alternative was located close to a mandatory Class I area, additional air pollution control requirements would be required. As noted in Section 2.2.2.1, there are no mandatory Class I Federal areas within 50 mi (80 km) of the STP site.
The emissions from the coal-fired alternative at the STP site, projected by the NRC staff based on published EIA data, EPA emission factors, and based on performance characteristics for this alternative and likely emission controls, would be:
Environmental Impacts of Alternatives
- particulate matter PM10446 tons (405 MT) per year, and
- particulate matter PM2.5223 tons (202 MT) per year.
8.3.1.1 Sulfur Oxides The coal-fired alternative at the STP site would likely use wet, limestone-based scrubbers to remove sulfur oxides. EPA indicates that this technology can remove more than 95 percent of sulfur oxides from flue gases. The staff projects total sulfur oxide emissions would be 3,260 tons (2,958 MT) per year. Sulfur oxide emissions from a new coal-fired power plant would be subject to the requirements of the CAA (42 U.S.C. §7651 et seq.). These regulations were enacted to reduce emissions of sulfur dioxide and nitrogen oxide, the two principal precursors of acid rain, by restricting emissions of these pollutants from power plants. The current SIP for Texas includes a Cap and Trade Program for sulfur dioxide. To operate the coal-fired plant, the plant operator would have to purchase sulfur dioxide allowances from the open market or shut down existing fossil-fired plant(s) and apply the credits to the new plant (STPNOC 2010a). Thus, provided the plant operator is able to purchase sufficient allowances to operate, the coal-fired alternative would not add to net regional sulfur dioxide emissions, although it might do so locally.
In addition, in August 2011, EPA published the Cross-State Air Pollution Rule, which included reductions of sulfur dioxide in Texas. According to the rule, coal-fired plants would need to comply with the new reductions by 2012.
8.3.1.2 Nitrogen Oxides A coal-fired alternative at the STP site would most likely employ various available nitrogen oxide-control technologies, which can be grouped into two main categoriescombustion modifications and post-combustion processes. Combustion modifications include low-nitrogen oxide burners, overfire air, reburning, flue gas recirculation, and operational modifications.
Post-combustion processes include SCR, selective noncatalytic reduction, and hybrid processes. Effective combination of the combustion modifications and post-combustion processes reduces nitrogen oxide emissions by up to 95 percent (EPA 1998). STPNOC indicated in its ER that it would use low-nitrogen oxide burners, overfire air, selective catalytic reduction, and scrubbers to reduce nitrogen oxide emissions from this alternative (STPNOC 2010a). Assuming the use of such technologies at the STP site, nitrogen oxide emissions after scrubbing would be approximately 2,869 tons (2,595 MT) annually.
Section 407 of the CAA establishes technology-based emission limitations for nitrogen oxide emissions. A new coal-fired power plant would be subject to the new source performance standards for such plants as indicated in 40 CFR 60.44 Subpart Da(a)(1). This regulation limits the discharge of any gases that contain nitrogen oxides to 200 nanograms (ng) of nitrogen oxides per joule (J) of gross energy output (equivalent to 1.6 pounds per megawatt-hours (lb/MWh), based on a 30-day rolling average.
The current SIP for Texas includes a Cap and Trade Program for nitrogen oxides. To operate the coal-fired plant, the plant operator would have to purchase nitrogen oxide allowances from the open market or shut down existing fossil-fired plant(s) and apply the credits to the new plant (STPNOC 2010a). Thus, provided the plant operator is able to purchase sufficient allowances to operate, the coal-fired alternative would not add to net regional nitrogen oxide emissions, although it might do so locally.
8.3.1.3 Greenhouse Gases A coal-fired plant would also have carbon dioxide emissions during operations, as well as during coal mining, processing, and transportation. The coal-fired plant would emit between 8-29
Environmental Impacts of Alternatives 19.3 million tons (17.5 million MT) and 19.9 million tons (18.1 million MT) of carbon dioxide per year from coal combustion, depending on the type and quality of the coal burned.
On July 12, 2012, EPA issued a final rule tailoring the applicability criteria that determine which stationary sources and modification to existing projects become subject to permitting requirements for greenhouse emissions under the PSD and Title V Programs of the CAA (77 FR 41051). According to the Tailoring Rule, greenhouse gases are a regulated new source review pollutant under the PSD major source permitting program if the source is otherwise subject to PSD (for another regulated new source review pollutant) and has a greenhouse gas potential to emit equal to or greater than 75,000 tons (68,000 MT) per year of carbon dioxide equivalent (carbon dioxide equivalent adjusting for different global warming potentials for different greenhouse gases). Such sources would be subject to BACT, although EPA has yet to determine BACT for greenhouse gases.
EPA issued a Federal Implementation Plan (FIP) on May 3, 2011, to permit greenhouse gas-emitting sources in states that do not have measures to lower greenhouse gases in their SIP. Because Texas has not updated its SIP to include greenhouse gases, EPA will be the official permitting authority for greenhouse gas-emitting sources in Texas if the SIP is not updated before the coal-fired plant begins operations.
8.3.1.4 Particulates The new coal-fired power plant would use fabric filters to remove particulates from flue gases (STPNOC 2010a). The fabric filters would remove 99.9 percent of PM (STPNOC 2010a). EPA notes that filters are capable of removing in excess of 99 percent of PM and that sulfur dioxide scrubbers further reduce PM emissions (EPA 2008); therefore, the NRC staff believes the STPNOC removal factor is appropriate. Based on this information, the new supercritical coal-fired plant would emit approximately 446 tons (405 MT) per year of particulate matter having an aerodynamic diameter less than, or equal to, 10 microns (PM10) annually. In addition, coal burning would also result in approximately 223 tons (202 MT) of particulate matter with an aerodynamic diameter of 2.5 microns or less (PM2.5). Coal-handling equipment would introduce fugitive dust emissions when fuel is being transferred to onsite storage and then reclaimed from storage for use in the plant.
During the construction of a coal-fired plant, onsite activities would also generate fugitive dust.
Vehicles and motorized equipment would create exhaust emissions during the construction process. These impacts would be intermittent and short-lived; however, to minimize dust generation, construction crews would use applicable dust-control measures, as described above.
8.3.1.5 Carbon Monoxide Based upon EPA emission factors (EPA 1998), the NRC staff estimates that total carbon monoxide emissions would be approximately 784 tons (711 MT) per year.
8.3.1.6 Conclusion While the GElS analysis mentions global warming from carbon dioxide emissions and acid rain from sulfur and nitrogen oxide emissions as potential impacts, it does not quantify emissions from coal-fired power plants; however, the GElS analysis does imply that air impacts would be substantial (NRC 1996). The above analysis shows that emissions of air pollutantsincluding sulfur oxides, nitrogen oxides, carbon monoxide, particulates, and carbon dioxideexceed those produced by the existing nuclear power plant, as well as those of the other alternatives considered in this section. The NRC analysis for a coal-fired alternative suggests that impacts from the coal-fired alternative would have clearly noticeable effects, but given existing regulatory 8-30
Environmental Impacts of Alternatives regimens, permit requirements, and emissions controls, the coal-fired alternative would not destabilize air quality. Based on this information, the overall air quality impacts of a new coal-fired plant located at the STP site would be MODERATE.
8.3.2 Surface Water Resources STPNOC did not propose using any surface water during the construction of Units 3 and 4 (NRC 2011). As a new coal-fired plant would occupy a smaller footprint relative to new nuclear units, its construction would enable less extensive excavation and earthwork than new nuclear units.
However, onsite construction of an engineered solid waste disposal facility (landfill), totaling 200 ac (80 ha), would also be required for disposal of coal ash and air pollution control scrubber sludge from 20 years of operations. The combined acreage of the coal-fired plant and ash disposal facility would slightly exceed that required for the new nuclear generation alternative.
Nevertheless, NRC would still expect that surface water would not be used to support construction activities under this alternative.
As for the aforementioned replacement-power alternatives, some temporary impacts to surface water quality may result from dredging activities in the Colorado River near the barge slip and from increased sediment loading in stormwater runoff from active construction areas. Due to the short-term nature of the dredging activities, the hydrologic alterations and sedimentation would be localized and temporary. Dredging would also be conducted under a permit from the USACE requiring the implementation of BMPs to minimize impacts. Runoff from construction areas, including construction of the disposal facility, would be controlled under a State-issued TPDES general permit that would require implementation of a stormwater pollution prevention plan and associated BMPs to prevent or significantly mitigate soil erosion and contamination of stormwater runoff from construction activities.
During operations, the coal-fired alternative would require a similar amount of cooling water as STP, Units 1 and 2. Because a similar amount of cooling water would be required, NRC expects that the existing intake and discharges on the MCR and the Colorado River would be sufficient to support this alternative. Surface water withdrawals would be subject to, and would remain well within, STPNOCs existing water rights, and effluent discharges and stormwater discharges associated with industrial activity would be subject to a revised State-issued TPDES permit under this alternative. In accordance with the applicable TPDES permit, implementation of a stormwater pollution prevention plan for industrial activities would address stormwater run-on and runoff issues associated with coal storage and handling, as well as other stockpiles (e.g., lime) at the plant. These requirements would also encompass the handling, storage, and disposal of coal ash and scrubber wastes so as to mitigate the potential water quality impacts of contaminated runoff and infiltration.
In consideration of the information above, the impacts on surface water use and quality from construction and operations under the coal-fired generation alternative would be SMALL.
8.3.3 Groundwater Resources Construction-related ground disturbance and excavation work would be somewhat less than that described for the new nuclear alternative, mainly due to a reduction in deep excavation work and less intensive structural work. However, construction and excavation for a coal ash and scrubber residue disposal facility would have additional potential impacts on groundwater.
Although groundwater dewatering of foundation excavations for a new coal-fired plant would likely be required, slurry walls and wells were proposed for use to minimize potential adverse 8-31
Environmental Impacts of Alternatives effects from dewatering both on site and off site (NRC 2011). Construction of the coal ash and scrubber residue disposal facility would have to be carefully managed and sited to minimize the need for construction dewatering due to the shallow depth of groundwater across many areas of the STP site. Application of BMPs in accordance with a state-issued NPDES general permit, including appropriate waste management and spill prevention practices, would prevent or minimize groundwater quality impacts during construction.
STPNOC assumed that a fossil-fuel-fired generation facility would be located adjacent to the STP, Units 1 and 2, site to use the existing infrastructure, including continued use of the existing onsite groundwater production wells at STP. Groundwater use for construction of a new coal-fired plant is expected to be similar to the volume required for new nuclear units under this alternative. This would encompass such uses as potable and sanitary uses, concrete production, dust suppression and soil compaction, and other uses.
For coal-fired plant operations, NRC assumed that the coal-fired generation alternative would entail the same relative ratio of groundwater use to surface water use as that used at STP, Units 1 and 2. This includes the use of groundwater for freshwater and service water makeup, potable and sanitary uses, and fire protection. It is expected that total groundwater usage and associated aquifer effects would likely be less than those under current STP operations. This is because of the fewer number of auxiliary systems requiring groundwater and the smaller workforce under the coal-fired generation alternative.
Disposal of coal ash and air pollution control scrubber wastes in an onsite landfill would have the potential to impact groundwater quality due to the generation and infiltration of leachate to the environment. NRC assumes that any disposal facility would incorporate a liner to prevent infiltration and would be operated with a leachate monitoring and collection system and ambient groundwater monitoring system. These systems and measures would ensure that facility operations would not impact groundwater quality. Operation of the facility would also be subject to a state-issued landfill permit.
Based on this information, the overall impact on groundwater use and quality from construction and operations under the coal-fired generation alternative would be SMALL.
8.3.4 Aquatic Ecology Construction activities for the coal-fired alternative (such as construction of heavy haul roads and the power blocks) could affect drainage areas or other onsite aquatic features due to site runoff. NRC assumed that the plant operator would install temporary and permanent erosion and sediment control measures to minimize the flow of disturbed soils into ditches and wetlands. Such BMPs would likely be described in a TPDES general permit relating to stormwater discharges for construction activities. To bring new materials to the site, NRC assumed the plant operator would dredge near the barge slip to transport some materials using barges. Permits and certifications from the USACE and other agencies would require the implementation of BMPs to minimize impacts. Due to the short-term nature of the dredging activities, the hydrological alterations to aquatic habitats would be localized and temporary.
During operations, the coal-fired alternative would require a similar amount of cooling water to be withdrawn from the Colorado River at STP, Units 1 and 2, and the thermal discharge would also be similar to STP, Units 1 and 2. Therefore, the number of fish and other aquatic organisms affected by impingement, entrainment, and heat shock would be similar for a coal-fired alternative as for license renewal. The cooling system for a new coal-fired plant would have similar chemical discharges as STP, but the air emissions from the coal-fired plant would emit particulates that would settle onto the river surface and introduce a new source of pollutants that would not exist if STP continued operating. However, the flow of the Colorado 8-32
Environmental Impacts of Alternatives River would dissipate pollutants, which would decrease the concentration of pollutants and minimize the exposure of fish and other aquatic organisms to pollutants.
Construction activities would require BMPs; dredging would be short-term; the surface water withdrawal and discharge for this alternative would be less than for STP, Units 1 and 2; and pollutants would dissipate with the Colorado River (minimizing exposure concentrations to aquatic resources). Therefore, impacts on aquatic ecology would be SMALL.
8.3.5 Terrestrial Ecology Coal-fired operations would affect terrestrial ecology both on the STP site and in offsite coal mining areas.
If the coal-fired alternative is constructed at the STP site, construction would likely affect a variety of habitats and land uses, including industrial land (buildings, parking areas, and mowed-maintained fields), drainage ditches, scattered small palustrine wetlands, scrub-shrub habitat, and mixed grassland habitat where abandoned farm lands previously existed prior to construction of Units 1 and 2. Most of these areas have been mildly to extensively disturbed during the construction and operations of Units 1 and 2 and other human activities. After the completion of the new units, construction crews would likely grade, landscape, and replant the areas used for temporary building support, which is similar to what STPNOC proposed to do after completion of proposed new nuclear Units 3 and 4 (STPNOC 2010b). The majority of permanently affected areas would be maintained (e.g., mowed) and industrial areas. The plant operator would likely implement BMPs to minimize impacts to wetlands. The plant operator would be required to comply with the USACEs 404 permits. Construction activities could also adversely affect onsite wildlife through noise, increased light pollution, and increased traffic.
However, these impacts would be temporary and minor.
Coal mining would affect terrestrial resources at offsite coals mines, although much of this land is likely already disturbed by mining, and the incremental effects of this alternative on coal mine terrestrial ecology are difficult to gauge.
STPNOC estimates that 253,000 tons of coal ash and 88,000 tons of scrubber sludge would be disposed of on site annually (STPNOC 2010a). Over a 40-year period, this would require approximately 200 ac for land disposal (STPNOC 2010a). As described above, these areas could affect terrestrial ecology, especially if they are located in habitats that are currently used by wildlife on the STP site. Once the disposal area is reclaimed, the habitats may be useable by wildlife that inhabits open areas.
Deposition of acid rain resulting from nitrogen or sulfur oxide emissions, and the deposition of other pollutants, can also affect terrestrial ecology both on and off site. Given the emission regulations discussed in Section 8.3.1, air deposition impacts may be noticeable but are unlikely to be destabilizing.
Because of the potential habitat disturbances and potential pollutant deposition, impacts to terrestrial resources from a coal-fired alternative would be MODERATE.
8.3.6 Human Health Coal-fired power plants introduce worker risks from coal and limestone mining, coal and limestone transportation, plant operations, and disposal of coal combustion and scrubber wastes. In addition, there are public risks from the inhalation of stack emissions (as addressed in Section 8.3.1) and the secondary effects of eating foods grown in areas subject to deposition from plant stacks.
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Environmental Impacts of Alternatives Human health risks of coal-fired power plants are described, in general, in Table 8-2 of the GEIS (NRC 1996). Cancer and emphysema, as a result of the inhalation of toxins and particulates, are identified as potential health risks to occupational workers and members of the public (NRC 1996). The human health risks of coal-fired power plants, both to occupational workers and to members of the public, are greater than those of the current STP due to exposures to chemicals such as mercury; sulfur oxides; nitrogen oxides; radioactive elements, such as uranium and thorium contained in coal and coal ash; and polycyclic aromatic hydrocarbon (PAH) compounds, including benzo(a)pyrene.
Regulations restricting emissionsenforced by EPA or state agencieshave acted to significantly reduce potential health effects but do not entirely eliminate them. These agencies also impose site-specific emission limits as needed to protect human health. Even if the coal-fired alternative were located in a non-attainment area, emission controls and trading or offset mechanisms could prevent further regional degradation; however, local effects could be visible. Many of the byproducts of coal combustion responsible for health effects are largely controlled, captured, or converted in modern power plants (as described in Section 8.3.1),
although some level of health effects may remain.
Aside from emission impacts, the coal-fired alternative introduces the risk of coal pile fires, and for those plants that use coal combustion liquid and sludge waste impoundments, the release of the waste due to a failure of the impoundment. Although there have been several instances of this occurring in recent years, these types of events are still relatively rare.
Despite the range of potential threats to human health, extensive health-based regulations exist to mitigate the risks to workers and the public. As a result, the NRC staff expects human health impacts to be characterized as SMALL.
Noise during construction activities and from plant operations may be detectable off site. The plant operator would need to adhere to local ordinances regarding maximum noise levels during construction and operations. Therefore, impacts from noise would likely be SMALL.
8.3.7 Land Use The GEIS generically evaluates the impact of constructing and operating various replacement power plant alternatives on land use, both on and off each plant site. The analysis of land use impacts focuses on the amount of land area that would be affected by the construction and operation of a supercritical coal-fired generation at the STP site.
Based on scaled GEIS estimates, the plant would require approximately 4,629 ac (1,873 ha) of land. STPNOC estimates that 353 ac (143 ha) of land would be required (STPNOC 2010a).
This estimate appears reasonable; therefore, it is used for this analysis. STPNOC estimates that an additional 200 ac (80 ha) of land area would be required on site for waste disposal (STPNOC 2010a). Land would also be required on site for frequent coal and limestone deliveries by rail or barge.
Offsite land use impacts would occur from coal mining, in addition to land use impacts from the construction and operation of the new power plant. Scaling from GEIS estimates, approximately 59,906 ac (24,244 ha) of land could be affected by mining coal and waste disposal to support the coal-fired alternative during its operational life (NRC 1996); however, most of the land in existing coal mining areas has already experienced some level of disturbance. The elimination of the need for uranium mining to supply fuel for the STP would partially offset this offsite land use impact. Scaling from GEIS estimates, approximately 2,560 ac (1,036 ha) would not be needed for mining and processing uranium during the operating life of the plant.
8-34
Environmental Impacts of Alternatives Since a substantial amount of onsite land at the STP site would be converted for coal and limestone delivery and waste disposal, land use impacts would be MODERATE.
8.3.8 Socioeconomics As previously discussed, socioeconomic impacts are defined in terms of changes to the demographic and economic characteristics and social condition of a region. For example, the number of jobs created by the construction and operation of a power plant could affect regional employment, income, and expenditures. Two types of jobs would be created by this alternative:
(1) construction jobs, which are transient, short in duration, and less likely to have a long-term socioeconomic impact; and (2) power plant operation jobs, which have the greater potential for permanent, long-term socioeconomic impacts. Workforce requirements of power plant construction and operation for the coal-fired alternative were determined to measure their possible effects on current socioeconomic conditions.
Scaling from GEIS estimates, the construction workforce would peak at 6,808 workers.
STPNOC projected a peak construction workforce of 3,955 employees (STPNOC 2010a).
STPNOCs estimate appears reasonable; therefore, it is used in this analysis. The relative economic impact of this many workers on the local economy and tax base would vary, with the greatest impacts occurring in the communities where the majority of construction workers would reside and spend their income. As a result, local communities could experience a short-term boom from increased tax revenue and income generated by construction expenditures and the increased demand for temporary (rental) housing and business services. Some construction workers could relocate to Matagorda and surrounding counties in order to be closer to the construction work site. However, given the proximity of STP to the Houston metropolitan area, many construction workers could commute to the STP site, thereby lessening the need for additional rental housing near STP.
After completing the installation of the supercritical coal-fired power plant, local communities could experience a return to pre-construction economic conditions. Based on this information, and given the number of workers, socioeconomic impacts during construction in communities near the STP site could range from SMALL to MODERATE.
Scaling from GEIS estimates, the plant operation workforce would be 681 workers. STPNOC estimated a plant operation workforce of approximately 348 workers. The STPNOC estimate appears to be reasonable and is consistent with trends toward lowering labor costs by reducing the size of plant operations workforces. The amount of property taxes paid under the coal-fired alternative may increase if additional land is required off site to support this alternative.
Socioeconomic impacts during operations could range from SMALL to MODERATE as the STP site transitions to the new supercritical coal-fired power plant. The potential reduction in overall employment at STP could affect property tax revenue and income in local communities and businesses. In addition, the permanent housing market could also experience increased vacancies and decreased prices if operations workers and their families move out of the region.
8.3.9 Transportation Transportation impacts associated with construction and operation of a four-unit, coal-fired plant would consist of commuting workers and truck deliveries of construction materials to the STP site. During periods of peak construction activity, up to 3,955 workers could be commuting daily to the site (STPNOC 2010a). Workers commuting to the STP site would primarily use two-lane roads. The volume of traffic on these roads, especially FM 521, would increase substantially.
In addition to commuting workers, trucks would be transporting construction materials and equipment to the worksite, thus increasing the amount of traffic on local roads. The increase in 8-35
Environmental Impacts of Alternatives vehicular traffic would peak during shift changes, resulting in temporary levels of service impacts and delays at intersections. Some power plant components and materials could also be delivered by train or barge. Train deliveries could cause additional traffic delays at railroad crossings. Based on this information, traffic-related transportation impacts during construction could range from MODERATE to LARGE.
Traffic-related transportation impacts would be greatly reduced after completing the installation of the coal-fired units. Transportation impacts would include daily commuting by the operating workforce, equipment and materials deliveries, and the removal of commercial waste material to offsite disposal or recycling facilities by truck. During operations, the estimated number of operations workers commuting to and from the STP site would be 348 workers. Frequent deliveries of coal and limestone by rail would add to the overall transportation impact by causing traffic delays at railroad crossings. Onsite coal storage would make it possible to receive several trains per day. Limestone delivered by rail could also add additional traffic (though considerably less traffic than that generated by coal deliveries). Traffic-related transportation impacts would be considerably less than current operations because the new supercritical coal-fired power plant would employ far fewer workers than STP, Units 1 and 2. Overall, transportation impacts would be SMALL during power plant operations.
8.3.10 Aesthetics The analysis of aesthetic impacts focuses on the degree of contrast between the coal-fired alternative and the surrounding landscape and the visibility of the coal-fired power plant. During construction, all of the clearing and excavation would occur on the STP site. These activities may be visible from offsite roads, particularly FM 521. Since the STP site already appears industrial, construction of the coal-fired power plant would appear similar to onsite activities during refueling outages.
The coal-fired alternative would be up to 200 ft (61 m) tall with an exhaust stack up to 500 ft (152 m), which may be visible off site in daylight hours. The coal-fired plant, however, would be shorter and less noticeable than the current STP reactor building, which has a height of approximately 250 ft (76 m) (STPNOC 2010b). Lighting on plant structures may be detectable off site. Noise generated during power plant operations would be limited to routine industrial processes and communications.
In general, given the industrial appearance of the STP site, the new coal-fired power plant would blend in with the surroundings if the existing STP, Units 1 and 2, remains. Aesthetic changes would be limited to the immediate vicinity of the existing STP site, and any impacts would be SMALL.
8.3.11 Historic and Archaeological Resources The same considerations, discussed in Section 8.1.11, for the impact of the construction of a new nuclear plant on historic and archaeological resources apply to the construction activities that would occur on the STP site for a coal-fired plant. As described in Section 2.2.10, much of the STP site has been previously disturbed by the construction of STP, Units 1 and 2. In addition, in preparation for the COL application for Units 3 and 4, STPNOC conducted a cultural resources assessment of the STP site. STPNOC reviewed existing information for the STP site and the area within a 10-mi (16-km) radius. STPNOC concluded that any cultural resource sites that may have existed on site would no longer retain their integrity because the area was heavily disturbed during the construction of Units 1 and 2 (STPNOC 2010b). In December 2006, STPNOC reported these findings to the SHPO at the Texas Historical Commission. The SHPO 8-36
Environmental Impacts of Alternatives concurred, in January 2007, that there would be no impacts to historic properties (STPNOC 2006; THC 2007).
There is a low potential for cultural resources to be located in previously undisturbed portions of the STP site. However, if the coal-fired units were to be sited within undisturbed areas or within areas of known cultural sensitivity (historic grave site located on the property and described in Section 2.2.10), these areas would need to be surveyed by a professional archaeologist to identify and develop possible mitigation measures to address any adverse effects from project activities. NRC assumes the plant operator would follow similar procedures to those described in the final EIS for STP, Units 3 and 4 (NRC 2011), if the plant operator discovered any historic or cultural resources during ground-disturbing activities associated with building the new units.
The NRC staff determined that the impact of the coal-fired alternative at the STP site on historic and archaeological resources would be SMALL for the following reasons:
- NRC (2011) and STPNOC (2010a, 2010b) did not identify any cultural resources that could be affected by Units 3 and 4.
- The SHPO determined that construction for Units 3 and 4 would not affect cultural and historic resources.
- NRC assumes that the plant operator would follow environmental compliance procedures for new ground-disturbing activities.
8.3.12 Environmental Justice The environmental justice impact analysis evaluates the potential for disproportionately high and adverse human health, environmental, and socioeconomic effects on minority and low-income populations that could result from the construction and operation of a new power plant. As previously discussed in Section 8.1.12, such effects may include human health, biological, cultural, economic, or social impacts. Some of these potential effects have been identified in resource areas discussed in this SEIS. For example, increased demand for rental housing during plant construction could disproportionately affect low-income populations. Minority and low-income populations are subsets of the general public residing in the vicinity of the STP site, and all are exposed to the same hazards generated from constructing and operating a new coal-fired plant. Section 4.9.7, Environmental Justice, presents demographic information about minority and low-income populations residing in the vicinity of the STP site.
Potential impacts to minority and low-income populations from the construction and operation of a new coal-fired plant at the STP site would mostly consist of environmental and socioeconomic effects (e.g., noise, dust, traffic, employment, and housing impacts). Noise and dust impacts during construction would be short-term and primarily limited to onsite activities. Minority and low-income populations residing along site access roads would be directly affected by increased commuter vehicle and truck traffic. However, because of the temporary nature of construction, these effects would only occur during certain hours of the day and are unlikely to be high and adverse. Increased demand for rental housing during construction could affect low-income populations living near STP. However, given the proximity of the STP site to the Houston metropolitan areas, many construction workers could commute to the STP site, thereby lessening the additional need for rental housing.
Based on this information, and the analysis of human health and environmental impacts presented in this SEIS, the construction and operation of a new coal-fired power plant would not have disproportionately high and adverse human health and environmental effects on minority and low-income populations residing in the vicinity of the STP site.
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Environmental Impacts of Alternatives 8.3.13 Waste Management During the construction stage of the coal-fired alternative, land clearing and other construction activities would generate waste that could be recycled, disposed of on site, or shipped to an offsite waste disposal facility. Because the alternative would be constructed on or near the previously disturbed STP site, the amounts of waste produced during land clearing would be reduced.
Coal combustion generates several waste streams including ash (a dry solid) and sludge (a semi-solid by-product of emission control system operation). This coal-fired alternative would produce roughly 446,000 tons (405,000 MT) of ash, and 43 percent (193,000 tons (175,000 MT)) of the ash would be recycled for beneficial use (STPNOC 2010a).
STPNOC (2010a) estimated that approximately 88,000 tons (80,000 MT) of scrubber sludge would be disposed of on site each year, which was based on an assumed annual lime usage of approximately 107,000 tons (97 MT). Approximately 200 ac (81 ha) would be required to dispose of the ash and scrubber waste on site over a 40-year plant life (STPNOC 2010a). All waste disposal would occur on site.
The impacts from waste generated during operation of this coal-fired alternative would be MODERATE because the impacts would be clearly visible but would not destabilize important resources.
8.3.14 Summary of Impacts for the Supercritical Coal-Fired Generation Alternative Table 8-4 provides a summary of the environmental impacts of the supercritical coal-fired alternative compared to continued operation of STP.
Table 8-4. Summary of Environmental Impacts of the Supercritical Coal-Fired Alternative Compared to Continued Operation of STP, Units 1 and 2 Supercritical Coal-Fired Continued STP Operation Generation Air quality MODERATE SMALL Surface water SMALL SMALL Groundwater SMALL SMALL Aquatic resources SMALL SMALL Terrestrial resources MODERATE SMALL Human health SMALL SMALL to MODERATE Land use MODERATE SMALL Socioeconomics SMALL to MODERATE SMALL Transportation SMALL to LARGE SMALL Aesthetics SMALL SMALL Historic & archaeological SMALL SMALL Waste management MODERATE SMALL 8-38
Environmental Impacts of Alternatives 8.4 Combination Alternative In this section, the NRC staff evaluates the environmental impacts of a combination of alternatives. This combination includes 640 MWe supplied by one NGCC unit similar to the units identified in Section 8.2, 1,620 MWe supplied by wind energy projects, and 300 MWe of energy conservation and efficiency (also known as demand-side management). Because wind is an intermittent resource, wind energy projects would be interconnected to one another on the transmission grid, and the NGCC unit could be used, if needed, to be a baseload resource.
Interconnecting wind farms through the transmission grid increase the probability that at least one site experiences sufficient wind to produce electricity. Thus, as more sites are added to the transmission grid, the interconnected wind farms provide electricity that is comparable to a single wind farm providing near constant deliverable wind power. Archer and Jacobson (2007) looked at 19 wind energy sites in the southeast, including 2 sites in Texas, and determined that the 19 interconnected wind farms could guarantee 312 kWe of power for 79 percent of time.
Based on this data, NRC assumed that to provide 1,620 MWe of wind energy, the installed capacity would need to be at least 7,714 MWe. NRC included this contribution from wind power because Texas has significant wind energy resources and leads the Nation in wind-powered generation capacity. As of June 30, 2011, the installed wind capacity in Texas was 10,135 MWe (DOE 2011b). In addition, wind energy projects totaling 36,124 MWe are currently under ERCOTs review (ERCOT 2011a), and the installed wind capacity in Texas has been increasing annually by 500 MWe to 3,000 MWe in each of the past 7 years (DOE 2011b).
Therefore, NRC considers 1,620 MWe of wind energy (with an installed capacity of 7,714 MWe) to be a reasonable amount by the time the STP licenses expire in 2027 and 2028. Section 8.6.3 discusses the status of wind energy technology and implementation in greater detail.
NRC assumed that one new NGCC unit of the type described in Section 8.2 would be constructed and installed at the STP site with a total capacity of 640 MWe. The appearance of an NGCC unit would be similar to that of the full NGCC alternative considered in Section 8.2, although only one unit would be constructed. The NRC estimates that it would require about one-fourth of the space necessary for the alternative considered in Section 8.2 and that construction and operational effects would scale accordingly.
NRC assumed that the wind turbines could be constructed at multiple sites scattered over large distances to minimize the likelihood that all sites would be exposed to the same weather events at the same time. Some of these sites could potentially be offshore, although no turbines currently operate offshore anywhere in the U.S. NRC assumed that the contribution from offshore wind energy would be relatively small because offshore wind capacity of the magnitude analyzed in this alternative exceeds by a factor of 10 or more the amount of offshore wind projected by the EIA for the entire U.S. by the year 2035 (EIA 2011a). Assuming each turbine has a capacity of 2 MWe, construction and operation of approximately 3,877 turbines would be required. In addition, new transmission lines would likely be needed to connect the wind energy projects to one another and the distribution system.
STPNOC estimated that a utility-scale wind plant requires 60 ac of land per MWe of installed capacity in open, flat terrain (STPNOC 2010a). Approximately 462,900 ac (187,300 ha) of land would be required for the installed capacity of 7,714 MWe. A small percentage of this area would be occupied by turbines, access roads, and other infrastructure, with the rest of the area potentially available for compatible other uses, such as agriculture. For example, NREL (2009) estimates that 0.7 ha (1.7 ac) of land would be temporarily disturbed per MWe of installed capacity and that 0.3 ha (0.7 ac) of land would be permanently disturbed per MWe of installed capacity. For this alternative, approximately 2,185 ac (884 ha) would be temporarily disturbed, and 937 ac (379 ha) would be permanently disturbed.
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Environmental Impacts of Alternatives For the combination alternative, the NRC assumed that an Energy Efficiency and Conservation Program would replace 300 MWe of current STP output. As discussed in Section 8.6.2, beginning in 2009, all electric transmission and distribution utilities within the ERCOT market including CPS Energy and Austin Energy (two of the owners of STP, Units 1 and 2)were required to implement energy efficiency and conservation programs to reduce their customers energy consumption by a minimum of 20 percent of the utilitys annual growth in 2009, 25 percent in 2012, and 30 percent in 2013 and beyond. CPS Energy and Austin Energy currently implement programs to promote energy efficiency and conservation. The 300 MWe reduction in energy use for this alternative would be beyond the required energy efficiency and conservation programs currently implemented by CPS Energy and Austin Energy. No major construction would be necessary for the energy efficiency and conservation component of the combination alternative.
8.4.1 Air Quality As discussed in Section 2.2.2.1, the STP site is located in central Matagorda County, Texas, at the southern edge of the Metropolitan Houston-Galveston Intrastate Air Quality Control Region (40 CFR 81.38). The Corpus Christi-Victoria Intrastate Air Quality Control Region (40 CFR 81.136) lies immediately south and west of Matagorda County. EPA has designated all of the counties in these Air Quality Control Regions adjacent to the STP site as in compliance with the National Ambient Air Quality Standards (40 CFR 81.344) except Brazoria County to the north; Brazoria County is classified Nonattainment/Severe relative to the 8-hour ozone standard (EPA 2011b).
Construction activities for both the NGCC plant and wind energy components would cause some localized temporary air quality effects because of equipment emissions and fugitive dust from operation of earth-moving and material-handling equipment. Emissions from workers vehicles and motorized construction equipment exhaust would be temporary. NRC assumed that construction crews would use dust-control practices to control and reduce fugitive dust because §111.145 of TCEQs regulations require dust suppression control during the construction of facilities and parking lots. Impacts from wind turbine installation would be spread across multiple locations, but these impacts would be short in duration. In its programmatic final EIS, which analyzed the impacts of offshore wind projects generically within U.S. waters, U.S. Minerals Management Service (MMS, which is currently Bureau of Ocean Energy Management) determined that construction of offshore wind projects could result in air quality impacts, mainly from fugitive dust emissions, and emissions of sulfur dioxide and ozone precursors (MMS 2007).
New air emission sources in Texas must comply with Federal, Texas, and local air quality control laws. The NGCC component of this combination alternative would qualify as a new major-emitting industrial facility and would be subject to PSD requirements under CAA (EPA 2011c). The NGCC unit would need to comply with the standards of performance for electric utility steam generating units set forth in 40 CFR Part 60 Subpart KKKK. The plant would also require an operating permit from TCEQ.
Subpart P of 40 CFR Part 51 contains the visibility protection regulatory requirements, including the review of new sources that would be constructed in the attainment or unclassified areas and may affect visibility in any Federal Class I area. If an NGCC plant was located close to a mandatory Class I area, additional air pollution control requirements would be required. As noted in Section 2.2.2.1, there are no mandatory Class I Federal areas within 50 mi of the STP site.
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Environmental Impacts of Alternatives The NRC projects the following emissions, assuming a maximum of 640 MWe power from the NGCC component of this combination alternative based on data published by the EIA, EPA, and on performance characteristics and emissions controls:
- TSP97 tons (88 MT) per year, and
- particulate matter PM1097 tons (88 MT) per year.
During operations, the wind energy projects would not produce emissions. However, workforce transportation and eventual decommissioning could result in carbon dioxide emissions.
For the Energy Efficiency and Conservation Program, the GEIS notes that the environmental impacts are likely to be centered on indoor air quality (NRC 1996). This is due to increased weatherization of the home in the form of extra insulation and reduced air turnover rates from the reduction in air leaks. However, the actual impact is highly site-specific and not yet well-established.
8.4.1.1 Sulfur Oxide and Nitrogen Oxide The new NGCC plant would have to comply with Title IV of the CAA (42 USC 7651) reduction requirements for sulfur and nitrogen oxides, which are the main precursors of acid rain and the major cause of reduced visibility. Title IV establishes maximum sulfur and nitrogen oxide emission rates from existing plants and a system of sulfur oxide emission allowances that can be used, sold, or saved for future use by new plants. In addition, in August 2011, EPA published the Cross-State Air Pollution Rule, which included reductions of sulfur and nitrogen oxides in Texas. According to the rule, NGCC plants would need to comply with the new reductions by 2012.
As stated above, the new NGCC plant would produce 50 tons (46 MT) per year of sulfur oxides and 219 tons (199 MT) per year of nitrogen oxides based on the use of the dry low-nitrogen oxide combustion technology and use of SCR to significantly reduce nitrogen oxide emissions.
The new plant would be subjected to the continuous monitoring requirements for sulfur and nitrogen oxides. The current SIP for Texas includes a Cap and Trade Program for sulfur and nitrogen oxide emissions. To operate the NGCC plant, the plant operator would have to purchase sulfur dioxide allowances from the open market or shut down existing fossil-fired plant(s) and apply the credits to the new plant (STPNOC 2010a). Thus, provided the plant operator is able to purchase sufficient allowances to operate, the NGCC portion of this alternative would not add to net regional sulfur dioxide or nitrogen oxide emissions, although it might do so locally.
8.4.1.2 Greenhouse Gases The new plant would release greenhouse gases, such as carbon dioxide and methane. The plant would be subjected to the continuous monitoring requirements for carbon dioxide, as specified in 40 CFR Part 75. The NGCC plant would emit approximately 1.7 million tons (approximately 1.6 million MT) per year of carbon dioxide emissions.
On July 12, 2012, EPA issued a final rule tailoring the applicability criteria that determine which stationary sources and modification to existing projects become subject to permitting requirements for greenhouse emissions under the PSD and Title V Programs of the CAA 8-41
Environmental Impacts of Alternatives (77 FR 41051). According to the Tailoring Rule, greenhouse gases are a regulated new source review pollutant under the PSD major source permitting program if the source is otherwise subject to PSD (for another regulated new source review pollutant) and has a greenhouse gas potential to emit equal to or greater than 75,000 tons (68,000 MT) per year of carbon dioxide equivalent (carbon dioxide equivalent adjusting for different global warming potentials for different greenhouse gases). Such sources would be subject to BACT, although EPA has yet to determine BACT for greenhouse gases.
EPA issued a FIP on May 3, 2011, to permit greenhouse gas-emitting sources in states that do not have measures to lower greenhouse gases in their SIP. Because Texas has not updated its SIP to include greenhouse gases, EPA will be the official permitting authority for greenhouse gas-emitting sources in Texas if the SIP is not updated before the NGCC plant begins operations.
8.4.1.3 Particulates The new NGCC plant would produce 97 tons (88 MT) per year of TSP, all of which would be emitted as PM10. STPNOC (2010a) indicated that all PM10 emissions would be PM2.5.
DOE (2007) evaluated the emissions from a hypothetical 560 MWe NGCC unit using BACT to meet the emission requirements of the 2006 New Source Performance Standards. DOE concluded that emissions from particulates would be negligible because NGCC use natural gas as fuel; therefore, NGCC plants would not require emissions controls equipment or features to reduce these emissions.
8.4.1.4 Hazardous Air Pollutants In December 2000, EPA issued regulatory findings (65 FR 79825) on emissions of HAPs from electric utility steam-generating units, which said that natural gas-fired plants emit HAPs such as arsenic, formaldehyde, and nickel, and stated the following:
Also in the utility RTC (Report to Congress), the EPA indicated that the impacts due to HAP emissions from natural gas-fired electric utility steam generating units were negligible based on the results of the study. The Administrator finds that regulation of HAP emissions from natural gas-fired electric utility steam generating units is not appropriate or necessary.
As a result of EPAs conclusion, the NRC staff finds no significant air quality effects from HAPs from the NGCC component of this alternative. The wind and energy efficiency and conservation components of this alternative release no HAPs.
8.4.1.5 Conclusion Based on the NRC staffs analysis, the overall air quality impacts of a combination alternative that includes a new NGCC plant located at the STP site, wind energy projects, and the Energy Efficiency and Conservation Program would be SMALL to MODERATE. Emissions from the wind energy projects and the Energy Efficiency and Conservation Program would not be noticeable. Emissions from the NGCC portion of this alternative would be noticeable for greenhouse gases; carbon dioxide emissions would be two orders of magnitude larger than the threshold in EPAs tailoring rule for greenhouse gas (75,000 tons (68,000 MT) per year of carbon dioxide equivalent) that would trigger a regulated new source review. Impacts would not be noticeable for sulfur and nitrogen oxides because the Texas SIP requires a Cap and Trade Program, and there would be no net increase in sulfur and nitrogen oxide emissions. Based on analyses from DOE (2007) and EPA (2000, 65 FR 79825), TSPs and HAPs from the NGCC unit would have negligible impacts.
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Environmental Impacts of Alternatives 8.4.2 Surface Water Resources STPNOC did not propose using any surface water during the construction of Units 3 and 4 (NRC 2011). Because a single NGCC unit occupies a smaller footprint, and its construction would entail substantially less excavation and earthwork at the STP site as compared to Units 3 and 4, NRC expects that surface water would not be used during construction for the NGCC component of this alternative.
As further described in Section 8.5.2 for the NGCC alternative, some temporary impacts to surface water quality may result from dredging activities in the Colorado River near the barge slip and from increased sediment loading in stormwater runoff from active construction areas.
These activities would be conducted under a permit from the USACE requiring the implementation of BMPs to minimize impacts. Runoff from construction areas would be controlled under a State-issued TPDES general permit that would require implementation of a stormwater pollution prevention plan and associated BMPs.
Small amounts of water would be required during the construction phase for each of the 3,877 wind turbines for dust suppression and compaction during site clearing and for concrete production for pad and piling construction, as appropriate. Although surface water from nearby water bodies may be used for pad site construction at some locations, it is likely that water would be procured from offsite sources and trucked to the point of use on an as needed basis.
Use of ready-mix concrete would also reduce the need for onsite use of nearby water sources.
Further, the installation of land-based wind turbines would require installation of access roads and possibly transmission lines (especially for turbine sites not already proximal to transmission line corridors). Access road construction would also require some water for dust suppression and roadbed compaction and would have the potential to result in soil erosion and stormwater runoff from cleared areas. Water would likely be trucked to the point of use from offsite locations along with road construction materials. Construction activities would be conducted in accordance with State-issued TPDES or equivalent permits for stormwater discharges associated with construction activity, which would require the implementation of appropriate BMPs to prevent or mitigate water quality impacts.
Construction of offshore wind turbines, including the offshore foundation and pilings, associated anchoring devices, undersea cables, and onshore support installation (e.g., transformers) would also have the potential to cause water quality impacts due to soil and sediment erosion and runoff. Most notably, potential impacts would include disturbance of marine sediments from pile driving and erection of cofferdams for the wind turbine superstructures. Nevertheless, such water quality impacts would be temporary, and activities would be conducted in accordance with USACE and other applicable permits and requiring the use of BMPs to minimize impacts.
For facility operations, the NGCC component of this alternative would require about one-fourth of the water required by the NGCC alternative. It is expected that use of the existing intake and discharge infrastructure on the MCR and the Colorado River would be sufficient to support the NGCC plant. Surface water withdrawals would be subject to, and would remain well within, STPNOCs existing water rights, and effluent discharges and stormwater discharges associated with industrial activity would be subject to a revised State-issued TPDES permit under this alternative. To support operations of individual wind turbine installations, only very small amounts of water would be used to periodically clean turbine blades and motors as part of routine servicing. It would be expected that water would be trucked to the point of use and procured from nearby sources.
Implementation of the Energy Efficiency and Conservation Program component of this alternative would likely entail little or no impact on surface water resources.
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Environmental Impacts of Alternatives In consideration of the information above, the impacts on surface water use and quality from construction and operations under the combination alternative would be SMALL.
8.4.3 Groundwater Resources For the single NGCC plant at the STP site, construction-related ground disturbance and excavation work would be substantially less than that described for the NGCC alternative.
Although groundwater dewatering of foundation excavations for a new NGCC plant would likely be required, slurry walls and wells were proposed for use to minimize potential adverse effects from dewatering both on site and off site (NRC 2011). Groundwater dewatering, where required, for installation of wind turbines on land, would be minimal due to the small footprint of foundation structures. For all construction activities, appropriate BMPs, including spill prevention practices, would be employed during wind turbine construction to prevent or minimize impacts on groundwater quality.
For NGCC plant operations, NRC assumed that the NGCC alternative would entail the same relative ratio of groundwater use to surface water use as that used at STP, Units 1 and 2. As such, for a single NGCC unit, groundwater use would be about one-fourth of the water required by the NGCC alternative and easily supported by existing onsite groundwater production wells at STP. Little or no groundwater use would be expected for operation of wind turbines.
Implementation of the Energy Efficiency and Conservation Program component of this alternative would likely entail little or no impact on groundwater resources.
Based on this information, the overall impact on groundwater use and quality from construction and operations under the combination alternative would be SMALL.
8.4.4 Aquatic Ecology Construction activities for the NGCC plant and land-based wind power projects (such as construction of heavy haul roads and support facilities) could affect drainage areas or other onsite aquatic features due to site runoff. NRC assumed that the plant operator would install temporary and permanent erosion and sediment control measures to minimize the flow of disturbed soils into ditches and wetlands. Such BMPs would likely be described in a TPDES general permit relating to stormwater discharges for construction activities.
To bring new materials to the STP site for the NGCC plant, NRC assumed the plant operator would dredge near the barge slip to transport some materials using barges. Permits and certifications from the USACE and other agencies would require the implementation of BMPs to minimize impacts. Due to the short-term nature of the dredging activities, the hydrological alterations to aquatic habitats would be localized and temporary.
During operations, the NGCC plant would require approximately one-fourth of the cooling water to be withdrawn from the Colorado River than the NGCC alternative analyzed in Section 8.2, and the thermal discharge would similarly be smaller. Therefore, the number of fish and other aquatic organisms affected by impingement, entrainment, and thermal impacts would be less for the combination alternative than for license renewal and the NGCC alternative. The cooling system for a new NGCC plant would have similar chemical discharges as STP, but the air emissions from the NGCC plant would emit particulates that would settle onto the river surface and introduce a new source of pollutants that would not exist if STP continued operating.
However, the flow of the Colorado River would dissipate pollutants, which would minimize the exposure of fish and other aquatic organisms to pollutants.
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Environmental Impacts of Alternatives Construction and operation of offshore wind projects could affect aquatic communities. In its programmatic final EIS, MMS determined that construction and operations could have moderate impacts to aquatic organisms due to pile driving for installation of the structures, removal of structures by cutting or the use of explosives, and vessel traffic to and from the site (MMS 2007). Organisms most likely to be affected would be marine mammals, sea turtles, and fish due to noise from pile driving and vessel traffic as well as benthic organisms and habitats that are directly affected during site preparation. Siting offshore wind projects away from biologically productive areas could minimize such impacts. During operations, impacts from a spill as a consequence of a vessel collision could be moderate to major (MMS 2007).
Because little water use would be required as part of the Energy Efficiency and Conservation Program component of this alternative, impacts from the Energy Efficiency and Conservation Program on aquatic resources would likely be minimal.
Because of the potential habitat disturbances and noticeable impacts on aquatic organisms during construction and operation of offshore wind projects, impacts on aquatic resources from the combination alternative would be SMALL to MODERATE. Impacts from the NGCC portion of the alternative and Energy Efficiency and Conservation Program would not be noticeable because less water withdrawal and discharge would be required than for STP, Units 1 and 2. In addition, for the NGCC portion of the alternative, the construction activities would require BMPs, dredging would be short-term, and pollutants would dissipate without the Colorado River (minimizing exposure concentrations to aquatic resources).
8.4.5 Terrestrial Ecology Constructing the NGCC plant would require approximately 92 ac (37 ha), which includes a new pipeline that would run approximately 2 mi (3 km) from the STP site to an existing pipeline.
These estimates are based on GEIS scaling factors and details provided by STPNOC in its ER (STPNOC 2010a). Impacts on terrestrial ecology from onsite construction of the one NGCC unit would be less than the impacts described for the four-unit NGCC alternative, which are described in Section 8.2.
STPNOC estimated that a utility-scale wind plant requires 60 ac of land per MWe of installed capacity in open, flat terrain (STPNOC 2010a). Approximately 462,900 ac (187,300 ha) of land would be required for the installed capacity of 7,714 MWe. Of this area, approximately 2,186 ac (884 ha) would be temporarily disturbed during construction activities, and 937 ac (379 ha) would be permanently disturbed during operations. The permanently disturbed area would be filled with turbines, access roads, and other infrastructure, and the rest of the area would potentially be available for compatible other uses, such as agriculture (ranch, pasture, or cropland).
Impacts on terrestrial ecology from construction of the wind projects, including new transmission lines, could include loss of terrestrial habitat, an increase in habitat fragmentation, and corresponding increase in edge habitat, which may affect threatened and endangered species.
Construction and operations of wind power projects could result in increased mortality of birds flying along the Trans-Gulf migratory route and might also cause increased mortality of migratory and resident bats. Offshore wind power development would also affect avian and aquatic resources. MMS (2007) determined that populations of marine and coastal birds as well as migrating inland birds may experience minor to potentially major impacts due to turbine collisions offshore and that endangered species would be the most impacted.
For this combination alternative, construction of the (a) 2-mi (3-km) natural gas pipeline and (b) transmission lines to connect the wind projects to distribution systems could result in habitat fragmentation and avian collisions with transmission lines. Depending on the length of new 8-45
Environmental Impacts of Alternatives transmission lines, impacts could potentially destabilize attributes of the terrestrial ecosystem because the transmission lines could permanently convert forested or cover habitats into open, maintained areas. To the extent possible, STPNOC would route the pipeline through previously disturbed areas (STPNOC 2010a). Threatened and endangered species may also be affected by construction of the natural gas pipeline and new transmission lines. Long-linear projects, such as pipelines and transmission lines, can often be sited to avoid sensitive areas.
Because no construction would occur for the Energy Efficiency and Conservation Program, impacts from the Energy Efficiency and Conservation Program on terrestrial resources would likely be minimal. Wind energy projects could have a noticeable impact on avian and bat communities because wind energy projects in the Trans-Gulf migratory route could result in increased mortality of migratory and resident birds and bats. Building new transmission lines would also increase habitat fragmentation. Offshore wind power could also result in increased mortality of coastal birds. Based on this information, impacts on terrestrial resources would be MODERATE.
8.4.6 Human Health The human health risks from a combination of alternatives include the effects already discussed in Section 8.2.6 for the NGCC plant. However, the effects would be slightly less since one, rather than four, NGCC unit would be constructed and operated. For wind power, the GEIS notes that, except for a potential small number of occupational injuries, routine operations would not affect human health. For the Energy Efficiency and Conservation Program, the GEIS notes that the environmental impacts are likely to be centered on indoor air quality (NRC 1996). This is due to increased weatherization of the home in the form of extra insulation and reduced air turnover rates from the reduction in air leaks. However, the actual impact is highly site-specific and not yet well-established. Overall, human health risks to occupational workers and to members of the public from the combination alternative would likely be SMALL.
Noise during operations of NGCC plant would be limited to industrial processes and communications. Pipelines delivering natural gas fuel could be audible off site near compressor stations. Pipeline companies would need to adhere to local ordinances regarding maximum noise levels during construction and at compressor stations. Noise from the wind energy project would be audible in the immediate area but would likely be unobtrusive. Some noise impacts could occur in instances of energy conservation and efficiency upgrades to major building systems, but this impact would be intermittent and short-lived. Therefore, impacts from noise would likely be SMALL.
8.4.7 Land Use The GEIS generically evaluates the impact of constructing and operating various replacement power plant alternatives on land use, both on and off each plant site. The analysis of land-use impacts focuses on the amount of land area that would be affected by the construction and operation of a single-unit NGCC plant at the STP site, wind energy projects, and energy conservation and efficiency.
Based on scaled GEIS estimates, constructing the single-unit NGCC unit would require approximately 92 ac (37 ha) at the STP site. This amount of land use would include other plant structures and associated infrastructure, such as the new 2-mi (3-km) pipeline, and is unlikely to exceed 92 ac (37 ha), excluding land for natural gas wells and collection stations.
In addition to onsite land requirements, land would be required off site for natural gas wells and collection stations. Scaling from GEIS estimates, approximately 2,400 ac (970 ha) would be 8-46
Environmental Impacts of Alternatives required for wells and collection stations to bring the natural gas to the power plant. Most of this land requirement would occur on land where natural gas extraction already occurs.
STPNOC estimated that utility-scale, land-based wind energy projects would require 60 ac of land per MWe of installed capacity in open, flat terrain (STPNOC 2010a). Approximately 462,900 ac (187,300 ha) of land would be required for the installed capacity of 7,714 MWe. Of this area of land, approximately 2,186 ac (884 ha) would be temporarily disturbed during construction activities, and 937 ac (379 ha) would be permanently used for each wind turbine during operations. Land used for the wind energy projects would be filled with turbines, access roads, and other infrastructure, and the rest of the land area between the turbines would be available for other uses, such as agriculture (ranch, pasture, or cropland).
Offshore wind energy projects would need to avoid impeding navigation. For both land-based and offshore wind projects, new electrical transmission systems would need to be built to connect the wind energy projects to the electric distribution system.
The elimination of uranium fuel for STP could partially offset offsite land requirements for other energy projects. Scaling from GEIS estimates, approximately 2,560 ac (1,036 ha) would no longer be needed for the mining and processing of uranium.
The land use impacts of the Energy Efficiency and Conservation Program would be minimal.
The rapid replacement and disposal of older inefficient appliances and other equipment would generate waste material and could increase the size of landfills; however, given the time for program development and implementation, the cost of replacements, and the average life of equipment, the replacement process would probably be gradual. More efficient appliances and equipment would replace older equipment (especially in the case of frequently replaced items, such as light bulbs). In addition, many items (such as home appliances and industrial equipment) have recycling value and would not be disposed of in landfills.
The wind energy portion of this combination alternative would require a substantial amount of open land, although only a small portion would be used for wind turbines, access roads, and infrastructure. Therefore, land use impacts from the combination alternative could range from SMALL to MODERATE.
8.4.8 Socioeconomics As previously discussed, socioeconomic impacts are defined in terms of changes to the demographic and economic characteristics and social conditions of a region. For example, the number of jobs created by the construction and operation of a new NGCC plant and wind power projects could affect regional employment, income, and expenditures. Two types of jobs would be created by this alternative: (1) construction jobs, which are transient, short in duration, and less likely to have a long-term socioeconomic impact; and (2) power plant and wind energy operation jobs, which have the greater potential for permanent, long-term socioeconomic impacts. Workforce requirements for the construction and operation of the combination alternative were evaluated to measure their possible effects on current socioeconomic conditions.
Based on GEIS estimates, the construction workforce would be up to 800 (maximum) workers for the NGCC plant. Scaling from STPNOCs estimates, the estimated construction workforce would be up to 507 (maximum) workers (STPNOC 2010a). STPNOCs estimate appears reasonable; therefore, it is used in this analysis. STPNOC did not provide a construction workforce estimate for wind energy projects. In Exelon Generation Companys, LLC (Exelon)
ER for Limerick Generating Station, Exelon estimated a construction workforce of 200 for approximately half the amount of wind capacity needed for this combination alternative 8-47
Environmental Impacts of Alternatives (Exelon 2011). This estimate includes both land-based and offshore wind energy projects.
Scaling from this estimate, wind energy projects could require a construction workforce of up to 400 workers. The relative economic impacts of this many workers on the local economy and tax base would vary, with the greatest impacts occurring in the communities where the majority of construction workers would reside and spend their income. As a result, local communities could experience a short-term economic boom from increased tax revenue and income generated by construction expenditures and the increased demand for temporary (rental) housing and business services. Some construction workers could relocate to Matagorda and surrounding counties in order to be closer to the construction work sites. However, given the proximity of STP to the Houston and other metropolitan areas, workers could commute to the various construction sites, thereby lessening the need for additional rental housing near STP.
After completing the installation of the single NGCC unit and wind turbines, local communities could experience a return to pre-construction economic conditions. Based on this information, and the given number of workers, socioeconomic impacts during construction in communities near the STP site and wind farms could be SMALL, due to the small number of workers needed to construct the NGCC plant and because the wind energy project workers would be spread throughout the service region.
Scaled from GEIS estimates, the single-unit NGCC power plant operation workforce would be 100 workers. Based on STPNOCs estimates, the maximum NGCC operation workforce would be 23 workers (STPNOC 2010a). STPNOCs estimate appears reasonable; therefore, it is used in this analysis. STPNOC did not provide an operations workforce estimate for wind energy projects. In Exelons ER for the Limerick Generating Station, Exelon estimated a wind energy workforce of 50 workers for approximately half the amount of wind capacity needed for this combination alternative (Exelon 2011). This estimate includes both land-based and offshore wind energy projects. Scaling from this estimate, wind energy projects could require an operations workforce of up to 100 workers. The amount of property taxes paid under the combination alternative may increase if additional land is required off site to support this alternative. As noted in the GEIS, an Energy Conservation and Efficiency Program would also create jobs for additional workers (NRC 1996). Socioeconomic impacts during operations could range from SMALL to MODERATE as the STP site transitions to the new, single-unit NGCC power plant. The reduction in overall employment at STP could affect property tax revenue and income in local communities and businesses. In addition, the permanent housing market could also experience increased vacancies and decreased prices if operations workers and their families move out of the region.
8.4.9 Transportation Construction and operation of an NGCC plant at the STP site and wind energy projects throughout the region would increase the number of vehicles on the roads near these facilities.
During construction, cars and trucks would deliver workers, materials, and equipment to the worksites. Traffic volumes on local roads near these worksites would noticeably increase and peak during shift changes resulting in temporary levels of service impacts and delays at intersections. Transporting components of wind turbines via roadways could also have a noticeable impact on traffic conditions, and this effect is likely to be spread over a large area.
Pipeline construction and modification to existing natural gas pipeline systems could also have a temporary impact. Based on this information, traffic-related transportation impacts during construction could range from SMALL to MODERATE depending on the location of the wind energy sites, road capacities, and traffic volumes.
Traffic volumes on local roads near construction sites after the installation of the NGCC and wind turbines would be noticeably reduced. Given the small number of workers needed to 8-48
Environmental Impacts of Alternatives operate the energy projects in this combination alternative, the levels of service impacts on local roads during shift changes would be SMALL. In addition, wind energy project operation workers would be spread across the service region, and any traffic-related transportation effects from the energy efficiency alternative would also be widely distributed. Therefore, overall transportation impacts for this combination alternative during operations would be SMALL.
8.4.10 Aesthetics The analysis of aesthetic impacts focuses on the degree of contrast between the surrounding landscape and the visibility of the NGCC plant and wind energy projects. In general, aesthetic changes would be limited to the immediate vicinity of the STP site and wind energy projects.
Aesthetic impacts from the NGCC plant component of the combination alternative would be essentially the same as those described for the NGCC alternative in Section 8.2.10, except there would be one unit rather than four units. During construction, all of the clearing and excavation would occur on the STP site. These activities may be visible from offsite roads, particularly FM 521. Since the STP site already appears industrial, construction of the NGCC power plant would appear similar to onsite activities during refueling outages. Power plant infrastructure would be smaller and less noticeable than STP containment and turbine buildings.
Noise during plant operations would be limited to industrial processes and communications.
Pipelines delivering natural gas fuel could be audible off site near gas compressor stations. In general, aesthetic changes due to the construction and operation of the single-unit NGCC would be limited to the immediate vicinity of the STP site and would be SMALL.
The wind energy projects would have the greatest visual impact. Approximately 3,877 wind turbines at over 300 ft (100 m) tall would be spread across multiple land-based sites covering 462,900 ac (187,300 ha). The turbines would dominate the view and would likely become the major focus of attention. Offshore wind projects would also be visible because of the height and size of the wind turbine generators (MMS 2007). Depending on their location, the aesthetic impacts from the construction and operation of the wind energy projects would be MODERATE to LARGE.
Impacts from the Energy Conservation and Efficiency Program would be SMALL because it would not require any visible changes to existing infrastructure.
8.4.11 Historic and Archaeological Resources The same considerations, discussed in Section 8.2.11, for the impact of the construction of a four-unit NGCC plant on historic and archaeological resources apply to the construction activities that would occur on the STP site for a new one-unit NGCC plant. As described in Section 2.2.10, much of the STP site has been previously disturbed by the construction of STP, Units 1 and 2. In addition, in preparation for the COL application for Units 3 and 4, STPNOC conducted a cultural resources assessment of the STP site. STPNOC reviewed existing information for the STP site and the area within a 10-mi (16-km) radius. STPNOC concluded that any cultural resource sites that may have existed on site would no longer retain their integrity because the area was heavily disturbed during the construction of Units 1 and 2 (STPNOC 2010b). In December 2006, STPNOC reported these findings to the SHPO at the Texas Historical Commission. The SHPO concurred, in January 2007, that there would be no impacts to historic properties (STPNOC 2006; THC 2007).
There is a low potential for cultural resources to be located in previously undisturbed portions of the STP site. However, if the NGCC unit was to be sited within undisturbed areas or within areas of known cultural sensitivity (historic grave site located on the property and described in 8-49
Environmental Impacts of Alternatives Section 2.2.10), these areas would need to be surveyed by a professional archaeologist to identify and develop possible mitigation measures to address any adverse effects from project activities. NRC assumes the plant operator would follow similar procedures to those described in the final EIS for STP, Units 3 and 4 (NRC 2011), should the plant operator discover any historic or cultural resources during ground-disturbing activities associated with building the new units.
Studies would be needed for all areas of potential disturbance at the proposed plant site, wind project locations, and along associated corridors where new construction would occur (e.g., the new 2-mi pipeline, roads, transmission corridors, rail lines, or other ROWs). Any affected areas would need to be surveyed to identify and record historic and archaeological resources, identify cultural resources (e.g., traditional cultural properties), and develop possible mitigation measures to address any adverse effects from ground-disturbing activities. In most cases, long-linear projects (e.g., pipelines) can be sited to avoid areas of greatest sensitivity.
Construction of wind energy projects could affect cultural resource because areas approximately 15 to 25 ft (4.6 to 6 m) in diameter would be excavated. Wind turbines can likely be sited to avoid sensitive areas because the disturbed area is a small portion of the total amount of area required. In addition, wind turbines within the viewshed of traditional cultural properties and historic properties could have noticeable impacts to cultural and historic resources. Proper siting may be able to mitigate these potential impacts.
The NRC staff determined that the impact on historic and archaeological resources from the NGCC portion of the combination alternative would be SMALL for the following reasons:
- NRC (2011) and STPNOC (2010a, 2010b) did not identify any cultural resources that could be affected by Units 3 and 4.
- The SHPO determined that construction for Units 3 and 4 would not affect cultural and historic resources.
- Long-linear projects (e.g., pipelines) can usually be sited to avoid sensitive areas.
- NRC assumes that the plant operator would follow environmental compliance procedures for new ground-disturbing activities.
Depending on the resource richness of the site chosen for the wind energy projects, the impacts could range between SMALL to MODERATE. Impacts to historic and archaeological resources from implementing the Energy Efficiency and Conservation Program would be SMALL and would unlikely affect land use or historical or cultural resources elsewhere in Texas. Therefore, the overall impacts on historic and archaeological resources from the combination alternative could range from SMALL to MODERATE.
8.4.12 Environmental Justice The environmental justice impact analysis evaluates the potential for disproportionately high and adverse human health and environmental effects on minority and low-income populations that could result from the construction and operation of a new NGCC power plant at the STP site, wind energy projects, and the Energy Efficiency and Conservation Program. As previously discussed in Section 8.1.12, such effects may include human health, biological, cultural, economic, or social impacts. Some of these potential effects have been identified in resource areas discussed in this SEIS. For example, increased demand for rental housing during plant construction could disproportionately affect low-income populations. Minority and low-income populations are subsets of the general public living near the STP site and wind energy project 8-50
Environmental Impacts of Alternatives sites, and all are exposed to the same hazards generated from constructing and operating an NGCC plant and wind energy projects. Section 4.9.7, Environmental Justice, presents demographic information about minority and low-income populations residing in the vicinity of the STP site.
Potential impacts to minority and low-income populations from the construction and operation of a new NGCC plant at the STP site and wind energy projects would mostly consist of environmental and socioeconomic effects (e.g., noise, dust, traffic, employment, and housing impacts). Noise and dust impacts during construction would be short-term and primarily limited to onsite activities. Minority and low-income populations residing along site access roads would be directly affected by increased commuter vehicle and truck traffic. However, because of the temporary nature of construction, these effects would only occur during certain hours of the day and are unlikely to be high and adverse. Increased demand for rental housing during construction of the NGCC and wind energy projects could also affect low-income populations living near STP and wind energy project sites. Given the proximity of STP to the Houston metropolitan area, many construction workers could commute to the STP and wind energy project sites, thereby lessening the additional need for rental housing near STP.
Low-income populations could benefit from weatherization and insulation in an Energy Conservation and Efficiency Program. This could have a greater beneficial effect on low-income populations than the general population because low-income households generally experience greater home energy burdens than the average household.
Based on this information, and the analysis of human health and environmental impacts presented in this SEIS, the combination alternative would not create disproportionately high and adverse human health and environmental effects on minority and low-income populations.
8.4.13 Waste Management During the construction stage for the NGCC plant and wind projects, land clearing and other construction activities would generate wastes that could be recycled, disposed of on site, or shipped to the offsite waste disposal facility. During the operational stage, spent SCR catalysts, which control nitrogen oxide emissions from the NGCC plant, would make up the majority of the waste generated by this alternative.
There would be an increase in wastes generated during installation or implementation of energy conservation measures, such as appropriate disposal of old appliances, installation of control devices, and modifications of buildings. New and existing recycling programs would help to minimize the amount of generated waste.
The NRC concludes that overall waste impacts from the combination alternative would be SMALL.
8.4.14 Summary of Impacts of the Combination Alternative Table 8-5 summarizes the environmental impacts of the combination alternative compared to continued operation of the STP.
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Environmental Impacts of Alternatives Table 8-5. Summary of Environmental Impacts of the Combination Alternative Compared to Continued Operation of STP, Units 1 and 2 Category Combination Alternative Continued STP Operation Air quality SMALL to MODERATE SMALL Surface water SMALL SMALL Groundwater SMALL SMALL Aquatic resources SMALL to MODERATE SMALL Terrestrial resources MODERATE SMALL Human health SMALL SMALL to MODERATE Land use SMALL to MODERATE SMALL Socioeconomics SMALL to MODERATE SMALL Transportation SMALL to MODERATE SMALL Aesthetics SMALL to LARGE SMALL Historic & archaeological SMALL to MODERATE SMALL Waste management SMALL SMALL 8.5 Purchased Power Under the purchased power alternative, STPNOC would purchase 2,500 MWe of electricity from other power generators. No new generating capacity would be built and operated by STPNOC.
In its ER, STPNOC assumed that purchased power is a reasonable alternative for the following reasons:
- A wholesale electricity market currently exists in the ERCOT region.
- ERCOT implements rules to anticipate and meet electricity demands and promote competition among electricity suppliers.
- Most of ERCOTs retail customers can choose a supplier to purchase electricity.
If STPNOC purchased electricity, the source of all generated electricity would be within the ERCOT region because ERCOT operates wholly within the State of Texas and does not interconnect with neighboring reliability regions for the purpose of importing or exporting power (STPNOC 2010a). In 2010, electricity produced within the ERCOT region was dominated by coal (40 percent), followed by natural gas (38 percent), nuclear (13 percent), wind (8 percent),
and other sources (1 percent) (ERCOT 2011a). As of April 2011, new energy projects under ERCOTs review included 36,124 MWe of wind power (58 percent); 12,954 MWe of natural gas-fired generation (21 percent); 5,900 MWe of nuclear power (9 percent); 4,075 MWe of coal-fired generation (7 percent); 1,454 MWe solar power (2 percent); 150 MWe of biomass-fired generation (less than 1 percent); and 1,980 MWe of other resources (3 percent)
(ERCOT 2011a). Based on current and likely future electric generation, NRC assumed that the purchased power would likely come from a mixture of coal, natural gas, wind, and nuclear energy.
Because the purchased power would be limited to resources available within the ERCOT region, new energy generation facilities may need to be built to supply the electricity.
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Environmental Impacts of Alternatives Construction impacts would be similar to those described under the new nuclear, coal, natural gas, and wind alternatives described in the previous sections. In addition to the construction impacts described in Sections 8.1 through 8.3, there could be additional impacts if new plants are built on greenfield sites. For example, impacts to aquatic and terrestrial resources and historical and cultural resources are likely to be greater due to land clearing of previously undisturbed areas. Additional impacts would also occur from construction of support infrastructure, like transmission lines and roads. Furthermore, the community would not be familiar with the appearance of a power facility, which would change the regions aesthetic character. Workers skilled in power plant or wind farm operations may not be available near a greenfield site.
During operations, impacts from new nuclear, coal-fired, and natural gas-fired plants and wind energy projects would be similar to that described under the new nuclear, coal, natural gas, and wind alternatives described in the previous sections. Impacts from the operations of existing coal- and natural gas-fired plants would likely be greater than the operations of new plants because older plants are more likely to be less efficient and without modern emissions controls.
Air quality impacts from the combination of all sources would likely be greater than license renewal because a large portion of the purchased power would likely be from coal- and natural gas-fired plants.
While purchased power is a reasonable alternative, the potential impacts of constructing and operating new power generating facilities is addressed elsewhere in this chapter. In general, the impacts would likely be greater than license renewal due to potential new construction and because continued operation of older plants could result in higher emissions. Ultimately, the impacts would depend on the mix of sources used to supply the 2,500 MWe of electricity.
Below is a brief summary of the impacts for each resource area.
8.5.1 Air Quality New and existing nuclear plants and wind farms would not have noticeable impacts on air quality. New and existing natural gas- and coal-fired plants would have noticeable impacts on air quality; both natural gas- and coal-fired plants emit higher amounts of nitrogen oxides, sulfur oxides, PM, HAPs, carbon monoxide, carbon dioxide, and mercury as compared to STP, Units 1 and 2. The impacts on air quality would be SMALL to MODERATE.
8.5.2 Surface Water and Groundwater Resources New and existing nuclear, coal-fired, and natural gas-fired plants and wind energy projects would not have noticeable impacts on water resources assuming all energy generating facilities operate within their associated water quality and water use permits. The impacts on surface water and groundwater resources would be SMALL.
8.5.3 Terrestrial and Aquatic Ecology New and existing natural gas-fired and nuclear plants would not have noticeable impacts on aquatic and terrestrial resources assuming plants are built in areas that avoid sensitive species and habitats. New, land-based wind energy projects would not have noticeable impacts on aquatic resources assuming projects are built in areas that avoid sensitive species and habitats.
New wind energy projects would have noticeable impacts on avian and bat communities and new offshore wind energy projects could have noticeable impacts on fish, whales, turtles, benthic organisms, and other marine life. New and existing coal-fired plants would have noticeable impacts on terrestrial communities primarily due to the deposition of ash and other 8-53
Environmental Impacts of Alternatives pollutants and because of the extent of terrestrial habitat disturbance associated with coal mining. The impacts on terrestrial and aquatic ecology would be SMALL to MODERATE.
8.5.4 Human Health New and existing nuclear, coal-fired, and natural gas-fired plants and wind energy projects would have SMALL impacts on human health due to the extent of regulations to protect public health.
8.5.5 Land Use Purchased power from existing power plants would not cause any land use changes. New power plants would likely be constructed at existing power plant sites. Purchased power from coal- and natural gas-fired plants could have a noticeable impact on land use due to the amount of land required for coal mining and gas drilling. New wind energy projects would have a noticeable land use impact because of the large amount of land required for wind farms. Land use impacts would be SMALL to MODERATE.
8.5.6 Socioeconomics (including transportation and aesthetics)
Purchased power from existing power plants would not have any socioeconomic impact because there would be no change in power plant operations or workforce. Construction of new electrical power generating facilities could cause noticeable short-term socioeconomic and transportation impacts due to the number of construction workers required to build the new power plant. Traffic volumes would increase on local roads during shift changes.
Wind energy projects would have the greatest visual impact; wind turbines would dominate the view and would likely become the major focus of attention.
The impacts would be SMALL to LARGE.
8.5.7 Historic and Archaeological Resources Purchased power from existing power plants would not have any impact on historic and archaeological resources. In addition, ground-disturbing maintenance activities during operations also have the potential to affect historic and archaeological resources.
Construction of new nuclear, coal-fired, and natural gas-fired plants and wind energy projects could affect archaeological and historic resources. Archaeological surveys would need to be conducted prior to any excavations at proposed power plant sites. After surveys are completed, sensitive resource areas could be avoided or mitigated prior to construction. The overall impacts on historic and archaeological resources would be SMALL to MODERATE.
8.5.8 Environmental Justice Low-income populations could be disproportionately affected by increased utility bills due to the cost of purchased power. However, programs are available to assist low-income families in paying for increased electrical costs.
Potential impacts to minority and low-income populations from the construction and operation of new power plants would mostly consist of environmental and socioeconomic effects (e.g., noise, dust, traffic, employment, and housing impacts). Noise and dust impacts during construction would be short-term and primarily limited to onsite activities. Minority and low-income populations residing along site access roads would be directly affected by increased commuter 8-54
Environmental Impacts of Alternatives vehicle and truck traffic. However, because of the temporary nature of construction, these effects would only occur during certain hours of the day and are unlikely to be high and adverse.
Increased demand for rental housing during construction could also affect low-income populations living near the construction site. However, workers could commute to the construction site, thereby lessening the need for additional rental housing near the construction sites. Based on this information, and the analysis of human health and environmental impacts presented in this section, the purchased power alternative could disproportionately affect low-income populations, but these effects would not be high and adverse.
8.5.9 Waste Management New and existing nuclear and natural gas-fired plants and wind energy projects would not have noticeable impacts. However, new and continued generation of coal-fired plants would have noticeable impacts due to the accumulation of ash and scrubber sludge. The overall impacts on waste management would range from SMALL to MODERATE.
8.5.10 Summary of Impacts of the Purchased Power Alternative Table 8-6 summarizes the environmental impacts of the purchased power alternative compared to continued operation of the STP.
Table 8-6. Summary of Environmental Impacts of the Purchased Power Alternative Compared to Continued Operation of STP, Units 1 and 2 Category Purchased Power Continued STP Operation Air quality SMALL to MODERATE SMALL Surface water & groundwater SMALL SMALL Aquatic & terrestrial resources SMALL to MODERATE SMALL Human health SMALL SMALL to MODERATE Land use SMALL to MODERATE SMALL Socioeconomics (including SMALL to LARGE SMALL transportation & aesthetics)
Historic & archaeological SMALL to MODERATE SMALL Waste management SMALL to MODERATE SMALL 8.6 Alternatives Considered but Dismissed Alternatives to license renewal that were considered and eliminated from detailed study are presented in this section. These alternatives were eliminated due to technical, resource availability, or current commercial limitations. Many of these limitations would continue to exist when the current STP licenses expire. NRC evaluated an alternative of wind energy in combination with an NGCC plant and energy efficiency and conservation programs in Section 8.4. The evaluations of wind technology and energy conservation and efficiency appearing in this section are as discrete alternatives.
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Environmental Impacts of Alternatives 8.6.1 Offsite Nuclear-, Gas-, and Coal-Fired Capacity While nuclear-, gas-, and coal-fired power generating alternatives like those considered in Sections 8.1 through 8.3, respectively, could be constructed offsite, the impacts would be greater than constructing these facilities and making use of existing infrastructure at the STP site. Additional impacts would occur from the construction of new water intake and discharge structures, as well as other support infrastructure, including transmission lines and roads that are already present on the STP site. Furthermore, the community around STP is already familiar with the appearance of a power generating facility, and it is an established part of the regions character. Workers skilled in power plant operations may not be available in other locations. However, support infrastructure and skilled power-plant workers may be available near existing industrial sites, but remediation may also be necessary in order to make the site ready for redevelopment. In short, an existing power plant site would present the best location for a new replacement power facility.
8.6.2 Energy Conservation and Energy Efficiency Though often used interchangeably, energy conservation and energy efficiency are different concepts. Energy efficiency means deriving a similar level of services by using less energy while energy conservation indicates a reduction in energy consumption. Both fall into a larger category known as demand-side management. Demand-side management measures address energy end usesunlike energy supply alternatives discussed in previous sections.
Demand-side management can include measures that do the following:
- shift energy consumption to different times of the day to reduce peak loads,
- interrupt certain large customers during periods of high demand,
- interrupt certain appliances during high demand periods,
- replace older, less efficient appliances, lighting, or control systems, and
- encourage customers to switch from gas to electricity for water heating and other similar measures that utilities use to boost sales.
Unlike other alternatives to license renewal, the GEIS notes that conservation is not a discrete power-generating source; nonetheless, it represents an option that states and utilities may use to reduce their need for power generation capability, so the NRC addressed it in the GEIS (NRC 1996).
In 2010, the Public Utility Commission of Texas approved Substantive Rule §25.181, which requires all electric transmission and distribution utilities within the ERCOT market, including CPS Energy and Austin Energy (two of the owners of STP, Units 1 and 2), to use demand-side management to reduce their customers energy consumption by a minimum of 20 percent of the utilitys annual growth. The rule further requires a minimum of 25 percent reduction in 2012 and 30 percent in 2013 and beyond.
CPS Energy and Austin Energy implement programs to promote demand-side management.
These programs include load curtailment incentives during periods of peak demand; rebates and financial incentives for commercial, industrial, and residential customers for installation of energy-efficient appliances and equipment; and the adoption of updated energy codes for new building construction (STPNOC 2010a). Demand-side management programs from other Texas utilities would also help offset the 2,500 MWe produced by STP because STPNOC sells power produced at STPNOC into the ERCOT interconnection (STPNOC 2010a).
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Environmental Impacts of Alternatives Because Substantive Rule §25.181 already requires annual 30 percent reductions in energy consumption from demand-side management, it is unlikely that additional increases in energy efficiency in the State of Texas will have grown enough to offset the loss of 2,500 MWe produced by STP by the time the licenses expire in 2027 and 2028. Because of this, the NRC staff has not evaluated energy conservation and efficiency as a discrete alternative to license renewal. NRC evaluated an alternative with energy efficiency and conservation programs in combination with an NGCC plant and wind energy in Section 8.4.
8.6.3 Wind Power Texas has significant wind energy resources and leads the Nation in wind-powered generation capacity (DOE 2011b). As discussed in Section 8.4, as of June 30, 2011, the installed wind capacity in Texas was 10,135 MWe (DOE 2011b). Wind resource areas in the Texas Panhandle, along the Gulf coasts south of Galveston and in the mountain passes and ridgetops of the Trans-Pecos region, offer some of the greatest wind power potential in the U.S. The Roscoe Wind Farm in Texas is the largest wind farm in the world with a total capacity of 781.5 MWe spread across approximately 100,000 ac (40,470 ha) in four counties near Roscoe in central Texas.
Newer wind turbines typically operate at approximately a 36 percent annual capacity factor (DOE 2008). Wind turbines generally can serve as an intermittent power supply (NPCC 2005).
Wind power might serve as a means of providing baseload power (a) if it is combined with energy storage mechanisms, such as pumped hydroelectric or compressed air energy storage (CAES), (b) if many wind farms are interconnected to one another on the transmission grid, as described in Section 8.4, or (c) if another readily dispatchable power source is used when wind power is unavailable (e.g., hydropower).
EIA is not projecting any growth in pumped storage capacity through 2035 (EIA 2011a). As described below, the potential for new hydroelectric development in Texas is limited. Therefore, NRC concludes that the use of pumped storage in combination with wind turbines to generate 2,500 MWe is unlikely in the ERCOT region or Texas.
A CAES plant is another potential storage mechanism that could potentially serve as means for wind to provide baseload power. A CAES plant consists of motor-driven air compressors that use low cost off peak electricity to compress air into an underground storage medium. During high electricity demand periods, the stored energy is recovered by releasing the compressed air through a combustion turbine to generate electricity (NPCC 2009). Only two CAES plants are currently in operation. A 290-MWe plant near Bremen, Germany, began operating in 1978, and a 110-MWe plant located in McIntosh, Alabama, has been operating since 1991. Both facilities use salt caverns (Succar and Williams 2008). A CAES plant requires suitable geology, such as an underground cavern for energy storage, which would likely be available in Texas due to the presence of salt domes. A 268-MWe CAES plant coupled to a wind farm, the Iowa Stored Energy Park, had been proposed for construction near Des Moines, Iowa. The facility would have used a porous rock storage reservoir for the compressed air (Succar and Williams 2008).
However, the project has been cancelled due to geologic concerns (ISEPA 2011). Other pilot, demonstration, prototype, and research projects involving CAES have been announced, including projects in Texas and throughout the U.S. Norton Energy Storage is proposing to construct a CAES plant that would provide up to 2,700 MWe of storage capacity in Norton, Ohio (OPSB 2011). Projects such as the Conoco-Phillips and General Compression venture may use compressed air storage directly without the combustion of fuel such as natural gas.
However, NRC is not aware of a CAES project coupled with wind generation that is providing baseload power. Therefore, NRC concludes that the use of CAES in combination with wind turbines to generate 2,500 MWe in the ERCOT region is unlikely.
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Environmental Impacts of Alternatives A significant challenge for new wind power facilities is that wind farms can be built more quickly than transmission lines. It can take a year to build a wind farm, but 5 years to build the transmission lines needed to send power to cities. Moreover, wind power developers are reluctant to build where transmission lines do not yet exist, and utilities are equally reluctant to install transmission in areas that do not yet have power generators (TSECO 2008). Archer and Jacobson (2007) examined whether wind projects interconnected to one another on the transmission grid could provide a source of baseload power, as described in Section 8.4. This study determined that interconnecting wind farms through the transmission grid increases the probability that at least one site experiences sufficient wind to produce electricity. Thus, as more sites are added to the transmission grid, the interconnected wind farms provide electricity that is comparable to a single wind farm providing near constant deliverable wind power.
However, due to the amount of new transmission lines required and the cost limitations of building new transmission lines, it is unlikely that sufficient transmission lines could be built to interconnect sufficient wind projects to provide 2,500 MWe of baseload power (with an installed capacity of at least 12,000 MWe).
Offshore Wind. Wind data suggest there is potential for offshore wind farms along the coast of Texas, although project costs likely limit the future potential of large-scale projects (NRC 2011; Southern and GIT 2007). Southern Company and the Georgia Institute of Technology (GIT) studied the viability of offshore wind turbines in the southeast and determined that offshore project costs would run approximately 50 to 100 percent higher than land-based systems. Also, based on current prices for wind turbines, the 20-year levelized cost of electricity produced from an offshore wind farm would be above the current production costs from existing power generation facilities. In addition, the current commercially available offshore wind turbines are not built to withstand major hurricanes above a Category 3 or a 1-minute sustained wind speed of 124 mph. Additional details on the limitations of offshore wind power as a source of baseload power is described in the final EIS for STP, Units 3 and 4 (NRC 2011).
The National Renewable Energy Laboratory (NREL) issued a report that identified offshore wind projects in the southeast (NREL 2010). The report identified the proposed Coastal Point Energy Project (also called the Galveston Wind Project) off the Texas coast near Galveston (approximately 9 mi from shore), which is anticipated to have a capacity of 300 MWe (NREL 2010). No other wind energy projects were identified by NREL off the coast of Texas or its adjoining State (Louisiana).
Conclusion. Although wind power is an important energy resource in the ERCOT region and Texas, NRC concludes that a wind energy facility at or in the vicinity of the STP site or elsewhere in the ERCOT region would not currently be a reasonable alternative to license renewal. NRC evaluated an alternative of wind energy in combination with an NGCC plant and energy efficiency and conservation programs in Section 8.4.
8.6.4 Solar Power Solar technologies use the suns energy to produce electricity at a utility scale. Solar energy can be converted to electricity using solar thermal technologies or photovoltaics. Solar thermal technologies employ concentrating devices to create temperatures suitable for power production. Concentrating thermal technologies are currently less costly than photovoltaics for bulk power production.
The ERCOT region receives 3.5 to 7.0 kWh/m2/day of direct solar radiation (STPNOC 2010a).
Solar power constituted less than 1 percent of electricity produced in the ERCOT region during 2010 (ERCOT 2011a). As of April 2011, applications for energy projects under review at ERCOT included 1,454 MWe of proposed solar projects (ERCOT 2011a).
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Environmental Impacts of Alternatives As described in the GEIS, solar power is intermittent (i.e., it does not work at night and cannot serve baseload when the sun is not shining), and the efficiency of collectors varies greatly with weather conditions. Therefore, solar power by itself would not be able to provide baseload power as an alternative to Units 1 and 2. Rather, a solar-powered alternative would require energy storage or backup power supply from other sources to potentially supply baseload power during periods when the sun is not shining. Potential storage mechanisms include pumped storage, CAES, molten salt storage, or thermal storage. As described above in Section 8.6.3 and in STP, Units 3 and 4, EIS (NRC 2011), storage possibilities in this region of Texas are limited. NRC is not aware of any storage facility coupled with solar generation that is providing baseload power.
For the term of license renewal, because solar energy is an intermittent resource, and the amount of solar capacity required to replace Units 1 and 2 far exceeds existing and planned amounts of future solar power generation within ERCOT and exceeds storage potential (if CAES or pumped storage were used), NRC does not consider solar energy to be a reasonable alternative to license renewal.
8.6.5 Hydroelectric Power Hydropower constituted less than 1 percent of electricity produced in the ERCOT region during 2010 (ERCOT 2011a). EIAs reference case in its Update Annual Energy Outlook 2011 projects that U.S. electricity production from hydropower plants will remain essentially stable through 2035 (EIA 2011a). Idaho National Energy and Environmental Laboratory (1998) estimated that 1,234 MWe of undeveloped potential hydroelectric resources at 89 sites occur throughout the State of Texas. Given that the available hydroelectric potential in the State of Texas constitutes less than one-tenth of the generating capacity of STP, the NRC staff did not evaluate hydropower as a reasonable alternative to license renewal.
8.6.6 Wave and Ocean Energy Wave and ocean energy has created considerable interest in recent years. Ocean waves, currents, and tides are often predictable and reliable. Ocean currents flow consistently, while tides can be predicted months and years in advance with well-known behavior in most coastal areas. Most of these technologies are in relatively early stages of development. The potential for wave and ocean energy in Texas is limited because the Gulf of Mexico is shallow and semi-enclosed (TCPA 2008). Because most technologies are relatively undeveloped (and none are developed on the scale of STP), and because the Gulf of Mexico has limited potential for wave and ocean energy, the NRC did not consider wave and ocean energy as a reasonable alternative to STP license renewal.
8.6.7 Geothermal Power Hydrothermal resources, reservoirs of steam or hot water that can be used for electrical generation, are available primarily in the western states, including Hawaii, Alaska, California, Utah, and Nevada (TCPA 2008). This type of geothermal energy has an average capacity factor of 90 percent and can be used for baseload power where available. Geothermal systems have a relatively small footprint and minimal emissions (MIT 2006). However, Texas does not have the sort of readily accessible, high-temperature hydrothermal resource (Virtus 2008).
Lower-temperature geothermal resources (90 °F to 160 °F) occur in the central part of Texas and along the Rio Grande. In the technical report (TCPA 2008), Texas Comptroller of Public Accounts (TCPA) suggests that such areas could provide low-temperature applications, such as space heating. Other uses could also include greenhouse cultivation, aquaculture, crop drying, 8-59
Environmental Impacts of Alternatives and milk pasteurization. The potential for hot dry rock geothermal power in Texas is presently unknown (Virtus 2008).
Geopressured-geothermal power plants use existing, deep oil and gas wells to access hot fluids that have been co-produced from oil and gas exploration, such as geopressured reservoirs of hot water and natural gas or hot wastewater from deep oil and gas wells. This technology has future potential in Texas because hydrocarbon exploration and production industries have data on the thermal characteristics in existing wells and because areas with sufficient geothermal energy may exist where deep oil and gas wells exists (TCPA 2008). Current data suggest that wells 16,000 ft (4,877 m) or deeper in the ERCOT region contain high-temperature fluid (250 °F (121 °C) or greater), and some wells are above 400 °F (204 °C) (STPNOC 2010a). In addition, transmission lines are located near many of the existing wells (TCPA 2008).
In 1989, DOE operated a test geopressured-geothermal power plant at Pleasant Bayou, approximately 60 mi (97 km) northwest of STP. The 1 MW binary power plant operated for 6 months and produced approximately 3,500 MWh of electricity (TCPA 2008). GEA (2007) estimates that electric power production potential from oil and gas wells in Texas could produce 400 MWe in the near-term to over 2,000 MWe once the technology is refined and more widespread. Even if the oil and gas wells produced 2,000 MWe, this output would not be sufficient to make up for the 2,500 MWe produced by STP, Units 1 and 2. Additional capital and significant investment is required to develop and operate geopressured-geothermal power plants to produce a sufficient amount of baseload power.
As of 2008, no geothermal projects produced electricity on a commercial scale in Texas (TCPA 2008), but some potential exists for geopressured-geothermal power plants and low-temperature projects at smaller scales. Energy companies, Texas State Energy Conservation Office, and Southern Methodist University are currently assessing Texass potential for various forms of geothermal technology. A significant amount of investment would be required for geothermal energy to be used in Texas (TCPA 2008). Given the immature status of geothermal technology and the limited resource availability in Texas, the NRC concludes that geothermal energy is not a reasonable alternative to STP license renewal.
8.6.8 Municipal Solid Waste Municipal-solid-waste combustors use three types of technologiesmass burn, modular, and refuse-derived fuel. Mass burning is used most frequently in the U.S. and involves little sorting, shredding, or separation. Consequently, toxic or hazardous components present in the waste stream are combusted, and toxic constituents are exhausted to the air or become part of the resulting solid wastes. Currently, approximately 86 waste-to-energy plants operate in the U.S.
These plants have a generating capacity of 2,572 MWe, or an average of 30 MWe per plant (Michaels 2010). More than 85 average-sized plants would be necessary to provide the same level of output as STP.
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 power 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-fired facilities or at wood-waste facilities because of the need for specialized waste separation and handling equipment (NRC 1996).
The decision to burn municipal waste to generate energy is driven by the need for an alternative to landfills rather than energy considerations. The use of landfills as a waste disposal option is likely to increase as energy prices increase; however, it is possible that municipal waste 8-60
Environmental Impacts of Alternatives combustion facilities may become attractive again if there is a need for an alternative to landfills or an introduction of other regulatory incentives.
Given the small average installed size of municipal solid-waste plants and the unfavorable regulatory environment, the NRC staff does not consider municipal solid-waste combustion to be a reasonable alternative to STP license renewal.
8.6.9 Biomass Using biomass for energy consists of the direct burning of plant or animal matter, including wood waste, mill waste, agricultural residues, and energy crops. Biomass fuel provided less than 1 percent of electricity produced in the ERCOT region during 2010 (ERCOT 2011a). As of April 2011, applications for energy projects under review at ERCOT included 150 MW of proposed biomass-fuel projects (ERCOT 2011a). In Texas, the Red River Army Depot cofires biomass with fossil fuels (DOE 2004).
Biomass resources in Texas include crops (e.g., cotton, corn, and some soybeans), forests (especially in east Texas), and agricultural wastes (e.g., cattle manure, poultry litter, rice straw, peanut shells, cotton gin trash, and corn stover) (TCPA 2008). Houston Advanced Research Center estimated that Texas agricultural wastes could potentially produce 418.9 MWe (HARC 2008).
In NUREG-1437, the NRC staff determined that a wood-burning facility can provide baseload power and operate with an average annual capacity factor of around 70 to 80 percent and with 20 to 25 percent efficiency (NRC 1996). The fuels required are variable and site-specific. A significant impediment to the use of wood waste to generate electricity is the high cost of fuel delivery and high construction cost per megawatt of generating capacity. The larger woodwaste power plants typically produce 40 to 50 MWe. Estimates in NUREG-1437 suggest that the overall level of construction impacts per megawatt 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 (NRC 1996). Similar to coal-fired plants, wood waste plants require large areas for fuel storage and processing and involve the same type of combustion equipment.
One of the largest wood-fired biomass power plants began operations in June 2012 in Sacul, Texas (Southern 2012). The 100 MWe wood-fired biomass power plant uses logging residue as its main fuel source. It also uses urban wood waste (TCPA 2008). The plant owner, Southern Power, estimated that the plant will require approximately 1 million tons of biomass per year, which it plans to procure within a 75-mi (121-km) radius of the project site (Southern 2009).
Nearly 26 similarly sized facilities would be necessary to replace STP, Units 1 and 2.
Because of uncertainties associated with obtaining sufficient wood, wood waste, agricultural waste, or other biomass to fuel a baseload power plant, the ecological impacts of large-scale timber cutting (e.g., soil erosion and loss of wildlife habitat), and the relatively small size of wood generation plants, the NRC staff does not consider biomass fuel to be a reasonable alternative to STP license renewal.
8.6.10 Biofuels Biofuels include biomass that has been refined into a liquid fuel, such as ethanol, or gasified (including crops and wood waste). The use of biofuels has increased during the past decade (TCPA 2008). However, the biofuels are primarily used in the transportation sector, and limited projects have been completed to use biofuels for energy generation.
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Environmental Impacts of Alternatives In the GEIS, the NRC staff indicated that none of the biofuel technologies progressed to the point of being competitive on a large scale or of being reliable enough to replace a baseload plant such as STP. After re-evaluating current technologies, the NRC staff finds biofuel-fired alternatives as still unable to reliably replace the STP capacity. For this reason, the NRC staff does not consider biofuels to be a reasonable alternative to STP license renewal.
8.6.11 Oil-Fired Power The EIA (2009) projects that oil-fired plants will account for very few of new generation capacity constructed in the U.S. during the 2011 to 2028 time period. Furthermore, EIA does not project that oil-fired power will account for any significant additions to capacity (EIA 2009).
The variable costs of oil-fired generation are greater than those of nuclear or coal-fired operations, and oil-fired generation has greater environmental impacts than natural gas-fired generation. In addition, EIA expects future increases in oil prices will make oil-fired generation increasingly more expensive (EIA 2009). The high cost of oil has prompted a steady decline in its use for electricity generation. Thus, the NRC staff does not consider oil-fired generation as a reasonable alternative to STP license renewal.
8.6.12 Fuel Cells Fuel cells oxidize fuels without combustion and its environmental side effects. Power is produced electrochemically by passing a hydrogen-rich fuel over an anode and passing air (or oxygen) over a cathode and then separating the two by an electrolyte. The only byproducts (depending on fuel characteristics) 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 technologically competitive with other alternatives for large-scale electricity generation. In addition, fuel cell units are likely to be small (the EIA (2009) reference plant is 10 MWe). While it may be possible to use a distributed array of fuel cells to provide an alternative to STP, it would be extremely costly to do so. Accordingly, the NRC staff does not consider fuel cells to be a reasonable alternative to STP license renewal.
8.6.13 Delayed Retirement STPNOC is not aware of any of ERCOTs electric generating plants currently proposed or planning for retirement, and additional capacity within the ERCOT region is not expected (STPNOC 2010a). Electric generating plants that may be retired by 2028 are likely to be older, less efficient, and without modern emissions controls. As a result, delayed retirement is not a reasonable alternative to license renewal.
In response to the requirements to reduce levels of sulfur dioxide in Texas as a part of the Cross-State Air Pollution Rule, ERCOT analyzed the impact of the reliability of the ERCOT grid (ERCOT 2011b). In this analysis, ERCOT noted that several facilities may need to idle during portions of the year. ERCOT did not state that any facilities would permanently close.
Statements from power generation companies, such as Luminant, also suggest that facilities may need to remain idle in order to comply with the Cross-State Air Pollution Rule (Luminant 2011). The NRC is not aware of any facilities that are currently being proposed for permanent closure as a result of the Cross-State Air Pollution Rule.
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Environmental Impacts of Alternatives 8.7 No-Action Alternative This section examines the environmental effects that would occur if NRC takes no action. No action in this case means that NRC denies renewed operating licenses for STP, and the licenses expire at the end of the current terms, in 2027 and 2028. If NRC denies the renewed operating licenses, the plants will shut down at or before the end of the current licenses. After shutdown, plant operators will initiate decommissioning in accordance with 10 CFR 50.82.
The NRC staff notes that the no-action alternative is the only alternative that is considered in-depth that does not satisfy the purpose and need for this SEIS because it neither provides power generation capacity nor does it meet the needs currently met by STP or the alternatives evaluated in Sections 8.1 through 8.5. Assuming that a need currently exists for the power generated by STP, the no-action alternative would require the appropriate energy-planning decisionmakers to rely on an alternative (or combination of them) to replace the capacity of STP or reduce the need for power.
This section addresses only those impacts that arise directly as a result of plant shutdown. The environmental impacts from decommissioning and related activities have been addressed in several other documents, including the Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, NUREG-0586, Supplement 1 (NRC 2002); Chapter 7 of the license renewal GEIS (NRC 1996); and Chapter 7 of this SEIS. These analyses either directly address or bound the environmental impacts of decommissioning whenever STPNOC ceases operating STP. In addition, the environmental impacts from potential replacement power alternatives are addressed in Sections 8.1 to 8.5.
The NRC staff notes that, even with renewed operating licenses, STP will eventually shut down, and the environmental effects addressed in this section will occur at that time. Since these effects have not otherwise been addressed in this SEIS, the impacts will be addressed in this section. As with decommissioning effects, the NRC staff expects the shutdown effects to be similar whether they occur at the end of the current licenses or at the end of renewed licenses.
8.7.1 Air Quality When the STP stops operating, there will be a reduction in emissions from activities related to plant operation, such as use of diesel generators and employee vehicles. In Chapter 4, the NRC staff determined that these emissions would have a SMALL impact on air quality during the renewal term; therefore, if emissions decrease, the impact to air quality would also decrease and would be SMALL.
8.7.2 Surface Water Resources The rate of consumptive use of surface water would decrease as STP is shut down and the reactor cooling system continues to remove the heat of decay. Wastewater discharges would also be reduced considerably. Shutdown would reduce the impacts on surface water use and quality and would remain SMALL.
8.7.3 Groundwater Resources The use of groundwater would diminish as the plant workforce is drawn down and operations requiring groundwater cease. Some consumption of groundwater would continue to support the operation of service water and fire protection systems and to meet the potable and sanitary needs of the reduced workforce prior to decommissioning. Overall impacts would be less than during operations and would remain SMALL.
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Environmental Impacts of Alternatives 8.7.4 Aquatic Ecology If STP were to cease operating, impacts to aquatic ecology would decrease, as the plant would withdraw and discharge less water than it does during operations. Therefore, fewer organisms would be subject to the impingement, entrainment, and heat shock. Shutdown would reduce the impacts to aquatic ecology and would remain SMALL.
8.7.5 Terrestrial Ecology Terrestrial ecology impacts would remain SMALL. No additional land disturbances on or off site would occur.
8.7.6 Human Health Human health risks would be smaller following plant shutdown. The plant, which is currently operating within regulatory limits, would emit less gaseous and liquid radioactive material to the environment. In addition, following shutdown, the variety of potential accidents at the plant (radiological or industrial) would be reduced to a limited set associated with shutdown events and fuel handling and storage. In Chapter 4 of this SEIS, the NRC staff concluded that the impacts of continued plant operation on human health would be SMALL. In Chapter 5, the NRC staff concluded that the impacts of accidents during operation were SMALL. Therefore, as radioactive emissions to the environment decrease, and as likelihood and variety of accidents decrease following shutdown, the NRC staff concludes that the risk to human health following plant shutdown would be SMALL.
Noise caused by plant operations would cease; therefore, impacts from noise would be SMALL.
8.7.7 Land Use STP shutdown would not affect onsite land use. Plant structures and other facilities would remain in place until decommissioning. Most transmission lines connected to STP would remain in service after the plant stops operating. Maintenance of most existing transmission lines would continue as before. Impacts on land use from plant shutdown would be SMALL.
8.7.8 Socioeconomics STP shutdown would have an impact on socioeconomic conditions in the region around STP.
Should the plant shut down, there would be immediate socioeconomic impact from loss of jobs (some, though not all, of the 1,378 employees would begin to leave), and tax payments may be reduced. As the majority of STP employees reside in Brazoria and Matagorda, socioeconomic impacts from plant shutdown would be concentrated in these counties, with a corresponding reduction in purchasing activity and tax contributions to the regional economy. Revenue losses from STP operations would directly affect Matagorda County and other local taxing districts and communities closest to, and most reliant on, the nuclear plants tax revenue. The impact of the job loss, however, may not be as noticeable given the amount of time required to decontaminate and decommission existing facilities and the proximity of STP to the Houston metropolitan area.
The socioeconomic impacts of plan shutdown (which may not entirely cease until after decommissioning) would, depending on the jurisdiction, range from SMALL to MODERATE.
8.7.9 Transportation Traffic volumes on the roads in the vicinity of STP would be reduced after plant shutdown. Most of the reduction in traffic volume would be associated with the loss of jobs at the plant.
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Environmental Impacts of Alternatives Deliveries to the plant would be reduced until decommissioning. Transportation impacts would be SMALL as a result of plant shutdown.
8.7.10 Aesthetics and Noise Plant structures and other facilities would remain in place until decommissioning. Therefore, aesthetic and noise impacts of plant closure and the termination of operations would be SMALL.
8.7.11 Historic and Archaeological Resources Impacts from the no-action alternative on historic and archaeological resources would be SMALL because no additional land disturbances would occur on or off the STP site.
8.7.12 Environmental Justice Impacts to minority and low-income populations would depend on the number of jobs and the amount of tax revenues lost by communities in the immediate vicinity of the plant after STP ceases operations. Closure of STP would reduce the overall number of jobs (there are currently 1,378 people employed at the facility) and tax revenue for social services attributed to nuclear plant operations. Minority and low-income populations in the vicinity of STP could experience some socioeconomic effects from plant shutdown, but these effects would unlikely be high and adverse. See Appendix J of NUREG-0586, Supplement 1, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities Regarding the Decommissioning of Nuclear Power Reactors (NRC 2002), for additional discussion of these impacts.
8.7.13 Waste Management If the no-action alternative were implemented, the generation of high-level waste would stop, and generation of low-level and mixed waste would decrease. Impacts from implementation of the no-action alternative are expected to be SMALL.
8.7.14 Summary of Impacts of No-Action Alternative Table 8-7 provides a summary of the environmental impacts of the no-action alternative compared to continued operation of STP.
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Environmental Impacts of Alternatives Table 8-7. Summary of Environmental Impacts of the No-Action Alternative Compared to Continued Operation of STP, Units 1 and 2 Category No-action Alternative Continued STP Operation Air quality SMALL SMALL Surface water SMALL SMALL Groundwater SMALL SMALL Aquatic resources SMALL SMALL Terrestrial resources SMALL SMALL Human health SMALL SMALL to MODERATE Land use SMALL SMALL Socioeconomics SMALL to MODERATE SMALL Transportation SMALL SMALL Aesthetics SMALL SMALL Historic & archaeological SMALL SMALL Waste management SMALL SMALL 8.8 Alternatives Summary In this chapter, the NRC staff considered the following alternatives to STP license renewal: new nuclear generation; NGCC generation; supercritical coal-fired generation; a combination alternative of natural gas, wind, and energy efficiency and conservation; and a purchased-power alternative. No action by NRC and its effects were also considered. The impacts for STP license renewal and for all alternatives to STP license renewal are summarized in Table 8-8.
In conclusion, the environmentally preferred alternative is the license renewal of STP. All other alternatives capable of meeting the needs currently served by STP entail potentially greater impacts than the proposed action of license renewal of STP. In order to make up the lost generation if license renewal is denied, the no-action alternative necessitates the implementation of one or a combination of alternatives, all of which have greater impacts than the proposed action. Hence, the NRC staff concludes that the no-action alternative will have environmental impacts greater than or equal to the proposed license renewal action.
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Table 8-8. Summary of Environmental Impacts of Proposed Action and Alternatives Impact Area Aquatic and Terrestrial Socioeconomics Archaeological &
(including Groundwater and Transportation &
Air Quality Surface water Resources Human Health Land Use Aesthetics)
Historic Resources Waste Management Alternative SMALL to License renewal SMALL SMALL SMALL SMALL SMALL SMALL SMALL MODERATE New nuclear at STP SMALL to SMALL SMALL SMALL SMALL SMALL SMALL SMALL site LARGE 8-67 NGCC at the STP SMALL to SMALL to SMALL to SMALL SMALL SMALL SMALL SMALL site MODERATE MODERATE MODERATE Supercritical coal at SMALL to SMALL to MODERATE SMALL SMALL MODERATE SMALL MODERATE STP site MODERATE LARGE Combination of SMALL to SMALL to SMALL to SMALL to SMALL to SMALL SMALL SMALL alternatives MODERATE MODERATE MODERATE LARGE MODERATE SMALL to SMALL to SMALL to SMALL to SMALL to SMALL to Purchased power SMALL SMALL MODERATE MODERATE MODERATE LARGE MODERATE MODERATE SMALL to No-action alternative SMALL SMALL SMALL SMALL SMALL SMALL SMALL MODERATE Environmental Impacts of Alternatives
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[TCEQ] Texas Commission on Environmental Quality. 2011. Status of Air Permits and Permit Applications. Available at
<http://www.tceq.texas.gov/permitting/air/nav/air_status_permits.html> (accessed 26 October 2011).
[TCPA]. Texas Comptroller of Public Accounts. 2008. The Energy Report 2008. Austin, TX.
Available at <http://www.window.state.tx.us/specialrpt/energy/> (accessed 17 October 2011).
[THC]. Texas Historical Commission. 2007. Response from WA Martin for FL Oaks, THC, to SL Dannhardt, STPNOC. Stamped Reply: No Historic Properties Affected Project May Proceed. January 19, 2007. ADAMS No. ML092100145.
[TSECO]. Texas State Energy Conservation Office. 2008. Wind Energy Transmission.
Austin, TX. ADAMS No. ML100700550.
[TWDB] Texas Water Development Board. 2007. State Water PlanWater for Texas 2007.
Austin, TX: TWDB. Document No. GP-8-1.
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Available at <http://www.vera.com/re_b_psdoc_07.htm.> (accessed 17 October 2011).
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9.0 CONCLUSION
This supplemental environmental impact statement (SEIS) contains the environmental review of STP Nuclear Operating Companys (STPNOCs) application for renewed operating licenses for South Texas Project, Units 1 and 2 (STP) as required by Title 10 of the U.S. Code of Federal Regulations (CFR) Part 51 (10 CFR Part 51), the U.S. Nuclear Regulatory Commissions (NRCs) regulations that implement the National Environmental Policy Act (NEPA). This chapter presents conclusions and recommendations from the site-specific environmental review of STP and summarizes site-specific environmental issues of license renewal that the NRC staff (staff) identified during the review. Section 9.1 summarizes the environmental impacts of license renewal; Section 9.2 presents a comparison of the environmental impacts of license renewal and energy alternatives; Section 9.3 discusses unavoidable impacts of license renewal, energy alternatives, and resource commitments; and Section 9.4 presents conclusions and staff recommendations.
9.1 Environmental Impacts of License Renewal Based on the staffs review of site-specific environmental impacts of license renewal presented in this SEIS, the staff concludes that issuing renewed licenses would have mostly SMALL impacts. The site-specific review included applicable Category 2 issues and uncategorized issues. The staff considered mitigation measures for each Category 2 issue, as applicable.
The staff concluded that no additional mitigation measure is warranted.
Additionally, the staff independently reviewed STPNOCs SAMA. The staff agrees with STPNOCs conclusion that none of the candidate SAMAs are potentially cost-beneficial.
The staff also considered cumulative impacts of past, present, and reasonably foreseeable future actions, regardless of what agency (Federal or non-Federal) or person undertakes them.
The staff concluded in Section 4.12 that cumulative impacts would be SMALL to MODERATE depending on the resource area. However, except for the electromagnetic fields-acute effects, the incremental contribution from STP during the period of extended operation would be SMALL.
9.2 Comparison of Alternatives In the conclusion to Chapter 8, the staff considered the following alternatives to STP license renewal:
- new nuclear generation,
- natural gas-fired combined-cycle generation (NGCC),
- supercritical coal-fired generation,
- combination alternative (the combination includes 640 MWe supplied by one NGCC unit; 1,620 MWe supplied by wind energy projects; and 300 MWe of energy conservation and efficiency, also known as demand-side management), and
- purchased power.
In addition, the staff also considered many other alternatives that were subsequently dismissed for reasons of technical, resource availability, or commercial limitations.
9-1
Conclusion As summarized in Table 8-7, the staff concluded that the alternatives of supercritical coal at STP, purchased power, or combination alternative would have environmental impacts ranging from SMALL to LARGE. The alternatives of new nuclear at STP, NGCC at STP, and the no-action alternative would have impacts ranging from SMALL to MODERATE. In comparison to other alternatives, the STP license renewal alternative would have mostly SMALL impacts in all areas of the environmental analysis. Based on the staffs independent review, the staff concluded that the STP license renewal is the environmentally preferred alternative.
9.3 Resource Commitments 9.3.1 Unavoidable Adverse Environmental Impacts Unavoidable adverse environmental impacts are impacts that would occur after implementation of all workable mitigation measures. Carrying out any of the energy alternatives considered in this SEIS, including the proposed action, would result in some unavoidable adverse environmental impacts.
Minor unavoidable adverse impacts on air quality would occur due to emission and release of various chemical and radiological constituents from power plant operations. Nonradiological emissions resulting from power plant operations are expected to comply with U.S.
Environmental Protection Agency (EPA) emissions standards, though the alternative of operating a fossil-fueled power plant in some areas may worsen existing attainment issues.
Chemical and radiological emissions would not exceed the national emission standards for hazardous air pollutants.
During nuclear power plant operations, workers and members of the public would face unavoidable exposure to radiation and hazardous and toxic chemicals. Workers would be exposed to radiation and chemicals associated with routine plant operations and the handling of nuclear fuel and waste material. Workers would have higher levels of exposure than members of the public, but doses would be administratively controlled and would not exceed standards or administrative control limits. In comparison, the alternatives involving the construction and operation of a non-nuclear power generating facility would also result in unavoidable exposure to hazardous and toxic chemicals to workers and the public.
The generation of spent nuclear fuel and waste material, including low-level radioactive waste, hazardous waste, and nonhazardous waste would be unavoidable. Hazardous and nonhazardous wastes would be generated at non-nuclear power generating facilities. Wastes generated during plant operations would be collected, stored, and shipped for suitable treatment, recycling, or disposal in accordance with applicable Federal and state regulations.
Due to the costs of handling these materials, power plant operators would be expected to carry out all activities and optimize all operations in a way that generates the smallest amount of waste possible.
9.3.2 Short-Term Versus Long-Term Productivity The operation of power generating facilities would result in short-term uses of the environment, as described in Chapters 4, 5, 6, 7, and 8. Short-term is the period of time that continued power generating activities take place.
Power plant operations require short-term use of the environment and commitment of resources and commit certain resources (e.g., land and energy), indefinitely or permanently. Certain short-term resource commitments are substantially greater under most energy alternatives, including license renewal, than under the no-action alternative because of the continued 9-2
Conclusion generation of electrical power and the continued use of generating sites and associated infrastructure. During operations, all energy alternatives entail similar relationships between local short-term uses of the environment and the maintenance and enhancement of long-term productivity.
Air emissions from power plant operations introduce small amounts of radiological and nonradiological constituents to the region around the plant site. Over time, these emissions would result in increased concentrations and exposure, but they are not expected to impact air quality or radiation exposure to the extent that public health and long-term productivity of the environment would be impaired.
Continued employment, expenditures, and tax revenues generated during power plant operations directly benefit local, regional, and state economies over the short term. Local governments investing project-generated tax revenues into infrastructure and other required services could enhance economic productivity over the long term.
The management and disposal of spent nuclear fuel, low-level radioactive waste, hazardous waste, and nonhazardous waste requires an increase in energy and consumes space at treatment, storage, or disposal facilities. Regardless of the location, the use of land to meet waste disposal needs would reduce the long-term productivity of the land.
Power plant facilities are committed to electricity production over the short term. After decommissioning these facilities and restoring the area, the land could be available for other future productive uses.
9.3.3 Irreversible and Irretrievable Commitments of Resources This section describes the irreversible and irretrievable commitment of resources that have been noted in this SEIS. Resources are irreversible when primary or secondary impacts limit the future options for a resource. An irretrievable commitment refers to the use or consumption of resources that are neither renewable nor recoverable for future use. Irreversible and irretrievable commitment of resources for electrical power generation include the commitment of land, water, energy, raw materials, and other natural and man-made resources required for power plant operations. In general, the commitment of capital, energy, labor, and material resources are also irreversible.
The implementation of any of the energy alternatives considered in this SEIS would entail the irreversible and irretrievable commitment of energy, water, chemicals, andin some cases fossil fuels. These resources would be committed during the license renewal term and over the entire life cycle of the power plant, and they would be unrecoverable.
Energy expended would be in the form of fuel for equipment, vehicles, and power plant operations and electricity for equipment and facility operations. Electricity and fuel would be purchased from offsite commercial sources. Water would be obtained from existing water supply systems. These resources are readily available, and the amounts required are not expected to deplete available supplies or exceed available system capacities.
9.4 Recommendations The NRC staffs recommendation is that the adverse environmental impacts of license renewal for STP are not great enough to deny the option of license renewal for energy-planning decisionmakers. The NRC staff based this recommendation on the following:
9-3
Conclusion
- the analysis and findings in NUREG-1437, Volumes 1 and 2, Generic Environmental Impact Statement for License Renewal of Nuclear Plants,
- the Environmental Report (ER) submitted by STPNOC,
- consultation with Federal, state, and local agencies,
- the NRCs environmental review, and
- consideration of public comments received during the scoping process and the draft SEIS comment period.
9-4
10.0 LIST OF PREPARERS This supplemental environmental impact statement (SEIS) was prepared by members of the Office of Nuclear Reactor Regulation (NRR) with assistance from other U.S. Nuclear Regulatory Commission (NRC) organizations and contract support from Pacific Northwest National Laboratory (PNNL). Table 10-1 lists the NRC staff who contributed to the development of the SEIS. PNNL provides contract support for cultural resource, hydrology, and severe accident mitigation alternative (SAMA) reviews.
Table 10-1. List of Preparers Name Affiliation Function or Expertise NRC D. Wrona NRR Management oversight B. Pham NRR Management oversight M. Wong NRR Management oversight A. Imboden NRR Management oversight T. Tran NRR Project management A. BeBault NRR Socioeconomic, environmental justice, land use S. Klementowicz NRR Human health K. Folk NRR Hydrology and alternatives M. Moser NRR Aquatic and marine ecology and alternatives B. Grange NRR Terrestrial ecology and protected species and habitats A. Travers NRR Cultural resource J. Rikhoff NRR Socioeconomic, environmental justice, and land use E. Larson NRR Cultural resource and socioeconomic W. Rautzen NRR Air quality and meteorology (climatology)
J. Dozier NRR SAMA National Laboratory Personnel (a)
S. Short PNNL SAMA R. Schmitt PNNL SAMA C. Kincaid PNNL Hydrology R. Prasad PNNL Hydrology T. ONeil PNNL Cultural resource 10-1
List of Preparers Name Affiliation Function or Expertise (a)
PNNL is operated by Battelle for the U.S. Department of Energy.
10-2
11.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES OF THIS SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT ARE SENT Name Affiliation D. Klima Advisory Council on Historic Preservation O. Sylestine Tribal NationAlabama-Coushatta Tribe B. Horse Tribal NationKiowa Tribe of Oklahoma R. Toahty Tribal NationComanche Nation M. Orms U.S. Fish & Wildlife Service D. Bernhart National Marine Fisheries Service K. Boydston Texas Parks & Wildlife Department M. Wolfe State Historic Preservation Officer A. Street Tribal NationTonkawa Tribe of Oklahoma M. Blount Tribal NationApalachicola Band of Creek Indians B. Barcena Jr. Tribal NationLipan Apache Tribe of Texas D. Romero Jr. Tribal NationLipan Apache Band of Texas J. Mendoza Tribal NationPamaque Clan of Coahuila Y Tejas R. Hernandez Tribal NationTap PilamCoahuiltecan Nation J. Garza Jr. Tribal NationKickapoo Traditional Council J. Loera Tribal NationYsleta del Sur Pueblo N. Hudgins Coastal Plains Groundwater Conservation District L. Gaul Texas Department of State Health Services EIS Scoping Participant* Affiliation & Address (or E-mail Address)
N. McDonald Matagorda County Judge 1700 7th Street, Room 301, Bay City, TX 77414 J. Gibean Matagorda County Resident 25000 Hwy 35 South, Palacios, TX 77465 S. Dancer S.T.A.R.E PO Box 209, Blessing, TX 77419 R. Malachowski McDonalds PO Box 1110, Bay City, TX 77404 M. Butter Matagorda County Economic Development Corporation 2200 7th Street, Suite 302, Bay City, TX 77414 11-1
List of Agencies, Organizations, and Persons to Whom Copies of This Supplemental Environmental Impact Statement Are Sent L. Bracken Realtor 2055 Ave F, Bay City, TX 77414 B. Watts Matagorda County EMC 2200 7th St, Bay City, TX 77414 M. B. Johnston Palacios City PO Box 782, Palacios, TX 77465 A. Acosta Matagorda Advocate Victoria Matagorda Advocate Newspaper C. Dunohue WCJC Nuke Program 2919 Ave J, Bay City, TX 77414 M. Crews Matagorda County Resident 2200 Golden Ave, Bay City, TX 77414 C. Corporon South Texas Project Nuclear Operating Company 2608 Wofford Rd, Bay City, TX 77414 K. Hadden SEED Coalition 1303 San Antonio Suite 100, Austin, TX 78701 D. Kile U.S. Congressman Ron Paul 122 W Way Suite 301, Lake Jackson, TX 77566 A. Moore Bay City Public Library 1100 7th Street, Bay City, TX 77414 O. Bludau Matagorda County Economic Development Corporation obludau@co.matagorda.tx.us T. Farrar Farrar Financial Group tfarrar4@gmail.com C. Thames Bay City Resident thamesforbaycity@yahoo.com EIS Filing Section U.S. Environmental Protection Agency 1200 Pennsylvania Ave NW, Washington, D.C. 20004
- requested to be on the mailing list 11-2
12.0 INDEX accidents, xiv, 4-46, 4-52, 5-1-5-3, 8-64, design-basis accident, 4-52, 5-1, B-8 B-8, F-16, F-28 discharges, 2-5, 2-8, 2-9, 2-17, 2-19, 2-20, Advisory Council on Historic 2-47, 2-48, 4-8, 4-9, 4-11, 4-20, 4-24-4-26, Preservation (ACHP), 1-6, 4-45, E-1 4-37-4-39, 4-56, 4-66, 8-8, 8-15, 8-19, 8-20, 8-26, 8-31, 8-32, 8-43, 8-44, 8-63, B-2, B-3, aesthetic, 4-47, 8-11, 8-12, 8-23, 8-36, C-3 8-49, 8-53, 8-65 dose, 2-2, 2-3, 4-37, 4-38, 4-71, 4-72, 4-76, alternatives, 1-5, 4-54, 4-68, 5-2, 5-3, 6 5-7, 5-8, 5-10, 6-2, B-6, B-8, F-1, F-6, F-7, 6-5, 8-1-8-3, 8-10, 8-12, 8-21, 8-30, 8-31, F-16-F-19, F-21, F-23, F-26-F-28 8-34, 8-39, 8-46, 8-53, 8-55, 8-56, 8-62, 8-63, 8-66, 8-67, 9-1-9-3, 10-1, B-8, F-1, education, 3-2, 4-41, B-7 F-2, F-22, F-23, F-32 electromagnetic fields, 1-3, 4-27, 4-27, 4-archaeological resources, 1-6, 2-76, 2-77, 41, 4-52, 4-72, 9-1, B-5, B-7 3-2, 4-42, 4-74, 4-76, 8-12, 8-13, 8-23, 8-24, Endangered Species Act (ESA), xiv, 2-47, 8-36, 8-37, 8-49, 8-50, 8-54, 8-65, B-8, D-1 2-48, 2-50, 2-51, 2-53, 2-55, 2-56, 2-58, 4-biota, 4-11, 4-15, 4-56, 4-66 8-8, B-2 28-4-32, 4-81 boiling water reactor (BWR), F-21 entrainment, 2-61, 4-12-4-17, 4-12-4-17, 4-20-4-22, 4-24, 4-26, 4-27, 4-33, 4-66, 8-8, burnup, 2-1, B-10 8-9, 8-20, 8-32, 8-44, 8-64, B-2, B-3 chronic effects, 1-3, 4-34, 4-41, B-7 essential fish habitat, 2-59, 2-61, 2-84, 4-Clean Air Act (CAA), 8-16, 8-17, 8-26, 21, 4-33, 4-66, 4-81, 4-83, E-9 8-28-8-30, 8-40, 8-41 Generic Environmental Impact Statement closed-cycle cooling, 4-20, 4-26, B-4, B-5 (GEIS), xvii, xviii, 1-3-1-7, 2-6, 2-67, 3-1, Coastal Zone Management Act (CZMA), 3-2, 4-1, 4-2, 4-5, 4-6, 4-8, 4-11, 4-12, 4-27, 1-7, 2-79 4-28, 4-34, 4-35, 4-39, 4-41-4-44, 4-54, 4-55, 4-58, 4-72, 5-1, 5-2, 6-1-6-3, 7-1, 7-2, cooling system, xviii, 1-4, 1-5, 2-17, 4 8-1, 8-2, 8-10, 8-14, 8-15, 8-21, 8-22, 8-25, 4-13, 4-20, 4-21, 4-24, 4-26, 4-54, 4-56, 4- 8-27, 8-34, 8-35, 8-41, 8-45-8-48, 8-56, 57, 8-3, 8-4, 8-8, 8-20, 8-32, 8-44, 8-63, 8-59, 8-60, 8-62, 8-63, B-8, E-7, E-8 B-3, B-4, F-7 greenhouse gases, 8-6, 8-15, 8-17, 8-30, core damage frequency, 5-4-5-11, F 8-41, 8-42 F-9, F-11, F-13-F-16, F-20-F-23, F F-30, F-33 groundwater, 1-5, 2-9, 2-10, 2-12, 2-16, 2-19-2-23, 2-36, 2-37, 2-65, 3-1, 4-5-4-11, 4-Council on Environmental Quality (CEQ), 35-4-37, 4-53-4-56, 4-61, 4-63-4-65, 4-67, 1-3, 4-13, 4-47, 4-78 4-75, 5-2, 8-3, 8-7, 8-8, 8-19, 8-31, 8-32, critical habitat, 2-43, 2-49, 2-52, 2-79, 4- 8-44, 8-53, 8-55, 8-63, B-4, B-5, B-8, C-1 29, 4-31, 8-9, C-5 hazardous waste, 2-4, 2-5, 9-2, 9-3, C-3, cultural resources, 2-76, 2-77, 2-85, 4-45, C-4 4-46, 4-74, 4-82, 8-12, 8-13, 8-23, 8-24, heat shock, 4-24, 4-66, 8-9, 8-20, 8-32, 8-36, 8-37, 8-49, 8-50, 8-53, C-1 8-64, B-3 Decommissioning, xiv, 7-1, 7-2, 8-63, high-level waste, xviii, 1-4, 6-1, 6-2, 8-14, 8-65, 8-70, B-10 8-65, B-8-B-10 12-1
Index impingement, 2-61, 4-12, 4-13, 4-15, 4-16, solid waste, 2-1-2-4, 6-1, 7-2, 8-2, 8-27, 4-18, 4-20, 4-21, 4-24, 4-26, 4-27, 4-33, 4- 8-31, 8-60 B-10, C-1 66, 8-8, 8-9, 8-20, 8-32, 8-44, 8-64, B-2-B-4 spent fuel, xviii, 1-4, 2-2, 4-71, 6-1, 6-2, low-level waste, 2-4, 6-1, 8-14, B-9 B-8-B-10 maximum occupational doses, 4-35, B-7 State Historic Preservation Officer (SHPO), 1-6, 2-85, 4-45, 4-46, 4-81, 8-12, mitigation, xviii, 1-3-1-5, 4-2, 4-27, 4-35, 4-8-13, 8-23, 8-24, 8-36, 8-37, 8-49, 8-50, E-2 40, 4-57, 4-72, 5-2, 7-1, 7-2, 8-12, 8-24, 8-37, 8-50, 9-1, 9-2, 10-1, E-5, F-1, F-14 State Pollutant Discharge Elimination System, C-1 mixed waste, 8-14, 8-65, B-9 surface water, 2-10, 2-18, 2-21, 2-22, 3-1, National Environmental Policy Act 4-2, 4-3, 4-5, 4-8, 4-9, 4-36, 4-52, 4-53, 4-(NEPA) , xvii, xviii, 1-1, 1-5, 1-7, 1-8, 2-75, 55, 4-61-4-63, 4-67, 4-69, 4-75, 8-3, 8-6, 2-77, 2-85, 3-3, 4-13, 4-45-4-47, 4-65, 4-79, 8-7, 8-18-8-20, 8-31-8-33, 8-43, 8-44, 8-53, 4-81, 4-82, 5-1, 6-2, 6-3, 6-10, 7-2, 8-1, 8-63, B-1, B-4, C-1 8-70, 9-1, B-1, B-9, E-7 transmission lines, 2-6, 2-8, 2-43, 2-48, 2-National Marine Fisheries Service 63, 4-2, 4-11, 4-29, 4-34, 4-39-4-42, 4-45, (NMFS), 1-6, 2-47, 2-79, 2-84, 2-85, 4-28, 4-55, 4-57, 4-67, 4-70, 4-72, 4-74, 8-39, 4-80, 4-81, 11-1, D-1-D-4 8-43, 8-45, 8-46, 8-53, 8-56, 8-58, 8-60, National Pollutant Discharge Elimination 8-64, B-6, B-8 System (NPDES), 4-21, 8-7, 8-19, 8-32, tritium, 2-22-2-24, 4-9-4-11, 4-35-4-37, 4-B-2, C-1, C-3 63 no-action alternative, 4-13, 4-65, 8-2, U.S. Department of Energy (DOE), 4-37, 8-63, 8-65, 8-66, 9-2 4-41, 8-2, 8-3, 8-18, 8-27, 8-39, 8-42, 8-57, nonattainment, 4-60 8-60, 8-61, 8-68, 8-69 once-through cooling, 4-20, 4-26, B-2, B-3 U.S. Environmental Protection Agency radon, 4-36, B-8, B-9 (EPA), 2-1, 2-4-2-6, 2-14, 2-22-2-24, 2-37, 2-38, 2-65, 2-67, 2-81, 2-88, 2-89, 4-9-4-13, reactor, xvii, xviii, 1-5, 2-1, 2-2, 2-4, 2-6, 2- 4-20, 4-21, 4-24, 4-25, 4-37, 4-38, 4-59, 4-13, 2-16, 2-23, 2-47, 3-1, 3-2, 4-38, 4-43, 4- 63, 4-65, 4-71, 4-72, 4-76, 4-78, 4-79, 8-2, 57, 4-59, 4-71-4-73, 4-76, 5-1-5-3, 5-10, 8-5, 8-16-8-18, 8-26, 8-28-8-30, 8-34, 6-2, 6-4, 7-1, 8-4, 8-7, 8-11, 8-12, 8-23, 8-40-8-42, 8-68, 8-69, 9-2, C-1-C-5 8-36, 8-63, B-4, B-8, F-16, F-18, F-29 uranium, 2-1, 2-2, 4-71, 4-72, 6-1, 6-2, 6 refurbishment, 2-14, 2-48, 2-75, 3-1, 3-2, 6-8, 8-10, 8-21, 8-34, 8-47, B-8-B-10 4-34, 4-35, 4-38, 4-42, 4-46, 4-55-4-57, 4-60, B-1, B-2, B-4-B-8, C-3, F-28 wastewater, 2-5, 2-9, 2-78, 2-88, 4-2, 4-69, 8-60, B-2, C-3 salinity gradients, 4-2, B-1 Yucca Mountain project, B-10 scoping, xvii, 1-2, 1-5, 1-6, 4-1, 4-2, 4-5, 4-12, 4-13, 4-27, 4-35, 4-42, 4-46, 4-55-4-58, 5-2, 6-2, 7-2, 9-4, E-1-E-4, E-7 Severe Accident Mitigation Alternatives (SAMA), xiv, 5-3, 5-4, 5-8-5-11, 5-13, 9-1, 10-1, F-1-F-3, F-7, F-8, F-11, F-12, F F-34, F-37 severe accidents, xiv, 4-52, 5-1-5-3, B-8, F-13, F-27-F-29 12-2
APPENDIX A COMMENTS RECEIVED ON THE STP ENVIRONMENTAL REVIEW
COMMENTS RECEIVED ON THE STP ENVIRONMENTAL REVIEW A.1 Comments Received During the Scoping Period The scoping process began on January 31, 2011, with the publication of the U.S. Nuclear Regulatory Commissions (NRCs) Notice of Intent to conduct scoping in the Federal Register (76 FR 5410). The scoping process included two public meetings held at the Bay City Civic Center in Bay City, Texas, on March 2, 2011. Approximately 60 members of the public attended the meetings. After the NRCs prepared statements pertaining to the license renewal process, the meetings were open for public comments. Attendees provided oral statements that were recorded and transcribed by a certified court reporter. Any written statements submitted at the public meeting are documented in the transcript of the meetings. Transcripts of the two meetings are an attachment to the Scoping Meeting Summary, dated May 19, 2011 (Agencywide Documents Access and Management System (ADAMS) No. ML110770661). In addition to the comments received during the public meetings, comments were also received electronically and through the mail.
Each commenter was given a unique identifier, so every comment could be traced back to its author. Table A-1 identifies the individuals who provided comments applicable to the environmental review and the Commenter ID associated with each persons set of comments.
The individuals are listed in the order in which they spoke at the public meeting and in numerical order for the comments received by letters or e-mails.
Specific comments were categorized and consolidated by topic. Comments with similar specific objectives were combined to capture the common essential issues raised by participants.
Comments fall into one of the following general groups:
- Specific comments that address environmental issues within the purview of the NRC environmental regulations related to license renewal. These comments address Category 1 (generic) or Category 2 (site-specific) issues identified in NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS) or issues not addressed in the GEIS. The comments also address alternatives to license renewal and related Federal actions.
- General comments in support of or opposed to nuclear power or license renewal or comments regarding the renewal process, the NRCs regulations, and the regulatory process.
- Comments that address issues that do not fall within or are specifically excluded from the purview of NRC environmental regulations related to license renewal. These comments typically address issues such as the need for power, emergency preparedness, security, current operational safety issues, and safety issues related to operation during the renewal period.
Table A-1. Individuals Providing Comments During the Scoping Comment Period Commenter Commenter ID Affiliation (if stated) ADAMS No.
Randy Weber STP 1 State Representative ML110840441 Matagorda County judge and local Judge Nate McDonald STP 2 ML110840441 emergency response official A-1
Appendix A Commenter Commenter ID Affiliation (if stated) ADAMS No.
Mark Bricker STP 3 Bay City Mayor ML110840441 Ron Pauls office STP 4 U.S. congressman ML110840441 Ed Halpin STP 5 STP CEO ML110840441 Carolyn Thames STP 6 Bay city council member ML110840441 Don Booth STP 7 Director local 211 Pipefitter union of 3,000 ML110840441 Bay City Community Development Cheryl Stewart STP 8 Corporation board member and Bay City ML110840441 Historic Commission David Dunham STP 9 Matagorda County resident ML110840441 Director of Matagorda County Economic Owen Bludau STP 10 ML110840441 Development Corporation Congressional candidate for 22nd Kesha Rogers STP 11 ML110840441 Congressional District James Lovett STP 12 ML110840441 Bay City Community Development D. C. Dunham STP 13 ML110840441 Corporation Willie Rollins STP 14 Matagorda County resident ML110840441 Ian Overton STP 15 LaRouche PAC organizer ML110840441 John Corder STP 16 Brazoria County resident ML110840433 Judge Nate McDonald STP 17 Matagorda County judge ML110840433 Chamber of Commerce, emergency Mitch Thames STP 18 ML110840433 response public information officer Tim Powell STP 19 STP Vice President ML110840433 Ken Head STP 20 ML110840433 Mike Bolin STP 21 ML110840433 John Corder STP 22 Brazoria County resident ML110840433 Bay City Babe Ruth (local sport Casey Kile STP 23 ML110840433 organization)
Robert Singleton STP 24 Austin resident ML110840433 Karen Hadden STP 25 Executive director of SEED Coalition ML110840433 Bobby Head STP 26 Matagorda County resident ML110840433 Tom Kovar STP 27 Bay City resident ML110840433 Vicki Adams STP 28 Superintendent Palacios ISD ML110730188 Eva Esparza STP 29 Austin resident ML110960078 Darby Riley STP 30 San Antonio resident ML110960079 Kamala Platt STP 31 ML110960080 Marion Mlotok STP 32 Austin resident ML110960081 Karen Seal STP 33 Lacoste resident ML110960082 A-2
Appendix A Commenter Commenter ID Affiliation (if stated) ADAMS No.
Kassandra Levay STP 34 San Antonio resident ML110960083 Unknown STP 35 ML110960084 T. Burns STP 36 Midland resident ML110960086 Jolly Clark STP 37 ML110960087 Dale Bulla STP 38 ML110960088 William Stout STP 39 ML110960089 C. J. Keudell STP 40 Austin resident ML110960090 Tarek Tonsson STP 41 ML110960091 Carol Geiger STP 42 ML110960092 Veryan and Greg Thompson STP 43 ML110960093 Robert Singleton STP 44 ML110960094 Karen Hadden STP 45 SEED Coalition ML110960095 Alan Apurim STP 46 ML110960096 Brandi Clark Burton STP 47 Austin resident ML110960097 Carol Geiger STP 48 Austin resident ML110960098 Eric Lane STP 49 San Antonio resident ML110960099 Jenna Findley STP 50 ML111010476 Margaret Reed STP 51 Austin resident ML111010477 Scott and Cyndy Reynolds STP 52 ML111010478 Jennifer Meador STP 53 Austin resident ML111010604 Joy Malacara STP 54 Austin resident ML111010479 Melanie and David Winters STP 55 ML111010506 J. R. Rhode STP 56 ML111010507 Christine Fry STP 57 ML111010508 Leona Slodge STP 58 Austin resident ML111010509 Carolyn Campbell STP 59 Austin resident ML111010510 Bryan Dunlap and Todd STP 60 ML111010517 Rinehart Peggy Cravens STP 61 Austin resident ML111010518 Shannon Jurak STP 62 Austin resident ML111010519 Thomas Nelms STP 63 ML111010520 T. Nelms STP 64 ML111010521 Peggy Pryor STP 65 Andrews resident ML110960077 Edmund Kelley STP 66 Austin resident ML11105A023 Maria Hogan STP 67 ML11105A020 A-3
Appendix A Commenter Commenter ID Affiliation (if stated) ADAMS No.
STP 1 (letter, also captured in Randy Weber Texas State Representative ML11108A059 public meeting transcript)
Beth Larsen STP 68 Austin resident ML11119A007 Dzan Nguyen STP 69 Austin resident ML11119A008 John Trimble STP 70 Austin resident ML11119A010 Aguilar family STP 71 ML11119A011 Juan Aguilar STP 72 ML11119A012 Douglas McArthur STP 73 Austin resident ML11119A013 Shawn Tracy STP 74 ML11119A014 Kelly Simon STP 75 Austin resident ML11119A015 N/A STP 76 ML11119A016 Judy Moore STP 77 ML11119A017 Cynthia Gebhardt STP 78 ML11119A018 Rory Holcomb STP 79 Austin resident ML11119A019 N/A STP 80 ML11119A020 Comments received during the scoping comment period applicable to this environmental review are presented in this section along with the NRC response. The comments that are general or outside the scope of the environmental review for South Texas Project (STP) license renewal are not included here but can be found in the Scoping Summary Report (ADAMS No. ML11153A082). To maintain consistency with the Scoping Summary Report, the unique identifier used in that report for each set of comments is retained in this Appendix A.
Applicable scoping comments are grouped in the following categories and presented in the following order:
- alternatives to license renewal of STP,
- socioeconomic impact of STP,
- water usage,
- human health,
- postulated accidents,
- terrestrial or aquatic ecology, and
- uranium fuel cycle and waste management.
A.1.1 Alternatives to License Renewal of STP, Units 1 and 2 The original sources for the comments in this category (alternatives to license renewal) can be found at the back of the Scoping Summary Report and are labeled with the following identifiers:
12-2, 15-1, 24-3, 25-5, 26-2, 27-2, 27-4, 29-2, 30-1, 31-2, 32-3, 35-2, 36-6, 38-2, 39-3, 40-2, 43-3, 45-3, 46-3, 47-4, 49-2, 51-2, 52-2, 53-2, 54-3, 55-2, 57-2, 59-2, 60-3, 61 2, 62-2, 69-2, 73-2, 74-1, 77-2, 79-2, and 80-2. These comments are extracted from the original sources.
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Appendix A Comment 12-2: Several nations have nuclear energy policies. These policies are all variations on one theme: one, oil is not a dependable source of energy, it can be interrupted at any time and it is not feasible to store more than a few months worth of reserve supply; two, nuclear energy is the only source of energy, other than wind and solarwhich I hope come along in the future but at the present have to be considered in the development stagenuclear energy is the only source of energy that can produce large quantities of energy without dumping large quantities of carbon dioxide into the atmosphere.
Yes, the natural gas plant is better than the coal plant, and Im not particularly in favor of a coal plant in Matagorda County, but natural gas is contributing to global warming, and we cannot afford to build any more of it than we have to.
Im a strong supporter of nuclear energy; Im a strong supporter of renewing these. In due course, I will be a strong supporter of Units 3 and 4. Thank you.
Comment 15-1: And, I think that its probably best, when talking about the environmental benefits of nuclear power, to compare it with the environmental problems that other forms of power offer. So for example, the amount of energy in one pellet of uranium, about the size of my fingernail here, is equivalent in energy to about 30 barrels of oil or 6.15 tons of coal, or 23 1/2 tons of dry wood.
When you start going into other examples of energy, such as wind or solar, the amount of return gets even worse because the amount of radiant heat coming down from the sun is only about 200 watts per square meter, and the amount of land area and the cost of building and maintaining solar panels or windmills is far, far greater than the actual benefit you get from them, not to mention that windmills kill birds by the dozen and solar panels, with their polarized lights, kill insects by the countless numbers.
Comment 24-3: Nuclear power was also always intended to be a bridge technology. Were always going to find something better, and what we could do right now instead of re-license these is make an investment in renewables which could have, in terms of jobs, just as much of an impact as extending the life of this plant or building new units.
The other thing about switching forms of energy is that you can create jobs locally that are going to be exclusively locally. Nuclear power, a lot of the jobs that are generated are going to be foreign manufacturing jobs. The components for these plants are built off site; they dont really generate that much for your local economy.
There are new and exciting technologies that we could be counting on. For example, theres an Australian company called EnviroMission thats just about to open a project in Arizona. What it is; its a tower, just a tower, covered around the base with thick plastic. What it does is it captures the heat of the sun; the heated air rises up a chimney and turns a turbine. Its basically the only moving part, so the turbine and then the generators from it.
The cool thing about it is that it continues to generate electricity even at night because the hea[t]
of the ground continues to make this temperature differential, and the air continues up the chimney, and the turbines continue to turn.
This is the kind of thing that can be built and provide localized power. In West Texas, for example, we could build these things and not have to ship the power across the State. We could actually use it to provide energy where its built.
Comment 25-5: A big issue is need for power. Right now in the legal case involving Units 3 and 4, the Atomic Safety and Licensing Board has agreed to hear a contention that is one of omission. There was a failure to analyze what alternatives were there in terms of looking at energy efficiency. Building codes in particular are going to be saving; theyve been adopted, A-5
Appendix A going to be saving some 2,200 megawatts of power in Texas. We need to look at whether the power is needed and then we need to look at how else it could be generated.
And, certainly[,] jobs are crucially important in every community. We realize that thats important here. I think its time to look at what are the options in terms of transition, what other kinds of ways to generate electricity could occur here; I think there are many and to start looking at training and what other options exist.
Comment 26-2: Randy Weber was here last week. Hes our State representative. He got over in the next room and he said that Texas is growing by 113,000 people a month. Wow. Were outgrowing all the states combined. Were getting more people into Texas. He says if we keep growing the way we are, that by 2015 were going to have to have five new nuclear plants, or 16 coal plants, or 28 gas plants, or 3,000 windmills if the windmills agree to turn 24-7-365. You know thats not going to happen.
Would I like to see all of our power generated totally clean[?] Yes, I would. Its not realistic, not with what we have as todays knowledge.
Comment 27-2: You have to have electricity and you have to have a lot of it. I wish I could afford Austins 16 percent. But, you have to have a lot of electricity nowadays because of the way the population is, and if you look at the last 40-50 years of power generation, of gas-fired plants or coal-fired plants and how hazardous they are to the environment and people, then I think you [cannot] help but realize how safe nuclear power is. The Government has been using it to power their vehicles in the military for a long time.
Comment 29-2: There are safer alternative technologies that can replace the energy generated by these reactors.
Comment 30-1: Well before 2027, we should have outgrown the need for nuclear power with clean alternative energy and conservation [and] efficiency Comment 31-2: I urge the denial of the relicensing of the STP. As a San Antonio resident, I value my community and know that we are committed to renewables and conservation, much better paths to the future on a sustainable planet.
Comment 32-3: We should be investing in solar and wind and dismantling our aging reactors.
Comment 35-2: There are cheaper and renewable ways to get our power, and I would love to see Texas lead the way in these fields. Not continue to lead us down a dead end road with nuclear power.
Comment 36-6: STP does not displace [carbon dioxide] emissions. Other, truly renewable energy sources are much more highly developed now and can replace STP. By scheduled renewal, nuclear energy will be totally unnecessary.
Comment 38-2: We need to move toward heavy development of solar and wind regardless of the cost[]they would be so much safer (and most likely cheaper in the long run, considering
[(lacking of or merit of)] all the waste and other negatives of solar).
Comment 39-3: Safer, cleaner alternative ways to generate the same power (in essence[,] to boil water) exist today and should be used and funded, just like the Nuclear and Petroleum industries have been subsidized by the U.S. Government to the tune of BILLIONS of dollars annually.
Comment 40-2: At this point in time, I feel that the U.S. should move away from nuclear and oil as primary energy sources. Lets develop more renewable options.
A-6
Appendix A Comment 43-3: Here in Texas, we have a wonderful abundance of sun as well as wind, neither depend[e]nt on other countries. We should be making use of these natural resources[,] which are safer, reduce use of scarce water, and [cannot] be used as political weapons.
Comment 45-3: Safer, cleaner alternative ways to generate the same power exist today and should be used. We should not be subjected to worrying about radioactive contaminationjust to generate electricity. We should not have to worry about terrorists attacking a radioactive energy generation source, and we dont have these worries with solar, geothermal, natural gas, or wind power. These forms of energy generation, combined with energy efficiency and ever-improving methods of storage, could easily replace the electricity generated by Units 1
[and] 2. When these units have been down due to problems or fuel replacement, it did not cause problems with the grid or lead to blackouts. We can replace the generation of these units with safer, cleaner technologies.
Comment 46-3: For alternative energy sources, and a way to get the USA off foreign oil dependence that is costing us both in trade balance and military costs, see the downloadable document describing achievable ecological solutions for all these needs:
http://phoenixprojectfoundation.us/uploads/USA Article V SHE Document.pdf Thank you for your hard work and consideration of these issues. Please be sure to keep me informed as this regulatory process proceeds.
Comment 47-4: We have safer and cleaner ways to generate the same powerTHAT is where our money and attention need to be directed.
Comment 49-2: There are safer, cleaner alternatives to generate the same power that exists today, and we should commit the country to use them.
Comment 51-2: Safer, cleaner alternative ways to generate the same power exist today and should be used. Studies have found that energy efficiency and renewable energy sources, which are abundant in Texas, could replace the power generated by these two old nuclear reactors.
Comment 52-2: NOW is the time to make a commitment to safer and renewable energy sources.
Comment 53-2: Safer, cleaner alternative ways to generate the same power exist today and should be used. Studies have found that energy efficiency and renewable energy sources, which are abundant in Texas, could replace the power generated by these two old nuclear reactors.
Comment 54-3: There are safer, cleaner alternative ways to generate the same power available today, and these should be used instead of nuclear energy.
Comment 55-2: Safer, cleaner alternative ways to generate the same power exist today and should be used. Studies have found that energy efficiency and renewable energy sources, which are abundant in Texas, could replace the power generated by these two old nuclear reactors.
Comment 57-2: I believe there are alternative ways to generate power and support a more
[uncertain handwriting].
Comment 59-2: There are safer, cleaner alternative ways to generate power!
Comment 60-3: Texas is ready for a new way to power our lives; give Texa[s] a chance for a cleaner, safer power of energy A-7
Appendix A Comment 61-2: There are safer, cleaner alternative ways to generate the same power that exist today and should be used.
Comment 62-2: Safer, cleaner alternative ways to generate the same power exist today and should be used.
Comment 69-2: Safer, cleaner alternative ways to generate the same power exist today and should be used.
Comment 73-2: Rather than pushing for more water-consuming nuclear power plants, Texas needs to focus more on the development of renewable energy sources such as wind and solar.
While many promises are made as to the safety of nuclear power, recent history demands we not place too much reliance on them. Some things do not readily lend themselves to engineering solutions. I believe nuclear power is one of those things, and thus I am opposed to the requested re-licensing.
Comment 74-1: To ensure the safety of my family and other Texas families, I believe the re-licensing of these two reactors for an additional [20] years should be halted for safety reasons. There are safer and cleaner alternatives than outdated reactors. These alternatives (solar, wind, etc.) should be strongly considered.
Comment 77-2: There are safer and cleaner ways to generate power today that we need to support and use. Renewable energy sources are everywhere in Texas and could replace more dangerous sources if funded and supported. Another factor to think about is the huge amount of water used in the reactors. The water from the Colorado River is needed to farming, cattle and families. Are we not just creating another problem by using energy sources that use so much water?
Comment 79-2: Safer, cleaner alternative ways to generate the same power exist today and should be used. Studies have found that energy efficiency and renewable energy sources, which are abundant in Texas, could replace the power generated by these two old nuclear reactors.
Comment 80-2: Safer, cleaner alternative ways to generate the same power exist today and should be used. Studies have found that energy efficiency and renewable sources, which are abundant in Texas, could replace the power generated by these two old nuclear reactors.
Response: These comments provide input (or data) for the staffs environmental analysis of the alternatives to license renewal, including the alternative of not renewing the operating licensealso known as the no-action alternative. In Chapter 8 of this supplemental environmental impact statement (SEIS), the staff evaluated the alternatives to license renewal.
These include new nuclear generation, natural-gas-fired combined-cycle generation, supercritical coal-fired generation, combination alternative, and purchased power. In addition, in Chapter 8 of this SEIS, the staff considered many other options that were subsequently dismissed for reasons of technical, resource availability, or commercial limitations. These include offsite nuclear, gas and coal-fired capacity; energy conservation and energy efficiency; wind power; solar power; hydroelectric power; wave and ocean energy; geothermal power; municipal solid waste; biomass; biofuels; oil-fired power; fuel cells; and delayed retirement.
A.1.2 Socioeconomic Impact of STP, Units 1 and 2 The original sources for the comments in this category (socioeconomic) can be found at the back of the Scoping Summary Report and are labeled with the following identifiers: 1-2, 3-1, 5-2, 6-2, 8-1, 9-1, 10-1, 13-1, 14-1, 20-2, 23-1, and 24-1. These comments are extracted from the original sources.
A-8
Appendix A Comment 1-2: STP is the largest employer in Matagorda County with more than 1,200 employees and for 30 years has been a key part of the county and local communities.
The companys employees are active in the local community, serving on school boards, chambers and in civic and service organizations.
For over 20 years, [the] existing [STP] units have supplied safe, clean and reliable energy to more than 2 million Texas homes while also providing permanent, well-paying jobs. The facility is a recognized industry leader in production, reliability and safety, as well as being focused and committed to the safety of its employees and the surrounding communities.
Comment 3-1: With that being stated, STP makes it obvious. STP is the largest employer to the county, their employees stay active in numerous organizations, and many serve as elected officials. They have a very high importance to safety as well as the environment. Their employees set the standard for their industry. Just last October, STP was named one of Americas safest companies, the first nuclear facility to ever be honored with that award.
In 2008, STP started its educational incentive program as part of its workforce development efforts. It represents a $4.2 million investment that provides great opportunities for well-paying jobs in this community. For over 20 years, the facility has produced safe, reliable energy to the citizens of Texas, and for the past [7] consecutive years, STP has produced more electricity than any other two-unit nuclear plant in the country.
The license extension of STP will continue to provide jobs and economic benefits to our local community.
Comment 5-2: Our employees try to contribute and try to continue to do what they can to improve life within this community by serving, as the judge said, on various boards and providing leadership positions, and were thankful that you give us that opportunity.
Comment 6-2: During the record low temperatures when there were problems in Texas with other sources of power, our local plant didnt have any problems keeping the power generating for Texans.
The culture of continuing improvement for all aspects of power generation overflows in the community. STP[NOC]s contributions to our local charities, our chambers of commerce and civic groups provide the commitment to our future and our joint success. They give both time and money to make sure Matagorda County is the best in all of Texas.
Comment 8-1: My name is Cheryl Stewart, and Im on the Bay City Community Development Corporation Board and also the Historic Commission, and Im here today to inform you of the many ways that I have personally seen STP impact our community in a positive way.
STP contributed $100,000 to the Center for Energy Development and currently provides staffing to train our communitys young adults. STP employees have been strong leaders in our strategic planning for the future of this community with our Bay City Matagorda United Plan.
STP employees have also invested in the renovation of our historic downtown district and its beautification efforts. I have also served with STP employees on various community boards and have witnessed firsthand their dedication, their desire to be good neighbors, and their commitment to our community.
I am sure that our community would experience a huge loss without the involvement and support of STP.
Comment 9-1: The importance of STP to that future [cannot] be overemphasized. My employer is an educational partner with STP and their contribution to the future of our community through support of education is unprecedented in my 20 years of higher education experience.
A-9
Appendix A Comment 10-1: STP personifies the best type of economic development project that a community could want. Its created a large number of jobs that have been filled with highly educated and highly skilled workers. It pays wages far above the county average. Its greatly enhanced the tax base of Matagorda County and to the taxing entities in whose location it is situation. It makes significant annual financial contributions to civic, educational, and promotional programs benefitting all of the county. It has created and funded a major grow-your-own technical education program, providing good career opportunities for all of our local youth. Its employee and their families are extensively involved in all aspects of our community and political life, and, by so doing, they make Matagorda County a much better place in which to live for all the rest of us.
Comment 13-1: And have you ever wondered what Bay City and Matagorda County would be like if we didnt have South Texas Nuclear Operating Company [STPNOC] here? There isnt a day that goes by that we dont run into or communicate with STP employees. Theyre involved throughout our community, and I really have a hard time imagining what it would be like here without them because theyre such a huge asset to our community.
And, of course, we love to show off our assets, and Im proud to say that every time I meet someone I always talk about were the home of a nuclear power plant, because Im just really proud of that. And, because of that, Ive also invited all of our surrounding economic development associates to come and visit STP because I want them to see the high level of security and safety that they operate in every day. And, Ive got them actually scheduled next month, so Mr. Halpin, hopefully you can stop by and say hello.
But, as an economic developer and resident of Matagorda County, Im very thankful to have such a great asset in our community, and they will not only have a positive impact but an excellent impact on our taxes, community development, and our environmental justice.
Comment 14-1: I dont have a lot of knowledge on technical skills about nuclear energy, so Im just going to limit my comments to the social environmental impact that STP has had on this community.
Matagorda County, like many rural communities, over the years has suffered from brain drain, where your best and your brightest tend to leave and seek their fortunes other places. Well, STP has helped to reverse that trend in Matagorda County. Not only does it provide great paying jobs for our youth that even go off to college and return to become productive citizens in this community, they have reduced the amount of exodus of kids leaving this community in the first place with the creation of the Center for Energy Development where we can now grow our own.
The social environmental impact of that, just in and of itself, has been tremendous. If we were to track the intellectual scale of Matagorda County within the last 20 years, you can begin to see that if you start off with the census of 2000, the number of high school graduated individuals in Matagorda County represented about one-third, another group of individuals that did not have a high school diploma represented another third. So effectively, basically, two-thirds of the population of Matagorda County had a high school diploma or less.
If you begin to look at the recent trend since the [STP] has been in this community, you can see that trend reversing and the numbers of educated citizens of this community going up.
When I returned to Matagorda County several years ago, I became actively involved in a lot of the nonprofit organizations. The premier nonprofit organization for this community was United Way, but at that time, unfortunately, United Way was under poor leadership and dysfunctional.
A-10
Appendix A Thanks to the leadership of two employees from STP, one by the name of Gerald Wilson, another by the name of Chris Johnson, who took the leadership of the United Way and made it the organization that it is today thats supporting over 30 other non-profit organizations in this community, there are others that could talk more eloquently about the economic impact of STP, but the ancillary benefit of its employees serving on nonprofit boards, and not to mention our faith-based communities through their tithes, their offerings that support churches and other community-based organizations, that contribution is almost immeasurable.
Comment 20-2: What should you focus on? Obviously, our environmental concerns are a huge part of this. Im [with] the Convention and Visitors Bureau, and one of our main focuses is bringing tourists down to Matagorda County to see what we have to offer.
Comment 23-1: And Id just like to say that, on behalf of Babe Ruth, were very grateful for everything STP does for us as an organization. Theyre a major sponsor in all of our events.
Over the last [10] years, weve hosted [4] regional tournaments and [11] or [12] state tournaments, and without STP[NOC]s support, we would never have been able to participate in those tournaments or even host those tournaments.
On the economic standpoint, Mr. Head said earlier last year we hosted a regional tournament.
We had five states come to visit Bay City, over 400 visitors in town, over 100,000 new dollars just last year, and without STP supporting that, we wouldnt have been able to host that tournament. So, wed like to thank them.
Not only do they help us monetarily with our tournaments, but their employees also volunteer with us, and wed like to thank them for their employees and letting them volunteer.
Over the last [10] years, like I said, weve hosted about 15 tournaments and probably half a million new dollars in Matagorda County over the last [10] years.
Comment 24-1: You may ask why Id want to come down from Austin to talk to you. Well, Austin is a 16 percent partner in [Units 1 and 2], and if you look back over the history of the project, weve got a lot less reason to celebrate this plant than may be some people who live here do. Im not going to talk a lot about jobs, but Im going to wrap up with that tonight.
But, Austins experience with [Units] 1 and 2 was a nightmare. We had it thrust upon us by politicians who were determined to continue to take public votes until we bought a share of the plant. We tried to get out of the plant at one point, tried to sell our 16 percent share, and
[cannot].
The problem was at its worst in the 90s when 42 cents out of every dollar that we paid on a utility bill was going for debt service at NRG. For our 16 percent share, we were paying almost half of our utility bill for debt service on the project.
Response: These comments provided input (or data) for the staffs environmental analysis of the socioeconomic impacts of STP on local and regional communities. The comments include socioeconomic-related items such as taxes, employment, education, tourism, and public and civic services.
The socioeconomic impacts of renewing the STP operating license and alternatives to license renewal are discussed in Sections 2.2.9, 4.9, 8.1.8, 8.2.8, 8.3.8, 8.4.8, 8.5.8, and 8.7.8 of this SEIS.
A.1.3 Water Usage The original sources for the comments in this category (water usage) can be found at the back of the Scoping Summary Report and are labeled with the following identifiers: 25-4, 29-3, 32-2, A-11
Appendix A 36-5, 37-3, 39-4, 40-3, 41-2, 45-4, 47-2, 51-3, 53-3, 54-2, 55-3, 59-3, 60-2, 62-4, 63-2, 64-3, 67-2, 71-2, 75-2, 77-2, and 80-4. These comments are extracted from the original sources.
Comment 25-4: There is a problem with the leaking main cooling reservoir [MCR], which was described and documented in the license application for Units 3 and 4. There needs to be tracking of where the water is going. Is it reaching the Gulf, where is it going, what is it doing?
That should be part of the re-licensing study and analysis.
Water use is an increasing issue. Up until this point, the highest use that I know of through researchers looking at this is 49 percent of the Colorado River has been used for cooling purposes, and I know a couple of summers ago there was a lot of pumping going on to refill the reservoir when it got kind of low.
Its a problem for those of us in Austin. The Colorado River water has to serve a lot of purposes. Rice farmers need it; were going to need it for many, many purposes, recreation, fishing on our end. And, Lake Travis levels were at an all-time low several years ago. Every single dam on the whole lake was closed; you couldnt put a boat in.
And, we would like to see something shift to where this much water was no longer required.
Certainly, youre still going to have to still cool spent fuel rods and so on and so forth, but it is a question when you look at continuing the reactors life.
Comment 29-3: Vast water consumption requirements for these reactors add a hidden cost to taxpayers, farmers, ranchers and other industries. As water becomes more scarce in Texas, this becomes a very high risk should there be a meltdown like Japan.
Comment 32-2: We have been suffering for many years from drought conditions here in Texas.
Given the huge amount of water needed for normal operation and to avert nuclear catastrophe, we would be better served to use the little water we have for agriculture and residential use.
Comment 36-5: STP requires a large amount of cooling water to operate, critical, as seen in Japan. Texas is facing more and more serious water shortages, as population rises and global warming effects take place. The need for water for other purposes than STP will grow. STP should relinquish its water use and shut down.
Comment 37-3: Vast consumption of water use, largely Colorado River water, which is increasingly needed for drinking water, livestock, and farming. The [MCR] is leaking out the bottom. How and when will this be repaired? Climate changerising temperatures could affect whether there is enough cool water to cool the reactors.
Comment 39-4: Vast consumption of water use, largely Colorado River water, which is increasingly needed for drinking water, livestock, and farming in an era of more frequent and lengthy periods of drought. The [MCR] is leaking out of the bottom: How and when will this be repaired? Climate change considerations: The rising atmospheric temperatures could affect whether there is enough cool water to cool the reactors.
Comment 40-3: Also, as you know, nuclear power supplies require a lot of water for cooling purposes. Once again, the State of Texas is experienced drought in 98 [percent] of its counties.
Lets save the water for agricultural purposes.
Comment 41-2: The reactors consume vast quantities of water; use largely from the Colorado River; water that is needed for drinking water.
Comment 45-4: These reactors consume vast quantities of water use, largely Colorado River water, which is increasingly needed for drinking water, livestock, and farming. Drought is expected to increase in our region. We are concerned that there will not be adequate water to cool the reactors in an emergency or that the water will not be cool enough to effectively cool A-12
Appendix A the reactors. Some U.S. reactors have had to shut down due to high water temperatures, and this could [result in a] scenario [that] could worsen with climate change impacts, leaving us with a dangerous situation and a shortage of power during intense heat waves.
The [MCR] is leaking out the bottom, as documented in the license application for STP 3
[and] 4. The reactors should not be relicensed when this serious condition remains unresolved.
How and when will this be repaired? What studies have been done by the NRC on this serious problem? How can relicensing even be considered until this situation is corrected? Where is the water going, and how extensive is the radioactivity that may be leaking into the Gulf of Mexico [or the] Colorado River [or both]?
Comment 47-2: We have limited access to freshwater that can be used for this facility. The priority should be for drinking water, livestock, and farming. I understand that the [MCR] is leaking out the bottom. How and when will this be repaired?
Comment 51-3: These reactors consume vast quantities of water use, largely from the Colorado River, water that is needed for drinking water, livestock, and farming.
Comment 53-3: These reactors consume vast quantities of water use, largely from the Colorado River, water that is needed for drinking water, livestock, and farming.
Comment 54-2: The reactors would affect the Austin area by consuming vast quantities of our drinking water from the Colorado River Comment 55-3 these reactors consume vast quantities of water use, largely from the Colorado River, water that is needed for drinking water, livestock and farming; Comment 59-3: Leave the Colorado River for other purposesdrinking, livestock, and farming.
Comment 60-2: Please help protect Americans, Texans, and all human beings that come into contact with the Texas Colorado River from having it depleted by renewing these reactors licenses[,] to continue consuming vast quantities. Protect the waterways from being poisoned in the event of emergencies at nuclear plants.
Comment 62-4: These reactors consume large quantities of water use, largely from the Colorado River, water that is needed for drinking water, livestock, and farming.
Comment 63-2: Too much water is used to cool the reactors! Too much water is used. Its dangerous.
Comment 64-3: Too much water is wasted! There goes the drinking water; all gone and toxic!
Please do not relicense these two reactors.
Comment 67-2: The vast amount of water taken up by these reactors is very much needed for other purposes.
Comment 71-2: Nuclear reactors use large quantities of water, water that could be used for drinking, livestock, and farming.
Comment 75-2: These reactors consume vast quantities of water use, largely from the Colorado River[;] water that is needed for drinking water, livestock[,] and farming.
Comment 77-2: There are safer and cleaner ways to generate power today that we need to support and use. Renewable energy sources are everywhere in Texas and could replace more dangerous sources if funded and supported. Another factor to think about is the huge amount of water used in the reactors. The water from the Colorado River is needed [for] farming, cattle[,] and families. Are we not just creating another problem by using energy sources that use so much water?
A-13
Appendix A Comment 80-4: These reactors consume vast quantities of water use, largely from the Colorado River[;] water that is needed for drinking water, livestock, and farming.
Response: These comments provided input (or data) for the staffs environmental analysis of water resource impacts of STP on local and regional communities. These comments raise concerns about the water usage from the Colorado River and leakage from the MCR. The staff discusses water usage impacts in Sections 2.2.4, 2.2.5, 4.3, 4.4, 8.1.2, 8.1.3, 8.2.2, 8.2.3, 8.3.2, 8.3.3, 8.4.2, 8.4.3, 8.5.2, 8.7.2, and 8.7.3 of this SEIS.
A.1.4 Human Health The original sources for the comments in this category (human health or Radiation Impact) can be found at the back of the Scoping Summary Report and are labeled with the following identifiers: 25-1, 29-4, 36-3, and 45-6. These comments are extracted from the original sources.
Comment 25-1: I also have concerns about the re-licensing of reactors 1 and 2. I think there are a number of issues that need to be looked at carefully during this process and bearing worker safety in mind. One of them is tritium, and basically, there has been tritium showing up in wells on the site. This needs to be looked into thoroughly, as well as tritium in the Colorado River, and documented, measured, carefully analyzed to see if its safe to continue down this path at this point in time.
Comment 29-4: There is currently a leak in the bottom. What are the health implications to wildlife and people of this leak? When will it be fixed? They have not repaired this, how can they be trusted for another 20 years?
Comment 36-3: I have heard the news reports that the leakage of plutonium and cesium is not a cause for concern. As a physician interested in this area, I know that this is ridiculous. I remember how much polonium [alpha emitter] was required to assassinate a Russian person in the UK.
Comment 45-6: We are concerned about increasing tritium levels in wells [on site] and in the Colorado River. Extensive testing should occur for all organisms in the region, and exposure of whooping cranes to tritium and other radionuclides should be examined since they are an endangered species and their winter grounds are only 35 miles from the STP site.
Response: These comments provided input (or data) for the staffs environmental analysis of human health and environmental impacts related to possible radioactive leaks from STP.
To ensure that STP is operated safely, the NRC licenses the plant and plant operators and establishes license conditions for safe operation. The NRC provides continuous oversight of STP through its reactor oversight process (ROP) to verify that operations are in accordance with NRC regulations. The NRC has full authority to take necessary actions to protect public health and safety and the environment, and it may demand immediate STPNOC actions, up to and including a plant shutdown.
Radiation doses to members of the public from the current operations of STP are evaluated in the SEIS in Section 4.8.2. In that section, the staff reviewed the radioactive releases from STP (i.e., radioactive gaseous and liquid effluents, radiation from radioactive waste storage buildings, radiological impacts from refueling and maintenance activities, and tritium leaks) and the results of STPNOCs radiological environmental monitoring program (REMP) (i.e., analysis of air, water (surface, ground, and drinking), sediment, vegetation, and aquatic and terrestrial biota for radioactivity). Based on its review, the staff concluded that the radiological impacts to members of the public were within NRCs and U.S. Environmental Protection Agencys (EPAs) dose A-14
Appendix A standards, and there were no radiological effects to the environment and non-human species (i.e., local biota) from plant operation.
The staff also evaluated the STP REMP. The REMP quantifies the environmental impacts associated with radioactive releases from the plant. The REMP monitors the environment over time, starting before the plant operates to establish background radiation levels and throughout its operating lifetime to monitor radioactivity in the local environment. The REMP provides a mechanism for determining the levels of radioactivity in the environment to ensure that any accumulation of radionuclides released into the environment will not become significant as a result of plant operations. Based on the review of several years of data, the staff concluded that there were no measurable impacts to the environment as a result of radioactive releases from STP.
In summary, the NRC provides continuous oversight of STP through its ROP to verify that they are being operated in accordance with NRC regulations. STP is required to maintain its radioactive effluent release program in compliance with NRC regulations and consistent with EPA standards. The NRC will continue to inspect STPNOCs compliance with radioactive effluent.
A.1.5 Postulated Accidents The original sources for the comments in this category can be found at the back of the Scoping Summary Report and are labeled with the following identifiers: 25-3, 37-2, 39-2, 42-1, 45-2, and 48-1. These comments are extracted from the original sources.
Comment 25-3: [I]n 1982, there was a study done for the [NRC] called the [CRAC 2] Study. It found that if there were an accidentand they were looking at Units 1 and 2that there would be 18,000 early deaths. They would also be followed by thousands of cancers. That study has not been updated. The population in some of this region has grown, and it needs to be looked at again to find out what is the reality of the situation today, and that needs to be compared to other ways of generating electricity.
Comment 37-2: Risks of an accident, fires, or explosions at one or more reactors at the site, risks that could increase with aging reactors NRCs 1982 CRAC 2 study found that there could be 18,000 early deaths if a serious accident occurred at the STP site.
Comment 39-2: Risks of an accident, fires, or explosions at one or more reactors at the site, risks that could increase with aging reactors. [NRCs] 1982 CRAC 2 study found that there could be 18,000 early deaths if a serious accident occurred at the STP site.
Comment 42-1: The [license renewal application (LRA)] is inadequate because it: (a) fails to adequately address the applicants capacity to deal with fires and explosions that cause a loss of large areas of the plantthe mitigative strategies for addressing fires and explosions are inadequate to address the consequences of events such as the impacts of large commercial aircraft crashing into the reactors or related facilities, (b) fails to describe the means that would be used to determine radiation exposures to fire and explosion responders, and (c) fails to describe the means that would be used to protect fire and explosion responders from excessive radiation exposures.
Comment 45-2: We are all too aware of the fact that meltdowns can and do happen, and a recent Union of Concerned Scientists report notes that there were 14 near misses in the U.S. in 2010. NRCs 1982 CRAC 2 study found that there could be 18,000 early deaths if a serious accident occurred at the ST(N)P site, followed by thousands of cancers.
A-15
Appendix A Comment 48-1: The [LRA] is inadequate because it: (a) fails to adequately address the applicants capacity to deal with fires and explosions that cause a loss of large areas of the plantthe mitigative strategies for addressing fires and explosions are inadequate to address the consequences of events such as the impacts of large commercial aircraft crashing into the reactors or related facilities, (b) fails to describe the means that would be used to determine radiation exposures to fire and explosion responders, and (c) fails to describe the means that would be used to protect fire and explosion responders from excessive radiation exposures Response: These comments provided input (or data) on various aspects of severe accidents associated with fire and explosion hazards, ranging from the applicability of results from earlier NRC consequence studies (e.g., CRAC) to emergency management operation. The evaluations of STPNOCs severe accident analysis are discussed in Section 5.2 of this SEIS.
The NRC and the global nuclear research and safety community have done extensive research over the past three decades evaluating reactor accidents and how they could affect the public.
Earlier studies (e.g., NUREG/CR-2239, Technical Guidance for Siting Criteria Development, commonly referred to as the 1982 Siting Study or CRAC 2 Study) had uncertainties and conservatisms and did not include information on current plant design, operation, accident management strategies, emergency preparedness procedures, or post-9/11 enhancements to mitigative measures. Earlier work was also limited by both computer hardware and software available at that time. Researchers attempted to overcome these limitations by simplifying some estimates or assumptions concerning possible damage to the reactor core, the possible radioactive contamination that could be released, and possible failures of the reactor vessel and containment buildings. These efforts led to overestimates in the results, particularly in the 1982 Siting Study (or CRAC 2 Study) report. This report was meant to assist the NRC staff in considering regulations for choosing nuclear power plant locations, but it has been regularly misinterpreted and misused as an estimate of accident consequences. Since those early studies, information from both NRC and cooperative foreign research has greatly increased our understanding of the timing and magnitude of possible radioactive releases from potential accidents at nuclear power plants.
The NRC established a research project in 2006 to update its assessment of severe reactor accident scenarios and their potential consequences to human health. This research project, titled State-of-the-Art Reactor Consequence Analyses (SOARCA), was designed to develop best estimates of the public health effects that might result from a radiological release during a nuclear power plant accident. The SOARCA project used state-of-the-art computer codes to calculate accident progression and offsite consequences for important scenarios at two plants, Peach Bottom, a boiling-water reactor (BWR), and Surry, a pressurized-water reactor (PWR).
These codes have been continuously updated to incorporate decades of experimental research.
The SOARCA project had cooperation from the licensees of these plants to model them in great detail as they exist in their current state and include operator action timelines based on plant-specific procedures. The project also modeled the use of additional equipment and strategies required by the NRC following the terrorist attacks of September 11, 2001, to further improve each plants capability to mitigate events involving a loss of large areas of the plant caused by fire and explosions.
SOARCA results show that when operators are successful in using available onsite equipment during the accidents analyzed in SOARCA, they can either (a) prevent the reactor from melting or (b) delay or reduce releases of radioactive material to the environment. Even if operators are unsuccessful in stopping the accident, SOARCA shows that the accidents progress more slowly and release much smaller amounts of radioactive material than calculated in the 1982 Siting Study or CRAC 2 Study. Therefore, public health consequences from severe nuclear reactor accident scenarios are smaller than previously calculated. The delayed releases calculated A-16
Appendix A provide more time for emergency response actions, such as evacuating or sheltering. All modeled scenarios in SOARCA showed essentially zero early fatalities. In contrast, the 1982 Siting Study calculated 92 mean early fatalities for Peach Bottom, 45 for Surry, and 6.5 1 (not 18,000) 2 for STP conditional on the occurrence of a hypothetical large source term being released. In addition, in SOARCA, the calculated individual long-term risks of dying from cancer from exposure to radiation from these accidents are very smallmillions of times lower than the general risk of dying from cancer in the U.S. from all causes.
Because STP and the Surry plant studied in SOARCA are both Westinghouse-designed PWRs with large dry containments, the insights gained from the SOARCA project regarding accident progression and offsite health consequences can generally be applied to the STP site.
More information regarding the SOARCA project is available on NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/research/soar.html.
A.1.6 Terrestrial or Aquatic Ecology The original sources for the comments in this category can be found at the back of the Scoping Summary Report and are labeled with the following identifiers: 18-1, 20-3, 44-2, and 45-7.
These comments are extracted from the original sources.
Comment 18-1: I want to touch on two aspects of the review. One is going to be the environmental aspect. Its very important when you talk about Matagorda Countyand Ill do just a little bit of a commercialwe have a very, very sensitive area in that we have the freshwater from our Colorado River, two bays, estuaries, as well as the Gulf of Mexico. We are the North American Christmas bird count winner about [11] out of the last [12] years. It was foggy one morning, and we missed some of those birds. But, as you see that as weve got such a great ecological area here the whole time Units 1 and 2 have been operating. So, were very, very proud of the fact that the [STPNOC], with Units 1 and 2, continues to operate in a strong fashion while our environment is protected.
Comment 20-3: What should you focus on? Obviously, our environmental concerns are a huge part of this. Im [with] the Convention and Visitors Bureau, and one of our main focuses is bringing tourists down to Matagorda County to see what we have to offer. Good thing one of our sights to see is STP, as well as all around STP we have tons of fishing, birding, we have farm lands and everything else, and from what Ive seen, there have been no concerns with those at all, as I grew up fishing right below STP on the Colorado River. And, I would like to thank STP for providing that to me, providing the safe waters and the safe grounds for me to do that on.
Comment 44-2: In addition, the existing South Texas units need to be evaluated to see if they will need to be modified to meet the newly proposed cooling water requirements that the [EPA]
announced this week.
Comment 45-7: We are concerned about increasing tritium levels in wells [on site] and in the Colorado River. Extensive testing should occur for all organisms in the region, and exposure of whooping cranes to tritium and other radionuclides should be examined since they are an endangered species and their winter grounds are only 35 miles from the STP site.
1 The 1982 Siting Study calculated 5.2 mean early fatalities for STP for the SST1 source term. This value is based upon a standard 1,120 MWe PWR. When corrected for the actual electrical output (1410 MWe), the result is 6.5 mean early fatalities.
2 The 1982 Siting Study calculated 18,000 early fatalities as the 99th percentile value, and it is dependent upon the SST1 source term release, assuming New York City meteorology and Indian Point population and wind rose as well as no evacuation. This was included as a sensitivity to show the effect of evacuation distance on early fatalities and was not meant to be a realistic estimate of the offsite health consequences of a severe nuclear reactor accident.
A-17
Appendix A
Response
These comments provided input (or data) for the staffs environmental analysis of the ecology impacts of STP. The staff discusses these impacts in Sections 2.2.6, 2.2.7, 4.5, 4.6, 4.8, 8.1.4, 8.1.5, 8.2.4, 8.2.5, 8.3.4, 8.3.5, 8.4.4, 8.4.5, 8.5.3, 8.7.4, and 8.7.5 of this SEIS.
A.1.7 Uranium Fuel Cycle and Waste Management The original sources for the comments in this category can be found at the back of the Scoping Summary Report and are labeled with the following identifiers: 29-5, 32-4, 33-2, 34-1, 36-2, 37-4, 39-5, 43-2, 45-5, 46-2, 47-3, 49-3, 51-4, 53-4, 54-4, 55-4, 59-4, 61-4, 62-5, 63-3, 64-2, 69-4, 71-3, 75-3, 77-3, 79-3, 80-5. These comments are extracted from the original sources. In summary, these comments express concerns about transportation of radioactive materials, long-term stewardship of nuclear waste, and uranium mining.
Comment 29-5: Whose backyard is the waste being transported through? [In] whose backyard is the waste being dumped?
Comment 32-4: Lastly, there is no way this can be justified as a result of the lack of safe storage for thousands and thousands of years of the nuclear waste. Please reject the renewal applications. The danger to our citizens is too great.
Comment 33-2: Uranium mining is a health issue. Nuclear waste remains a serious threat to future generations as well as the current population.
Comment 34-1: Please do not approve the licensing. Nuclear waste is too dangerous.
Comment 36-2: I also know, from following WCS in Andrews, Texas, that there is no safe disposal for LLRW [low-level radioactive waste], and still no safe disposal for the high-level waste fuel rods such as are melting in Japan today.
Comment 37-4: There is no adequate solution for radioactive waste, so it makes sense to stop generating more.
Comment 39-5: There is no adequate solution for radioactive waste, so it makes sense to stop generating more.
Comment 43-2: As we have seen in the last few weeks, nuclear energy is not as safe as made out to be, and there are too many problems with disposal that have not been solved.
Comment 45-5: It is time to stop generating more radioactive waste since there is no safe storage and disposal solution, even after attempts have been made for some [60] years.
Relicensing would the creation of waste. There may not be enough room for even the so-called
[LLRW] at the planned West Texas radioactive waste dump, since there is an attempt to allow Out of Compact waste[,] and the volume and curies limits may be reached long before all STP waste could be shipped. There is still no high-level repository for spent fuel rods.
Comment 46-2: Im opposed to their continuation for all the usual reasons that any kind of accident and even a Category 4 or 5 hurricane-induced storm surge could remove external supports such as cooling ponds or water access (and who knows what hammering debris-laden waves on top of the storm surge could do), plus disposal of nuclear wasteno human technology is foolproof and totally isolated for thousands of years!
Comment 47-3: At the most fundamental level[,] we cannot justify generating more radioactive waste when there is no adequate solution for dealing with it.
Comment 49-3: Every nuclear power plant is a potential disaster waiting to happen[,] and every nuclear power plant is a long-term disaster by the toxic waste they generate.
A-18
Appendix A Comment 51-4: There is no adequate solution for radioactive waste, so it makes no sense to continue generating more.
Comment 53-4: There is no adequate solution for radioactive waste[,] so it makes no sense to continue generating more.
Comment 54-4: There is no adequate solution for radioactive waste, so it makes no sense to continue generating more.
Comment 55-4: [T]here is no adequate solution for radioactive waste, so it makes no sense to continue generating more.
Comment 59-4: Until there is an adequate solution for radioactive waste, we should not continue to generate more.
Comment 61-4: There is no adequate solution for radioactive waste, so it makes no sense to continue generating more.
Comment 62-5: There is no adequate solution for radioactive waste, so it makes no sense to continue generating more.
Comment 63-3: What about waste? Radioactive waste is terrible to contend with.
Comment 64-2: Too much water is wasted! Way too much [water] daily to cool it!
These [] dangerous radioactive waste! Is not safe. What are you going to do with the radioactive waste?
Comment 69-4: There is no adequate solution for radioactive waste, so it makes no sense to continue generating more.
Comment 71-3: There is no solution for the disposal of radioactive waste, so it makes no sense to continue generating more.
Comment 75-3: There is no adequate solution for radioactive waste, so it makes no sense to continue generating more.
Comment 77-3: Radioactive waste is and will continue to be a big problem[,] so why would we go in that direction. Leadership and creating thinking is needed at this moment in history.
Please be part of solving problems and not adding new problems.
Comment 79-3: There is no adequate solution for radioactive waste, so it makes no sense to continue generating more.
Comment 80-5: There is no adequate solution for radioactive waste, so it makes no sense to continue generating more.
Response: These comments raise concerns about the uranium fuel cycle and waste management. The staff addresses the environmental impacts of the uranium fuel cycle and waste management in Chapter 6 of this SEIS.
A.2 Comments Received on the Draft SEIS On December 5, 2012, the NRC issued the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding South Texas Project, Draft Report for Comment (NUREG 1437, Supplement 48, referred to as the draft SEIS) to Federal, tribal, state, and local government agencies and interested members of the public. The U.S. Environmental Protection Agency (EPA) issued its Notice of Availability on December 14, 2012 (77 FR 74479) that A-19
Appendix A included the draft SEIS. The public comment period ended on February 22, 2013. As part of the process to solicit public comments on the draft SEIS, the NRC did the following:
- placed a copy of the draft SEIS on the NRC Web site, on December 5, 2012, at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1437/supplement48/,
- provided a copy of the draft SEIS to any member of the public that requested one,
- sent copies of the draft SEIS to certain Federal, tribal, state, and local government agencies,
- published a notice of availability of the draft SEIS in the Federal Register on December 18, 2012 (77 FR 74882),
- announced and held two public meetings at the Bay City Civic Center in Bay City, Texas, on January 15, 2013, to describe the preliminary results of the environmental review, answer any related questions, and take public comments.
Approximately 30 people attended the meetings, and 6 attendees provided oral comments. A certified court reporter recorded the oral comments and prepared written transcripts of the meeting. A meeting summary is available in ADAMS (ADAMS No. ML13023A344). In addition to the comments received at the public meetings, the NRC received nine comment submittals (i.e., individual e-mail, entry at Regulations.Gov, or letters with comments). Excerpts from the public meeting transcripts and all letters and e-mails are included in Section A.3 with labels marking individual comments.
To identify each individual comment, the NRC reviewed the transcript of the public meetings and each e-mail and letter received on the draft SEIS. The NRC identified statements related to the proposed action and recorded the statements as comments.
Each commenter was given a unique identifier, so every comment could be traced back to its author. Table A-2 identifies the individuals who provided comments applicable to the environmental review and the Commenter ID associated with each persons set of comments.
The individuals are listed in the order in which they spoke at the public meeting and in numerical order for the comments received in the transcript or by e-mails or letters.
Table A-2. Individuals Providing Comments During the Comment Period Commenter Commenter ID Affiliation (If Stated) ADAMS No.
Owen Bludau STP-1 Matagorda County Economic ML13023A334 Development Corporation (MCEDC)
Carolyn Thames STP-2 Bay City Resident ML13023A334 Terry Farrar STP-3 Farrar Financial Group ML13023A334 A-20
Appendix A Commenter Commenter ID Affiliation (If Stated) ADAMS No.
Karen Hadden STP-4 Sustainable Energy and Economic ML13023A334 Development Susan Dancer STP-5 South Texas Association for ML13023A334 Responsible Energy (STARE)
Eugene Davis STP-6 Crisis Center ML13023A334 Marvin Lewis STP-7 Philadelphia Resident ML12356A233 Sonia Santana STP-8 Austin Resident ML13017A405 John Elder STP-9 San Antonio Resident ML13025A357 Cynthia Weehler STP-10 Austin Resident ML13025A358 Elizabeth Tobin STP-11 San Antonio Resident ML13025A359 Kenneth Taplett STP-12 STP Nuclear Operating Company ML13044A496 Mary Sixwomen STP-13 Apalachicola Creek Indians ML13072A072 Blount Debra Griffin STP-14 EPA Region VI ML13071A059 Stephen Spencer STP-15 DOI Office of the Secretary ML13058A027 Each comment has a comment ID consisting of two numbers separated by a hyphen. The part of the comment ID before the hyphen is the Commenter ID. The part of the comment ID after the hyphen is the comment number, which refers to the sequential comment given by the commenter. For example, comment xx-yy is the yy comment from the Commenter xx.
In response to the comments, the staff did not identify any new and significant information provided on Category 1 issues or information that required further evaluation of Category 2 issues. Therefore, the conclusions in the GEIS and draft SEIS remained valid and bounding, and no further evaluation was performed.
The following sections present the comments, or summaries of the comments, along with the NRC responses to them. In response to the issues raised, consistent with 10 CFR 51.91, the staff provides explanations of why the comments do not warrant further response, citing sources, authorities, or reasons that support the explanation, as appropriate. When comments have resulted in modification or supplementation of information presented in the draft SEIS, those changes are noted within the NRC response. Changes made to the draft document are marked with a change bar (vertical lines) on the side margin of the page.
Comments are grouped in the following categories and presented in the following order:
- general comments in support of or opposition to STPNOC, nuclear power, or license renewal for STP,
- alternatives to license renewal,
- cumulative impacts,
- socioeconomic impact of STP,
- water usage,
- human health, A-21
Appendix A
- postulated accidents,
- terrestrial or aquatic ecology,
- uranium fuel cycle and waste management,
- license renewal rule,
- tribal consultation,
- noise levels,
- comments beyond the scope of NRCs environmental review, and
- safety and aging management of plant systems
- events at Fukushima Japan
- text clarification.
A.2.1 General Comments in Support of or Opposition to STPNOC, Nuclear Power, or License Renewal for STP The original sources for the comments in this category (general) can be found in Section A.3 and are labeled with the following identifiers: 1-1, 1-2, 3 1, 4-2, and 6-5. These comments are extracted from the original sources.
Comment 1-1: The results that were presented are exactly as I anticipated they could be, that there were small to minimal impacts of any kind. I think the proof of the pudding is that STP has been here for well over 20 years now, and we have an environment that we appreciate and admire.
Comment 1-2: We went through a lot of internal furor [2] years ago over a coal plant, and the people who opposed that kept saying we have such a great environment here, we dont want to destroy it. That means STP has not done anything adverse to it, and I dont think renewal of this permit is going to do anything thats going to change that, so I firmly am in support of the findings of this environmental impact study.
Comment 4-2: There are many ways to move forward. The risks of continuing with nuclear power are great, and thats because of the inherent nature of nuclear power. There are accidents; there are fires. Weve just been through that.
Response
These comments are general in nature. The comments express general support of or opposition to STPNOC, nuclear power, or license renewal of STP.
The comments provide no new and significant information for this environmental review (as specified in 10 CFR 51.95(c)(3)) and are not evaluated. No changes have been made to the SEIS as a result of these comments.
Comment 3-1: Ive been here for 28 years. The entire time Ive been here, STP has been, without a doubt, the lifeblood of this community. I do not know anybody who donates as much money to civic purposes, fund raisers. Theyre very good about being a part of this community with the Chamber.
Buddy Eller is the current chairman of the Chamber of Commerce. He works at STP. Tim Powell, the vice president at STP, is the president of the school board here. Bart Brown is the A-22
Appendix A department director of my Sunday School class there where Im a Sunday School teacher. Tim is a Sunday School teacher at First Baptist Church.
The people at STP are not onlydo not only just give the money that they give to make this community viable, but they give their time. The leadership that we experience because of the training that these people have received at STP has made a difference in this community. This community is what it is predominantly because of STP and their influence in this community.
Comment 6-5: And then, too, finally, is the fact that STP is, in my view, an excellent corporate citizen, always willing to step in, always willing to make the difference, always willing to help, and has instilled that in all its employees, that their employees are also involved in the community. And they are a vital part of this community that we really appreciate and want to see them stay.
Response
These comments provided similar or the same input (or data) in comparison to the scoping comments (Section A.1.2 of this SEIS), for the staffs environmental analysis of the socioeconomic impacts of STP on local and regional communities. The comments include socioeconomic-related items such as education and community services.
The comments provide no new and significant information for this environmental review (as specified in 10 CFR 51.95(c)(3)) and are not evaluated. No changes have been made to the SEIS as a result of these comments.
A.2.2 Alternatives to License Renewal The original source for the comment in this category (alternatives) can be found in Section A.3 and is labeled with the following identifier: 4-1. The comment is extracted from the original sources.
Comment 4-1: Im going to speak in opposition to relicensing Units 1 and 2. In fact, the option that I think should be pursued is not actually on the list of options.
I understand the importance of a major industry in this community. I understand the importance of jobs, and our organization does as well, and we support that. We want every community in Texas to be economically viable and thriving.
But, what I think should be happening, instead of relicensing two nuclear reactors that are set to retire in 2027 and 2028, this is the time to plan for a transition, to plan for worker training, to plan to move toward cleaner, safer energy for the future.
And with 14 and 15 years to work with, that is a doable goal. Its also very doable in todays world to replace the energy with renewables combined with energy efficiency, and that can be backed up with natural gas. This is affordable; this is real. Other communities are looking at these options. It can be done; it is being done.
For an example, right now wind turbines are booming across Texas. Weve already had a point in time where wind was producing 25 percent and more of the power that was up on the ERCOT grid. Nuclear reactors at the time were around 11 percent.
We can do this; we are doing this. Granted, the wind comes in and out. Thats why you combine with energy storage, thats why you do backup. And ERCOT is becoming very expert in making these things level out.
What could this do for the community? There could still be jobs, and lots of them, and hopefully even more. This could be growth for the community. So, I think the thing to do is to plan.
A-23
Appendix A Nuclear reactors were used in this country as a bridge between the time when we could get to the point where renewables were viable. That day is here; that time is now.
Im personally using this in my own home. I have solar panels on the roof that do more than I ever thought they would. There are days when I can run the whole house and charge an electric car, which does most of my daily driving. Thats possible, thats doable. Were doing it.
Its here today.
Response
This comment expresses concern about adequate discussion for various forms of alternative energy production (including wind, natural gas, solar) and energy efficiency as alternatives to STP license renewal. Consistent with 10 CFR 51.91(a)(1) and 51.91(b), in Chapter 8 of the SEIS, the NRC evaluates potential alternatives to license renewal, including energy production from wind farms, natural gas-fired power plants, and solar plants, and from energy efficiency programs.
The comment provides no new and significant information for this environmental review (as specified in 10 CFR 51.95(c)(3)) and is not evaluated. No changes have been made to the SEIS as a result of this comment.
A.2.3 Cumulative Impacts The original source for the comment in this category (cumulative) can be found in Section A.3 and is labeled with the following identifier: 4-14. The comment is extracted from the original sources.
Comment 4-14: Preliminary findings of small to moderate in terms of cumulative impacts, that should be none. Theres a serious problem here. If this community was hosting wind energy or solar, I dont think you would be having these same impacts.
Moderate is not acceptable. And it matters to whom? Who is it moderate for? To whom is it low? The workers on site?
Response
The staff concluded that the projected incremental impacts associated with continued STP operations would be minimal overall (i.e., the impacts are SMALL except for electric shock which is SMALL to MODERATE as described in Section 4.8.4). While the projected incremental impacts of STP operations during the license renewal term are minimal, in Section 4.12, the staff performed analysis of cumulative impacts for STP license renewal. Cumulative impacts are the environmental effects associated with STP license renewal that are overlaid or added to those associated with other past, present, and reasonably foreseeable future actions (through the period of STP extended operation). The staffs conclusion of SMALL to MODERATE for cumulative impacts associated with STP license renewal is based on its review of the aggregation of the incremental impacts of STP license renewal when added to the impacts associated with the potential construction of two new STP reactor units, neighboring energy projects being considered (i.e., White Stallion Energy Center, LCRA-San Antonio Water System Project, and Mary Rhodes Pipeline Phase II) and the Brazos Bend State Park, Mad Island Marsh Preserve, Mad Island Wildlife Management Area, Big Boggy National Wildlife Refuge, and the Texas Prairie Wetland Project; as well as continued urbanization and habitat fragmentation.
The comment provides no new and significant information for this environmental review (as specified in 10 CFR 51.95(c)(3)) and is not evaluated. No changes have been made to the SEIS as a result of this comment.
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Appendix A A.2.4 Socioeconomic Impact of STP The original sources for the comments in this category (socioeconomic) can be found in Section A.3 and are labeled with the following identifiers: 2-1, 4-13, 5-4, 6-2, 10-2, and 11-1. These comments are extracted from the original sources.
Comment 2-1: STP is the largest employer in Matagorda County, with approximately 1,200 employees.
STPs license renewal will provide jobs for our children and build a strong, stable economic base for our community.
In my two terms on council, Ive had the opportunity to serve with several employees. These people donate their time, their talents to make a difference in our community.
We trust the employees of STP; theyre experts at engineering, operations, maintenance, and the environment. They are our neighbors, they are our friends.
Thank you for being here. Thank you for consideration of the license renewal.
Response
This comment provides similar or the same input (or data) in comparison to the scoping comments (Section A.1.2 of this SEIS), for the staffs environmental analysis of the socioeconomic impacts of STP on local and regional communities. The comments include socioeconomic related items such as employment and community services.
The comments provide no new and significant information for this environmental review (as specified in 10 CFR 51.95(c)(3)) and are not evaluated. No changes have been made to the SEIS as a result of these comments.
Comment 4-13: There are questions about the impacts of when the reactor is down. It becomes expensive. With the 16 percent ownership of Austin Energy, the months that they were down, roughly from November till almost April of 2012November 2011 to almost April, that cost Austin 42 million, and so I think its increasingly expensive as we have these outages.
These reactors have been part of the year-long outages in years past.
Comment 5-4: STPNOCs only objective is to make money for their owners. The appearance and grand gestures toward community and safety are an important part of that process, but the actual implementation of the same is counterproductive to the process of making money.
For example, STP has long been a top producer in the nuclear industry in both profit and output; however, when forced outages in Unit 2 caused the profitability to fall, the new management sent nearly 300 people, 25 percent of STPs workforce, home without pay days before Thanksgiving, and they were unpaid through the end of the year.
Where was the professed concern for family and employees and community then? Taking a backseat to profit, as they always will, and even more so as the plant ages and reasonable maintenance is neglected in the interest of cost savings.
Todays corporate world demands lean, efficient operation. A process of trial and error establishes how lean a company can be and still profit. The workforce is ever more and more comprised of contract workers with lower wages and no benefits.
One might argue thats just business, and I completely agree. However, framed by the reason that we are here, to discuss STPs environmental impact, including the socioeconomic indicators, on our community, we must consider all the factors fully and realistically in the final
[S]EIS.
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Appendix A Comment 6-2: And with that, I think thats the second point, is the efficiency, that we do have an excellent run plant. As my predecessor made the comment just a moment ago about what happened with the contract workers, we are in a unique situation where STP is, because of the price of natural gas, losing money, and as in any household, if you spend more than you make, you go under, so theres that need to conserve resources.
Comment 10-2: The expense of old, aging nuclear reactors is too costly to maintain, especially when the marketplace shows clear signs of embracing renewable generation sources and energy efficiency technologies. If the reactors manage to function until 2027, fine. At that time, they should be replaced with whats new and affordable in the energy market. Committing to extending their licenses now is not fiscally responsible.
Comment 11-1: The expense of old, aging nuclear reactors is too costly to maintain, especially when the marketplace shows clear signs of embracing renewable generation sources and energy efficiency technologies. If the reactors manage to function until 2027, fine. At that time they should be replaced with whats new and affordable in the energy market. Committing to extending their licenses now is not fiscally responsible.
Response
These comments raised concerns about the operational economy (i.e., operational efficiency, viability, and profitability) of STP. The NRC has no role in the operational economy of STP, except for the STP capability to comply with NRC requirements for protecting the public safety, security, and the environment. Furthermore, the NRC has long considered that determination of the economic viability of continuing the operation of a nuclear power plant is an issue that should be left to appropriate energy-planning decisionmakers (State regulatory and utility officials).
The comments provide no new and significant information for this environmental review (as specified in 10 CFR 51.95(c)(3)) and are not evaluated. No changes have been made to the SEIS as a result of these comments.
A.2.5 Water Usage The original sources for the comments in this category (hydrology) can be found in Section A.3 and are labeled with the following identifiers: 4-6 and 5-2. These comments are extracted from the original sources.
Comment 4-6: Youve already got the factor that the huge amount of water being used to cool these reactors means less freshwater can reach the Gulf of Mexico; less blue crabs. That impacts birds.
Comment 5-2: Another aspect of the [S]EIS I think is understated and not given serious weight:
the serious water shortage facing our region. To assign a small impact valuation to a shortage of life-giving necessity is irresponsible. In what will undoubtedly be a new drought of record, this is premature and presumptuous.
Response
Surface water and aquatic resources at STP, and the effects of plant operations on surface water hydrology and aquatic resources, are presented in Sections 2.2.4, 2.2.6, 4.3, and 4.5 of this SEIS, respectively. STP surface water usage, water rights, and surface water withdrawal restrictions imposed on plant operations are specifically discussed in Sections 2.1.7.1 and 4.3.2.
In the State of Texas, water use is heavily regulated through an appropriation process. As discussed in Section 4.3.2, STP is limited to withdrawing 55 percent of the river flow that A-26
Appendix A exceeds 300 cubic feet per second or 135,000 gallons per minute. In other words, STPNOC is limited in its ability to withdraw water from the Colorado River during low flow conditions. This limitation is designed to ensure flow for downstream uses including protection of freshwater inflows to Matagorda Bay during low flow conditions. In support of statewide water planning, regional water supply planning, encompassing the region in which STP is located, is performed by the Lower Colorado Regional Water Planning Group, which accounts for STP surface water withdrawals and consumptive uses along with those of other appropriated uses. While the Lower Colorado Regional Water Planning Group has projected potential surface water shortages in the coming decades based on a set of conservative assumptions, it has identified strategies to address such shortages using a variety of strategies even under conditions similar to the drought of record. Based on the regional planning data and consideration of STP surface water withdrawals, the staff concluded that the impact on surface water resources, including associated instream (aquatic) ecological communities and downstream water availability, in the lower Colorado River from continued withdrawals during the license renewal term would be SMALL.
The comments provide no new and significant information for this environmental review (as specified in 10 CFR 51.95(c)(3)) and are not evaluated. No changes have been made to the SEIS as a result of these comments.
A.2.6 Human Health The original sources for the comments in this category (human health) can be found in Section A.3 and are labeled with the following identifiers: 4-5, 4-7, 4-9, 4-15, 4-17, and 14-5. These comments are extracted from the original sources.
Comment 4-5: Im concerned about at the plantand I think there needs to be further look at tritium. There are tritium problems at the site. Theres monitoring wells that show that.
When you combine that with the fact that the bottom of the main cooling reservoir has some leakage going onthis is documented; this was in the application for South Texas Project 3 and 4okay, where is the research? Where is that tritium going? Is it going out the bottom of the cooling reservoir and going into the Gulf of Mexico?
Is it going into fish? Is it going into the food chain? Is it impacting animals that feed upon these species? Could it be a factor impacting whooping cranes, which are endangered?
Nobody has looked at this, and it needs to be looked at. This is part of the environmental impact assessment.
Comment 4-7: But in addition to that, we need to be looking at, at this point in time, whether the radiation is getting into these species; not just the numbers of fish. There needs to be additional analysis.
Comment 4-9: Now, in 2003 there was leakage of radioactive material outside the reactor, at the base of it. Thats not where radioactive materials supposed to be, ever.
And I remember when these reactors got built. We were told there was a backup system and then another backup system and then another. In fact, there were 12there used to be 12 backup systems, and radioactivity would never escape, and yet it did. It has, within this operating lifetime.
We still have quite a ways to go before the retirement dates of these reactors, and weve got these problems.
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Appendix A Comment 4-17: And even though theres been luck so far, I have great concerns, as do many others who are not here tonightand Ill go ahead and say that Im speaking for many other people as wellthat while we have so far no major accident at the site, there needs to be research in the amount of radiation, radionuclides migrating off the site.
Response
The staff reviewed STPs radioactive effluent monitoring and radiological environmental monitoring programs for potential impacts to the environment (i.e., human beings, aquatic and terrestrial biota) in Section 4.8. The staff concluded that STPs radioactive effluent monitoring and radiological environmental monitoring programs would be effective in controlling the radiological impacts to the workers, the public, and the environment within the radiation protection limits and standards of the NRC and the EPA. These radiological programs are ongoing programs that are performed throughout the licensed operation of STP and are subject to periodic NRC inspection for compliance with regulatory standards. For these reasons, the impacts to the environment are SMALL.
In addition, in Section 4.11 of this SEIS, the staff provided a discussion of a new generic issue, Exposure of aquatic organisms to radionuclides. This is a new issue evaluated by the NRC in its revised license renewal GEIS. This new issue considers the impacts to aquatic organisms from exposure to radioactive effluents discharged from a nuclear power plant during the license renewal term. The GEIS generically concludes that the impacts to aquatic organisms are SMALL for all nuclear power plants when radioactive effluent discharges are maintained within NRC requirements.
In addition, the staffs evaluation of groundwater resources at STP, and the effects of plant operations on groundwater quality, are presented in Sections 2.2.5.2 and 4.4.3 of the SEIS.
Specifically, Section 2.2.5.2 summarizes the results of the staffs review of STPNOCs Groundwater Protection Program for STP, including the placement of site groundwater monitoring wells. As part of this evaluation, the staff specifically reviewed the hydrogeologic investigation prepared for STP in 2009 and the results of ongoing groundwater quality monitoring.
As detailed in Section 4.4.3, the staffs review of data pertaining to seepage from the MCR and the releases of liquids containing tritium within the protected area of STP, Units 1 and 2, found that releases have not altered current groundwater use in the region downgradient of the STP site. No migration of tritium in groundwater in excess of the EPAs drinking water standard is occurring or is projected to occur. The staff further concluded that groundwater-quality impacts would remain SMALL during the license renewal term.
The comments provide no new and significant information for this environmental review (as specified in 10 CFR 51.95(c)(3)) and are not evaluated. No changes have been made to the SEIS as a result of these comments.
Comment 4-15: Im concerned about the fact that as contract employees get laid off, as some of the existing workers are impacted in the world of job cuts, that safety is taking a backseat to economics and trying to shave costs.
That means workers on the site have to work longer hours, have to work more, and potentially are exposed to more radioactivity. That is of great concern, and these things need to be addressed in the environmental impact statement.
And so for a worker, that impact might not be moderate; that impact might be huge. It depends on who were talking about.
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Appendix A
Response
The NRCs mission is to ensure adequate protection of plant workers, members of the public, and the environment from the impacts of radiation from the operation of nuclear power reactors.
The NRC does this by establishing regulatory dose limits for radiological protection. The limits are set to protect workers and the public from the harmful health effects of radiation. The limits are based on the recommendations of standards-setting organizations. Radiation standards reflect extensive scientific study by national and international organizations. The NRC actively participates and monitors the work of these organizations to keep current on the latest trends in radiation protection.
To ensure that nuclear power plants are operated safely, the NRC licenses the plants to operate, licenses the plant operators, and establishes license conditions for the safe operation of each plant. The NRC provides continuous oversight of each plant under the NRCs inspection and enforcement programs. The NRCs reactor oversight process integrates the NRCs inspection, assessment, and enforcement programs. The operating reactor assessment program evaluates the overall safety performance of operating commercial nuclear reactors and communicates those results to applicant management, members of the public, and other government agencies. The assessment program collects information from inspections and performance indicators in order to enable the NRC to arrive at objective conclusions about an applicants safety performance. Based on this assessment information, the NRC determines the appropriate level of agency response, including supplemental inspection and pertinent regulatory actions ranging from management meetings up to and including orders for plant shutdown. The NRC conducts follow-up actions, as applicable, to ensure that the corrective actions designed to address performance weaknesses were effective.
While the NRC maintains regulatory oversight of STP, it is the responsibility of STPNOCs management to ensure that plant operation complies with NRC requirements, including the radiation protection requirements in 10 CFR Part 20, Standards for Protection Against Radiation, at all times. Changes in staffing levels do not alter STPNOCs requirement to comply with NRC regulations.
In Table 4-15 in Section 4.8 of this SEIS, the staff identifies occupational radiation exposures as an issue it reviewed for STP. As stated in Section 4.8, the staff did not identify any potentially new and significant information regarding STPNOCs Radiation Protection Program that would prevent STPNOC from providing adequate protection to its workers. Therefore, the impacts are within the bounds of those discussed in the GEISthat the projected maximum occupational doses during the license renewal term are within the range of doses experienced during normal operations and normal maintenance outages and would be well below regulatory limits.
The comment provides no new and significant information for this environmental review (as specified in 10 CFR 51.95(c)(3)) and is not evaluated. No changes have been made to the SEIS as a result of this comment.
Comment 14-5: This section describes the STP Radiological Environmental Monitoring Program (REMP) and states that reports were reviewed and no adverse radiological trends were observed. It also stated the data showed there was no measurable impact to the environment from operations at STP.
- Include, or incorporate by reference, a synopsis of the data, methods, and analysis used to determine that no adverse trends or no measurable impact to the environment would occur from STP operations in the Final EIS.
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Appendix A
Response
For license renewal, the NRC performed a comprehensive evaluation of all nuclear power plants in the U.S. to assess the scope and impact to public health and safety and the environment from radioactive material released from a nuclear power plant for an additional 20 years of operation.
The impact evaluation performed by the staff and presented in the Generic Environmental Impact Statement for License Renewal of Nuclear Plants (NUREG 1437 (GEIS)) identified 92 environmental issues that were considered for the license renewal evaluation for power reactors in the U.S. The industry, Federal, state, and local governmental agencies, members of the public, and citizen groups commented on and helped identify these 92 issues during the preparation of the GEIS. For each of the identified 92 issues, the staff evaluated existing data from all operating power plants throughout the U.S. From this evaluation, the staff determined which issues could be considered generically and which issues need to be considered on a site specific basis. The GEIS divides the 92 issues that were assessed into two principal categoriesone for generic issues (which are termed Category 1 issues) and the other for site-specific issues (termed Category 2 issues).
Category 1 (generic) issues are those that meet all of the following criteria:
- The environmental impacts associated with the issue have been determined to apply either to all plants or, for some issues, to plants having a specific type of cooling system or other specified plant or site characteristic.
- A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to the impacts (except for collective offsite radiological impacts from the fuel cycle and from high-level waste and spent fuel disposal) for all plants.
- Mitigation of adverse impacts associated with the issue has been considered in the analyses, and it has been determined that additional plant-specific mitigation measures are not likely to be sufficiently beneficial to warrant implementation.
Category 1 issues are termed generic issues because the conclusions related to their environmental impacts were found to be common to all plants (or, in some cases, to plants having specific characteristics such as a particular type of cooling system). For Category 1 issues, a single level of significance was common to all plants, mitigation was considered, and the NRC determined that it was not likely to be beneficial. Issues that were resolved generically are not re-evaluated in the SEIS because the conclusions reached would be the same as in the GEIS, unless new and significant information is identified that would lead the NRC staff to re-evaluate the GEISs conclusions. During the environmental reviews of license renewal applications, the NRC staff makes a concerted effort to determine whether any new and significant information exists that would change the generic conclusions for Category 1 issues.
Radiological issuesradiological impacts on human health and radiation doses to members of the public from the current operation of nuclear power facilitieswere examined from a variety of perspectives, and the impacts were found to be well within NRCs and EPAs radiation protection standards in each instance. As a result, the issues are classified as Category 1 issues.
Category 2 issues are those that require a site-specific review. For each of the Category 2 issues applicable to the site under review, the staff evaluates site-specific data provided by the applicant, other Federal agencies, state agencies, tribal and local governments, as well as information from the open literature and members of the public. From this data, the staff makes a site-specific evaluation of the particular issues and presents its analyses and conclusions in the SEIS for the facility.
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Appendix A This does not mean that the NRC takes the generic (Category 1) issues off the table for public review. If there is new and significant information that would change the conclusions reached in the GEIS, the issue requires a site-specific analysis. During the scoping process and the environmental review, the NRC looks for any information that could demonstrate that there are unique characteristics related to the facility or the environment surrounding the facility that would lead to the conclusion that the generic determination for a particular issue is not valid for a specific site. The NRC staff discusses and evaluates the potential new and significant information relative to impacts of operations during the renewal term in the SEIS.
The NRC expects its applicants to continue to comply with its radiation protection standards during the period of license renewal; therefore, there is no reason to expect radioactive effluents to increase during the period of the renewal license. However, as with all Category 1 conclusions, the NRC staff review evaluates each license renewal application and the site to determine if there is new and significant information that would change the conclusion in the GEIS. In addition, the staff notes that effective use of radioactive waste treatment systems and practices at nuclear power plants have resulted in public radiation dose being well within NRCs ALARA dose criteria contained in Appendix I to 10 CFR Part 50. The NRC staff concluded in the GEIS that the significance of radiation exposures to the public attributable to operation after license renewal will be small at all sites and that this is a generic (Category 1) issue.
The REMP was evaluated in detail in the GEIS and determined that it is a Category 1 issue. As part of the staffs independent review for new and significant information, the staff reviewed STPs radiological environmental monitoring data and found it to be within the bounds of the detailed assessment performed in the GEIS. In addition, the staff reviewed the radiological environmental monitoring data reported by the Texas Department of State Health Services (DSHS) from its Environmental Monitoring Program. The State concluded that the sample data indicated no release of radioactive material to the environment that exceed the regulatory or license limits of the DSHS or any other agency such as the NRC or DOE. The staff has also evaluated groundwater quality and groundwater protection monitoring at STP and the effects of plant operations on groundwater quality, which are presented in Sections 2.2.5.2 and 4.4.3 of the SEIS, respectively. The discussion of STPNOCs REMP is contained in Section 4.8.2 of this SEIS.
The comment provides no new and significant information for this environmental review (as specified in 10 CFR 51.95(c)(3)) and is not evaluated. No changes have been made to the SEIS as a result of this comment.
Comment 14-7: Tritium sample levels at STP, Units 1 and 2, have ranged from 17,000 picocuries per liter (pCi/L) to less than 7,000 pCi/L. The EPA primary drinking water standard for tritium is 20,000 pCi/L. Cumulative impacts to groundwater resources from the increased tritium levels produced by the proposed STP, Units 3 and 4, were not discussed.
- Include a detailed description of how the proposed STP, Units 3 and 4, will affect tritium levels monitored on or near the STP.
NRC staff concluded that the cumulative impact to groundwater resources as a result of relicensing would be small. The building of STP, Units 3 and 4, and the resulting increase in tritium levels, are reasonably foreseeable future actions, which should be included in the cumulative impacts to groundwater resources section. The analysis of cumulative tritium levels for Units 3 and 4 may warrant a designation of cumulative impacts as moderate.
- Analyze the expected cumulative tritium levels as a result of Units 3 and 4 being built and the effect this would have on groundwater resources. After A-31
Appendix A factoring in the impacts from Units 3 and 4; determine if the cumulative impacts are small or moderate.
Response
As discussed in the GEIS, the REMP was evaluated in detail and determined that it is a Category 1 issue. As part of the staffs independent review for new and significant information, the staff reviewed STP radiological environmental monitoring data and found it to be within the bounds of the detailed assessment performed in the GEIS. Separate from the assessment of the impacts of reasonably foreseeable future actions on groundwater use and quality presented in Section 4.11.3.2 of the SEIS, the staff performed a radiological cumulative impacts assessment, which is included in Section 4.11.6. The analysis in Section 4.11.6 encompasses the extended operation of STP, Units 1 and 2, and the projected operation of Units 3 and 4, as well as the reasonably foreseeable installation of a dry fuel (used fuel) storage system. The staff concluded that STPs radioactive effluent monitoring and radiological environmental monitoring programs would be effective in controlling the radiological impacts to the workers, the public, and the environment within the radiation protection limits and standards of the NRC and the EPA.
Specific to the monitoring of tritium in the groundwater, the staffs evaluation of groundwater resources at STP, and the effects of plant operations on groundwater quality, are presented in Sections 2.2.5.2 and 4.4.3 of the SEIS. Section 2.2.5.2 specifically summarizes the results of the staffs review of STPNOCs Groundwater Protection Program for STP, including the placement of site groundwater monitoring wells. As part of this evaluation, the staff reviewed the hydrogeologic investigation prepared for STP in 2009 and the results of ongoing groundwater quality monitoring. STP Groundwater Protection Program monitors the groundwater for inadvertent leaks or spills of liquids containing radioactive material. As detailed in Section 4.4.3, the staffs review of data pertaining to seepage from the main cooling reservoir (MCR), and the releases of liquids containing tritium within the protected area of STP, Units 1 and 2, found that releases have not altered current groundwater use in the region downgradient of the STP site. No migration of tritium in groundwater in excess of the EPAs drinking water standard is occurring or is projected to occur. The staff further concluded that groundwater quality impacts would remain SMALL during the license renewal term.
Also, as discussed in Section 4.8.2, STPNOC has a REMP that monitors the environment outside the STP site to verify that radioactive material from STP is not building up in the environment. STP is required by NRC regulations in 10 CFR Part 20 to limit radiation exposure to members of the public from its radioactive effluents (gaseous, liquids, and direct radiation).
The monitoring programs at STP will alert STP personnel to adverse trends in radiation levels onsite and offsite. These radiological programs are ongoing programs that will be performed throughout the licensed operation of STP and are subject to periodic NRC inspection for compliance with regulatory standards. Since compliance with NRC radiation protection limits is required at all times, the NRC expects STPNOC to take appropriate actions to ensure that the levels of tritium at STP, Units 1 and 2, as well as for the projected Units 3 and 4 comply with NRC limits.
The comment provides no new and significant information for this environmental review (as specified in 10 CFR 51.95(c)(3)) and is not evaluated. No changes have been made to the SEIS as a result of this comment.
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Appendix A A.2.7 Postulated Accidents The original source for the comment in this category (postulated accidents) can be found in Section A.3 and is labeled with the following identifier: 4-3. The comment is extracted from the original source.
Comment 4-3: Theres an increasing amount of fracking, and fracking has been linked to earthquakes, and who knows what will be happening over time. I think the environmental impact research needs to look further at that question.
Response
This comment expresses concerns about the practices of fracking and the need for additional research on fracking as it relates to earthquakes. Additional research on fracking is beyond the scope of this environmental review for STP license renewal.
For the purpose of license renewal, the GEIS concludes that environmental impacts associated with postulated reactor accidents, including earthquake risks, are SMALL (10 CFR Part 51, Subpart A, Appendix B). In Chapter 5 and Appendix F of the SEIS, the staff considers the best available information for seismic data from the U.S. Geological Survey (USGS) applicable for STP in considering the severe accident mitigation alternatives (consideration of applicable cost-beneficial severe accident mitigation measures) and issued RAI to the applicant, as appropriate.
Based on its review, the staff did not identify any new and significant information that would change the GEIS conclusion.
Regarding an induced earthquake related to hydraulic fracturing, because the earthquakes associated with the injection process occur within a few kilometers of the injection wells, the region potentially impacted will be limited to the immediate vicinity of the injection activities.
STP is not located near a shale formation; thus, it is not impacted by fracking.
The comment provides no new and significant information for this environmental review (as specified in 10 CFR 51.95(c)(3)) and is not evaluated. No changes have been made to the SEIS as a result of this comment.
A.2.8 Terrestrial or Aquatic Ecology The original sources for the comments in this category (ecology) can be found in Section A.3 and are labeled with the following identifiers: 5-1, 6-4, and 15-1. These comments are extracted from the original sources.
Comment 5-1: I have several areas of this [S]EIS that I would like to fundamentally disagree with and respectfully ask you to reconsider.
I continually see and hear that STP is lauded as beneficial to local wildlife and habitat, and that angle is accepted and incorporated into the [S]EIS. This is not what I see as a local citizen and one of only three licensed wildlife rehabilitators here in our county.
I see a large corporation doing a great job of showing you and the public the good and beneficial to them part of the picture.
In reality, the contract granted by STP to deal with wildlife issues goes to the lowest bidder, currently GCA. GCA, as well as previous environmental contractors, requires its employees to destroy bird nests, eggs, and infant birds that nest on the site as part of standard housekeeping.
These employees receive no training in applicable laws such as the Migratory Bird Treaty Act, no training on species identification, and [they] dont even know what kind of avian life theyre destroying.
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Appendix A One year ago this week, STP initiated a nuisance-bird eradication program, whereby seed was set out for several days in a row to establish feeding stations on site, and then the seed was replaced with poison.
This project was aimed primarily at several protected species of grackles that congregate in large numbers to overwinter on the Texas Gulf Coast. The poisons that are used are neurotoxic, and the animals that ingest them die a horrible death, often beating themselves to death on the ground.
Predator species such as hawks, eagles, and owls are drawn to the activity and, by ingesting the tainted birds, they ingest the poisons as well. These are biocumulative in the food chain.
I got calls about several raptors on and around the STP site that week that were acting abnormally. One red-tail hawk was brought to my facility but could not be saved.
I e[-]mailed STP authorities before this poisoning took place and asked them to consider other options. They did not reply to my e[-]mail, which is attached; Ill leave my comments here.
There are much more humane ways to keep the site free of unwanted birds, short of killing them, though maybe none so inexpensive. These kinds of activities must be considered in the scoping process, and we must acknowledge that fact, that profit supersedes environmental concerns.
STP also regularly deals with mammals on site with lethal solutions, and when problem animals are relocated, employees lack the training to recognize disease, which may be infectious, and they are not trained on the laws that pertain especially to our fur-bearing species.
Our wildlife rehabilitation group has offered training to STP personnel at no expense but were toldand I quoteWe are not ready to take it to that level.
Additionally, STP regularly kills entire bee colonies that swarm on site. Honeybee numbers are in serious decline, and most of our food crops depend on their pollination.
Response
This comment expresses several concerns regarding STPNOCs onsite wildlife management.
In response to this comment, the NRC issued a request for additional information (RAI) from STPNOC in a letter dated February 15, 2013 (ADAMS No. ML13037A678). STPNOC responded to the RAI by letter dated March 6, 2013 (ADAMS No. ML13079A334). In its RAI response, STPNOC addressed the comment in full. The remainder of this comment response summarizes STPNOCs RAI response.
The commenter asserts that STPNOC requires its contractors and employees to destroy bird nests, eggs, and infant birds that nest on the site. STP site procedure OPGP03-Z0-0025, Site Environmental Compliance, provides instructions for site workers on wildlife protection and control. The purpose of this procedure is to provide guidelines necessary for site compliance with applicable nonradiological environmental laws, regulations, procedures, and commitments at the South Texas site. This procedure prohibits site personnel (other than the licensed animal controllers or those individuals designated by the site Facilities Management Group) from engaging in wildlife protection and control measures or taking any action that may cause harm to any wildlife found on site. Regarding bird nests, eggs, and young, the procedure states, No site personnel shall disturb, move, or destroy an active bird nest, eggs, or young. The procedure also states, If young are inadvertently dislodged from a nest or found separated from their nest, Facilities Management should be contacted and the young protected if possible until arrival of Facilities personnel.
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Appendix A The commenter states that contractor employees are not trained in applicable laws such as the Migratory Bird Treaty Act (MBTA) or in identification of species protected under such laws.
STPNOC does not provide employees or contractors specific training on the Endangered Species Act, the Migratory Bird Treaty Act, or the Bald and Golden Eagle Protection Act and does not provide employees training on identification of protected species that are likely to occupy on the South Texas site. However, as noted above, site procedure OPGP03-Z0-0025 prohibits site personnel from engaging in wildlife protection and control measures or taking any action that may cause harm to any wildlife found on site. STPNOC hires or works with licensed personnel for onsite wildlife management as needed, including Janak Alligators LLC for relocating nuisance alligators and nest stamps; the United States Department of Agriculture (USDA) for wildlife damage management under a Non-Commercial Political Pesticide Applicators License; Orkin Services for bee eradication under the appropriate permit; and Gulf Coast Wildlife Rescue for wildlife rehabilitation.
The commenter discusses a nuisance bird eradication program that the commenter asserts STPNOC put in place to eradicate several species of protected grackles through neurotoxin poisoning. The commenter notes that predator species such as hawks, eagles, and owls may eat the poisoned birds, thereby ingesting the neurotoxin. STPNOC does not have such a program. However, STPNOC has coordinated with the USDA Wildlife Services for wildlife damage management on the site. USDA performs such activities, which include bird depredation (control), at STPNOCs request on an as-needed basis. STPNOC has requested these services specifically to control the overpopulation of blackbirdswhich could include the common grackle (Quiscalus quiscula), a species protected under the MBTA, though not Federally or State-listed as threatened or endangered. The MBTA prohibits removal of all listed species or their parts from private property, except in circumstances for which the property owners have a Federal permit. In cases where the birds pose a health or safety hazard to site employees and equipment, USDA performed bird depredation from 2001 through 2005 and then again in 2010, 2011, and February 2013. When STPNOC requests such services from the USDA, the USDA Animal and Plant Health Service monitor bird activity using a pre-bait to determine the number of target and non-target species present in the area and to determine an acceptable area for targeting. The USDA then replaces the pre-bait with Starlicide, a chemical salt also known as Compound DRC-1339. Starlicide is a slow-acting avicide registered for controlling blackbirds, starlings, pigeons, gulls, magpies, and ravens that damage agricultural crops or personal property or prey upon Federally designated threatened or endangered species. STPNOC also uses Fog Force', which is a bird repellent, during refueling outages, when the personnel population onsite is at its maximum. Fog Force'is not a poison and, therefore, will not affect the food chain for predators. STPNOC has also used various bird deterrent measures in the past, including falcons, avian laser dispersal agents, butane cannons, deterrent bird spikes, plastic owls, bird screen netting, and prey calls.
The commenter asserts that agents of the applicant regularly kill or relocate mammals on the site. As discussed previously, STPNOC has a site procedure that prohibits untrained site personnel from engaging in wildlife management activities. STPNOC Facilities Management has contracted with licensed animal controllers or individuals to trap and relocate mammals found in areas that potentially pose a health or safety threat to site employees or equipment.
Such activities occur on an as-needed basis.
Finally, the commenter asserts that STPNOC kills bee colonies on the site. The commenter suggests that honeybees, specifically, may be targeted. STPNOC has eradicated bee colonies in cases where they have been in populated areas that could pose a health and safety threat to employees or plant equipment. In these instances, STPNOC Facilities Management contracts a A-35
Appendix A licensed pest controller. Bee colonies in non-populated areas that do not pose a health or safety concern are not disturbed. No specific species are targeted.
The comment provides no new and significant information for this environmental review (as specified in 10 CFR 51.95(c)(3)) and is not evaluated. No changes have been made to the SEIS as a result of this comment.
Comment 6-4: I look at the overall impact, county- and area-wide. Every year Matagorda County is rated number one in migratory bird population in different species. That tells me, with STP having been here for 30 years, that environmentally they have had a minimal, at best, impact upon this area. Otherwise we would not see that kind of wildlife still in the region across this area.
Response
This comment suggests that the high avian species diversity in Matagorda County supports a conclusion that STP has had a minimal impact on the environment since it began its operation.
The comment provides no new and significant information for this environmental review (as specified in 10 CFR 51.95(c)(3)) and is not evaluated. No changes have been made to the SEIS as a result of this comment.
Comment 15-1: Pursuant to Section 7 of the Endangered Species Act (ESA), the U.S. Nuclear Regulatory Commission initiated and is currently undergoing informal consultation with the U.S. Fish and Wildlife Service regarding [F]ederally listed species:
Threatened San Marcos salamander (Eurycea nana)
Piping plover (Charadrius melodus)
Endangered Houston toad (Bufo houstonensis)
Texas blind salamander (Typhlomolge rathbuni)
Golden-cheeked warbler (Dendroica chrysoparia)
Northern aplomado falcon (Falco Femoralis septentrionalis)
Whooping crane (Grus amercana)
Attwaters greater prairie-chicken (Tympanuchus cupido attwateri)
Black-capped vireo (Vireo atricapilla)
Candidate Species. Candidate species are those being considered for possible listing pursuant to the ESA. While these species are not legally protected under the ESA, the FWS provides information on these species for consideration in your environmental review process and to encourage efforts to avoid adverse impacts to these species. The following candidate freshwater mussel species may occur within the project area.
Freshwater mussels Texas Fatmucket Lampsilis bracteata Smooth Pimpleback Quadrula houstonensis Texas Pimpleback Quadrula petrina Texas Fawnsfoot Truncilla macrodon The enclosure details best management practices for use during maintenance activities in the project area and along transmission corridors to assist in reducing impacts to freshwater mussels.
Response
A-36
Appendix A This comment indicates that the NRC and FWS are currently in consultation under Section 7 of the Endangered Species Act of 1973, as amended (ESA), for several Federally listed species.
Section 4.7 of the SEIS discusses Federally listed species and Section 7 consultation. The staff has updated this section between publication of the draft SEIS and the final SEIS to reflect the current status of consultations.
The comment also provides best management practices that could reduce impacts during maintenance activities in the project area and along transmission line corridors. The best management practices are applicable to construction activities and maintenance activities that cross or potentially affect river, stream, or tributary aquatic habitat. However, the proposed license renewal would not involve any construction, refurbishment, or other land-disturbing activities.
The comment provides no new and significant information for this environmental review (as specified in 10 CFR 51.95(c)(3)) and is not evaluated. No changes have been made to the SEIS as a result of this comment.
Comment 14-4: After reviewing [F]ederal and [S]tate threatened and endangered species lists, a no effect determination was made on 31 species, and a is not likely to adversely affect (NLAA) determination was made on 10 species. A no effect determination is appropriate when a proposed action will not affect listed species. No further consultation with the [FWS] is required if a [F]ederal agency makes a no effect determination. A[n] NLAA determination is appropriate when a proposed action will have insignificant or beneficial effects to listed species.
Written concurrence must be obtained from the FWS to satisfy Section 7 consultation requirements of the Endangered Species Act for the 10 species where a[n] NLAA determination was made.
Obtain written concurrence from [FWS] on the 10 species where a[n] NLAA determination was made. Include this concurrence in the Final EIS.
Response
The commenter summarizes the NRC staffs determinations regarding Federally threatened and endangered species. The commenter states that written concurrence with the NRCs determination that the proposed action is not likely to adversely affect 10 species must be obtained from the FWS in accordance with Section 7 of the ESA. The NRC staff requested the FWSs concurrence with its effect determinations in a letter dated December 10, 2012 (ADAMS No. ML12285A415). Section 4.7 of the SEIS discusses Federally listed species and Section 7 consultation. Although closure of informal consultation with FWS is not required for the final SEIS, the staff has updated this section of the final SEIS to reflect the current status of consultations. Neither a separate biological assessment or a biological opinion has been identified as waaranted by the NRC staff or FWS. .
A.2.9 Uranium Fuel Cycle and Waste Management The original sources for the comments in this category (waste) can be found in Section A.3 and are labeled with the following identifiers: 7-1, 9-1, 10-4, and 14-8. These comments are extracted from the original sources.
Comment 7-1: I suggest that this license proceeding be stopped until such time as the Waste Confidence Rulemaking finds in favor of the concept of waste confidence.
Comment 9-1: The U.S. Court of Appeals for the District of Columbia has recently ruled as invalid the waste confidence rule, which states that it is safe to store radioactive waste onsite at power plants for extended periods. Since no reasonable solution to the storage and A-37
Appendix A containment of nuclear waste exists anywhere in the world, it is irresponsible to consider producing more of it by relicensing nuclear reactors.
Comment 10-4: The U.S. Court of Appeals for the District of Columbia has recently ruled as invalid the waste confidence rule.
Response
The commenters correctly observe that on June 8, 2012, the U.S. Court of Appeals for the District of Columbia vacated the NRCs Waste Confidence Decision and Rule. The comment is incorporated into Chapter 6 of the SEIS. In this chapter, the staff provides the status of this rule.
Comment 14-8: Uranium mining impacts were generally addressed in the GElS for In-Situ Leach Uranium Milling Facilities (NUREG-1910). However, potential site[ ]specific impacts were not addressed in that document. As was discussed during a conference call with NRC on January 9, 2013; these site[ ]specific assessments for [t]ribal consultation and environmental justice are initiated for individual mining project licenses. This was not readily apparent from reading the [draft] SEIS.
- We recommend the final [S]EIS clarify the relationship amongst various NRC programs and their respective documents and clarify when [t]ribal consultations and [environmental justice] assessments are initiated for actions.
Long Term Storage of Onsite Nuclear Waste.
As indicated in the [draft] SEIS, this issue is currently being addressed in an EIS to support the update of the Waste Confidence Decision and Rule (WCD). In addition, no licenses dependent upon this decision and rule will be issued until the WCD EIS has been completed. If the results of the WCD EIS identify information that requires a supplement to this EIS, NRC will perform the appropriate additional NEPA review for those issues before making a final licensing decision. EPA will review the WCD EIS and any appropriate supplemental NEPA documentation, as required.
Response
The NRCs environmental review for this SEIS is confined to environmental matters relevant to the extended period of operation requested by the applicant. As noted in this comment, the NRC conducts separate environmental reviews for uranium mining, as well as other actions related to the uranium fuel cycle and reactor operations and construction. Tribal consultation and environmental justice assessments are conducted for each review, as appropriate, and discussed in each respective environmental review.
The NRC acknowledges that the EIS currently being prepared for the NRCs Waste Confidence Decision and Rule will be reviewed by EPA. Chapter 6 of this final SEIS contains a discussion of the NRCs actions on the Waste Confidence Decision and Rule.
The comment provides no new and significant information for this environmental review (as specified in 10 CFR 51.95(c)(3)) and is not evaluated. No changes have been made to the SEIS as a result of this comment.
A.2.10 License Renewal Rule The original sources for the comments in this category (rulemaking or issuance of regulation) can be found in Section A.3 and are labeled with the following identifiers: 13-1 and 14-1. These comments are extracted from the original sources.
A-38
Appendix A Comment 13-1: We respectfully recommend that all operating license renewals be reduced from [20] to [10]-year limits. Our reasoning is the loss of scientific predictability given the current crisis in global change. World scientists have no experience-based strategies to reduce loss of life from yet unknown events. This is true worldwide and not just with our neighbors living in
[STP] areas. Our plea is to ask that the NRC exercise greater caution in relicensing due to loss of environmental predictability.
A [10]-year license renewal will at least buy more time for an early warning system and perhaps one last chance to avoid the tipping point. We believe shorter licensing will add the extra time needed to ensure at least the campfire is extinguished before leaving the nuclear reactor site.
Comment 14-1: The [draft] SEIS states that If the renewed license is issued, the appropriate energy-planning decision makers, along with STPNOC, will ultimately decide if the reactor units will continue to operate on factors such as the need for power. While informative, this statement does not explain to the public and Federal agencies the need for the power in regard to the region or Nation.
- Include detailed language in the purpose and need statement about why the energy created by the facility is needed.
Response
In summary, these comments express concern about the adequacy of the license renewal rule.
These comments are beyond the scope of the NRCs environmental review. Comment petitioning to issue, amend, or rescind the license renewal rule is governed by 10 CFR 2.802, Petition for Rulemaking, and is beyond the scope of this environmental review for STP license renewal.
The comments provide no new and significant information for this environmental review (as specified in 10 CFR 51.95(c)(3)) and are not evaluated. No changes have been made to the SEIS as a result of these comments.
A.2.11 Tribal Consultation Comment 14-9: The [U.S.] has a unique legal relationship with Federally recognized tribes based on the Constitution, treaties, statutes, Executive Orders, and court decisions. This relationship includes recognition of the right of tribes as sovereign governments to self-determination, and an acknowledgment of the Federal Governments trust responsibility to tribes. The precise nature of this relationship will vary depending upon the identity of the tribes, nature of trust resources, and Federal agencies involved.
The [draft] SEIS indicates that tribes were identified and contacted for the limited purpose of discussing the National Historic Preservation Act, but [it] does not provide complete information to determine if [t]ribal officials have been contacted for government-to-government consultation on the full scope of potential effects of the [STP] under Executive Order (EO) 13175. It appears that the proposed project could affect tribal resources and citizens or government services.
EPA recommends NRC take the following actions to satisfy consultation with tribes under EO 13175:
- identify all potentially affected tribes and tribal resources,
- identify potentially applicable treaties, laws, policies, legal responsibilities and duties, and
- contact and, as appropriate, initiate consultation with tribes concerning the potential effects of its action.
A-39
Appendix A
Response
In accordance with the NRCs National Environmental Policy Act (NEPA) implementing regulation (10 CFR Part 51), as well as the spirit of EO 13175, the NRC staff identified and initiated dialogue with 10 Federally recognized Native American tribal governments that have historic ties to the region surrounding STP or would be potentially affected by continued operation of STP or both. Because the NRC has chosen to comply with National Historic Preservation Act (NHPA) through incorporation of NHPA Section 106 requirements in its NEPA review (per 36 CFR Part 800), tribes were invited to participate in the identification and possible decisions concerning historic properties, as well as invited to provide input to other areas of environmental review such as terrestrial ecology, aquatic ecology, hydrology, cultural resources, and socioeconomic issues (among others). Four tribes responded to the NRC with scoping comments ranging from concerns with potential accidents, requests to resurvey the STP site, requests for notification if historic and cultural resources of cultural significance were discovered on the STP site, and statements of no concern with the undertaking. The NRC responded to the tribes in October 2011 and has taken the comments into consideration while preparing this SEIS. This correspondence can be found in Appendix D, and a summary of these actions can be found in Section 4.9.6. Consequently, dialogue with, and comments from, Federally recognized tribes have been considered during the draft period of this SEIS.
A.2.12 Noise Levels Comment 14-3: Page 2-62 states noise from STP operations sometimes exceeds 55 A weighted decibels (dBA) and can be detected off site. This noise level has been identified as causing annoyance with outdoor activities; while a level of 45 dBA can have undesirable effects to indoor activities.
- It is unclear if this information is based on a study of STP noise and how it affects the surrounding area or if the noise levels cited are those typical of industrial operations similar to STP. Please clarify whether the noise level was derived from a site specific study of the STP or [if] the noise level given as an example of those that would typify industrial operations similar to STP.
Also, clarify if 55 dBA is the level of noise detected at the STP, the property line, or nearby sensitive noise receptors.
Response
The noise levels cited on page 2-62 of the draft SEIS are typical of industrial operations and are given as an example of those that would typify industrial operations similar to STP. Given the industrial nature of most nuclear power plants, loud noises can be heard offsite. Sources of noise vary, but include the sound of turbines, large pump motors, and other industrial machines and equipment.
Noise is a Category 1 environmental impact (NEPA) issue (see Table B-1 in Appendix B to Subpart A of 10 CFR Part 51, Environmental Effect of Renewing the Operating License of A Nuclear Power Plant) that has been generically resolved in the 1996 GEIS for license renewal.
The environmental review for the license renewal GEIS found that noise has not been a problem at existing operating nuclear power plants, and, since power plant operations are not expected to change during the license renewal term, noise conditions also would not change at any nuclear power plant. Based on a review of the STP Environmental Report, scoping comments, other available information, and site information visit, the NRC did not identify any new and significant information about noise at STP that would change the conclusions presented in the license renewal GEIS. STPNOC also reported that there have been no noise A-40
Appendix A complaints. Noise levels during the period of extended operation are, therefore, expected to remain unchanged from what is currently being experienced. There would also be no new noise sources or increase in noise levels, either in frequency distribution or in intensity.
The comment provides no new and significant information for this environmental review (as specified in 10 CFR 51.95(c)(3)) and is not evaluated. No changes have been made to the SEIS as a result of this comment.
A.2.13 Comments Beyond the Scope of NRCs Environmental Review The original sources for the comments in this category (emergency, safety, or Fukushima) can be found in Section A.3 and are labeled with the following identifiers: 4-4, 4-8, 4-10, 4-11, 4-12, 4-16, 4-18, 5-3, 6-1, 8-1, 10-1, 10-3, and 11-2. These comments are extracted from the original sources.
In summary, these comment express concerns about plant security, emergency preparedness, safety, and plant aging. These comments are beyond the scope of the license renewal environmental review. As discussed during the scoping public meeting of March 2, 2011, the NRC addresses plant performance as part of the ongoing regulatory oversight provided for all currently operating power reactors. Therefore, the NRC does not re-evaluate them as part of the license renewal review, in accordance with 10 CFR 54.29, Standard for issuance of a renewed license, and 10 CFR 54.30, Matter not subject to a renewal review. Furthermore, the aging management of structures and components within the scope of the license renewal safety review will be addressed in the staffs safety evaluation report, separately from the environmental review.
Emergency Preparedness Comment 4-12: And its good that it appears that no radioactivity got released, but what if this fire was bigger? What if it was elsewhere? What if circumstances had somehow been different?
It concerns me that reactors are operating in a community that, after all of these years, still has no paid professional fire department. Im sure the volunteers are very good people and probably trained, but if youve got nuclear reactor in your backyard, that means that there should be a paid professional fire department that can be called on.
Furthermore, I think everyone should be asking the question, if this was a very large fire, extensive, how long would it take to get backup fire departments here; for example, from Houston?because I have a feeling that its longer than just the drive to get here.
These are serious safety concerns.
Response
These comments express concerns regarding emergency preparedness in the unlikely event of a reactor accident at STP. As stated during the scoping public meeting of March 2, 2011, comments concerning emergency preparedness are beyond the scope of license renewal environmental review. This is because this subject is under the NRCs review as a part of the oversight of the current licensing basis. The NRC addresses these areas of performance as part of the ongoing regulatory oversight, including during the STP period of extended operation if the licenses are renewed.
Over the years, the combined efforts of the NRC, Federal Emergency Management Agency (FEMA), STPNOC, Texas State and local officials, as well as thousands of volunteers and local first responders (such as police, firefighters, and medical response personnel), have produced A-41
Appendix A comprehensive emergency preparedness programs that assure the adequate protection of the public in the event of a radiological emergency at STP. The emergency preparedness planning incorporates the means to rapidly identify, evaluate, and react to a wide spectrum of emergency conditions. Emergency plans are dynamic and are routinely reviewed and updated to reflect an ever changing environment during the operation of STP, including during the period of extended operation if the STP licenses are renewed.
The Commission considered the need for a review of emergency planning issues during its license renewal rulemaking proceedings on 10 CFR Part 54, which included public notice and comment. As discussed in the Statement of Consideration for this rulemaking (56 FR 64966),
the programs for emergency preparedness apply to all nuclear power facilities. Requirements for emergency planning are in the regulations at 10 CFR 50.47 and Appendix E to 10 CFR Part
- 50. Through its standards and required exercises, the Commission reviews existing emergency preparedness plans throughout the life of STP, keeping up with changing demographics and other site-related factors. Therefore, the Commission determination at the time of the rule change was that emergency planning was adequately considered on an ongoing basis and did not need to be part of license renewal.
The most recent emergency drill for STP occurred on May 9, 2012. The results of the STP drill are published in a FEMA report and are viewable at the following Web site:
http://www.nrc.gov/about-nrc/emerg-preparedness/related-information/fema-after-action-reports.html These comments do not provide new and significant information for this environmental review, and these are not evaluated further in the development of the SEIS.
Safety and Aging Management of Plant Systems Comment 4-8: There have been problems with this reactor over the years, and they seem to be increasing. While we read about great safety reports and great numbers of days without shutting down, well, thats good, and great worker safety; thats what the reports say.
But when you look across the countrytheres an expert by the name of David Lochbaum; he has worked for the NRC; hes also worked for the Union of Concerned Scientists, and he did a report called The Nuclear Tightrope.
And he looked at plants where they had year-long outages. What he found was a typical pattern, that in a reactor that had a serious accident, serious problem, there would be glowing reports, right up until the accident happened. Nothing was wrong, everything was perfect, and then all of a sudden, catastrophic problem that had been missed all along that just wasnt showing up. And then we had this major problem.
So this has happened over and over, and I think its time for this reportand for the NRC in generalto look deeply into whats going on.
Comment 4-10: Recently, there have been problems with the control rods getting stuck, not being able to function properly. We had an outage just last week that involved that, control rods dropping when theyre not supposed to.
That is unsafe. That means that we dont have full control of this reactor. Im concerned. I personally live in Austin, Texas, and Austin is an owner of this reactor. Im happy that we get some power from it, but Im very concerned about this safety aspect, for the people who live here, for people downwind and around the state.
Comment 4-11: Metal fatigue increases as reactors age. The most dangerous years are the early startup years and the final years of a reactor. So, to consider giving a nuclear reactor A-42
Appendix A 20 more years of time to operate 14 and 15 years ahead of time, to me this is like telling somebody youre going to sell them a used car, but youre going to sell it to them today, and theyre going to receive it 14 and 15 years later. That doesnt make sense.
This decision is being looked at and this meeting is being held way, way too early. This is wrong timing, and it needs to hold, it needs to wait.
Short of declaring that its time to look at transition away, I would urge you to do no action for now and to delay until we know more. With the current problems with the reactor, with the current fire, that needs to be fully investigated.
Comment 4-16: And I wish I could say that I shared the opinion of transparency for [STP]. I find it to be of concern that information is not more forthcoming.
And in terms of safety, Im very concerned about the cutting of employees. I think thats a way to increase safety risks.
Comment 4-18: And, also, we need to prepare, because historically at some of the sites that were touted as being the safest, the most productive, the ones that were running beautifully, that is exactly where the major problems have occurred in U.S. nuclear history.
And, I think we should be looking carefully. I think we should be more forthcoming with information, digging into recent events such as the fire that occurred; digging deeper on many issues and looking more closely.
Comment 5-3: As time goes on and more and more equipment ages and fails, safety and concern for community must be sacrificed if shareholders are to be kept satisfied.
Comment 6-1: One is that what I have observed and seen and heard is that STP has an excellent safety record. It seeks to be transparent; it seeks to let people know when things are going on and seeks to be proactive, from my point of view.
I believe, from my point of view, that STP has the safety of everyone at stake and is one of the best-run plants as far as safety and energy in the U.S.
Comment 6-3: Also, I cannot comment about what my predecessor has said about the environment on plant site. However, I know that with safety being what it is and the need for safety, they are taking that as the most important course.
Comment 8-1: These nuclear reactors are old, and continued incidents like the recent fire on January 8th should make them come under more scrutiny. These reactors should not get an automatic 20 year renewal. They should in fact [be] made to go into planned retirement as they pose too many risks to human life and health to the surrounding community.
Comment 10-1: I am commenting on the proposed relicensing of Units 1 [and] 2 at the [STP]
Docket ID NRC-2010-0375. These reactors should not be relicensed at this time because of the following concern.
Units 1 [and] 2, which are 24 and 25 years old, are licensed to run for 40 yearsuntil 2027-28.
We should wait 14 years until 2027 and determine what shape they are in at that time before considering relicense. Already the reactors are showing signs of age that should concern anyone wishing to avoid accidents at nuclear power plants:
- fire in the reactor 2 main transformer on Jan[uary] 8, 2013,
- replacement of the control rod drive mechanisms in both reactors deviate from standard measurements sufficiently that many of them are permanently stuck and unusable, and A-43
Appendix A
- Unit 2 was off-line for 5 winter months, indicating it is no longer reliable.
Comment 10-3: The [STP] is on a list of nuclear plants with a high risk of flooding-related failures. A leaked July 2011 [NRC] report labeled not for public release deals with flood risk to plants across the country if dams break upstream. The very fact that the agency charged with regulating nuclear plants would label a report of significant import to the public it serves as not for public release, shows that agency as not a reliable one to decide relicensing issues. Since the STP is considered at risk for flooding, it should not be relicensed at this time.
Comment 11-2: The [STP] is on a list of nuclear plants with a high risk of flooding-related failures. A leaked July 2011 [NRC] report labeled not for public release deals with flood risk to plants across the country if dams break upstream. The very fact that the agency charged with regulating nuclear plants would label a report of significant import[ant] to the public it serves as not for public release, shows that agency as not a reliable one to decide relicensing issues.
Since the STP is considered at risk for flooding, it should not be relicensed at this time.
Response
These comments express concerns about the safety issues or aging management of STP plant systems or both. These comments are beyond the scope of license renewal environmental review. This is because this subject is under the NRCs review as a part of the oversight of the current licensing basis. The NRC addresses these areas of performance as part of the ongoing regulatory oversight, including during the STP period of extended operation if the licenses are renewed. In addition, the aging management of structures and components within the scope of the license renewal safety review will be addressed in the staffs safety evaluation report for STP. This is separate from the environmental review which focuses on the environmental impacts of license renewal. The comments have been provided to the license renewal safety review team for consideration in the development of the SER as appropriate.
In the safety review, the staff examines STPNOCs programs and processes designed to manage the effects of structures and components aging and to ensure adequate protection of the publics health and safety during the 20-year license renewal period. This may result in additional aging management measures as necessary.
The comments provide no new and significant information for this environmental review (as specified in 10 CFR 51.95(c)(3)) and are not evaluated. No changes have been made to the SEIS as a result of these comments.
Events at Fukushima Japan The original source for this comment in this category (Fukushima) can be found in Section A.3 and is labeled with the following identifier: 4-4. This comment is extracted from the original sources.
Comment 4-4: In the case of Fukushima, reactor number 1 had been set to retire [1] month before the accident there, which, you know, involved their diesel generators, to large extent, as well as tsunami and earthquake.
So, if that plant had been shut down as it should have beenthey were given 10 more years, not 20, like were looking at in this casethen that would be one less reactor that had a meltdown. And, the whole world is feeling the impacts of that disaster in many different ways, including radiation that travels around the globe and impacts fisheries, it impacts products and workers lives and people who live in Japan, as well as in the U.S. its been measured. This radiation does reach the U.S.
Response
A-44
Appendix A This comment expresses concerns about the safety issues and aging management of STP plant systems in comparison to the accident at Fukushima, Japan. The aging management of STP structures and components within the scope of the license renewal safety review is addressed in the staffs safety evaluation report (SER) for STP. This is separate from the environmental review, which focuses on the environmental impacts of license renewal. The comments have been provided to the license renewal safety review team for consideration in the development of the SER as appropriate. The SER for STP license renewal is available on the web for public inspection:
http://www.nrc.gov/reactors/operating/licensing/renewal/applications/south-texas-project.html Fukushima lessons learned. On March 11, 2011, a massive earthquake off the east coast of Honshu, Japan, produced a devastating tsunami that struck Fukushima. The six-unit Fukushima Dai-ichi nuclear power plant was directly impacted by these events. The resulting damage caused the failure of several of the units safety systems needed to maintain cooling water flow to the reactors. As a result of the loss of cooling, the fuel overheated, and there was a partial meltdown of the fuel contained in several of the reactors. Damage to the systems and structures containing reactor fuel resulted in the release of radioactive material to the surrounding environment.
In 2011, the Commission directed the staff to convene an agency task force of senior leaders and experts to conduct a methodical and systematic review of the relevant NRC regulatory requirements, programs, and processes, including their implementation, and to recommend whether the agency should make near-term improvements to its regulatory system. As part of the short-term review, the task force concluded that, while improvements are expected to be made as a result of the lessons learned from the Fukushima events, the continued operation of nuclear power plants and licensing activities for new plants do not pose an imminent risk to public health and safety (NRC 2011).
The NRC will continue to evaluate the need to make improvement to existing regulatory requirements based on NRC assessments of the Fukushima events as more information is learned. To the extent that any revisions are made to NRC regulatory requirements, they would be made applicable to STP regardless of whether or not STP has renewed licenses. The information available about the event, NRC assessment of the event, NRC actions in response to the event, and other information on the ongoing lessons learned are available for public inspection at the NRC web site:
http://www.nrc.gov/reactors/operating/ops-experience/japan-info.html A.2.14 Text Clarification The original sources for the comments in this category (clarification) can be found at the end of this Section A.2 and are labeled with the following identifiers: 12-1, 14-2, and 14-6. These comments are extracted from the original sources.
Comment 12-1: On Page 2-1, lines 25 and 26, revise the sentence to state The Units 1 and 2 steam generators were replaced in 2000 and 2002, respectively, with new Westinghouse steam generators.
On Page 2-27, Figure 2-2, revise the STAR legend to read STP, Units 1 and 2.
Comment 14-2: The dates listed for the Texas Pollution Discharge Elimination System (TPDES) in this section and Table C-1 contradict each other. Section 2.2.4.2 states the TPDES permit was administratively continued by the Texas Commission on Environmental Quality A-45
Appendix A (TCEQ) on July 13, 2009, but Table C-1 states a new TPDES permit was approved April 5, 2012.
- Clarify the correct date of issuance for the TPDES permit issued to the STP.
Comment 14-6: This section [4.11.3.1] lists many water projects and the respective water use totals for each project. As presented, it is difficult to determine the cumulative effects to surface water.
- In order to provide a more effective understanding of the cumulative impacts to surface water, include a tabular summary of project water use totals in the final [S]EIS.
Response
These comments are editorial or text clarification in nature. The comments are incorporated into the SEIS, as appropriate. The SEIS sections being revised are listed as follow:
Comment SEIS Section Summary Comment 12-1 2.1.1, 2.2.6.1 Staff updated Section 2.1.1 to correct the dates as specified in the comment.
There is no change to Figure 2-2 of Section 2.2.6.1 (this Figure 2-2 was extracted from the NRC EIS for the proposed STP, Units 3 and 4)
Comment 14-2 2.2.4.2 Staff updated Section 2.2.4.2 relative to the issuance of a revised TPDES permit to STPNOC in April 2012 and for consistency with Table C-1 in this SEIS.
Comment 14-6 4.11.3.1 Consistent with the review criteria in the NRC standard review plan for analysis of cumulative impacts, the staff takes into account compliance with environmental quality standards and requirements that have been imposed by other Federal, State, regional, local, and affected Native American tribal agencies. The staff also incorporates, by reference, any information contained in final environmental documents previously prepared by the NRC staff that relates to the same facility.
Consequently, as part of the staffs independent evaluation of the potential cumulative impacts on surface water resources presented in Section 4.12.3.1, the staff used, and incorporated by reference, the analyses of the major regional projects previously considered and presented in two primary sources. These reference sources are (1) NRCs environmental impact statement for combined licenses (COLs) for South Texas Project Electric Generating Station, Units 3 and 4 (cited as NRC 2011b) and (2) the Lower Colorado River Water Planning Group, 2011 Region K Water Plan (cited as LCRWPG 2010). The staff notes that the data presented in these references cannot simply be taken additively for comparison purpose to some threshold that correlates to the staff conclusion of impact significance (such as in construction of a tabular summary of project water use totals).
The staff has revised Sections 4.12.3 and 4.12.3.1 (formerly 4.11.3 and 4.11.3.1) to further clarify the references cited and data used, as appropriate, to improve clarity with respect to the conclusions drawn for cumulative impacts to surface water resources.
A-46
Appendix A A.3 Public Meeting Transcript Excerpts and Comment Letters Public Meeting Transcript January 15, 2013, afternoon session Comment 1-1 A-47
Appendix A Comment 1-2 Comment 2-1 A-48
Appendix A Comment 3-1 A-49
Appendix A A-50
Appendix A Comment 4-1 A-51
Appendix A Comment 4-2 A-52
Appendix A Comment 4-3 Comment 4-4 Comment 4-5 A-53
Appendix A Comment 4-6 Comment 4-7 Comment 4-8 A-54
Appendix A Comment 4-9 A-55
Appendix A Comment 4-10 Comment 4-11 A-56
Appendix A Comment 4-12 A-57
Appendix A Comment 4-13 Comment 4-14 Comment 4-15 A-58
Appendix A A-59
Appendix A Public Meeting Transcript January 15, 2013, evening session Comment 5-1 A-60
Appendix A A-61
Appendix A Comment 5-2 A-62
Appendix A Comment 5-3 Comment 5-4 A-63
Appendix A Comment 6-1 A-64
Appendix A Comment 6-2 Comment 6-3 Comment 6-4 A-65
Appendix A Comment 6-5 Comment 4-16 A-66
Appendix A Comment 4-16 (cont)
Comment 4-17 Comment 4-18 A-67
Appendix A Comment 7-1 A-68
Appendix A Comment 8-1 A-69
Appendix A Comment 9-1 A-70
Appendix A Comment 10-1 Comment 10-2 Comment 10-3 Comment 10-4 A-71
Appendix A Comment 11-1 Comment 11-2 A-72
Appendix A Comment 12-1 A-73
Appendix A Comment 13-1 A-74
Appendix A Environmental Protection Agency Comments Comment 14-1 Comment 14-2 A-75
Appendix A Comment 14-3 Comment 14-4 Comment 14-5 A-76
Appendix A Comment 14-6 Comment 14-7 Comment 14-8 A-77
Appendix A Comment 14-9 A-78
Appendix A Comment 15-1 A-79
Appendix A A-80
Appendix A A-81
Appendix A A-82
APPENDIX B NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE RENEWAL OF NUCLEAR POWER PLANTS
B NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE RENEWAL OF NUCLEAR POWER PLANTS The table in this appendix summarizes the National Environmental Policy Act (NEPA) issues for license renewal of nuclear power plants identified in Table B-1 in Appendix B, Subpart A, to Title 10 Part 51 of the Code of Federal Regulations (10 CFR Part 51). Data supporting this table are contained in NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Throughout this supplemental environmental impact statement (SEIS), generic issues are also referred to as Category 1 issues, and site-specific issues are also referred to as Category 2 issues. In addition, as described in Section 1.4, the U.S. Nuclear Regulatory Commission (NRC) has approved a revision to its environmental protection regulation, 10 CFR Part 51. The revised rule consolidates similar Category 1 and 2 issues, changes some Category 2 issues into Category 1 issues, and consolidates some of those issues with existing Category 1 issues. These issues are discussed in Section 4.11.
Table B-1. Summary of Issues and Findings Issue Type of Issue Finding Surface Water Quality, Hydrology, and Use Impacts of Generic SMALL. Impacts are expected to be negligible during refurbishment refurbishment on because best management practices are expected to be employed to surface water control soil erosion and spills.
quality Impacts of Generic SMALL. Water use during refurbishment will not increase appreciably refurbishment on or will be reduced during plant outage.
surface water use Altered current Generic SMALL. Altered current patterns have not been found to be a problem patterns at intake at operating nuclear power plants and are not expected to be a and discharge problem during the license renewal term.
structures Altered salinity Generic SMALL. Salinity gradients have not been found to be a problem at gradients operating nuclear power plants and are not expected to be a problem during the license renewal term.
Altered thermal Generic SMALL. Generally, lake stratification has not been found to be a stratification of problem at operating nuclear power plants and is not expected to be a lakes problem during the license renewal term.
Temperature Generic SMALL. These effects have not been found to be a problem at effects on sediment operating nuclear power plants and are not expected to be a problem transport capacity during the license renewal term.
Scouring caused Generic SMALL. Scouring has not been found to be a problem at most by discharged operating nuclear power plants and has caused only localized effects cooling water at a few plants. It is not expected to be a problem during the license renewal term.
Eutrophication Generic SMALL. Eutrophication has not been found to be a problem at operating nuclear power plants and is not expected to be a problem during the license renewal term.
Discharge of Generic SMALL. Effects are not a concern among regulatory and resource chlorine or other agencies, and are not expected to be a problem during the license B-1
Appendix B Issue Type of Issue Finding biocides renewal term.
Discharge of Generic SMALL. Effects are readily controlled through National Pollutant sanitary wastes Discharge Elimination System (NPDES) permit and periodic and minor chemical modifications, if needed, and are not expected to be a problem during spills the license renewal term.
Discharge of other Generic SMALL. These discharges have not been found to be a problem at metals in operating nuclear power plants with cooling-tower-based heat-wastewater dissipation systems and have been satisfactorily mitigated at other plants. They are not expected to be a problem during the license renewal term.
Water use conflicts Generic SMALL. These conflicts have not been found to be a problem at (plants with operating nuclear power plants with once-through heat-dissipation once-through systems.
cooling systems)
Water use conflicts Site-specific SMALL OR MODERATE. The issue has been a concern at nuclear (plants with cooling power plants with cooling ponds and at plants with cooling towers.
ponds or cooling Impacts on instream and riparian communities near these plants could towers using be of moderate significance in some situations.
makeup water from See §51.53(c)(3)(ii)(A).
a small river with low flow)
Aquatic Ecology Refurbishment Generic SMALL. During plant shutdown and refurbishment, there will be negligible effects on aquatic biota because of a reduction of entrainment and impingement of organisms or a reduced release of chemicals.
Accumulation of Generic SMALL. Accumulation of contaminants has been a concern at a few contaminants in nuclear power plants but has been satisfactorily mitigated by replacing sediments or biota copper alloy condenser tubes with those of another metal. It is not expected to be a problem during the license renewal term.
Entrainment of Generic SMALL. Entrainment of phytoplankton and zooplankton has not been phytoplankton and found to be a problem at operating nuclear power plants and is not zooplankton expected to be a problem during the license renewal term.
Cold shock Generic SMALL. Cold shock has been satisfactorily mitigated at operating nuclear plants with once-through cooling systems, has not endangered fish populations, or been found to be a problem at operating nuclear power plants with cooling towers or cooling ponds, and is not expected to be a problem during the license renewal term.
Thermal plume Generic SMALL. Thermal plumes have not been found to be a problem at barrier to migrating operating nuclear power plants and are not expected to be a problem fish during the license renewal term.
Distribution of Generic SMALL. Thermal discharge may have localized effects but is not aquatic organisms expected to affect the larger geographical distribution of aquatic organisms.
Premature Generic SMALL. Premature emergence has been found to be a localized emergence of effect at some operating nuclear power plants but has not been a B-2
Appendix B Issue Type of Issue Finding aquatic insects problem and is not expected to be a problem during the license renewal term.
Gas Generic SMALL. Gas supersaturation was a concern at a small number of supersaturation operating nuclear power plants with once-through cooling systems but (gas bubble has been satisfactorily mitigated. It has not been found to be a disease) problem at operating nuclear power plants with cooling towers or cooling ponds and is not expected to be a problem during the license renewal term.
Low dissolved Generic SMALL. Low dissolved oxygen has been a concern at one nuclear oxygen in the power plant with a once-through cooling system but has been discharge effectively mitigated. It has not been found to be a problem at operating nuclear power plants with cooling towers or cooling ponds and is not expected to be a problem during the license renewal term.
Losses from Generic SMALL. These types of losses have not been found to be a problem predation, at operating nuclear power plants and are not expected to be a parasitism, and problem during the license renewal term.
disease among organisms exposed to sublethal stresses Stimulation of Generic SMALL. Stimulation of nuisance organisms has been satisfactorily nuisance mitigated at the single nuclear power plant with a once-through organisms cooling system where previously it was a problem. It has not been (e.g.,shipworms) found to be a problem at operating nuclear power plants with cooling towers or cooling ponds and is not expected to be a problem during the license renewal term.
Aquatic Ecology (for Plants with Once-Through and Cooling-Pond Heat-Dissipation Systems)
Entrainment of fish Site-specific SMALL, MODERATE, OR LARGE. The impacts of entrainment are and shellfish in small at many plants but may be moderate or even large at a few early life stages plants with once-through and cooling-pond cooling systems. Further, ongoing efforts in the vicinity of these plants to restore fish populations may increase the numbers of fish susceptible to intake effects during the license renewal period, such that entrainment studies conducted in support of the original license may no longer be valid.
See §51.53(c)(3)(ii)(B).
Impingement of Site-specific SMALL, MODERATE, OR LARGE. The impacts of impingement are fish and shellfish small at many plants but may be moderate or even large at a few plants with once-through and cooling-pond cooling systems.
See §51.53(c)(3)(ii)(B).
Heat shock Site-specific SMALL, MODERATE, OR LARGE. Because of continuing concerns about heat shock and the possible need to modify thermal discharges in response to changing environmental conditions, the impacts may be of moderate or large significance at some plants.
See §51.53(c)(3)(ii)(B).
Aquatic Ecology (for Plants with Cooling-Tower-Based Heat-Dissipation Systems)
Entrainment of fish Generic SMALL. Entrainment of fish has not been found to be a problem at and shellfish in operating nuclear power plants with this type of cooling system and is early life stages not expected to be a problem during the license renewal term.
B-3
Appendix B Issue Type of Issue Finding Impingement of Generic SMALL. The impingement has not been found to be a problem at fish and shellfish operating nuclear power plants with this type of cooling system and is not expected to be a problem during the license renewal term.
Heat shock Generic SMALL. Heat shock has not been found to be a problem at operating nuclear power plants with this type of cooling system and is not expected to be a problem during the license renewal term.
Groundwater Use and Quality Impacts of Generic SMALL. Extensive dewatering during the original construction on refurbishment on some sites will not be repeated during refurbishment on any sites.
groundwater use Any plant wastes produced during refurbishment will be handled in the and quality same manner as in current operating practices and are not expected to be a problem during the license renewal term.
Groundwater use Generic SMALL. Plants using less than 100 gpm are not expected to cause conflicts (potable any groundwater use conflicts.
and service water; plants that use
<100 gallons per minute (gpm)
Groundwater use Site-specific SMALL, MODERATE, OR LARGE. Plants that use more than conflicts (potable 100 gpm may cause groundwater use conflicts with nearby and service water, groundwater users. See §51.53(c)(3)(ii)(C).
and dewatering plants that use
>100 gpm Groundwater use Site-specific SMALL, MODERATE, OR LARGE. Water use conflicts may result conflicts (plants from surface water withdrawals from small water bodies during low using cooling flow conditions which may affect aquifer recharge, especially if other towers withdrawing groundwater or upstream surface water users come online before the makeup water from time of license renewal. See §51.53(c)(3)(ii)(A).
a small river)
Groundwater use Site-specific SMALL, MODERATE, OR LARGE. Ranney wells can result in conflicts (Ranney potential groundwater depression beyond the site boundary. Impacts wells) of large groundwater withdrawal for cooling tower makeup at nuclear power plants using Ranney wells must be evaluated at the time of application for license renewal. See §51.53(c)(3)(ii)(C).
Groundwater Generic SMALL. Groundwater quality at river sites may be degraded by quality degradation induced infiltration of poor-quality river water into an aquifer that (Ranney wells) supplies large quantities of reactor cooling water. However, the lower quality infiltrating water would not preclude the current uses of groundwater and is not expected to be a problem during the license renewal term.
Groundwater Generic SMALL. Nuclear power plants do not contribute significantly to quality degradation saltwater intrusion.
(saltwater intrusion)
Groundwater Generic SMALL. Sites with closed-cycle cooling ponds may degrade quality degradation groundwater quality. Because water in salt marshes is brackish, this (cooling ponds in is not a concern for plants located in salt marshes.
B-4
Appendix B Issue Type of Issue Finding salt marshes)
Groundwater Site-specific SMALL, MODERATE, OR LARGE. Sites with closed-cycle cooling quality degradation ponds may degrade groundwater quality. For plants located inland, (cooling ponds at the quality of the groundwater in the vicinity of the ponds must be inland sites) shown to be adequate to allow continuation of current uses.
See §51.53(c)(3)(ii)(D).
Terrestrial Ecology Refurbishment Site-specific SMALL, MODERATE, OR LARGE. Refurbishment impacts are impacts insignificant if no loss of important plant and animal habitat occurs.
However, it cannot be known whether important plant and animal communities may be affected until the specific proposal is presented with the license renewal application. See §51.53(c)(3)(ii)(E).
Cooling tower Generic SMALL. Impacts from salt drift, icing, fogging, or increased humidity impacts on crops associated with cooling tower operation have not been found to be a and ornamental problem at operating nuclear power plants and are not expected to be vegetation a problem during the license renewal term.
Cooling tower Generic SMALL. Impacts from salt drift, icing, fogging, or increased humidity impacts on native associated with cooling tower operation have not been found to be a plants problem at operating nuclear power plants and are not expected to be a problem during the license renewal term.
Bird collisions with Generic SMALL. These collisions have not been found to be a problem at cooling towers operating nuclear power plants and are not expected to be a problem during the license renewal term.
Cooling pond Generic SMALL. Impacts of cooling ponds on terrestrial ecological resources impacts on are considered to be of small significance at all sites.
terrestrial resources Powerline right-of- Generic SMALL. The impacts of ROW maintenance on wildlife are expected way (ROW) to be of small significance at all sites.
management (cutting and herbicide application)
Bird collisions with Generic SMALL. Impacts are expected to be of small significance at all sites.
powerlines Impacts of Generic SMALL. No significant impacts of electromagnetic fields on terrestrial electromagnetic flora and fauna have been identified. Such effects are not expected to fields on flora and be a problem during the license renewal term.
fauna Floodplains and Generic SMALL. Periodic vegetation control is necessary in forested wetlands wetland on underneath powerlines and can be achieved with minimal damage to powerline ROW the wetland. No significant impact is expected at any nuclear power plant during the license renewal term.
Threatened and Endangered Species Threatened or Site-specific SMALL, MODERATE, OR LARGE. Generally, plant refurbishment endangered and continued operation are not expected to adversely affect B-5
Appendix B Issue Type of Issue Finding species threatened or endangered species. However, consultation with appropriate agencies would be needed at the time of license renewal to determine whether or not threatened or endangered species are present and whether or not they would be adversely affected.
See §51.53(c)(3)(ii)(E).
Air quality Air quality during Site-specific SMALL, MODERATE, OR LARGE. Air quality impacts from plant refurbishment refurbishment associated with license renewal are expected to be small. However, vehicle exhaust emissions could be cause for (non-attainment concern at locations in or near non-attainment or maintenance areas.
and maintenance The significance of the potential impact cannot be determined without areas) considering the compliance status of each site and the number of workers expected to be employed during the outage.
See §51.53(c)(3)(ii)(F).
Air quality effects Generic SMALL. Production of ozone and oxides of nitrogen is insignificant of transmission and does not contribute measurably to ambient levels of these gases.
lines Land Use Onsite land use Generic SMALL. Projected onsite land use changes required during refurbishment and the renewal period would be a small fraction of any nuclear power plant site and would involve land that is controlled by the applicant.
Powerline ROW Generic SMALL. Ongoing use of powerline ROWs would continue with no change in restrictions. The effects of these restrictions are of small significance.
Human Health Radiation Generic SMALL. During refurbishment, the gaseous effluents would result in exposures to the doses that are similar to those from current operation. Applicable public during regulatory dose limits to the public are not expected to be exceeded.
refurbishment Occupational Generic SMALL. Occupational doses from refurbishment are expected to be radiation within the range of annual average collective doses experienced for exposures during pressurized-water reactors and boiling-water reactors. Occupational refurbishment mortality risk from all causes including radiation is in the mid-range for industrial settings.
Microbiological Generic SMALL. Occupational health impacts are expected to be controlled by organisms continued application of accepted industrial hygiene practices to (occupational minimize exposure to workers.
health)
Microbiological Site-specific SMALL, MODERATE, OR LARGE. These organisms are not organisms (public expected to be a problem at most operating plants except possibly at health) (plants plants using cooling ponds, lakes, or canals that discharge to small using lakes or rivers. Without site-specific data, it is not possible to predict the canals, or cooling effects generically. See §51.53(c)(3)(ii)(G).
towers or cooling ponds that discharge to a B-6
Appendix B Issue Type of Issue Finding small river)
Noise Generic SMALL. Noise has not been found to be a problem at operating plants and is not expected to be a problem at any plant during the license renewal term.
Electromagnetic Site-specific SMALL, MODERATE, OR LARGE. Electrical shock resulting from fieldsacute direct access to energized conductors or from induced charges in effects (electric metallic structures have not been found to be a problem at most shock) operating plants and generally are not expected to be a problem during the license renewal term. However, site-specific review is required to determine the significance of the electric shock potential at the site. See §51.53(c)(3)(ii)(H).
Electromagnetic Uncategorized UNCERTAIN. Biological and physical studies of 60-hertz fieldschronic electromagnetic fields have not found consistent evidence linking effects harmful effects with field exposures. However, research is continuing in this area and a consensus scientific view has not been reached.
Radiation Generic SMALL. Radiation doses to the public will continue at current levels exposures to public associated with normal operations.
(license renewal term)
Occupational Generic SMALL. Projected maximum occupational doses during the license radiation renewal term are within the range of doses experienced during normal exposures (license operations and normal maintenance outages, and would be well below renewal term) regulatory limits.
Socioeconomic Impacts Housing impacts Site-specific SMALL, MODERATE, OR LARGE. Housing impacts are expected to be of small significance at plants located in a medium or high population area and not in an area where growth control measures that limit housing development are in effect. Moderate or large housing impacts of the workforce associated with refurbishment may be associated with plants located in sparsely populated areas or in areas with growth control measures that limit housing development.
See §51.53(c)(3)(ii)(I).
Public services: Generic SMALL. Impacts to public safety, social services, and tourism and public safety, social recreation are expected to be of small significance at all sites.
services, and tourism and recreation Public services: Site-specific SMALL OR MODERATE. An increased problem with water shortages public utilities at some sites may lead to impacts of moderate significance on public water supply availability. See §51.53(c)(3)(ii)(I).
Public services: Site-specific SMALL, MODERATE, OR LARGE. Most sites would experience education impacts of small significance but larger impacts are possible (refurbishment) depending on site- and project-specific factors. See §51.53(c)(3)(ii)(I).
Public services: Generic SMALL. Only impacts of small significance are expected.
education (license renewal term)
Offsite land use Site-specific SMALL OR MODERATE. Impacts may be of moderate significance at B-7
Appendix B Issue Type of Issue Finding (refurbishment) plants in low population areas. See §51.53(c)(3)(ii)(I).
Offsite land use Site-specific SMALL, MODERATE, OR LARGE. Significant changes in land use (license renewal may be associated with population and tax revenue changes resulting term) from license renewal. See §51.53(c)(3)(ii)(I).
Public services: Site-specific SMALL, MODERATE, OR LARGE. Transportation impacts (level of transportation service) of highway traffic generated during plant refurbishment and during the term of the renewed license are generally expected to be of small significance. However, the increase in traffic associated with the additional workers and the local road and traffic control conditions may lead to impacts of moderate or large significance at some sites.
See §51.53(c)(3)(ii)(J).
Historic and Site-specific SMALL, MODERATE, OR LARGE. Generally, plant refurbishment archaeological and continued operation are expected to have no more than small resources adverse impacts on historic and archaeological resources. However, the National Historic Preservation Act requires the Federal agency to consult with the State Historic Preservation Officer to determine whether or not there are properties present that require protection.
See §51.53(c)(3)(ii)(K).
Aesthetic impacts Generic SMALL. No significant impacts are expected during refurbishment.
(refurbishment)
Aesthetic impacts Generic SMALL. No significant impacts are expected during the license (license renewal renewal term.
term)
Aesthetic impacts Generic SMALL. No significant impacts are expected during the license of transmission renewal term.
lines (license renewal term)
Postulated Accidents Design basis Generic SMALL. The NRC staff has concluded that the environmental impacts accidents of design-basis accidents are of small significance for all plants.
Severe accidents Site-specific SMALL. The probability weighted consequences of atmospheric releases, fallout onto open bodies of water, releases to groundwater, and societal and economic impacts from severe accidents are small for all plants. However, alternatives to mitigate severe accidents must be considered for all plants that have not considered such alternatives. See §51.53(c)(3)(ii)(L).
Uranium Fuel Cycle and Waste Management Offsite radiological Generic SMALL. Offsite impacts of the uranium fuel cycle have been impacts (individual considered by the Commission in Table S-3 of this part. Based on effects from other information in the GEIS, impacts on individuals from radioactive than the disposal of gaseous and liquid releases including radon-222 and technetium-99 spent fuel and are small.
high-level waste)
Offsite radiological Generic The 100-year environmental dose commitment to the U.S. population impacts (collective from the fuel cycle, high-level waste, and spent fuel disposal effects) excepted, is calculated to be about 14,800 person rem, or 12 cancer fatalities, for each additional 20-year power reactor operating term.
B-8
Appendix B Issue Type of Issue Finding Much of this, especially the contribution of radon releases from mines and tailing piles, consists of tiny doses summed over large populations. This same dose calculation can theoretically be extended to include many tiny doses over additional thousands of years as well as doses outside the United States. The result of such a calculation would be thousands of cancer fatalities from the fuel cycle, but this result assumes that even tiny doses have some statistical adverse health effect which will not ever be mitigated (for example no cancer cure in the next thousand years), and that these doses projected over thousands of years are meaningful; however, these assumptions are questionable. In particular, science cannot rule out the possibility that there will be no cancer fatalities from these tiny doses. For perspective, the doses are very small fractions of regulatory limits, and even smaller fractions of natural background exposure to the same populations.
Nevertheless, despite all the uncertainty, some judgment as to the regulatory NEPA implications of these matters should be made and it makes no sense to repeat the same judgment in every case. Even taking the uncertainties into account, the Commission concludes that these impacts are acceptable in that these impacts would not be sufficiently large to require the NEPA conclusion, for any plant, that the option of extended operation under 10 CFR Part 54 should be eliminated. Accordingly, while the Commission has not assigned a single level of significance for the collective effects of the fuel cycle, this issue is considered Category 1 (Generic).
Offsite radiological Generic Chapter 6 of this SEIS provides further discussion of these impacts.
impacts (spent fuel and high-level waste disposal)
Nonradiological Generic SMALL. The nonradiological impacts of the uranium fuel cycle impacts of the resulting from the renewal of an operating license for any plant are uranium fuel cycle found to be small.
Low-level waste Generic SMALL. The comprehensive regulatory controls that are in place and storage and the low public doses being achieved at reactors ensure that the disposal radiological impacts to the environment will remain small during the term of a renewed license. The maximum additional onsite land that may be required for low-level waste storage during the term of a renewed license and associated impacts will be small.
Nonradiological impacts on air and water will be negligible. The radiological and nonradiological environmental impacts of long-term disposal of low-level waste from any individual plant at licensed sites are small. In addition, the Commission concludes that there is reasonable assurance that sufficient low-level waste disposal capacity will be made available when needed for facilities to be decommissioned consistent with NRC decommissioning requirements.
Mixed waste Generic SMALL. The comprehensive regulatory controls and the facilities and storage and procedures that are in place ensure proper handling and storage, as disposal well as negligible doses and exposure to toxic materials for the public and the environment at all plants. License renewal will not increase the small, continuing risk to human health and the environment posed by mixed waste at all plants. The radiological and nonradiological B-9
Appendix B Issue Type of Issue Finding environmental impacts of long-term disposal of mixed waste from any individual plant at licensed sites are small. In addition, the Commission concludes that there is reasonable assurance that sufficient mixed waste disposal capacity will be made available when needed for facilities to be decommissioned consistent with NRC decommissioning requirements.
Onsite spent fuel Generic SMALL. The expected increase in the volume of spent fuel from an additional 20 years of operation can be safely accommodated on site with small environmental effects through dry or pool storage at all plants if a permanent repository or monitored retrievable storage is not available.
Nonradiological Generic SMALL. No changes to generating systems are anticipated for license waste renewal. Facilities and procedures are in place to ensure continued proper handling and disposal at all plants.
Transportation Generic SMALL. The impacts of transporting spent fuel enriched up to 5 percent uranium-235 with average burnup for the peak rod to current levels approved by NRC up to 62,000 megawatt days per metric-ton uranium and the cumulative impacts of transporting high-level waste to a single repository, such as Yucca Mountain, Nevada are found to be consistent with the impact values contained in 10 CFR 51.52(c),
Summary Table S-4, Environmental Impact of Transportation of Fuel and Waste to and from One Light-Water-Cooled Nuclear Power Reactor. If fuel enrichment or burnup conditions are not met, the applicant must submit an assessment of the implications for the environmental impact values reported in §51.52.
Decommissioning Radiation doses Generic SMALL. Doses to the public will be well below applicable regulatory standards regardless of which decommissioning method is used.
Occupational doses would increase no more than 1 man-rem caused by buildup of long-lived radionuclides during the license renewal term.
Waste Generic SMALL. Decommissioning at the end of a 20-year license renewal management period would generate no more solid wastes than at the end of the current license term. No increase in the quantities of Class C or greater than Class C wastes would be expected.
Air quality Generic SMALL. Air quality impacts of decommissioning are expected to be negligible either at the end of the current operating term or at the end of the license renewal term.
Water quality Generic SMALL. The potential for significant water quality impacts from erosion or spills is no greater whether decommissioning occurs after a 20-year license renewal period or after the original 40-year operation period, and measures are readily available to avoid such impacts.
Ecological Generic SMALL. Decommissioning after either the initial operating period or resources after a 20-year license renewal period is not expected to have any direct ecological impacts.
Socioeconomic Generic SMALL. Decommissioning would have some short-term impacts socioeconomic impacts. The impacts would not be increased by delaying decommissioning until the end of a 20-year relicense period, but they might be decreased by population and economic growth.
B-10
Appendix B Issue Type of Issue Finding Environmental Justice Environmental Uncategorized NONE. The need for and the content of an analysis of environmental justice justice will be addressed in plant-specific reviews.
Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 B-11
APPENDIX C APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS
C APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS The Atomic Energy Act (AEA) authorizes the U.S. Nuclear Regulatory Commission (NRC) to enter into agreement with any state to assume regulatory authority for certain activities. For example, in accordance with Section 274 of the AEA, as amended, beginning on March 1, 1963, the State of Texas assumed regulatory responsibility over the following nuclear material usages:
- byproduct materials as defined in Section 11e.(1) of the Act,
- byproduct materials as defined in Section 11e.(2) of the Act,
- source materials, and
- special nuclear materials in quantities not sufficient to form a critical mass.
The Texas Department of State Health Services-Radiation Program administers the Texas Agreement State Program.
In addition to implementing some Federal programs, state legislatures develop state laws, which are subject to applicable Federal statutes and regulations. State laws supplement, as well as implement, Federal laws for protection of air, water quality, and groundwater. State legislation may address solid waste management programs, locally rare or endangered species, and historic and cultural resources.
The Clean Water Act (CWA) allows for primary enforcement and administration through state agencies, provided the state program is at least as stringent as the Federal program. The state program must conform to the CWA and to the delegation of authority for the Federal National Pollutant Discharge Elimination System (NPDES) Program from the U.S. Environmental Protection Agency (EPA) to the state. In accordance with the CWA, for surface water, the primary mechanism to control water pollution is the requirement that directs dischargers (e.g., point source dischargers) to obtain an NPDES permit or, in the case of states where the authority has been delegated from EPA, a State Pollutant Discharge Elimination System (SPDES) permit.
C.1 Federal and State Environmental Requirements Certain environmental requirements may have been delegated to state authorities for implementation, enforcement, or oversight by the applicable Federal agencies in exercising the agencies regulations. Table C-1 provides a list of STP licenses and permits needed for compliance with the major requirements of the Texas environmental laws that affect the license renewal of South Texas Project (STP). These licenses and permits are addressed in this supplemental environmental impact statement (SEIS), pursuant to the NRC ESRP, Section 1.3, Compliance and Consultations, including applicable tribal consultation.
Table C-1. Licenses and Permits Permit Number Dates Responsible Agency License to operate STP, Issued: 3/22/1988 NPF-76 NRC Unit 1 Expires: 8/20/2027 License to operate STP, Issued: 12/16/1988 NPF-80 NRC Unit 2 Expires: 12/15/2028 C-1
Appendix C Permit Number Dates Responsible Agency Hazardous materials Issued: 6/29/2011 U.S. Department of 0622110 550 067S shipments registration Expired: 6/30/2012 Transportation Permits for maintenance, 10570 Issued: 11/4/2004 U.S. Army Corps of dredging (barge slip) Expires: 12/31/2014 Engineers (USACE)
Permits for maintenance, Issued: 7/21/2009 SWG-1992-02707 USACE dredging (intake) Expires: 12/31/2019 Texas Pollutant Discharge Issued: 4/5/2012 WQ0001908000 TCEQ Elimination System Permit Expires: 12/1/2014 Air Permit (auxiliary Issued: 12/23/2004 7410 TCEQ boilers) Expires: 12/23/2014 Air Permit (emission Issued: 1/18/2011 0801 TCEQ sources) Expires: 1/18/2016 Registration of Industrial 30651, EPA ID Issued: 8/16/1976 TCEQ and Hazardous Waste No. TXD020810503 Expires: Not applicable Texas Commission on Environmental Quality Issued: Not applicable Potable Water System TCEQ (TCEQ) ID Expires: Not applicable No. 1610103/1610051 Source: STP License Renewal Application (STPNOC 2010).
C.2 References Several operating permit applications may be prepared and submitted. Regulatory approval or permits or both would be received prior to license renewal approval by the NRC. As a convenient source of references of environmental requirements, Table C-2 lists representative Federal, state, and local approvals by the responsible agencies applicable to license renewal.
Table C-2. Federal, State, and Local Laws and Other Requirements.
STP is subject to other requirements regarding various aspects of their environmental program.
Representatives of those requirements are briefly described below.
License, Permit, or Other Responsible Required Approval (or Submittal) Agency Authority Relevance Air Quality Protection Required for sources that are not U.S. EPA or Texas Air Pollution Nuclear Power plants are subject exempt and are major sources, TCEQ Control to 40 CFR Part 61, Subpart H, affected sources subject to the Acid RegulationTX National Emissions Standards Rain Program, sources subject to Administrative for Emissions of Radionuclides, new source performance standards, Code, Title 30 which is included in the terms and or sources subject to National conditions of the Title V Emission Standards for Hazardous Operating Permit.
Air Pollutants C-2
Appendix C License, Permit, or Other Responsible Required Approval (or Submittal) Agency Authority Relevance Water Resources Protection NPDES PermitConstruction Site U.S. EPA or CWA Any plant refurbishment involving Stormwaterrequired before TCEQ (33 USC 1251 et construction of more than 2 ha making point source discharges of seq.); (5 ac) of land would require a storm water from a construction 40 CFR Part 122 Stormwater Pollution Prevention project that disturbs more than 2 ha Plan and Construction Site Storm (5 ac) of land Water Discharge Permit.
NPDES PermitIndustrial Facility U.S. EPA or CWA Stormwater would be discharged Stormwaterrequired before TCEQ (33 USC 1251 et from the nuclear power plants making point source discharges of seq.); during operations. Stormwater storm water from an industrial site 40 CFR Part 122 would discharge through existing outfalls covered by a permit.
NPDES PermitProcess Water U.S. EPA or CWA Processed industrial wastewater Dischargerequired before making TCEQ (33 USC 1251 et would be discharged through point source discharges of industrial seq.); existing outfalls covered by the process wastewater 40 CFR Part 122 permit.
Spill Prevention Control and U.S. EPA or CWA A Spill Prevention Control and Countermeasures Planrequired TCEQ (33 USC 1251 et Countermeasures Plan is for any facility that could discharge seq.); required at nuclear power plants diesel fuel in harmful quantities into 40 CFR Part 112 storing large volumes of diesel navigable waters or onto adjoining fuel or other petroleum products shorelines or both.
CWA, Section 401, Water Quality U.S. EPA or CWA, Section 401 Certification for operation of a Certificationrequired to be TCEQ (33 USC 1341); nuclear power plant may require submitted to the agency a Federal license or permit responsible for issuing any Federal (e.g., a CWA, Section 404, Permit license or permit to conduct an or a CWA, Section 401, Water activity that may result in a Quality Certification).
discharge of pollutants into waters of a state New Underground Storage Tanks U.S. EPA or Resources This registration is required if new System Registrationrequired TCEQ Conservation and underground storage tank within 30 days of bringing a new Recovery Act systems would be installed during underground storage tank system (RCRA), as refurbishment at a nuclear power into service amended, plant.
Subtitle I (42 USC 6991a-6991i);
40 CFR §280.22 Above Ground Storage Tank Applicable This permit is required if new Permitrequired to install, remove, State Fire above-ground diesel fuel storage repair, or alter any stationary tank Marshal tanks would be installed during for the storage of flammable or refurbishment at a nuclear power combustible liquids plant. In accordance with STP ER, there is no refurbishment.
Waste Management & Pollution Prevention Registration and Hazardous Waste U.S. EPA or RCRA, as Generators of hazardous waste C-3
Appendix C License, Permit, or Other Responsible Required Approval (or Submittal) Agency Authority Relevance Generator Identification Number TCEQ amended must notify EPA that the wastes required before a person who (42 USC 6901 et exist and require management in generates over 100 kg (220 lb) per seq.), Subtitle C compliance with RCRA.
calendar month of hazardous waste ships the hazardous waste off site Hazardous Waste Facility Permit U.S. EPA or RCRA, as Hazardous wastes are usually not required if hazardous waste will TCEQ amended disposed of on site at nuclear undergo nonexempt treatment by (42 USC 6901 et power plants. Hazardous wastes the generator; be stored on site for seq.), Subtitle C generated on site are not longer than 90 days by the generally stored for more than generator of 1,000 kg (2,205 lb) or 90 days. However, should a more of hazardous waste per nuclear power plant store wastes month; be stored on site for longer on site for greater than 90 days than 180 days by the generator of for characterization, profiling, or between 100 and 1,000 kg (220 scheduling for treatment or and 2,205 lb) of hazardous waste disposal, a Hazardous Waste per month; be disposed of on site; Facility Permit would be required.
or be received from off site for treatment or disposal Emergency Planning & Response List of Material Safety Data State and local Emergency Nuclear power plant operators Sheetssubmission required for emergency Planning and are required to submit List of hazardous chemicals (as defined in planning Community Right- Material Safety Data Sheets to 29 CFR Part 1910) that are stored agencies to-Know Act of state and local emergency on site in excess of their threshold (State 1986 (EPCRA), planning agencies.
quantities Emergency Section 311 Response (42 USC 11021);
Commission or 40 CFR §370.20 SERC)
Annual Hazardous Chemical State and local EPCRA, If hazardous chemicals have Inventory Reportsubmission emergency Section 312 been stored at a nuclear power required when hazardous response (42 USC 11022); plant during the preceding year in chemicals have been stored at a agencies 40 CFR §370.25 amounts that exceed threshold facility during the preceding year in (SERC); local quantities, plant operators would amounts that exceed threshold fire department be required to submit an Annual quantities Hazardous Chemical Inventory Report.
Notification of Onsite Storage of an State and local EPCRA, If an extremely hazardous Extremely Hazardous Substance emergency Section 304 substance stored at a nuclear submission required within 60 days response (42 USC 11004); power plant in a quantity greater after onsite storage begins of an agencies 40 CFR §355.30 than the threshold planning extremely hazardous substance in (SERC) quantity, plant operators would a quantity greater than the prepare and submit the threshold planning quantity Notification of Onsite Storage of an Extremely Hazardous Substance.
Annual Toxics Release Inventory U.S. EPA or EPCRA, If required, nuclear power plant Reportrequired for facilities that TCEQ Section 313 operators would prepare and have 10 or more full-time (42 USC 11023); submit a Toxics Release C-4
Appendix C License, Permit, or Other Responsible Required Approval (or Submittal) Agency Authority Relevance employees and are assigned 40 CFR Part 372 Inventory Report to EPA.
certain standards Industrial Classification codes.
Transportation of Radioactive U.S. Hazardous When shipments of radioactive Wastes and Conversion Products Department of Material materials are made, nuclear Packaging, Labeling, and Routing Transportation Transportation Act power plant operators would Requirements for Radioactive (HMTA) comply with U.S. Department of Materialsrequired for packages (49 USC 1501 et Transportation packaging, containing radioactive materials that seq.); AEA, as labeling, and routing will be shipped by truck or rail amended (42 USC requirements.
2011 et seq.);
49 CFR Parts 172, 173, 174, 177, and 397 Biotic Resource Protection Threatened and Endangered U.S. Fish and Endangered The NRC would consult with the Species Consultationrequired Wildlife Service Species Act of FWS and state agencies between the responsible Federal (FWS) and 1973, as amended regarding the impact of license agencies and affected states to other (16 USC 1531 et renewal on threatened or ensure that the project is unlikely to applicable seq.) endangered species or their jeopardize the continued existence state agencies critical habitat.
of any species listed at the Federal (listed in or state level as endangered or Appendix D of threatened or result in destruction this SEIS) of critical habitat of such species CWA, Section 404, (Dredge and USACE CWA Any dredging or placement of fill Fill) Permitrequired to place (33 USC 1251 et material into wetlands within the dredged or fill material into waters seq.); jurisdiction of the USACE at a of the U.S., including areas 33 CFR Parts 323 nuclear power plant would require designated as wetlands, unless and 330 a Section 404 permit.
such placement is exempt or authorized by a Nationwide permit or a regional permit (A notice must be filed if a Nationwide or regional permit applies.)
Cultural Resources Protection Archaeological and Historical State Historic National Historic The NRC would consult with the Resources Consultationrequired Preservation Preservation Act of State or Tribal Historic before a Federal agency approves Officer or 1966, as amended Preservation Officers or both and a project in an area where Tribal Historic (16 USC 470 et applicable Indian tribes archaeological or historic resources Preservation seq.); (e.g., tribes that have historical might be located Officer or both Archaeological ties to the land) regarding the (listed in and Historical impacts of license renewal and Appendix D of Preservation Act of the results of archaeological and this SEIS) 1974 architectural surveys of nuclear (16 USC 469- power plant site.
469c-2);
Antiquities Act of C-5
Appendix C License, Permit, or Other Responsible Required Approval (or Submittal) Agency Authority Relevance 1906 (16 USC 431 et seq.);
Archaeological Resources Protection Act of 1979, as amended (16 USC 470aa-mm)
C-6
APPENDIX D CONSULTATION CORRESPONDENCE
D CONSULTATION CORRESPONDENCE D.1 Background The Endangered Species Act of 1973, as amended; the Magnuson-Stevens Fisheries Management Act of 1996, as amended; and the National Historic Preservation Act of 1966 (NHPA) require that Federal agencies consult with applicable state and Federal agencies and groups before taking action that may affect threatened or endangered species, essential fish habitat, or historic and archaeological resources, respectively. Table D-1 contains a list of correspondence between the U.S. Nuclear Regulatory Commission (NRC) and other agencies in compliance with these Federal acts.
Table D-1. Consultation Correspondence Author Recipient Date of Letter/Email January 27, 2011 NRC (B. Pham) Advisory Council on Historic Preservation (D. Klima)
February 9, 2011 NRC (B. Pham) Tribal NationYsleta del Sur Pueblo (J. Loera)
February 9, 2011 NRC (B. Pham) Tribal NationAlabama-Coushatta Tribe (O. Sylestine)
February 9, 2011 NRC (B. Pham) Tribal NationKiowa Tribe of Oklahoma (B. Horse)
February 9, 2011 NRC (B. Pham) Tribal NationComanche Nation (R. Toahty)
Tribal Nation NRC (Chief, Rules, Announcements, and Directives February 15, 2011 Tonkawa Tribe of Branch) (ML110490057)
Oklahoma (M. Allen)
February 16, 2011 NRC (B. Pham) U.S. Fish & Wildlife Service (M. Orms)
February 16, 2011 NRC (B. Pham) National Marine Fisheries Service (D. Bernhart)
February 16, 2011 NRC (B. Pham) Texas Parks & Wildlife Department (K. Boydston)
February 17, 2011 NRC (B. Pham) State Historic Preservation Officer (M. Wolfe)
February 17, 2011 NRC (B. Pham) Tribal NationTonkawa Tribe of Oklahoma (A. Street)
Tribal NationApalachicola Band of Creek Indians February 17, 2011 NRC (B. Pham)
(M. Blount) (ML110390321)
Tribal NationLipan Apache Tribe of Texas February 17, 2011 NRC (B. Pham)
(B. Barcena Jr.) (ML110390321)
Tribal NationLipan Apache Band of Texas February 17, 2011 NRC (B. Pham)
(D. Romero Jr.) (ML110390321)
D-1
Appendix D Author Recipient Date of Letter/Email Tribal NationPamaque Clan of Coahuila Y Tejas February 17, 2011 NRC (B. Pham)
(J.R. Mendoza) (ML110390321)
Tribal NationTap Pilam-Coahuiltecan Nation February 17, 2011 NRC (B. Pham)
(R. Hernandez) (ML110390321)
February 23, 2011 NRC (B. Pham) Tribal NationKickapoo Traditional Council (J. Garza Jr.)
National Marine March 3, 2011 Fisheries Service NRC (T. Tran)
(T. Mincey)
Tribal Nation Apalachicola Band of March 7, 2011 NRC (Chief, Rules, Announcements, & Directives Branch)
Creek Indians (ML110750424)
(M. Blount)
Tribal Nation April 1, 2011 Kickapoo Traditional NRC (Chief, Rules, Announcements, & Directives Branch)
Council (J. Garza Jr.)
Tribal NationTap April 1, 2011 Pilam-Coahuiltecan NRC (Chief, Rules, Announcements, & Directives Branch)
Nation (R. Hernandez)
Texas Parks & Wildlife April 20, 2011 Department NRC (B. Pham)
(A. Turner)
April 28, 2011 NRC (T. Tran) State Historic Preservation Officer (Bill Martin)
Pacific Northwest May 2, 2011 National Laboratory State Historic Preservation Officer (Bill Martin)
(T. O'Neil)
U.S. Fish & Wildlife June 2, 2011 NRC (T. Tran)
Service (M. Orms) (ML11173A235)
November 17, 2011 NRC (D. Wrona) Tribal NationKickapoo Traditional Council (J. Garza Jr.)
November 17, 2011 NRC (D. Wrona) Tribal NationTonkawa Tribe of Oklahoma (M. Allen)
Tribal NationTap November 29, 2011 NRC (D. Wrona)
Pilam-Coahuiltecan Nation (R. Hernandez) (ML11269A112)
Tribal NationApalachicola Band of Creek Indians January 19, 2012 NRC (D. Wrona)
(M. Blount) (ML11269A063)
December 10, 2012 NRC (M. Wong) U.S. Fish and Wildlife Service (B. Tuggle)
D-2
Appendix D Author Recipient Date of Letter/Email December 10, 2012 NRC (M. Wong) National Marine Fisheries Service (R. Crabtree)
December 11, 2012 NRC (M. Wong) National Marine Fisheries Service (M. Croom)
December 18, 2012 NRC (M. Wong) Tribal NationAlabama-Coushatta Tribe (O. Sylestine)
December 18, 2012 NRC (M. Wong) Tribal NationKiowa Tribe of Oklahoma (R. Twohatchet)
Tribal NationComanche Nation of Oklahoma December 18, 2012 NRC (M.Wong)
(W. Coffey) (ML12321A351)
December 18, 2012 NRC (M. Wong) Tribal NationTonkawa Tribe of Oklahoma (D. Patterson)
Tribal NationApalachicola Band of Creek Indians December 18, 2012 NRC (M. Wong)
(M. Sixwoman Blount) (ML12321A351)
Tribal NationLipan Apache Tribe of Texas December 18, 2012 NRC (M. Wong)
(B. Barcena, Jr.) (ML12321A351)
Tribal NationPamaque Clan of Coahuila y Tejas December 18, 2012 NRC (M.Wong)
(J.R. Mendoza) (ML12321A351)
Tribal NationTap-Pilam Coahuiltecan Nation December 18, 2012 NRC (M. Wong)
(R. Hernandez) (ML12321A351)
Tribal NationKickapoo Traditional Council of Texas December 18, 2012 NRC (M. Wong)
(J. Garza) (ML12321A351)
December 18, 2012 NRC (M.Wong) Tribal NationYsleta del Sur Pueblo (F. Paiz)
Tribal NationYsleta January 10, 2013 NRC (M. Wong) del Sur Pueblo (ML13030A445)
Tribal NationCarrizo/Comecrudo Tribe of Texas January 17, 2013 NRC (E. Larson)
(J. Mancias) (ML13029A795)
January 17, 2013 NRC (E. Larson) Tribal NationAtakapa Indians (ML13029A796)
National Marine January 29, 2013 Fisheries Service NRC (B. Balsam)
(N. Bailey)
Tribal NationApalachicola Band of Creek Indians January 29, 2013 NRC (E. Larson)
(M. Blount) (ML13029A797)
January 31, 2013 NRC (B. Balsam) U.S. Fish & Wildlife Service (M. Belton)
Tribal Nation February 21, 2013 Apalachicola Band of NRC (M. Wong)
Creek Indiands D-3
Appendix D Author Recipient Date of Letter/Email National Marine March 1, 2013 Fisheries Service NRC (B. Balsam)
(H. Young)
U.S. Fish and Wildlife March 14, 2013 NRC (B. Balsam)
Service (M. Belton) (ML13077A117)
D.2 Consultation Correspondence The following pages contain copies of the letters listed in Table D-1.
D-4
Appendix D D-5
Appendix D D-6
Appendix D D-7
Appendix D D-8
Appendix D D-9
Appendix D D-10
Appendix D D-11
Appendix D D-12
Appendix D D-13
Appendix D D-14
Appendix D D-15
Appendix D D-16
Appendix D D-17
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Appendix D D-20
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Appendix D D-27
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Appendix D D-36
Appendix D D-37
Appendix D D-38
Appendix D D-39
Appendix D D-40
Appendix D D-41
Appendix D D-42
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Appendix D D-44
Appendix D D-45
Appendix D D-46
Appendix D D-47
Appendix D D-48
Appendix D D-49
Appendix D D-50
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Appendix D D-76
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Appendix D D-117
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Appendix D D-133
Appendix D D-134
APPENDIX E CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE
E CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE This appendix contains a chronological listing of correspondence between the U.S. Nuclear Regulatory Commission (NRC) and external parties as part of its environmental review for the South Texas Project (STP). All documents, with the exception of those containing proprietary information, are available electronically from the NRCs Public Electronic Reading Room, which is found on the Internet at the following web address: http://www.nrc.gov/reading-rm.html.
From this site, the public can gain access to the NRCs Agencywide Documents Access and Management System (ADAMS), which provides text and image files of NRCs public documents. The ADAMS accession number for each document is included below.
E.1 Environmental Review Correspondence Table E-1 lists the environmental review correspondence in date order beginning with the request by South Texas Project Nuclear Operating Company (STPNOC) to renew the operating licenses for STP.
Table E-1. Environmental Review Correspondence Date Correspondence Description ADAMS No.
10/25/10 STP, Units 1 and 2, Transmittal of LRA ML103010257 11/4/10 Press Release-10-202, NRC Announces Availability of License Renewal ML103081029 Application for South Texas Project Nuclear Power Plant 11/23/10 Maintenance of Reference Materials at the Bay City Public Library for the ML103090389 Review of STP License Renewal Application 11/23/10 Receipt and availability of the LRA For STP, Units 1 and 2 (LTR) ML103020399 12/9/10 Project Manager Change for the License Renewal of STP, Units 1 and 2 (TAC ML103410524 No. ME4936) 1/6/11 Acceptance of LRA for STP, Units 1 and 2 ML103440610 1/7/11 Determination of acceptability and sufficiency for docketing, proposed review ML103420531 schedule, and opportunity for a hearing regarding the application from STPNOC for renewal of the operating licenses for STP electric gene 1/7/11 Notice of acceptance for docketing of the application and notice of opportunity for ML103420650 hearing regarding renewal of facility operating license numbers NPF-76 and NPF-80 for an additional 20-year period STPNOC, STP 1/13/11 Press Release-11-009: NRC Announces Opportunity for Hearing on Application ML110130500 to Renew Operating Licenses for South Texas Project Nuclear Power Plant 1/21/11 Notice of intent to prepare an environmental impact statement (EIS) and conduct ML103490511 scoping process for license renewal for STP, Units 1 and 2 1/25/11 3/2/11forthcoming meeting to discuss the license renewal process and ML103510697 environmental scoping for STP, Units 1 and 2, LRA review 1/27/11 STP, Units 1 and 2, LRA review (ACHP) ML110190591 1/31/11 Comment (44) of Edmund E. Kelley, opposing STP, Units 1 and 2, LRA review ML11105A023 1/31/11 Comment (51) of Juan Aguilar, on behalf of self, opposed to relicensing of STP, ML11119A011 Units 1 and 2 E-1
Appendix E Date Correspondence Description ADAMS No.
1/31/11 Comment (52) of Juan Aguilar, on behalf of self, opposing STP, Units 1 and 2, ML11119A012 relicensing application 1/31/11 Comment (54) of Shawn Tracy, on behalf of self, opposing STP, Units 1 and 2, ML11119A014 relicensing application 2/7/11 Press Release-11-017: NRC to Meet with Public March 2 for Input on South ML110380405 Texas Project Nuclear Plant Environmental Review for License Renewal 2/9/11 Comanche Nationrequest for comments concerning the STP, Units 1 and 2, ML110390265 LRA review 2/9/11 Kiowa Tribe of OklahomaRequest for comments concerning the STP, Units 1 ML110390244 and 2, LRA review 2/9/11 Ysleta del Sur PuebloRequest for comments concerning the STP, Units 1 ML110190385 and 2, LRA review 2/9/11 Alabama-Coushatta TribeRequest for comments concerning the STP, Units 1 ML110190418 and 2, LRA review 2/15/11 Comment (1) of Miranda Allen, on behalf of the Tonkawa Tribe of Oklahoma on ML110490057 request for comments concerning the STP, Units 1 and 2, LRA review 2/16/11 Request for list of Federally protected species and important habitats within the ML110190429 area under evaluation for the STP, Units 1 and 2, license renewal (FWS) 2/16/11 Request for list of Federally protected species and important habitats within the ML110190434 area under evaluation for the STP, Units 1 and 2, LRA review (NMFS) 2/16/11 Request for list of state-protected species and important habitats within the area ML110190571 under evaluation for the STP, Units 1 and 2, LRA review (Texas Parks and Wildlife Department) 2/17/11 Request for comments concerning the STP, Units 1 and 2, LRA review (Tribes) ML110390321 2/17/11 STP, Units 1 and 2, LRA online reference portal ML110610201 2/17/11 STP, Units 1 and 2, LRA review (SHPO) ML110190549 2/23/11 Kickapoo Traditional CouncilRequest for comments concerning the STP, ML110240161 Units 1 and 2, LRA review 2/28/11 Comment (46) of Randy K. Weber, on behalf of Texas House of ML11108A059 Representatives, supporting license renewal for STP, Units 1 and 2 2/28/11 Schedule for the conduct of review of the STP, Units 1 and 2, LRA ML110340478 3/3/11 3/3/11NRR e-mail captureSTP (NMFS) ML110690848 3/7/11 Comment (3) of Mary Sixwomen Blount, on behalf of Apalachicola Creek Indians, ML110750424 on STP, Units 1 and 2, LRA 3/11/11 Comment (2) of Vicki Adams, approving notice of intent to prepare an EIS and ML110730188 conduct the scoping process for STP, Units 1 and 2 3/14/11 Declaration of Karen Hadden on behalf of SEED Coalition ML110740852 3/14/11 Declaration of Susan Dancer on behalf of SEED Coalition ML110740850 3/14/11 Notice of appearance of Susan Dancer on behalf of SEED Coalition ML110740851 3/14/11 Petition for leave to intervene and request for hearing of SEED Coalition and ML110740848 Susan Dancer 3/16/11 Referral memorandum of the Secretary to the Board regarding license ML110750603 application request for STPNOC, STP, Units 1 and 2 E-2
Appendix E Date Correspondence Description ADAMS No.
3/17/11 Referral memorandum of the Secretary to the Board regarding license ML110760289 application request for STPNOC, STP, Units 1 and 2 (reissued) 3/17/11 STP, Units 1 and 2, LRA online reference portal ML110620203 3/23/11 Establishment of Atomic Safety and Licensing Board in the matter of STPNOC, ML110820735 STP, Units 1 and 2, license renewal 3/24/11 Comment (31) of Jennifer Meador, opposing relicensing of STP, Units 1 and 2 ML111010604 3/28/11 Comment (34) of unknown individual, supporting nuclear power and relicensing ML111010507 of STP, Units 1 and 2 3/28/11 Comment (37) of Carolyn Campbell, opposing STP, Units 1 and 2, relicensing ML111010510 (NRC-2010-0375) 3/28/11 Comment (48) of Beth Ann Larsen, on behalf of self, opposing STP, Units 1 ML11119A007 and 2, relicensing application 3/28/11 Comment (49) of Dzan Nguyen, opposed to relicensing STP, Units 1 and 2 ML11119A008 3/28/11 Comment (55) of Kelly Simon, on behalf of self, opposing relicensing of STP ML11119A015 nuclear reactors 3/28/11 Comment (58) of Cynthia Gebhardt, on behalf of self, opposing STP, Units 1 ML11119A018 and 2, relicensing application 3/28/11 Comment (59) of Rory Holcomb, on behalf of self, opposing STP, Units 1 and 2, ML11119A019 relicensing application 3/29/11 Comment (4) of Julie Sharp, on behalf of National Park Service, in regards to ML110910179 STPNOC STP with determination that no park units will be affected 3/30/11 Comment (32) Of Joy Malacara, opposing relicensing of STP, Units 1 and 2 ML111010479 3/30/11 Comment (33) of Melanie and David Winters, opposing STP, Units 1 and 2, ML111010506 relicensing 3/30/11 Comment (35) of Christine Fry, opposing STP, Units 1 and 2, relicensing ML111010508 (NRC-2010-0375) 3/30/11 Comment (36) of Leona A. Slodge, opposing STP, Units 1 and 2, relicensing ML111010509 3/30/11 Comment (39) of B. Dunlap and T. Rinehart, opposing relicensing of STP, Units ML111010517 1 and 2 3/30/11 Comment (40) of Peggy Cravens, opposing the relicensing of STP, Units 1 and 2 ML111010518 3/30/11 Comment (53) of Douglas S. McArthur, opposing relicensing of STP ML11119A013 3/30/11 Comment (6) of Eva Esparza, opposing STPNOCs notice of intent to prepare an ML110960078 EIS and conduct the scoping process for STP, Units 1 and 2 3/30/11 Comment (60) of unknown individual on behalf of self, opposing relicensing of ML11119A020 STP, Units 1 and 2, for an additional 20 years 3/30/11 Comment (7) of Darby Riley, regarding notice of intent to prepare an EIS and ML110960079 conduct the scoping process for STP, Units 1 and 2 3/30/11 Comment (38) of Melanie Sallis, opposing the relicensing of STP, Units 1 and 2 ML11273A082 3/31/11 Comment (10) of Karen Seal, opposing the licensing of STP, Units 1 and 2 ML110960082 3/31/11 Comment (5) of Peggy Pryor, opposing STP plants ML110960077 3/31/11 Comment (8) of Kamala Platt, opposing STP relicensing ML110960080 E-3
Appendix E Date Correspondence Description ADAMS No.
3/31/11 Comment (9) of Marion Mlotok, opposing the renewal of STP, Units 1 and 2 ML110960081 4/1/11 Comment (11) of Kassandra Levay, opposing STPNOCs notice of intent to ML110960083 prepare an EIS and conduct the scoping process for STP, Units 1 and 2 4/1/11 Comment (12) of unknown individual, regarding notice of intent to prepare an EIS ML110960084 and conduct the scoping process for STP, Units 1 and 2 4/1/11 Comment (13) of T. Burns, opposing South Texas plants (NRC-2010-0375) ML110960086 4/1/11 Comment (14) of Jolly J. Clark, opposing the relicensing of STP, Units 1 and 2 ML110960087 4/1/11 Comment (15) of Pat Bulla, regarding the decommissioning of STP, Units 1 ML110960088 and 2, not relicensing it 4/1/11 Comment (16) of William Stout, supporting the decommissioning of STP, Units 1 ML110960089 and 2, not relicensing it 4/1/11 Comment (19) of Carol Geiger, opposing the renewal of STP, Units 1 and 2, ML110960092 licensing 4/1/11 Comment (20) of Veryan Thompson, supporting STP, Units 1 and 2, ML110960093 decommissioning and denying its LRA 4/1/11 Comment (21) of Robert Singleton, opposing license extension for STP, Units 1 ML110960094 and 2 4/1/11 Comment (22) of Karen Hadden, on behalf of sustainable energy and economic ML110960095 development coalition, opposing relicensing of STP, Units 1 and 2 4/1/11 Comment (23) of Alan Alan Apurim, opposing relicensing of STP, Units 1 and 2 ML110960096 4/1/11 Comment (24) of Brandi Clark Burton, on behalf of self, opposing STP, Units 1 ML110960097 and 2, extending its license application renewal for public safety and environmental reasons 4/1/11 Comment (25) of Carol Geiger, on behalf of self, opposing STP, Units 1 and 2, ML110960098 extending its license application renewal 4/1/11 Comment (27) of Juan Garza, on behalf of Kickapoo Traditional Tribe of Texas, ML110980503 on the STP, Units 1 and 2, LRA review 4/1/11 Comment (45) of Maria Hogan, on safety standards of STP, Units 1 and 2, being ML11105A020 followed 4/1/11 Comment (47) of Miguel Acosta, on behalf of Raymond Hernandez of Tap Pilam ML11111A134 Coahuiltecan Nation, opposing the renewal license for STP, Units 1 and 2 4/4/11 Comment (17) of C.J. Keudell, opposing the relicensing of STP, Units 1 and 2 ML110960090 4/4/11 Comment (18) of Tarek Tonsson, opposing the relicensing of STP, Units 1 and 2 ML110960091 4/4/11 Comment (26) of Eric Lane, on behalf of self, opposing STP, Units 1 and 2, ML110960099 extending its license application renewal 4/5/11 Project Manager change for the license renewal of STP, Units 1 and 2 (TAC ML110872079 No. ME4938) 4/7/11 4/7/11Notice of appearance of Steven P. Frantz (STPNOC) ML110970467 4/7/11 4/7/11The NRC staffs answer to petition for leave to intervene and request for ML110970659 hearing of SEED Coalition and Susan Dancer 4/7/11 STPNOCs answer opposing request for hearing and petition for leave to ML110970544 intervene E-4
Appendix E Date Correspondence Description ADAMS No.
4/8/11 Comment (28) of Jenna Findley, opposing STP, Units 1 and 2, relicensing ML111010476 (NRC-2010-0375) 4/8/11 Comment (29) of Margaret Reed, opposing the relicensing of STP, Units 1 and 2 ML111010477 4/8/11 Comment (30) of Scott and Cyndy Reynolds, opposing relicensing of STP ML111010478 Nuclear reactors 4/9/11 Comment (43) of Thomas Nehms, opposing the relicensing of STP, Units 1 ML111010521 and 2 4/11/11 Comment (41) of Shannon Jurak, opposing the relicensing of STP, Units 1 and 2 ML111010519 4/11/11 Comment (42) of Thomas Nelms, opposing the relicensing of STP, Units 1 and 2 ML111010520 4/20/11 Comment (61) of Amy Turner, on behalf of Texas Parks and Wildlife, on ML11119A009 proposed license renewal of STP, Units 1 and 2, Matagorda County, TX 4/26/11 Comment (50) of John Trimble, opposing relicensing of STP, Units 1 and 2 ML11119A010 (NRC-2010-0375) 4/26/11 Comment (56) of unknown individual, opposing STP, Units 1 and 2, LRA ML11119A016 4/26/11 Comment (57) of Judy Moore, on behalf of self, opposing relicensing of STP ML11119A017 nuclear reactors 5/5/11 Notice of withdrawal of Megan Wright in the matter of STP, Units 1 and 2 ML111250147 5/8/11 Interveners request for oral argument on contentions raised on relicensing ML111280003 5/8/11 Petitioners proposed amended petition for leave to intervene and request for ML111280002 hearing of SEED Coalition and Susan Dancer 5/9/11 Notice of withdrawal of Emily Monteith ML111290341 5/11/11 Certificate of service for amended petition to intervene and request for hearing ML111310798 5/11/11 Certificate of service for request for oral hearing ML111310800 5/19/11 Summary of meeting with stakeholders to discuss issues related to the review of ML110770661 the STP, Units 1 and 2, LRA 5/23/11 Memorandum (notice pursuant to 10 CFR §2.309(i)) ML111430828 5/23/11 Order (scheduling oral argument) ML111430799 5/31/11 RAIs for the review of the STP LRA ML11140A015 6/2/11 U.S. Fish and Wildlife Service Consultation #65533STPNOC ML11173A235 6/2/11 The NRC staffs answer to proposed amended petition for leave to intervene and ML111530393 request for hearing of SEED Coalition and Susan Dancer 6/2/11 STPNOCs answer opposing amended petition to intervene ML111530425 6/13/11 Press Release-11-103: Licensing Board to Hold Teleconference Oral Argument ML11166A046 June 27 on South Texas Project Reactor License Renewal Application 6/17/11 Summary of telephone conference call held on 5/18/11 between the NRC and ML11143A166 STP, concerning RAI pertaining to the STP LRAsevere accident mitigation alternative RAI 6/17/11 RAI for the review of the STP LRA ML11167A113 6/21/11 Plan for the environmental-related regulatory audit regarding the STP, Units 1 ML11145A064 and 2, LRA Review (TAC Nos. ME4938 and ME4939)
E-5
Appendix E Date Correspondence Description ADAMS No.
6/27/11 Transcript of STPNOCs oral argument (telephone conference) on ML11182B033 June 27, 2011, pages 1-22 7/5/11 STP, Units 1 and 2, response to RAI for the review of the LRA ML11193A074 7/5/11 STP, Units 1 and 2, response to RAI for the STP LRA ML11193A016 7/18/11 Audit report regarding STP LRAcultural resource ML11173A304 7/27/11 License renewal environmental review for STP, Units 1 and 2 (open ML11217A017 meeting/records request, CPGCD) 7/28/11 Memorandum revised (notice pursuant to 10 CFR §2.309(i)) ML11210B458 8/4/11 RAI for the review of the STP LRA (TAC Nos. ME4938 and ME5122) ML11201A062 8/4/11 Summary of site audit related to the review of the LRA for STP, Units 1 and 2 ML11196A005 8/18/11 RAI for the review of the STP LRA (TAC Nos. ME4938 and ME512) ML11214A207 8/22/11 Comment (63) of Sandra Horris, on behalf of Coastal Plains Groundwater ML11249A042 Conservation District, on relicensing of STP, Units 1 and 2 (NRC-2010-0375) 8/23/11 STP, Units 1 and 2, response to RAI for LRA ML11250A067 8/23/11 Summary of telephone conference call held on July 28, 2011, between the NRC ML11216A263 and STPNOC, concerning RAI pertaining to the STP LRA 8/26/11 Memorandum and order (ruling on petition for leave to intervene and request for ML11238A160 hearing) 8/31/11 Documents to support review of the STP LRA, list of transmitted documents ML11256A057 including copy of each document, and enclosure to NOC-AE-11002720 8/31/11 Documents to support review of the STP LRA, WR-11, A Summary of Historic ML11256A059 and Current (past 5 years) Total Dissolved Solids Data for Groundwater Produced by STP Production Wells from the Deep Chicot Aquifer 8/31/11 Documents to support review of the STP LRA, WR-5, TCEQ ID ML11256A058 No. 1610103/1610051, Operation Of Public Potable Water System 8/31/11 STP, Units 1 and 2, transmittal of documents to support review of the STP LRA ML11256A056 9/1/11 RAI for the review of the STP LRA ML112360114 9/6/11 STP, Units 1 and 2, response to RAI for the LRA ML11255A211 9/12/11 STP, Units 1 and 2, response to RAI for the LRA ML11259A014 9/12/11 STP, Units 1 and 2, transmittal of document to support review of the LRA ML11259A031 9/13/11 NRR e-mail capture, STP license renewal, State Historic Preservation Office ML11259A029 meeting 9/22/11 STP, Units 1 and 2, response to RAIs for LRA (TAC Nos. ME4938 and ME5122) ML11270A060 9/28/11 RAIs for the review of the STP LRA (TAC Nos. ME4938 And ME5122) ML11269A002 10/18/11 STP, Units 1 and 2, response to RAIs for LRA (TAC Nos. ME4938 and ME5122) ML11298A085 10/26/11 STP, Units 1 and 2, contact information change, LRA (TAC Nos. ME4936 ML11305A075 and ME4937) 10/26/11 STP, Units 1 and 2, correction to NRC distribution list ML11307A371 11/17/11 STP, Units 1 and 2, license renewal environmental review (Kickapoo Traditional ML11269A011 Council)
E-6
Appendix E Date Correspondence Description ADAMS No.
11/17/11 STP, Units 1 and 2, license renewal environmental review (Tonkawa Tribe of ML11269A015 Oklahoma) 11/17/11 STP, Units 1 and 2, clarification to response to RAI for LRA (TAC Nos. ME4938 ML11333A094 and ME5122) 11/29/11 Summary of telephone conference call held on 11/1/11 between the NRC and ML11307A381 STPNOC concerning RAIs pertaining to the STP LRA 11/29/11 STP, Units 1 and 2, license renewal environmental review ( Tap Pilam, ML11269A112 Coahuiltecan Nation) 1/4/12 Summary of telephone conference call held on 12/15/11 between NRC and ML11350A222 STPNOC concerning RAI pertaining to the STP LRA 1/10/12 STP, Units 1 and 2, clarification of Information in support of the review of the ML12011A188 LRA 1/19/12 STP, Units 1 and 2, license renewal environmental review ML11269A063 2/14/12 Summary of telephone conference call held on 1/31/12 between the NRC and ML12033A134 STPNOC concerning RAIs pertaining to the STP LRA 2/16/12 STP, Units 1 and 2, clarification to response to RAI for LRA (TAC Nos. ME4938 ML12053A259 and ME5122) 2/29/12 RAI for the Review of the STP LRA (TAC Nos. ME4938 And ME5122) ML12017A128 2/29/12 Summary of telephone conference call held on 1/7/12 between the NRC and ML12047A285 STPNOC concerning RAIs pertaining to the STP 3/12/12 STP, Units 1 and 2, response to RAIs for LRA (TAC Nos. ME4938 and ME5122) ML12079A014 4/17/12 STP, Units 1 and 2, renewal of the Wastewater Discharge Permit ML12114A198 5/8/12 NEPA consultationWaterborne outbreak ML12128A061 5/18/12 Environmental Permit Updated Status ML12142A002 8/10/12 Revision of schedule for the conduct of environmental review of the STP LRA ML12171A483 (TAC Nos. ME5122, ME5123, ME4938, and ME4939) 11/14/12 Issuance of environmental scoping summary report associated with the staffs ML11153A082 review of the application by STPNOC for renewal of the operating license for STP, Units 1 and 2 (TAC No. ME4938) 11/30/12 NUREG-1437, Supplement 48 DFC, Generic Environmental Impact Statement ML12324A049 for License Renewal of Nuclear Plants: Regarding South Texas Project, Units 1 and 2 (draft for comment) 12/5/12 Notice of availability of the draft plant-specific supplement 48 to the GEIS for ML12195A085 license renewal of nuclear plants regarding STP, Units 1 and 2 (TAC Nos. ME5122, ME5123, ME4938, and ME4939).
12/5/12 Notice of availability of the draft plant-specific supplement 48 to the GEIS for ML12200A358 license renewal of nuclear plants regarding STP, Units 1 and 2 12/5/12 Notice of availability of the draft plant-specific supplement 48 to the GEIS for ML12339A265 license renewal of nuclear plants regarding STP, Units 1 and 2 (TAC Nos. ME5122, ME5123, ME4938, and ME4939) 12/10/12 Request for concurrence on the effects of the proposed STP license renewal on ML12285A415 threatened and endangered species 12/10/12 Request for concurrence on the effects of the proposed STP license renewal on ML12286A010 threatened and endangered species E-7
Appendix E Date Correspondence Description ADAMS No.
12/11/12 Request for essential fish habitat consultation for the proposed STP, Units 1 ML12285A197 and 2, license renewal 12/13/12 STP, Units 1 and 2, LRA review (THC No. 201002271) ML12320A603 12/18/12 STP, Units 1 and 2, LRA review ML12321A311 12/18/12 Notice of availability of the DSEIS for license renewal of STP, Units 1 and 2, for ML12321A351 public comment 12/18/12 Press Release-12-128: NRC Seeks Public Comment on Draft Environmental ML12353A356 Report for South Texas Project Nuclear Plant License Renewal 12/20/12 Comment (1) of Marvin Lewis suggesting that license proceeding for STP be ML12356A233 stopped until waste confidence rulemaking finds in favor of concept of waste confidence 1/3/13 Forthcoming meeting to discuss the DSEIS for the license renewal of STP, ML12342A397 Units 1 and 2 1/10/13 Comment (6) of Javier Loera, on behalf of Ysleta del Sur Pueblo, on the NRCs ML13030A445 environmental review of the effects of renewing the operating license for STP, Units 1 and 2 1/11/13 Comment (2) of Sonia Santana on STP GEIS for license renewal ML13017A405 1/17/13 NRR e-mail capture regarding license renewal of STP, Units 1 and 2, located in ML13029A795 Matagorda County, TX 1/17/13 NRR e-mail capture regarding license renewal of STP, Units 1 and 2 ML13029A796 1/20/13 Comment (3) of John Elder on behalf on himself on notice of receipt and ML13025A357 availability of application for renewal of facility operating license for STP, Units 1 and 2 1/21/13 Comment (4) of Cynthia Weehler on behalf of herself opposing notice of receipt ML13025A358 and availability of application for renewal of facility operating license for STP, Units 1 and 2 1/21/13 Comment (5) of Elizabeth Tobin on STPNOC, STP; notice of availability of draft ML13025A359 supplement 48 to the GEIS for license renewal of nuclear plants 1/21/13 STP, Units 1 and 2, update to LRAenvironmental permits ML13032A074 1/29/13 NRR e-mail capture regarding NRC STP ML13036A306 1/29/13 NRR e-mail capture regarding draft for commentlicense renewal of STP, ML13029A797 Units 1 and 2, located in Matagorda County, TX 1/30/13 DSEIS for license renewal of STP, Units 1 and 2 ML13029A469 1/31/13 NRR e-mail capture regarding STPt-line maps for T&E review ML13036A305 2/7/13 Comment (7) of Kenneth Taplett on behalf of STPNOC on STP, notice of ML13044A496 availability of draft supplement 48 to the GEIS for license renewal 2/11/13 Revision of schedule for the conduct of environmental review of the STP LRA ML13011A131 (TAC Nos. ME5122, ME5123, ME4938, and ME939) 2/15/13 RAI for the review of the STP LRA ML13037A678 2/21/13 Comment (8) of Stephen R. Spencer on behalf of U.S. Department of the Interior ML13058A027 on STP application for renewal of facility operating license 2/25/13 Summary of public meetings conducted on 1/15/13 to discuss DSEIS related to ML13023A334 review of STP, Units 1 and 2, LRA E-8
Appendix E Date Correspondence Description ADAMS No.
3/1/13 NRR e-mail capture regarding EFH consultation with NRC for STP nuclear plant ML13063A071 license renewal E-9
APPENDIX F NRC STAFF EVALUATION OF SEVERE ACCIDENT MITIGATION ALTERNATIVES
F NRC STAFF EVALUATION OF SEVERE ACCIDENT MITIGATION ALTERNATIVES F.1 Introduction South Texas Project Nuclear Operating Company (STPNOC) submitted an assessment of severe accident mitigation alternatives (SAMAs) for the South Texas Project, Units 1 and 2, (STP) as part of its Environmental Report (ER) (STPNOC 2010). This assessment was based on the most recent STP probabilistic risk assessment (PRA) available at that time, a plant-specific offsite consequence analysis performed using the MELCOR Accident Consequence Code System 2 (MACCS2) computer code, and insights from the STP individual plant examination (IPE) and individual plant examination of external events (IPEEE)
(HL&P 1992). In identifying and evaluating potential SAMAs, STPNOC considered SAMAs that addressed the major contributors to core damage frequency (CDF) and population dose at STP, as well as SAMA candidates found to be potentially cost beneficial in six other license renewal applications (LRAs). STPNOC initially identified a list of 21 potential SAMAs. This list was reduced to five unique SAMA candidates by eliminating SAMAs that are not applicable to STP for one or more of the following reasons:
- The SAMA has estimated implementation costs that would exceed the dollar value associated with eliminating the severe accident risk at STP.
STPNOC assessed the costs and benefits associated with each of the potential SAMAs and concluded in the ER that none of the candidate SAMAs evaluated are potentially cost beneficial.
As a result of the review of the SAMA assessment, the U.S. Nuclear Regulatory Commission (NRC) staff (the staff) issued requests for additional information (RAIs) to STPNOC by letters dated May 31, 2011 (NRC 2011a), and September 1, 2011 (NRC 2011b), and in conference calls for clarification on July 28, 2011 (NRC 2011c), and January 31, 2012 (NRC 2012). Key questions concerned the following:
- changes to STP design and operation since the version of the PRA used for the SAMA analysis (referred to as the STP_REV6 model, dated 2009),
- differences between STP, Units 1 and 2, designs or operation and identification of shared systems,
- the impact of open items and issues from the peer review of the PRA human reliability analysis (HRA),
- the process used to map Level 1 results into the Level 2 analysis and to group containment event tree (CET) end states into release categories,
- the selection of representative analysis cases,
- population assumptions used in the Level 3 analysis,
- the uncertainty analysis, F-1
Appendix F
- the impact of new information on fire- and seismic-initiated sequences, and
- further information on the cost-benefit analysis of several specific candidate SAMAs and low cost alternatives.
STPNOC submitted additional information by letters dated July 5, 2011 (STPNOC 2011a),
August 23, 2011 (STPNOC 2011b), January 19, 2012 (STPNOC 2012a), and February 16, 2012 (STPNOC 2012b). In these responses to the RAIs, STPNOC provided:
- identification of design and operation changes since the freeze date and their impact on PRA results,
- identification of design differences between units as well as shared systems,
- identification and an assessment of the impact of open items and issues from the PRA reviews,
- a discussion of the process for binning the source term release categories into release category groups,
- clarification of the bases for selecting representative analysis cases for each release category group,
- a discussion of the uncertainty analysis,
- further details on the external events PRA models including the impact of new information on fire and seismic sequences, and
- additional information regarding several specific SAMAs.
STPNOCs responses addressed the staffs concerns and did not result in the identification of any potentially cost-beneficial SAMAs.
An assessment of the SAMAs for STP is presented in Sections F.2 through F.6.
F.2 Estimate of Risk for STP STPNOCs estimates of offsite risk at STP are summarized in Section F.2.1. The summary is followed by the staffs review of STPNOCs risk estimates in Section F.2.2.
F.2.1 STPNOCs Risk Estimates Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA analysis. The first is the STP Level 1 and Level 2 PRA model, which reflects (a) the plant design configuration as of December 31, 2007, and (b) the plant data from January 1, 1998, through December 31, 2007, for component failure and equipment unavailability data (STPNOC 2010).
The second is a supplemental analysis of offsite consequences and economic impacts (essentially a Level 3 PRA model) developed specifically for the SAMA analysis. The SAMA analysis is based on the most recent STP Level 1 and Level 2 PRA model available at the time of the ER, referred to as the STP_REV6 model. The scope of the Level 1 model includes internal and external initiating events.
The STP CDF is approximately 6.4x10-6 per year for both internal and external events, as determined from quantification of the Level 1 PRA model. The CDF is based on the risk F-2
Appendix F assessment for internally initiated events, which includes internal flooding, and external events, which includes fire, seismic, external flooding, and tornado events. The internal events CDF is approximately 3.9x10-6 per year. The external events CDF is approximately 2.5x10-6 per year.
The external events CDF includes contributions of approximately 1.0x10-6 per year due to fire events, 7.3x10-8 per year due to seismic events, and 1.4x10-6 per year due to other external events (STPNOC 2010). When determined from the sum of the CET sequences, or Level 2 PRA model, the CDF is approximately 6.2x10-6 per year for both internal and external events.
The 6.2x10-6 is used as the baseline CDF in the SAMA evaluations (STPNOC 2010).
Note that the above results, and those given in Tables F-1 through F-5, are based upon the STP model of record (STP_REV6) as presented in the ER (STPNOC 2010) and do not include STPNOCs responses to RAIs. The RAIs consider the impact of new industry information concerning internal fire and seismic initiated events. The results relating to these RAIs are discussed in Sections F.2.2 and F.6.2.
The breakdown of CDF by initiating event is provided in Table F-1, Table F-2, Table F-3, and Table F-4 for internal, fire, seismic, and other external events, respectively (STPNOC 2011a).
Table F-1 shows how internal events contribute about 61 percent of the total CDF. The largest contributors to the internal event CDF are two loss of offsite power (LOOP) events, Loss of All Offsite Power and Loss of 345kV Offsite Power, which contribute 15 percent and 10 percent, respectively, to the total CDF.
Table F-2 shows how fire events make up the next largest contributor with about 16 percent contribution to the total CDF. Fire Zone 047 Scenario X and Fire Zone 071 Scenario X are the largest contributors with 6 percent and 3 percent contribution, respectively, to the total CDF.
Table F-3 shows how seismic events make up a small contribution of about one percent to the total STP CDF. Seismic events with 0.4 g acceleration and 0.6 g acceleration are the largest contributors to the seismic event CDF, contributing 0.6 percent and 0.3 percent, respectively.
Table F-4 shows how other external events (excluding fire and seismic) make up the next largest contributor, adding up to about 22 percent of the total CDF. Tornado Induced Failure of Switchyard and Essential Cooling Pond (ECP) and Essential Cooling Water (ECW) Failure due to Breach of Main Cooling Reservoir (MCR) are the largest contributors, with 17 percent and 5 percent contribution, respectively, to the total CDF.
The STP Level 2 PRA model that forms the basis for the SAMA evaluation is an updated version of the IPE Level 2 model with the latest update incorporated in the 2005 Revision (STP_REV5). The Level 2 model is linked to the Level 1 model by passing the status of all top events previously evaluated in the Level 1 model. The Level 1 model includes the status of all systems needed for the Level 2 analysis. The CET, containing only phenomenological events, is then quantified using these inputs.
The CET considers the influence of physical and chemical processes on the integrity of the containment and on the release of fission products once core damage has occurred. The quantified CET sequences are binned into a set of end-states or release categories that are subsequently grouped into four major release groups that provide the input to the Level 3 consequence analysis. The frequency of each major release group was obtained by summing the frequency of the individual accident progression CET endpoints (or release categories) that were binned (categorized) into the major release group. Source terms were developed for nine release categories using the results of Modular Accident Analysis Program (MAAP 4.0.5) computer code calculations. From these results, source terms were chosen to be representative of the four major release groups (STPNOC 2011a). The results of this analysis for STP are provided in Table F.3-2 of ER Attachment F (STPNOC 2010).
F-3
Appendix F Table F-1. STP Core Damage Frequency for Internal Events
% Contribution to % Contribution to CDF Initiating event (a) internal events total CDF (per year)
CDF (b, c)
Loss of all offsite power 9.6x10-7 25 15 Loss of 345kV offsite power 6.3x10-7 16 10 Steam generator tube rupture (SGTR) 4.4x10-7 11 7 Excessive loss-of-coolant accident (LOCA) 3.2x10-7 8 5 Steam line break outside containment 2.8x10-7 7 4 Loss of electrical auxiliary building heating, 2.6x10-7 7 4 ventilation and air conditioning (HVAC)
Turbine trip 1.8x10-7 5 3 Partial loss of main feedwater 1.5x10-7 4 2 Reactor coolant pump (RCP) seal LOCA 1.5x10-7 4 2 Interfacing system LOCA (ISLOCA) 1.3x10-7 3 2 Loss of DC busses 9.7x10-8 2 2 Small LOCAs 7.5x10-8 2 1 Reactor trip 6.5x10-8 2 1 Other internal events 3.6x10-7 9 6 Total CDF (internal events) 3.9x10-6 100 64 (a)
The impact of the sensitivity analysis to updated fire and seismic data on the total CDF is not included in these results. Section F.2.2 provides a discussion of these impacts.
(b)
Obtained from CDF given in ER Table F.2-1 (STPNOC 2010) divided by the total internal events CDF of 3.89x10-6.
(c)
May not total to 100 percent due to round off.
F-4
Appendix F Table F-2. STP Core Damage Frequency for Fire Events CDF % Contribution % Contribution Fire initiator description (a) (per year) to fire CDF (b, c) to total CDF (c)
Fire zone 047 scenario X 4.0x10-7 39 6 Fire zone 071 scenario X 2.1x10-7 21 3 Fire zone 047 scenario B 1.8x10-7 18 3 Control room fire scenario 18 1.2x10-7 12 2 Fire zone 047 scenario BC 6.4x10-8 6 1 Control room fire scenario 23 2.6x10-8 3 0.4
-8 Fire zone 147 scenario O 1.1x10 1 0.2 Control room fire scenario 10 1.0x10-9 <1 <0.1 Total CDF (fire events) 1.0x10-6 100 16 (a)
The impact of the sensitivity analysis to update fire and seismic data on the total CDF is not included in these results. Section F.2.2 provides a discussion of these impacts.
(b)
Obtained from CDF given in ER Table F.2-1 (STPNOC 2010) divided by fire events CDF of 1.02x10-6.
(c)
May not total to 100 percent due to round off.
Table F-3. STP Core Damage Frequency for Seismic Events CDF % Contribution to % Contribution to Initiating event (a) (per year) seismic CDF (b, c) total CDF (c)
Seismic event, 0.4 g acceleration 4.1x10-8 55 0.6 Seismic event, 0.6 g acceleration 2.1x10-8 28 0.3 Seismic event, 0.2 g acceleration 9.8x10-9 13 0.2 Seismic event, 0.1 g acceleration 2.1x10-9 3 <0.1 Total CDF (seismic events) 7.3x10-8 100 1.1 (a)
The impact of the sensitivity analysis to updated fire and seismic data on the total CDF is not included in these results. Section F.2.2 provides a discussion of these impacts.
(b)
Obtained from CDF given in ER Table F.2-1 (STPNOC 2010) divided by seismic events CDF of 7.31x10-8.
(c)
May not total to 100 percent due to round off.
F-5
Appendix F Table F-4. STP Core Damage Frequency for Other External Events
% Contribution to % Contribution to CDF Initiating event (a) other external total CDF (c)
(per year) events CDF (b, c)
Tornado induced failure of switchyard and 1.1x10-6 79 17 ECP ECW failure due to breach of MCR 2.9x10-7 21 5 External flooding scenarios 2-6 9.5x10-9 <1 0.2
-9 Flood induced LOOP 2.1x10 <1 <0.1 Total CDF (other external events) 1.4x10-6 100 22 (a)
The impact of the sensitivity analysis to updated fire and seismic data on the total CDF is not included in these results. Section F.2.2 provides a discussion of these impacts.
(b)
Obtained from CDF given in ER Table F.2-1 (STPNOC 2010) divided by other external events CDF of 1.41x10-6.
(c)
May not total to 100 percent due to round off.
The offsite consequences and economic impact analyses use the MACCS2 code to determine the offsite risk impacts on the surrounding environment and public. Inputs for these analyses include plant-specific and site-specific input values for core radionuclide inventory, source term and release characteristics, site meteorological data, projected population distribution (within a 50-mi radius) for the year 2050, emergency response evacuation modeling, and economic data.
The core radionuclide inventory is based on a plant-specific evaluation. The inventory corresponds to the end-of-cycle values for STP operating at a projected future 4,100 megawatts thermal (MWt). The current licensed power is 3,835 MWt (STPNOC 2010). The magnitude of the onsite impacts (in terms of cleanup and decontamination costs and occupational dose) is based on information provided in NUREG/BR-0184, Regulatory Analysis Technical Evaluation Handbook (NRC 1997a).
In the ER, the applicant estimated the dose risk to the population within 80-km (50-mi) of the STP site to be approximately 0.0174 person-Sievert (Sv) (1.74 person-roentgen equivalent man (rem)) per year. The breakdown of the total population dose by containment release mode is summarized in Table F-5. Large early releases are the dominant contributors (39 percent) to the population dose risk at STP. Small early releases (with pre-existing small containment failure) and late releases (with no sprays) are also significant contributors to the population dose risk.
F-6
Appendix F Table F-5. Breakdown of Population Dose by Containment Release Mode Containment release mode Population dose (person- % Contribution (major release categoryRC) (a) rem (b) per year)
RC Ilarge early releases (<3 hrs) 0.68 39 RC IIsmall early releases (<3 hrs) 0.59 34 RC IIIlate releases (>3 hrs) 0.42 24 RC IVintact containment 0.05 3 Total 1.74 100 (a)
The impact of the sensitivity analysis to updated fire and seismic data on the release category frequency is not included in these results. Section F.2.2 provides a discussion of these impacts.
(b)
One person-rem=0.01 person-Sv.
F.2.2 Review of STPNOCs Risk Estimates STPNOCs determination of offsite risk at STP is based on the following three major elements of analysis:
(1) the Level 1 and 2 risk models that form the bases for the 2005 model (STP_REV5) reviewed by the NRC staff for the approval of the Risk Managed Technical Specification (RMTS) application, which is an updated version of the 1992 IPE submittal (HL&P 1992), which incorporated both internal and external events, (2) the modifications to the STP_REV5 model that have been incorporated into the current STP PRA (STP_REV6), and (3) the MACCS2 analyses performed to translate fission product source terms and release frequencies from the Level 2 PRA model into offsite consequence measures.
Each of these analyses was reviewed to determine the acceptability of STPNOCs risk estimates for the SAMA analysis, as summarized below.
The first STP Level 1 PRA was completed in 1989 to support a request for revising certain STP technical specifications. This was subsequently updated and extended to incorporate a Level 2 analysis, as documented in the STP IPE. The 1989 PRA and the IPE incorporated internal fires and all external events as well as internal event initiators. The internal events and fire events portions of the 1989 PRA were reviewed extensively as part of the technical specification change request approval (NRC 1994a). The NRC review of the IPE (NRC 1994b) concluded that the applicant met the intent of Generic Letter (GL) 88-20 (NRC 1988). Although no vulnerabilities were identified in the IPE, four improvements were identified. The ER indicated that all of these improvements have been implemented.
The internal events CDF value from the 1992 IPE (4.3x10-5 per year) is near the average of the values reported for other 4-loop Westinghouse plants. Figure 11.6 of NUREG-1560 (NRC 1997b) shows that the IPE based total internal events CDF for 4-loop Westinghouse plants ranges from 3x10-6 per year to 2x10-4 per year, with an average CDF for the group of 6x10-5 per year. It is recognized that other plants have updated the values for CDF subsequent to the IPE submittals to reflect modeling and hardware changes. The internal events CDF result for STP used for the SAMA analysis (6.4x10-6 per year) is somewhat lower than that for other plants of similar vintage. This is considered to be reasonable due to the unique design of STP, which uses three independent emergency core cooling system trains and four auxiliary F-7
Appendix F feedwater pumps as well as having a significant amount of physical separation of the redundant trains.
There have been many revisions to the original STP PRA model. The most relevant are the IPE, Revision STP_1999 and the subsequent revisions leading up to the current revision used in the SAMA assessment. A breakdown of the contributors to total CDF and a description of the changes made to the STP PRA, since the peer reviewed Revision STP_1999, were provided in response to NRC staff RAIs (STPNOC 2011a, 2011b). These changes are summarized in Table F-6. The STP_REV6 model reflects the current (as of the date of the ER submittal) STP configuration and design. In response to an RAI, STPNOC stated that a review of plant design and operation changes made since the last model update indicates that one modification will require a PRA model revision. STPNOC does not expect this change to have a significant effect on the SAMA evaluation (STPNOC 2011a). The staff reviewed the response and agreed with the applicant that the prospective change to the PRA model would not have a significant effect on the SAMA evaluation.
The STP PRA model is a single unit model rather than a model that incorporates explicit events in both units. In response to an RAI, STPNOC states that the STP, Units 1 and 2, are designed to be identical; therefore, the PRA model applies to both STP, Units 1 and 2 (STPNOC 2011a).
However, STPNOC noted that there are two differences between Units 1 and 2 resulting from the phased implementation of design changes over several different refueling outages. One, involving load tap changers for engineered safety features transformers, was found to have less than a 0.5 percent increase in CDF and large early release frequency (LERF). The other, involving the addition of hand switches for the steam generator (SG) power operated relief valves in the control room, will exist for only a few months and is expected to result in a decrease in CDF and LERF (temporary modification to conservatively decrease CDF).
F-8
Table F-6. STP PRA Historical Summary CDF (a)
Summary of significant changes (per year) LERF (a)
PRA version from prior model (per year)
Internal External Flood High Total Seismic Fire events floods MCR wind IPE/IPEEE (b) Information from IPE/IPEEE report 4.3x10-5 1.4x10-6 1.4x10-6 1.4x10-6 1.4x10-6 1.4x10-6 4.4x10-5 9.9x10-7 (HL&P 1992)
(1992)
STP_1999 2002 WOG peer review 8.8x10-6 7.3x10-8 1.4x10-6 1.4x10-8 2.9x10-7 1.1x10-6 1.2x10-5 5.8x10-7 (9/2001)
STP_REV4 Reviewed by the NRC staff for RMTS 6.6x10-6 7.3x10-8 1.0x10-6 1.4x10-8 2.9x0-7 1.1x10-6 9.1x10-6 5.4x10-7 approval (9/2003)
Incorporated updated plant-specific train unavailability data, updated initiating events and component failure data Incorporated latest operator error F-9 modeling and improved LOOP recovery modeling Included safety injection accumulator modeling for large and medium LOCAs Included hot leg recirculation modeling for Large LOCA Removed credit for 150-ton air conditioning chillers Improved modeling of support system initiating events STP_REV41 (c) Reviewed by the NRC staff for RMTS 6.6x10-6 NA NA NA NA NA 9.2x10-6 NA approval Incorporated operator depressurization for small LOCA Appendix F Corrected modeling error for long-term
CDF (a)
Summary of significant changes (per year) LERF (a)
PRA version from prior model (per year)
Internal External Flood High Total Seismic Fire events floods MCR wind Appendix F response for medium LOCA Requantified frequency for inadvertent opening of one or two pressurizer safety valves Corrected conditional split fractions definitions to correct errors in basic event importance calculations Re-binned several maintenance duration data variables to correct input problems with RISKMAN version being used Split fault tree basic events containing several components to better reflect individual component importance.
F-10 STP_REV42 Reviewed by the NRC staff for RMTS NA NA NA NA NA NA 9.3 x 10-6 5.1x10-7 approval Corrected issues found during component risk ranking STP_REV5 Reviewed by the NRC staff for RMTS 7.7x10-6 7.3x10-8 9.7x10-7 1.4x10-8 2.9x10-7 1.1x10-6 1.0x10-5 6.1x10-7 approval (9/2005)
Incorporated plant modifications, procedure changes and data update through 2004 Incorporated modifications to Class IE vital AC system and main steam isolation valves Level 2 update including containment capability analysis Updated HRA to use of EPRI HRA
CDF (a)
Summary of significant changes (per year) LERF (a)
PRA version from prior model (per year)
Internal External Flood High Total Seismic Fire events floods MCR wind calculator STP_REV51 Added RMTS macros 7.7x10-6 7.3x10-8 9.7x10-7 1.4x10-8 2.9x10-7 1.1x10-6 1.0x10-5 6.1x10-7 STP_REV6 Updated equipment reliability data 3.9x10-6 7.3x10-8 1.0x10-6 1.3x10-8 2.9x10-7 1.1x10-6 6.4x10-6 5.0x10-7 (2009) Updated initiating event data Updated planned maintenance data Updated treatment of operator action for interfacing system LOCA (1/2012) (d) Updated fire analysis for impact of new 6.5x10-6 3.0x10-6 2.2x10-6 NA NA NA 1.1x10-5 7.3x10-7 information in NUREG/CR-6850 (NRC 2005)
Updated seismic analysis for impact of F-11 2008 USGS seismic hazard (USGS 2008)
NANot available, and value would not impact SAMA Review (a)
All CDF values are point estimate values unless otherwise indicated.
(b)
Total external events CDF is given as 3.2 percent of the total or 1.4x10-6 per year.
(c)
Based on a response to an NRC staff RAI (STPNOC 2011a), which indicated that the CDF was higher than that for STP_REV4 by 1.2 percent.
(d)
Provided for information only. The PRA version is not considered a formal update. The CDF and LERF values were provided in response to NRC RAI
-14 -12 (STPNOC 2012a). All values are based on truncation value of 1x10 whereas prior results are based on a truncation value of 1x10 . Values for floods and high winds are not explicitly provided but are not expected to change from prior values.
Appendix F
Appendix F In response to the same RAI, STPNOC indicated that the only shared systems between units are the common switchyard, MCR, and the ECP (STPNOC 2011a). The NRC staff concludes that since there are no other shared systems, modeling of the other units features is not required, and a single unit model is appropriate for the SAMA assessment.
The NRC staff noted that the STP PRA results (ER Table F.2-1) do not include any internal flooding initiated sequences. The NRC staff requested additional information (NRC 2011a), and STPNOC, in response, indicated that the high degree of separation between redundant divisions at STP resulted in all internal flooding sequences being screened out in the IPE and IPEEE (STPNOC 2011a). The NRC staff considered these sequences, as part of the RMTS review, discussed below. The staff concludes that the internal flood screening remains valid.
The NRC staff considered the peer reviews and other assessments performed for the STP PRA and the potential impact of the review findings on the SAMA evaluation. The most relevant of these are the 2002 peer review of the STP_1999 model, the STP self-assessment to the requirements of Regulatory Guide (RG) 1.200, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities (NRC 2007a),
and the NRC staffs review of the STP models REV4, REV41, REV42, and REV5 in support of STPNOCs RMTS application. STPNOC stated (STPNOC 2006) that the general assessment of the peer review was that the STP PRA could effectively be used to support applications involving risk significance determinations supported by deterministic analyses once the items noted in the element summaries and fact and observations (F&O) sheets were addressed. All F&O items were incorporated into STP_REV4, the original basis for the RMTS request, with two major exceptions. These exceptions were the Level 2 update and re-evaluation of the internal flood modeling. The resolutions of the F&Os associated with the two exceptions were incorporated into STP_REV5.
Revision 5 was performed to ensure that the STP PRA satisfies the requirements of Capability Category II of the American Society of Mechanical Engineers (ASME) PRA Standard (ASME 2002, 2003, 2005), as modified by RG 1.200, Appendix B. In response to an NRC RAI on the RMTS application, STPNOC provided information that described how the STP PRA meets the ASME criteria (STPNOC 2007). The HRA update, incorporated into Revision 5 of the PRA, was the subject of a follow-on peer review. As a result of the peer review, STPNOC found the F&Os from this review to not impact the RMTS application. In addition, these F&Os would be fully evaluated as part of the Revision 6 PRA (STPNOC 2007). In response to an RAI, STPNOC identified the content of the 10 Level A and B F&Os and stated that a preliminary review of the F&Os concluded that their resolution is not expected to have a significant impact on the STP PRA model or on the SAMA analysis (STPNOC 2011a).
The results of the NRC staffs review of the STP PRA through Revision 5 are documented in a safety evaluation report (SER) appended to the NRCs approval of the STP RMTS (NRC 2007a). The staff reviewed the scope and resolution of the 2002 peer review F&Os and concluded that the items were properly addressed by the applicant based on the documented resolutions. Based on the applicants assessments and the NRC staffs reviews, the staff determined that the STP PRA internal events models met the requirements of RG 1.200, Revision 1, and were acceptable for the RMTS application.
Based on the following information, the NRC staff concludes that the internal events Level 1 PRA model is of sufficient quality to support the SAMA evaluation:
- The STP internal events PRA model has been peer-reviewed and the peer review findings were all addressed.
F-12
Appendix F
- The model has been reviewed by the NRC staff as part of the RMTS application approval.
The STP PRA model includes seismic, fire, high winds, floods, and other external initiating events as well as internal initiating events. The updated external core damage results are described in ER Section F.2.1 and included in Table F-2 and Table F-3 along with the internal events results.
The STP IPEEE was submitted as part of the IPE in 1992 (HL&P 1992), in response to Supplement 4 of GL 88-20 (NRC 1991), and was based on the external events portion of the prior STP PRA submitted and reviewed by the NRC staff to support an STP license amendment (NRC 1994a). No fundamental weaknesses or vulnerabilities to severe accident risk concerning the external events were identified in the STP IPEEE. In a letter dated December 15, 1998 (NRC 1998), the NRC staff stated that on the basis of the staffs reviews of the PRA and IPEEE submittal, the staff concludes that the STP IPEEE process is capable of identifying the most likely severe accidents and severe accident vulnerabilities. Therefore, the STP IPEEE has met the intent of Supplement 4 to GL 88-20.
The STP IPEEE seismic analysis used a seismic PRA following NRC guidance (NRC 1991) and used the prior 1988 probabilistic safety assessment or PSA with enhancements recommended by the NRC guidance. The seismic PRA included a seismic hazard analysis, a fragility analysis, a plant logic analysis, and quantification of seismic CDF and various plant damage states.
The seismic hazard analysis estimated the annual frequency of exceedingly different levels of ground motion. The STP IPEEE used the Electric Power Research Institute (EPRI)
(EPRI 1989) hazard curves and provided a sensitivity study result using the Lawrence Livermore National Laboratory (LLNL) (NRC 1989) curve. Four discrete accelerations (0.1 g, 0.2 g, 0.4 g, and 0.6 g) were used to represent the full range of possible accelerations with point estimate values of the frequency for each acceleration determined from the mean exceedance frequency from the hazard curves.
The seismic fragility for safety-related structures, equipment, and components was determined from the results of an assessment of the median factor of safety against failure and its statistical variability under the safe-shutdown earthquake. System and fragility analysts supported the fragility analysis by plant walk downs. Fragilities for 2 structures and 18 components with median capacities less than 2.0 g were included in the model. Point estimate fragilities were then determined for each of the seismic initiating event accelerations evaluated.
The plant logic analysis determines the consequences of various structural and component failures in terms of CDF and release categories. A seismic failure event tree was used to represent the seismic failure impact of various plant components. The resulting seismic end-states were then inputted to support front line system trees that also consider non-seismic unavailabilities.
The seismic CDF resulting from the STP IPEEE was calculated to be 2x10-7 per year based on the EPRI hazard curve and 2x10-5 per year based on the LLNL hazard curve (HL&P 1992; NRC 1989). The current CDF value, based on the EPRI hazard curve, is 7x10-8 per year. The STP IPEEE did not identify any vulnerabilities due to seismic events or any potential improvements to reduce seismic risk.
In order to gain a perspective on the impact of the most recent USGS study of seismic hazard on the STP seismic risk, the NRC staff considered the analysis published for Generic Issue 199 F-13
Appendix F (NRC 2010). This analysis, using a simplified methodology and the 2008 USGS hazard curves (USGS 2008), gave a seismic CDF ranging from 9x10-7 to 6x10-6 per year for STP depending on spectral acceleration frequency (the peak ground acceleration or 10, 5, or 1 Hz). These results range from 8 to 14 times the corresponding seismic CDF value based on the EPRI hazard curves and used in the SAMA assessment in the ER.
In response to an NRC RAI (NRC 2011b), STPNOC updated the results of the seismic risk analysis to consider recent information for the determination of the seismic hazard frequency (STPNOC 2012a). The update considered the EPRI, LLNL, and the 2008 USGS hazard curves.
In addition, STPNOC modified the seismic model to include:
- an increase in the number of seismic initiators from 4 to 6 to incorporate higher accelerations than in the original model to be compatible with the USGS hazard curves which extend to 2.1 g,
- the elimination of credit for a sequence specific recovery term that was non-conservatively applied in the STP_REV6 model, and
- an update to seismic fragility curves for many selected components based on a review of the original calculations and a plant walkdown associated with this update.
The result of this update yielded a seismic CDF of 3.0x10-6 per year based on the 2008 USGS hazard curves. The NRC staff considers these hazard curves to be the most current data available. The impact of these curves on the SAMA analysis was provided in response to the NRC RAI and is discussed further in Sections F.3.2 and F.6.2.
For SAMA sensitivity consideration, STPNOC has satisfactorily addressed RAIs regarding the seismic PRA (taking into account the 2008 USGS hazard curves, which are the most current data available). Hence, the NRC staff concludes that the updated seismic PRA model including the impact of the 2008 USGS seismic hazard curves provides an acceptable basis for identifying and evaluating the benefits of SAMAs.
The STP IPEEE fire analysis used a fire PRA following NRC guidance (NRC 1991) and represented an update of the previous 1988 PSA. These analyses involved a two-phase evaluation processa spatial interaction analysis and the fire risk assessment. In the spatial interaction analysis, a large set of internal fire scenarios was identified and screened based on consideration of initiation frequency, spatial propagation, impact of mitigation, and the impact on components to plant safety. The resulting fire scenarios considered important were then analyzed in more detail. The resulting fire induced CDF of the unscreened areas was calculated to be 5x10-7 per year (NRC 1998).
The 1988 STP fire PSA was reviewed by Sandia National Laboratory (SNL). The SNL review concluded that the fire analysis was acceptable. This review was updated by the NRC staff in the review of the fire PRA contained in the STP IPEEE with the conclusion that the analysis examined the significant initiating events and dominant accident sequences for STP (NRC 1998). The IPE and IPEEE PRA was also used to support STPNOCs request for changes in certain technical specifications, which was granted in 1994 (NRC 1994).
The fire analysis was subsequently updated in 1994 to address Thermolag fire barrier performance. This fire analysis was supported by a comprehensive plant walkdown, in May 1994, by STP personnel.
As part of the RMTS approval process, the applicant confirmed that all of the high-level requirements for a fire PRA, given in RG 1.200, Revision 1, are addressed in the STP fire PRA model and supporting documentation. In response to a staff concern regarding the screening of F-14
Appendix F fire sequences for the RMTS application, the applicant determined that there were no screened sequences that should be included in the PRA model used for the RMTS application (STPNOC 2007).
The NRC staffs RMTS SER states that, based on STPNOCs submittal and the staffs focused reviews, the STP PRA fire model addresses the technical characteristics and attributes of these elements, identified in RG 1.200, Revision 1, as they relate to issues that could impact the fire models adequacy for implementation of RMTS. Therefore, the staff finds that the STP PRA fire model is acceptable for the RMTS application (NRC 2007a).
The NRC staff noted that the STP fire PRA may underestimate fire risk since it does not incorporate the latest guidance in NUREG/CR-6850, EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities (NRC 2005), and requested that STPNOC assess the impact of this updated guidance on the SAMA analysis (NRC 2011a). In response to this RAI, STPNOC provided the results of an assessment of the impact of the information and insights contained in NUREG/CR-6850 (NRC 2005) concerning fire ignition frequencies, hot short probabilities, and fire non-suppression probabilities on the eight non-screened fire scenarios included in the STP_REV6 model (STPNOC 2012a). This assessment yielded a modified fire initiated CDF of 2.2x10-6 per year, which is about 2.2 times higher than that used in the SAMA analysis. The impact of this modified fire CDF on the SAMA analysis is discussed in Sections F.3.2 and F.6.2.
Based on the following information, the NRC staff concludes that the fire PRA model, modified to address new information and insights contained in NUREG/CR-6850 (NRC 2005), provides an acceptable basis for identifying and evaluating the benefits of SAMAs:
The STP IPE and IPEEE analysis of high winds, floods, and other external events was based on the analysis in the 1988 PSA. A wide range of external events was considered; however, no vulnerabilities were identified in the STP IPEEE due to high winds, floods, and other external events.
For high winds, the STP design is such that critical structures can withstand winds in excess of 360 mph without major damage. The frequency of tornado winds in excess of 360 mph was determined to be 8x10-9 per year. Since there is considerable safety margin in the design, failures would not be expected until wind speeds exceed the design value. Tornado missiles were also considered and the associated risk found to be small.
The likelihood of the ECW intake structure being clogged by debris generated by tornados, hurricanes, or MCR failure were investigated with the dominant contribution being from tornadoes. The frequency of tornadoes that cause blockage and failure of the switchyard was found to be 1.2x10-6 per year (initiating frequency), leading to the currently assessed CDF of 1.1x10-6 per year.
External flooding of the STP site due to storms, offsite dam breaks, and onsite dam breaks were considered and evaluated in the STP IPE and IPEEE. Of all the sources affecting plant safety, the source of greatest importance was found to be the MCR. Many scenarios due to MCR failure that resulted in impacts to various plant equipment were evaluated with the most important being MCR failure leading to ECW failure. The current MCR failure frequency is 3.2x10-7 per year (MCR failure rate), leading to the currently assessed CDF of 2.9x10-7 per year.
F-15
Appendix F A review of transportation and nearby facility accidents confirmed that there were no severe accident vulnerabilities from these accidents (transportation and nearby facility external events).
The total contribution to CDF from these other non-fire and non-seismic external events is 1.4x10-6 per year.
For the STP RMTS license amendment approval, the NRC staff also reviewed the external events modeled in the STP PRA and found that the data and assumptions applied were reasonable and conservative. Based on the applicants submittals and the staff reviews, the staff concluded that the STP PRA external events models complied with the guidance of RG 1.200, Revision 1, and was acceptable for the RMTS application (NRC 2007b).
Given that the STP IPEEE external events PRA model has been reviewed by the NRC staff, that the current model has been reviewed by the NRC staff as part of the RMTS approval, and that STPNOC has satisfactorily addressed NRC staff questions regarding the PRA, the NRC staff concludes that the external events Level 1 PRA model, combined with the results of the analysis of the impacts of new fire and seismic information, is of sufficient quality to support the SAMA evaluation.
The NRC staff reviewed the general process used by STPNOC to translate the results of the Level 1 PRA into containment releases, as well as the results of the Level 2 analysis, as described in the ER and in response to NRC RAIs (STPNOC 2011a). As indicated above, the Level 2 STP PRA model that forms the basis for the SAMA evaluation is essentially an updated version of the IPE model.
The Level 2 analysis is linked to the Level 1 model by extending the model to include the CET, which characterizes the accident phenomena. The CET considers the influence of physical and chemical processes on the integrity of the containment and on the release of fission products once core damage has occurred. Conditions specifically considered on entry into the CET include reactor pressure at the time of core damage, steam generator heat removal, availability of water in the reactor cavity, containment isolation and bypass status, containment spray operation, containment heat removal, and the initiating event.
The STP CET addresses events occurring prior to vessel breach (including the potential for in-vessel recovery), the phenomena associated with both in-vessel and ex-vessel accident progression, containment integrity challenges, and the potential for containment failure. The quantified CET sequences result in 63 possible end-states (or release categories) based on combinations of reactor coolant system conditions at the time of vessel breach, the availability of water to cool the core debris, the availability of containment spray, and the mode and timing of containment failure. These release categories are then combined into the four major release groups: Ilarge early release, IIsmall early release, IIIlate release, and IVintact containment (STPNOC 2011a). The 15 highest frequency release categories that contribute to the major release groups are described in Table F.3-5 of the ER, Attachment F (STPNOC 2010).
Source terms were developed by the applicant for eight release categories using the results of MAAP 4.0.5 computer code calculations (STPNOC 2011a). The source term for the intact release category were estimated from the Wolf Creek SAMA submittal, which is acceptable to the NRC staff based on both the Wolf Creek and STP plants being Westinghouse 4-loop PWR plants and the intact containment release category being a small contributor to the total population dose risk. The results of these analyses for STP are provided in Table F.3-2 of the ER, Attachment F (STPNOC 2010).
Representative source terms for each of the four major release groups were then selected from the source terms for the nine release categories. This was done by reviewing the relevant F-16
Appendix F accident frequencies and release characteristics and selecting the representative accident sequence and source term that was considered the one that best represented how a change in major release group frequency would be reflected in terms of consequence. The representative sequences and source terms selected for the major release groups are identified along with consequence results in Table F.3-6 of the ER, Attachment F (STPNOC 2010).
In the ER, the applicant validated the selection of representative source terms for the major release groups by recalculating the base case consequences using the set of nine release categories, for which source terms were available, with their associated frequencies instead of the four major release groups. As shown in ER Table F.3-8, the total dose-risk consequence (person-rem per year) is identical to that using the representative source terms for the four major release groups. The resulting offsite economic consequence risk (dollars per year) is about 18 percent higher; however, this would only increase the maximum averted cost-risk (MACR), which is discussed in Section F.6.1, by about 1.5 percent, which the applicant considered a very minor change (within acceptable SAMA sensitivity consideration by the staff).
In an RAI, the NRC staff stated that while the reduced set of four representative sequences provided essentially the same result as using the full set of nine sequences, this would not necessarily be true for the cost-benefit analysis of individual SAMAs (NRC 2011a). Since the source terms for the representative sequences are not necessarily those that would yield the largest consequence, any SAMA that impacted a release category frequency whose source term is higher than that for the selected representative sequence would have its benefit underestimated. In response to the RAI, STPNOC provided a sensitivity analysis using the most conservative relevant available source term for each of the nine major release categories.
The result was an increase in population dose risk of over 300 percent to 0.0532 person-Sv per year (5.32 person-rem per year) and a corresponding increase in offsite economic cost risk of over 400 percent. However, while the results showed that selecting alternate conservative source terms for the consequence analysis significantly increases the benefit of the SAMAs evaluated, the conclusions of the SAMA analysis were unchanged (STPNOC 2011a). This is discussed further in Section F.6.2.
The ER notes that some of the MAAP source term release fractions were still increasing based on calculation times of 24 to 48 hours2 days <br />0.286 weeks <br />0.0658 months <br />. A sensitivity case was run with the releases extrapolated to 72 hrs. The resulting population dose risk increased by 5 percent, and the offsite economic cost risk increased by 3 percent.
As indicated above, the current STP Level 2 PRA model is an update of the model used in the IPE. No vulnerabilities were identified in the IPE back-end (i.e., Level 2) analysis. Risk-related insights and improvements discussed in the IPE submittal were discussed previously. The NRC staff and contractor review of the IPE Level 2 analysis concluded that the applicant has made reasonable use of the PSA techniques in performing the back-end analysis and that the techniques employed are capable of identifying severe accident vulnerabilities (NRC 1994b).
The LERF model was included in the Westinghouse Owners Group (WOG) peer review discussed previously, and all F&Os have been resolved (STPNOC 2007). The NRC staffs review of the RMTS application concluded that all F&Os (including those pertaining to LERF) were properly addressed. As stated previously, the staff concluded that the internal events PRA satisfied the guidance of RG 1.200, Revision 1 (NRC 2007b).
Based on the NRC staffs review of the Level 2 methodology, the staff finds that STPNOC has adequately addressed NRC staff RAIs, that the LERF model has been peer reviewed and all F&Os resolved, and that the LERF model was recently reviewed and found to be in conformance with RG 1.200 and the ASME PRA standard.
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Appendix F Based on these findings and the results of the sensitivity analysis, which showed that the conclusions of the SAMA analysis are not changed by using the full set of nine release categories, the NRC staff concludes that the Level 2 PRA provides an acceptable basis for evaluating the benefits associated with various SAMAs.
STPNOC used the MACCS2 code and a core inventory from a plant-specific calculation to determine the offsite consequences of activity release (STPNOC 2010). STPNOC indicated that the core inventory was generated using ORIGEN2.1 based on a conservative projected future power of 4,100 MWt for STP.
The NRC staff reviewed the process used by STPNOC to extend the containment performance (Level 2) portion of the PRA to an assessment of offsite consequences (essentially a Level 3 PRA). This included consideration of the source terms used to characterize fission product releases for the applicable containment release categories and the major input assumptions used in the offsite consequence analyses. Plant-specific input to the code includes the source terms for each source term category and the reactor core radionuclide inventory (both discussed above), site-specific meteorological data, projected population distribution within an 80-km (50-mi) radius for the year 2050, emergency evacuation modeling, and economic data.
This information is provided in Section F.3 of Attachment F to the ER (STPNOC 2010).
All releases were modeled as being from the top of the reactor building. The thermal content of each of the releases was assumed to be the same as ambient (a non-buoyant plume).
Sensitivity analyses were performed for the elevation and thermal content of the releases.
Decreasing the release height from the top of the reactor building to ground level and 25 percent, 50 percent, and 75 percent of containment height decreased the population dose risk by 1 to 2 percent and offsite economic cost risk by 2 to 7 percent. Increasing the release heat to 1 and 10 MW for each plume segment increased the population dose risk by 0 to 3 percent and the offsite economic cost risk by 2 to 7 percent. Building wake effects were also investigated by increasing and decreasing the wake size by a factor of two. The population dose risk showed no change, and the offsite economic cost risk either showed no change or increased by 1 percent. The NRC staff notes that previous SAMA analyses have shown only minor sensitivities to release height, buoyancy, and building wake effects. Based on the information provided, the staff concludes that the release parameters used are acceptable for the purposes of the SAMA evaluation.
STPNOC used site-specific meteorological data for the 2006 calendar year as input to the MACCS2 code. The development of the meteorological data is discussed in Section F.3.5 of Attachment F to the ER. The data were collected from the onsite meteorological monitoring system and the National Weather Service measurements at nearby Palacios Municipal Airport.
Missing meteorological data were first filled in from the onsite backup tower. Gaps in onsite data were filled in from the hourly data at the Palacios Municipal Airport. Remaining data gaps were to be filled in by (in order of preference) using corresponding data from the primary tower 60-meter level (taking the relationship between the levels as determined from immediately preceding hours), interpolation (if the data gap was less than 4 hours0.167 days <br />0.0238 weeks <br />0.00548 months <br />), or using data from the same hour and a nearby day of a previous year. A sensitivity analysis of available data of record was completed using MACCS2 and the meteorological data for the years 2006 and 2008 and found that data for the year 2006 resulted in the largest dose and economic cost risk and this was used for the baseline cost-benefit analysis as appropriate. The population dose risk decreased by 0 to 7 percent and the offsite economic cost decreased by 2 to 11 percent for years 2008 and 2007, respectively. An additional sensitivity case was completed for rainfall in the last spatial segment. The base case assumed rainfall at all times. The sensitivity study allowed the rainfall to follow the onsite meteorology. The resulting population dose risk decreased by 23 percent, and the offsite economic cost risk decreased by 35 percent. The F-18
Appendix F NRC staff notes that previous SAMA analyses results have shown little sensitivity to year-to-year differences in meteorological data and concludes that the use of the 2006 meteorological data in the SAMA analysis is reasonable.
The population distribution used by the applicant as input to the MACCS2 analysis was based on the year 2000 census data from an updated study for the potential construction of additional units (STPNOC 2009). County growth rates were applied to obtain the year 2050 population (Texas State Data Center 2006). In response to an NRC RAI, the applicant stated that the total population in year 2000 for the SAMA analysis was 1.4 percent higher than the SECPOP2000 values presented in Section 2.6.1 of the ER (STPNOC 2011a). This was due to the updated study using a population based on the construction of additional units that is not included in the SECPOP2000 data. SECPOP2000 is a computer coded developed for the NRC by Sandia National Laboratories to calculate the population within 20 and 50 miles of the site. In the RAI response, STPNOC also provided the year 2050 rosette population distribution. The transient population within the emergency planning zone (EPZ), was included in the residential population data for year 2000 and projected to year 2050 (STPNOC 2011a). STPNOC further clarified that the sector multipliers for the major metropolitan areas within the 50-mi radius included any expected high growth rates based on the county-weighted population projections (STPNOC 2011a). The NRC staff considers the methods and assumptions for estimating population reasonable and acceptable for purposes of the SAMA evaluation.
The emergency evacuation model was modeled as a single evacuation zone extending out 16 km (10 mi) from the plant (the EPZ). The applicant assumed that 95 percent of the population would evacuate. This assumption is conservative relative to the NUREG-1150 study (NRC 1990), which assumed evacuation of 99.5 percent of the population within the EPZ. The evacuated population was assumed to move at an average radial speed of approximately 1.34 meters per second (mps) (3.0 mph) with a delayed start time of 60 minutes after declaration of a general emergency for one-half the population. The evacuation speed was projected to conditions associated with year 2050 by conservatively assuming that all of the roads in 2007 transported traffic at their maximum throughput and that no new roads would be constructed. In response to an NRC RAI, the applicant clarified that the year 2007 evacuation study population was based on the exponential growth rate from year 2000 to year 2050 (STPNOC 2011a). Transient population was not calculated separately. A general emergency declaration was assumed to occur when plant conditions degraded to a point where it was judged that there was a credible risk to the public, based on STP emergency action levels.
Times for declaration of emergency are presented in Table F.3-4 of the ER. A sensitivity study was completed where the delayed population was increased and decreased by a factor of two.
The population dose risk increased and decreased by 1 percent, respectively, and the offsite economic cost risk showed no change. Another sensitivity study was performed for the evacuation speed, where the speed was increased and decreased by a factor of two. The increased evacuation speed resulted in a population dose risk decrease by 1 percent and no change in offsite economic cost risk. The decreased evacuation speed resulted in a population dose risk increase of 2 percent and no change in offsite economic cost risk. The NRC staff concludes that the evacuation assumptions and analysis are reasonable and acceptable for the purposes of the SAMA evaluation.
SECPOP2000 (NRC 2003) was used to access site-specific agriculture and economic data from the 1997 National Census of Agriculture for each of the counties surrounding STP to a distance of 80 km (50 mi). The data file accessed by SECPOP2000 for that information was modified to correct two errors in the issued version. These errors are generally known as the missing notes parameter error and the missing county numbers error. In response to an NRC RAI, the applicant clarified that a third error associated with column formatting of regional economic data F-19
Appendix F was also corrected (STPNOC 2011a). Region-wide wealth data (i.e., farm wealth and non-farm wealth) were also based on county-weighted averages for the region within 80 km (50 mi) of the site using data in the 1997 National Census of Agriculture, as accessed by SECPOP2000. In addition, generic economic data that applied to the region as a whole, as described in Section F.3.3 of the ER, were revised from the MACCS2 sample problem input in order to account for cost escalation since 1986 (the year the input was first specified). An escalation factor of 1.94, representing cost escalation from 1986 to January 2009, was applied to parameters describing cost of evacuating and relocating people, land decontamination, and property condemnation.
The NRC staff concludes that the methodology used by STPNOC to estimate the offsite consequences for STP, combined with the results of the sensitivity analysis associated with the selection of representative source terms, provides an acceptable basis from which to proceed with an assessment of risk reduction potential for candidate SAMAs. Accordingly, the NRC staff based its assessment of offsite risk on the CDF and offsite doses reported by STPNOC.
F.3 Potential Plant Improvements The process for identifying potential plant improvements, an evaluation of that process, and the improvements evaluated in detail by STPNOC are discussed in this section.
F.3.1 Process for Identifying Potential Plant Improvements STPNOCs process for identifying potential plant improvements (SAMAs) consisted of the following elements:
- review of the most significant split fractions from the current, plant-specific PRA,
- review of cost-beneficial SAMA candidates identified in LRAs for six other nuclear power plant sites, and
- review of generic SAMA candidates from Nuclear Energy Institute (NEI) 05-01 (NEI 2005) to identify SAMAs that might address areas of concern in the STP PRA.
Based on this process, an initial set of 21 candidate SAMAs, referred to as Phase I SAMAs, were identified. In Phase I of the evaluation, STPNOC performed a qualitative screening of the initial list of SAMAs and eliminated SAMAs from further consideration using the following criteria:
- The SAMA has already been implemented at STP or would achieve results that have already been achieved at STP by other means.
- The SAMA has estimated implementation costs that would exceed the dollar value associated with eliminating all severe accident risk at STP.
Based on this screening, 16 SAMAs were eliminated, leaving 5 SAMAs for further evaluation.
The results of the Phase I screening analysis are shown in Table F.5-3 of Attachment F to the ER. The remaining SAMAs, referred to as Phase II SAMAs, are listed in Table F.6-1 of Attachment F to the ER (STPNOC 2010). In Phase II, a detailed evaluation was performed for each of the five remaining SAMA candidates, as discussed in Sections F.4 and F.6.
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Appendix F F.3.2 Review of STPNOCs Process STPNOCs efforts to identify potential SAMAs included explicit consideration of potential SAMAs for both internal and external events since the STP PRA incorporates all initiating events including internal, fire, seismic, high winds, and floods. The initial list of SAMAs generally addressed the hardware considered to be important to CDF and release category frequency from risk reduction worth (RRW) perspectives at STP and included selected SAMAs from prior SAMA analyses for other plants.
STPNOC provided a tabular listing of the Level 1 PRA split fractions sorted according to their RRW (STPNOC 2010). SAMAs impacting these split fractions would have the greatest potential for reducing risk. STPNOC initially identified a RRW cutoff of 1.24, which corresponds to about a 24 percent change in CDF given 100-percent reliability of the SAMA. This equates to a benefit of approximately $50,000 for a single unit or $100,000 for both units. This is stated to be the minimum implementation cost associated with a procedure change. The applicant indicated that, at this cutoff, only two split fractions would need to be assessed for potential SAMAs.
Since this would only provide limited insights into potential SAMAs, STPNOC extended the Level 1 importance review to include the top 40 split fractions, which corresponds to a RRW of 1.022. This is the equivalent of a two-unit benefit of approximately $11,000. All split fractions in the Level 1 listing were reviewed to identify potential SAMAs and all were addressed by one or more SAMAs (STPNOC 2010).
STPNOC also provided and reviewed the top 40 Level 2 PRA split fractions, corresponding to a RRW of 1.027, for the release categories contributing over 97 percent of the population dose-risk and over 99 percent of the offsite economic cost risk. Major release categories I (large-early), II (small early), and III (late) were included in this assessment. The Level 2 split fractions for release Category IV (containment intact) were not included in the review to prevent split fractions unimportant to dose and cost risk from biasing the importance listing. All split fractions in the Level 2 listing were reviewed to identify potential SAMAs, and all were addressed by one or more SAMAs (STPNOC 2010).
As a result of the review of the Level 1 and Level 2 split fractions, 15 SAMAs were identified.
The applicant reviewed the cost-beneficial Phase II SAMAs from prior SAMA analyses for five Westinghouse PWR sites and one General Electric BWR site. The applicants review identified six additional SAMAs. It was determined that the other Phase II SAMAs reviewed were already represented by a SAMA identified from the importance list reviews, have low potential for risk reduction at STP (i.e., do not address split fractions on the importance lists), or were not applicable to STP.
The NRC staff noted that three SAMAs that were found to be cost beneficial at Prairie Island, were not addressed by STPNOC. Similarly, three SAMAs were found to be cost beneficial at Indian Point, were not addressed by STPNOC (NRC 2011a). STPNOC responded to an RAI indicating that the SAMAs in question had either (a) been implemented at STP or (b) the cost of implementing at STP exceeded the STP MACR (STPNOC 2011a), which justifies the screening of the SAMAs. The staff agrees with this assessment.
Wolf Creek SAMA 13, provide an alternate fuel oil tank with gravity feed capability, was considered already implemented at STP by an existing capability that requires a pump. The NRC staff noted that this has less capability than a gravity system and asked STPNOC to further justify the screening of this SAMA. In response to the RAI, STPNOC provided additional information on fuel oil storage at STP. The current STP fuel oil transfer system uses a gravity feed line between the fuel oil storage tank and the standby diesel generator (SBDG). Each SBDG is supplied from its own dedicated storage tank with a 7-day fuel oil supply. The system F-21
Appendix F described in the disposition of this SAMA is necessary only to refill these dedicated fuel oil storage tanks (STPNOC 2011a).
SAMA 16, provide a portable engine driven instrument air compressor, was identified from a review of industry cost-beneficial SAMAs and was screened out on the basis of having an excessive cost. The basis for this SAMA was Prairie Island SAMA 22, which used nitrogen bottles rather than a portable air compressor. In response to a staff RAI to consider this lower cost alternative, the applicant indicated that loss of instrument air was not identified as a significant contributor to STP risk (STPNOC 2011a). There is only one instrument air split fraction with a RRW greater than 1.000. Its RRW of 1.016 corresponds to an averted cost-risk of $8,100, which would not result in a cost-beneficial SAMA using nitrogen bottles even at the 95th percentile CDF.
STPNOC considered the potential plant improvements described in the STP IPE (HL&P 1992),
which included both internal and external events, in the identification of plant-specific candidate SAMAs. As a result of the review of the IPE, four improvements were identified and are listed in Section F.5.1.4 of Attachment F of the ER. The review of the IPE did not lead to any additional SAMA candidates since the four improvements identified in the IPE have already been implemented at STP (STPNOC 2010).
The applicant also considered the potential for cost-beneficial SAMAs that address the external event contributors screened out in the IPE and IPEEE because of low risk. For each of the screened initiator types, a potential averted cost-risk (PACR) was determined based on an estimate of the event occurrence frequency and assuming that the PACR is proportional to this frequency compared to the CDF. The PACR for each of the seven screened event types is given in Section F.5.1.5 of the ER. All are less than the minimum implementation cost for the site of $100,000 associated with a procedure change. This assessment includes internal floods, which were screened out in the IPE and IPEEE. In response to an NRC RAI, the applicant indicated that a review of the internal flood screening was performed in support of the RMTS license amendment with the conclusion that the earlier screening remained valid (STPNOC 2011a).
In response to an NRC RAI, the applicant clarified that the generic list of industry-based SAMA candidates provided in NEI 05-01 (NEI 2005) was used as an idea source to generate SAMAs for the important contributors identified from the STP PRA (STPNOC 2011a).
As discussed in Section F.2.2, in response to an NRC RAI, STPNOC provided an assessment of the impact of updated information concerning fire and seismic risks on the overall STP risk.
The postulated fire and seismic changes affect the risk profile and increase the maximum possible benefit if all risks were eliminated. Because of these changes, the importance analysis review for the identification of candidate SAMAs and the screening of potential SAMAs was redone. This reassessment is documented in Tables 8, 9 and 10 of the January 19, 2012, submittal (STPNOC 2012a). One additional SAMA (SAMA 1ainstall a seismic safe system) was identified. This SAMA is similar to SAMA 1 and includes earthquake resistant heat removal systems that could operate in the event of a seismically induced station blackout (SBO). This SAMA was screened as having an excessive cost.
Based on this information, the NRC staff concludes that the set of SAMAs evaluated in the ER, together with those identified in response to NRC staff RAIs, addresses the major contributors to both internal and external event CDF.
The NRC staff questioned the applicant about potentially lower cost alternatives to some of the SAMAs evaluated (NRC 2011a, 2012a), including:
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Appendix F
- use of the Technical Support Center (TSC) diesel generator (DG) to both supply the positive displacement pump (PDP) and support auxiliary feedwater (AFW) operation;
- installing an alternate intake structure for the ECW either in the ECP or the MCR that would minimize the likelihood of debris preventing ECW cooling or using temporary and portable pumps with a movable suction that could provide water to the ECW system; and
- strengthening the ECW pump seismic restraints, which was identified as limiting in the fragility update, in lieu of installing the complex seismic safe system (STPNOC 2012a).
In response to the RAIs, the applicant addressed the suggested lower cost alternatives and determined that they were either not feasible or were not cost beneficial (STPNOC 2011a, 2012b). This is discussed further in Section F.6.2.
The NRC staff notes that the set of SAMAs submitted is not all-inclusive since additional, possibly even less expensive, design alternatives can always be postulated. However, the NRC staff concludes that the benefits of any additional modifications are unlikely to exceed the benefits of the modifications evaluated and that the alternative improvements would be unlikely to cost less than the least expensive alternatives evaluated when the subsidiary costs associated with maintenance, procedures, and training are considered.
The NRC staff concludes that STPNOC used a systematic and comprehensive process for identifying potential plant improvements for STP, and the set of SAMAs evaluated in the ER, together with those evaluated in response to NRC staff inquiries, is reasonably comprehensive and, therefore, acceptable. This search included reviewing insights from the STP plant-specific risk studies that included internal initiating events as well as fire, seismic, and other external initiated events, and reviewing plant improvements considered in previous SAMA analyses.
F.4 Risk Reduction Potential of Plant Improvements In the ER, the applicant evaluated the risk-reduction potential of the five SAMAs that were not screened out in the Phase I analysis and retained for the Phase II evaluation. The SAMA evaluations were performed using realistic assumptions with some conservatism.
STPNOC used model re-quantification to determine the potential benefits for each SAMA. The CDF, population dose, and offsite economic cost reductions were estimated using the STP STP_REV6 PRA model. The changes made to the model to quantify the impact of SAMAs are detailed in Section F.6 of Attachment F to the ER (STPNOC 2010). Table F-7 lists the assumptions considered to estimate the risk reduction for each of the evaluated SAMAs, the estimated risk reduction in terms of percent reduction in CDF and population dose, and the estimated total benefit (present value) of the averted risk. The estimated benefits reported in Table F-7 reflect the combined benefit in both internal and external events. The determination of the benefits for the various SAMAs is further discussed in Section F.6.
The impact of SAMA 10, enhance procedures to ensure the SGs are filled or maintained filled in SGTR events to scrub fission products, was modeled by reassigning the SGTR CDF contribution for Release Categories I (7.48x10-9 per year) and III (1.35x10-7 per year) to Release Categories II and IV, respectively. In response to an NRC RAI regarding the source of these values, the applicant indicated that because SAMA 10 is dependent on the availability of F-23
Appendix F secondary side makeup, only a fraction of SGTR scenarios are relevant to the SAMA 10 evaluation. The relevant frequencies were obtained from an examination of the PRA models results (STPNOC 2011a).
The NRC staff noted that the evaluation of SAMA 12, enhance procedures to prevent clearing of RCS cold leg water seals, did not consider the condition in which non-condensable gases such as hydrogen are present since this condition is not modeled in the PRA. Additionally, the staff noted that SBO sequences were excluded in the modeling of this SAMA because AC power is needed to start an RCP. The staff asked STPNOC to assess whether these potential non-conservatisms impact the SAMA analysis (NRC 2011a). In response to the RAI, the applicant clarified that the scenario leading to hydrogen gas generation condition is represented conservatively in the induced SGTR event scenarios. The sequences for the scenarios are included in the assessment of SAMA 12 (STPNOC 2011a). The applicant further clarified that excluding the SBO sequences is appropriate because:
(a) Induced SGTR is not an issue for SBO scenarios in which offsite power is recovered in time to prevent core damage.
(b) Plant procedures do not instruct the operators to start the RCPs for SBO scenarios in which offsite power is restored only after core damage.
For these reasons, the applicant concluded that the evaluation of SAMA 12 is not underestimated.
The NRC staff has reviewed STPNOCs bases for calculating the risk reduction for the various plant improvements and concludes, with the above clarifications, that the rationale and assumptions for estimating risk reduction are reasonable and generally conservative (i.e., the estimated risk reduction is higher than what would actually be realized). Accordingly, the NRC staff based its estimates of averted risk for the various SAMAs on STPNOCs risk reduction estimates.
F.5 Cost Impacts of Candidate Plant Improvements STPNOC estimated the costs of implementing the 21 Phase I SAMAs through the development of site-specific cost estimates and use of other applicants estimates for similar improvements.
The costs were developed on a site basis (i.e., two units). If the cost estimate was for a single unit based on other applicants estimates for similar improvements, the cost estimate was multiplied by two to derive the costs on a site basis. The site-specific cost estimates did not include (a) contingency cost (unexpected implementation obstacles) or (b) the cost of replacement power during extended outages required to implement the modifications (STPNOC 2010). This approach is in accordance with NEI 05-01 and conservative. The cost estimates based on other applicants estimates did not account for inflation, which is also conservative.
In response to an NRC RAI regarding the source of the cost estimates, the applicant replied that the scope and definition of the SAMA were initially developed by the PRA analyst and then reviewed and modified by the STP design staff to account for any plant-specific issues that could interfere with or improve the SAMA design. The major cost contributors were then identified, and their cost magnitudes were estimated by the design engineers (cost estimating is a normal part of STPNOCs design engineers functions as appropriate) (STPNOC 2011a).
The NRC staff reviewed the applicants cost estimates, presented in Table F-6.1 of Attachment F to the ER in response to NRC RAIs (STPNOC 2011a). For certain improvements, the NRC staff compared the cost estimates to estimates developed elsewhere for similar F-24
Appendix F improvements, including estimates developed as part of other applicants analyses of SAMAs, for operating reactors.
The NRC staff noted that the estimated cost of $7.6M for SAMA 17a, install Westinghouse RCP shutdown seals, is higher than other estimates for Westinghouse improved seals such as the estimate by Tennessee Valley Authority for Watts Bar Unit 2 of $1.1M (TVA 2010). In response to the RAI, STPNOC indicated that the STP RCP seal design is different from that used at Watts Bar and other Westinghouse plants (STPNOC 2011a). Because of this unique design, STP would incur an entire new seal design and associated engineering costs while the other plants would be able to spread the costs over a larger number of units. STPNOC provided the details of the STP cost estimate, which included engineering, procedure revision, modified seal housing, new seals, and installation. The NRC staff notes that even with some cost savings that might be possible, not included in STPNOCs estimate, the cost is expected to be well above the Watts Bar estimate and the STP MACR. The NRC staff considers STPNOCs justification for the cost of implementing SAMA 17a reasonable.
The NRC staff also noted that the estimated cost of $4.5M for SAMA 14, provide capability to cross-tie emergency 4 KV divisions on a single unit, seems high given that an inter-unit cross-tie is already available. In response to the RAI, the applicant stated that the original intent of SAMA 14 was to provide the capability to perform the cross-tie between emergency 4 KV AC buses within a unit rapidly enough to prevent an RCP seal LOCA. The most effective means for achieving this capability was a direct bus-to-bus connection, which does not currently exist at STP. An indirect path is, however, available through an emergency transformer using existing hardware. Using this path would require significant engineering and procedure development costs due to the potential for creating single failure potential among multiple divisions of equipment. While the estimated costs for the work associated with this alternative is not cost beneficial, STPNOC also notes that the available time to prevent RCP seal failure is such that navigating through the procedures and implementing the cross-tie in time to prevent seal failure is unlikely (STPNOC 2011a). The NRC staff considers STPNOCs justification for the cost of implementing SAMA 14 reasonable.
In response to an NRC RAI (STPNOC 2011a), the applicant provided the details of the cost estimates for two SAMAs: SAMA 3b, install fire wrap on PDP cables in cable spreading room, and SAMA 11, modify fire protection system to supply containment spray headers. The detailed cost estimate for SAMA 11 supports the cost used and the conclusion in the SAMA analysis (as discussed in the response). For SAMA 3b, the applicant estimated the engineering portion of the cost to be $250,000 per unit, which appears high to the NRC staff. The staff notes that this estimated cost may be valid due to the need to identify the PDP cables (as explained by the applicant). Furthermore, if the engineering costs were reduced by $50,000 per unit, the resulting total cost of $700,000 ($800K minus 2x$50K) is still well above the benefit reported for this SAMA (see Table F-7). The NRC staff concludes that, with the above clarifications, the cost estimates provided by STPNOC are sufficient and appropriate for use in the SAMA evaluation.
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Table F-7. SAMA Cost-Benefit Screening Analysis for STP
% Risk reduction Total benefit ($)
Baseline Baseline with Cost ($)
Appendix F Population CDF (internal + uncertainty (b) dose SAMA (a) Assumptions external)
(c) 3b Install fire wrap on PDP cables Eliminate failure of the PDP due to a fire in <1 <1 3K 7K 800K in cable spreading room the cable spreading room 4Develop procedures to isolate eliminate failure of the operator action to 2 10 27K 72K 100K CCW inside containment isolate CCW 10Enhance procedures to ensure Reassign a portion of the SGTR CDF 0 2 3K 8K 100K the SGs are filled or maintain filled in contribution for the large early release SGTR events to scrub fission products category (7.48E-06 per year) and late release category (1.35E-07 per year) to the small early release category and intact containment release category, respectively F-26 12Enhance procedures to prevent Reassign the induced SGTR CDF 0 0 <1K <1K 100K clearing of RCS cold leg water seals contribution (2.4E-09 per year) for sequences in which offsite power is available from the large early release category to the intact containment release category 13Develop procedures to open Eliminate failure of the operator action to <1 0 1K 3K 100K doors or use portable fans for alternate provide SBDG room cooling SBDG room cooling or both 15Develop emergency procedures Eliminate failure of the operator action to 1 2 8K 20K 100K for alternate essential ECWIS room provide ECWIS room cooling cooling (a)
The impact of the sensitivity analysis to updated fire and seismic data is not included in these results. Section F.6.2 provides a discussion of these impacts.
(b)
Based on the response to NRC staff RAI 1.d (STPNOC 2011b), the NRC staff increased the baseline benefits by a factor of 2.7 to account for uncertainties.
(c)
SAMA 3b retained as a Phase II SAMA based on the results of the uncertainty analysis.
Appendix F F.6 Cost-Benefit Comparison STPNOCs cost-benefit analysis and the NRC staffs review are described in the following sections.
F.6.1 STPNOCs Evaluation The methodology used by the applicant was based primarily on NRCs guidance for performing cost-benefit analysis (i.e., NUREG/BR-0184 (NRC 1997a)). The guidance involves determining the net value for each SAMA according to the following formula:
Net Value = (APE + AOC + AOE + AOSC) COE where:
APE = present value of averted public exposure ($)
AOC = present value of averted offsite property damage costs ($)
AOE = present value of averted occupational exposure costs ($)
AOSC = present value of averted onsite costs ($)
COE = cost of enhancement ($)
If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the benefit associated with the SAMA, and it is not considered cost beneficial. STPNOCs derivation of each of the associated costs is summarized below.
NUREG/BR-0058 has been revised to reflect the NRCs policy on discount rates. Revision 4 of NUREG/BR-0058 states that two sets of estimates should be developed, one at 3 percent and one at 7 percent (NRC 2004). The applicant provided a base set of results using the 3 percent discount rate and a sensitivity study using the 7 percent discount rate (STPNOC 2010).
Averted Public Exposure (APE) Costs The APE costs were calculated using the following formula:
APE = Annual reduction in public exposure ( person-rem per year) x monetary equivalent of unit dose ($2,000 per person-rem) x present value conversion factor (15.04 based on a 20-year period with a 3-percent discount rate)
As stated in NUREG/BR-0184 (NRC 1997a), it is important to note that the monetary value of the public health risk after discounting does not represent the expected reduction in public health risk due to a single accident. Rather, it is the present value of a stream of potential losses extending over the remaining lifetime, in this case, the renewal period, of the facility.
Thus, it reflects the expected annual loss due to a single accident, the possibility that such an accident could occur at any time over the renewal period, and the effect of discounting these potential future losses to present value. For the purposes of initial screening, which assumes elimination of all severe accidents due to internal and external events, the applicant calculated an APE of approximately $52,300 for the 20-year license renewal period (STPNOC 2010).
Averted Offsite Property Damage Costs (AOC)
The AOCs were calculated using the following formula:
AOC = Annual CDF reduction x offsite economic costs associated with a severe accident (on a per event basis) x present value conversion factor F-27
Appendix F For the purposes of initial screening, which assumes all severe accidents due to internal and external events are eliminated, the applicant calculated an annual offsite economic risk of about
$1,600 based on the Level 3 risk analysis. This results in a discounted value of approximately
$24,400 for the 20-year license renewal period (STPNOC 2010).
Averted Occupational Exposure (AOE) Costs The AOE costs were calculated using the following formula:
AOE = Annual CDF reduction x occupational exposure per core damage event x monetary equivalent of unit dose x present value conversion factor The applicant derived the values for averted occupational exposure from information provided in Section 5.7.3 of the NUREG/BR-0184 (NRC 1997a). Best estimate values provided for immediate occupational dose (3,300 person-rem) and long-term occupational dose (20,000 person-rem over a 10-year cleanup period) were used. The present value of these doses was calculated using the equations provided in the handbook in conjunction with a monetary equivalent of unit dose of $2,000 per person-rem, a real discount rate of 3 percent, and a time period of 20 years to represent the license renewal period. For the purposes of initial screening, which assumes all severe accidents due to internal and external events are eliminated, the applicant calculated an AOE of approximately $4,000 for the 20-year license renewal period (STPNOC 2010).
Averted Onsite Costs Averted onsite costs (AOSC) include averted cleanup and decontamination costs and averted power replacement costs. Repair and refurbishment costs are considered for recoverable accidents only and not for severe accidents. The applicant derived the values for AOSC based on information provided in Section 5.7.6 of NUREG/BR-0184 (NRC 1997a).
The applicant divided this cost element into two partsthe onsite cleanup and decontamination cost, also commonly referred to as averted cleanup and decontamination costs, and the replacement power cost.
Averted cleanup and decontamination costs (ACC) were calculated using the following formula:
ACC = Annual CDF reduction x present value of cleanup costs per core damage event x present value conversion factor The total cost of cleanup and decontamination subsequent to a severe accident is estimated in the NUREG/BR-0184 (NRC 1997a) to be $1.5x109 (undiscounted). This value was converted to present costs over a 10-year cleanup period and integrated over the term of the proposed license extension. For the purposes of initial screening, which assumes all severe accidents due to internal and external events are eliminated, the applicant calculated an ACC of approximately $124,500 for the 20-year license renewal period (STPNOC 2010).
Long-term replacement power costs (RPC) were calculated using the following formula:
RPC = Annual CDF reduction x present value of replacement power for a single event x factor to account for remaining service years for which replacement power is required F-28
Appendix F x reactor power scaling factor The applicant based its calculations on the rated STP net electric output of 1,365 megawatt-electric (MWe) per unit and scaled up from the 910 MWe reference plant in NUREG/BR-0184 (NRC 1997a). Therefore, the applicant applied a power-scaling factor of 1,365/910 (or STP net electric output divided by reference plant output) to determine the replacement power costs. For the purposes of initial screening, which assumes all severe accidents due to internal and external events are eliminated, STPNOC calculated an RPC of approximately $53,000 and an AOSC of approximately $178,000 for the 20-year license renewal period (STPNOC 2010).
Using the above equations, the applicant estimated the total present dollar value equivalent associated with eliminating severe accidents from internal and external events at STP to be about $258,200 for a single unit, rounded to $259,000. Because all SAMA costs and benefits were provided on a site basis, the applicant doubled this value to obtain the two-unit site value of $518,000. This represents the dollar value associated with eliminating severe accident risks for all internal and external events at the two STP units (referred to as the maximum averted cost-risk (MACR)).
STPNOCs Results If the implementation costs for a candidate SAMA exceeded the calculated benefit, the SAMA was considered not to be cost beneficial. In the baseline analysis contained in the ER (using a 3 percent discount rate), STPNOC identified no potentially cost-beneficial SAMAs. STPNOC also did not identify any potentially cost-beneficial SAMAs even after consideration of analysis uncertainties.
F.6.2 Review of STPNOCs Cost-Benefit Evaluation The cost-benefit analysis performed by STPNOC was based primarily on NUREG/BR-0184 (NRC 1997a) and discount rate guidelines in NUREG/BR-0058 (NRC 2004). The analysis was executed consistently with this guidance. No SAMAs were determined to be cost beneficial in STPNOCs baseline analysis in the ER.
The applicant considered the impact that possible increases in benefits from analysis uncertainties would have on the results of the SAMA assessment. In the ER, STPNOC presents the results of an uncertainty analysis of the internal and external events CDF for STP, which indicates that the 95th percentile value is a factor of 1.6 greater than the mean CDF for STP. The applicant considered whether any additional Phase I SAMAs might be retained for further analysis if the MACR is increased by a factor of 1.6. One such SAMA was identified SAMA 3b, install fire wrap on PDP cables in cable spreading room.
The applicant also considered the impact on the Phase II analysis if the estimated benefits from internal and external events were increased by the 1.6 uncertainty factor. The additional Phase I SAMASAMA 3bwas included in this sensitivity analysis. No SAMAs became cost beneficial in STPNOCs analysis (STPNOC 2010).
In Section F.7.1 of the ER, the total CDF of 6.39x10-6 per year is described as being the mean from the RISKMAN Monte Carlo quantification. In response to the NRC RAI on the uncertainty analysis, STPNOC provided further information describing how the analysis was performed.
Since the quantification of the complete STP Level 1 PRA results in a large number of sequences, for which an uncertainty analysis is impractical, a reduced set of sequences is used.
The results of the Monte Carlo analysis were then scaled so that the mean of the distribution F-29
Appendix F matched the mean of the CDF point estimates. The total CDF of 6.39x10-6 per year is, therefore, a point estimate (STPNOC 2011a).
In response to an NRC RAI (NRC 2011a), STPNOC provided an uncertainty analysis that indicated the 95th percentile CDF for the reduced set of sequences used is 1.59x10-5 per year while the mean CDF and point estimate CDF for these sequences are 8.52x10-6 per year and 5.89x10-6 per year, respectively. The uncertainty multiplier was then revised to be the ratio of the 95th percentile CDF to the point estimate, both for the reduced set of sequences, or 1.59x10-5 divided by 5.89x10-6 or 2.7 (STPNOC 2011b). The applicant considered whether any additional Phase I SAMAs might be retained for further analysis if the MACR is increased by a factor of 2.7. No additional SAMAs were identified.
The applicant also considered the impact on the Phase II analysis if the estimated benefits from internal and external events were increased by the 2.7 uncertainty factor. No SAMAs became cost beneficial in STPNOCs analysis (STPNOC 2011b).
The NRC staff noted that the original 1.6 uncertainty ratio developed for STP appeared to be low considering the larger uncertainty bands associated with external events. The applicant responded that, with the exception of seismic initiating events, probability distributions for all initiating events were included in the Monte Carlo uncertainty analysis and that use of point estimates for the seismic sequences was considered justified because of the small seismic CDF contribution (STPNOC 2011a). However, as discussed in Section F.2.2, the seismic CDF may be considerably larger than that used in the cost-benefit analyses presented in the ER.
Based on the following information, the NRC staff considers the use of the 2.7 uncertainty multiplier for the SAMA analysis. This is consistent with the guidance provided in NEI 05-01 and acceptable:
- STPNOCs revised analysis used the higher uncertainty factor of 2.7, which is generally higher than the 95th percentile uncertainty factor used in other SAMA analyses.
- STPNOC performed a separate assessment of the impact of the higher seismic CDF on the SAMA analysis.
- The increased uncertainty in seismic risk would not be expected to impact the benefit of SAMAs not specifically addressing seismic failures.
STPNOC provided the results of additional sensitivity analyses in the ER, including use of a 7 percent discount rate and variations in MACCS2 input parameters. These analyses did not identify any additional potentially cost-beneficial SAMAs (STPNOC 2010).
As discussed in Section F.2.2, the selection of representative sequences and associated source terms to be used for the four major release categories could yield non-conservative risk benefits. In response to an NRC RAI, the applicant provided the results of a sensitivity analysis that used the most conservative relevant available source term for each of the nine major release categories (STPNOC 2011a). STPNOC revised the baseline analysis using the conservative source terms (using a 3 percent discount rate) and identified no potentially cost-beneficial SAMAs. The NRC staff also increased the revised baseline benefits by a factor of 2.7 to account for uncertainties and identified no potentially cost-beneficial SAMAs. The results for the revised baseline and revised baseline with uncertainty are provided in Table F-8.
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Appendix F Table F-8. SAMA Cost-Benefit Screening Analysis for STP Using Conservative Source Terms Total benefit ($)
Conservative Conservative source terms source terms Cost ($)
SAMA revised baseline revised baseline (internal + with external) uncertainty(a) 3bInstall fire wrap on PDP cables in cable 7K 18K 800K spreading room 4Develop procedures to isolate CCW inside 35K 94K 100K containment 10Enhance procedures to ensure the SGs are 30K 80K 100K filled or maintain filled in SGTR events to scrub fission products 12Enhance procedures to prevent clearing of <1K <1K 100K RCS cold leg water seals 13Develop procedures to open doors or use 4K 10K 100K portable fans for alternate SBDG room cooling or both 15Develop emergency procedures for alternate 14K 38K 100K ECWIS room cooling (a)
Based on the response to NRC RAI 1.d (STPNOC 2011b), the NRC staff increased the revised baseline benefits by a factor of 2.7 to account for uncertainties.
SAMAs identified primarily on the basis of the internal events analysis could provide benefits in certain external events, in addition to their benefits in internal events. Since the STP_REV6 PRA model is an integrated internal and external events model, STPNOCs evaluation accounted for the potential risk reduction benefits associated with both internal and external events.
As discussed in Section F.2.2, the NRC staff asked STPNOC to assess the impact of the updated fire and seismic information on the SAMA analysis (NRC 2011a). In this analysis, STPNOC revised the baseline analysis using the updated fire and seismic information and increased these revised baseline analyses by 2.7 to account for uncertainties (using a 3 percent discount rate) and identified no potentially cost-beneficial SAMAs. The NRC staff also increased these revised benefits to account for the conservative source terms and identified no potentially cost-beneficial SAMAs. The results of these analyses are provided in Table F-9.
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Appendix F Table F-9. SAMA Cost-Benefit Screening Analysis for STP Using Updated Fire and Seismic Risk Analysis and Conservative Source Terms Total benefit ($)
Updated fire and Updated fire and seismic risk seismic risk assessment SAMA assessment Cost ($)
(internal + external)
(internal + with uncertainty(a) external) with and conservative uncertainty(a) source terms(b) 3bInstall fire wrap on PDP cables in cable 18K 44K 800K spreading room 4Develop procedures to isolate CCW inside 71K 94K 100K containment 10Enhance procedures to ensure the SGs are 8K 84K 100K filled or maintain filled in SGTR events to scrub fission products 12Enhance procedures to prevent clearing of 3K 4K 100K RCS cold leg water seals 13Develop procedures to open doors or use 16K 51K 100K portable fans for alternate SBDG room cooling or both 15Develop emergency procedures for 22K 41K 100K alternate ECWIS room cooling (a)
Baseline benefits increased by a factor of 2.7 to account for uncertainties (STPNOC 2012a, 2012b).
(b)
The impact of conservative source terms is obtained from the results provided in Table 2-11 of the July 5, 2011, submittal (STPNOC 2011a) compared with the results of the original submittal (STPNOC 2010).
As indicated in Section F.3.2, the NRC staff asked the applicant to evaluate potentially lower cost alternatives to the SAMAs considered in the ER (NRC 2011a), as summarized below:
- SAMA 1, involving using a portable AC generator for long term AFW support and protecting the Technical Support Center (TSC) emergency diesel generator (EDG) from tornado events, was identified as a means of mitigating a large number of important basic events. While the tornado protection is important for high wind initiated sequences, many other sequences would be mitigated without the cost of the tornado protection.
STPNOC provided the results of a cost estimate that did not include the costs associated with the tornado protection. The revised cost of $2.4 million is much larger than the MACR; hence, such an alternative was determined not to be cost beneficial (STPNOC 2011a).
- An additional alternate to SAMA 1 would be to use the TSC DG to both supply the PDP and support AFW operation rather than requiring a portable AC generator. STPNOC provide the results of a cost estimate for this alternative. The revised cost of $1.9 million remains above the MACR; hence, this alternative was determined not to be cost beneficial (STPNOC 2011a).
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Appendix F
- The tornado induced failure of the switchyard and emergency cooling pond could be mitigated by installing an alternate intake structure for the ECW either in the ECP or the MCR that would minimize the likelihood of debris preventing ECW cooling or using a temporary and portable pumps with a movable suction that could provide water to the ECW system. In response to the RAI, STPNOC provided the results of a cost estimate for a large surface area debris cage as a less costly alternative to an additional intake structure.
This cost was $828,000, which is approximately equal to the 95th percentile MACR. The cost for the even less costly portable truck-mounted pump alternative was given as $350,000. While less than the MACR, this cost is more than the benefit associated with eliminating the tornado initiated sequence (17 percent of the total CDF), or $143,000 at the 95th percentile; hence, this alternative was determined to not be cost beneficial (STPNOC 2011a).
- Strengthening ECW pump seismic restraints was identified as an alternative to the SAMA 1a seismic safe system. While not mitigating all seismically induce SBOs, it is potentially less costly than the complex seismic safe system. STPNOC assessed the benefit of eliminating the risk to ECW pump seismic failures using the Fussell-Vesely importance results and found the benefit to be $54,000 using the 2.7 uncertainty multiplier. However, it is not cost beneficial because it is less than the minimum SAMA implementation cost (for procedure changes) of $100,000 (STPNOC 2012b). If adjusted to incorporate the potential impact of the more conservative source terms, the NRC staff estimates that the benefit could be somewhat greater than $100,000. However, based on the expected cost of strengthening the seismic restraints, which would involve replacing 24 seismic bolts deeply imbedded in concrete, and that the analysis conservatively assumes all of the risk would be eliminated by replacing the seismic bolts, the NRC staff concludes that this alternative is unlikely to be cost beneficial.
As indicated in Section F.4, the NRC staff questioned STPNOC on the risk reduction potential for certain SAMAs (NRC 2011a, 2011b). In response to the RAIs, STPNOC addressed each SAMA and addressed the staffs concerns.
The NRC staff concludes that the costs of all of the SAMAs evaluated would be higher than the associated benefits.
F.7 Conclusions STPNOC compiled a list of 21 SAMAs based on a review of the most significant split fractions from the plant-specific internal and external event PRA, insights from the plant-specific IPE, cost-beneficial SAMAs from LRAs for other plants, and review of other industry documentation.
An initial qualitative screening removed SAMA candidates that:
- modified features not applicable to STP due to design differences,
- were determined to have already been implemented at STP or would achieve results that have already been achieved at STP by other means, or
- have estimated implementation costs that would exceed the dollar value associated with completely eliminating all severe accident risk at STP.
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Appendix F Based on this screening, 16 SAMAs were eliminated, leaving 5 candidate SAMAs for evaluation.
For the remaining SAMA candidates, a cost-benefit analysis was performed, with the results shown in Table F-7. The cost-benefit analyses showed that none of the SAMA candidates were potentially cost beneficial in the baseline analysis. STPNOC performed additional analyses to evaluate the impact of parameter choices and uncertainties on the results of the SAMA assessment. In this process, one additional SAMA was identified for detailed cost-benefit analysis. However, additional analyses did not result in the discovery of any of the SAMA candidates being potentially cost beneficial.
The NRC staff reviewed the STPNOC analysis and concludes that the methods used, and the implementations of those methods, were sound. The treatment of SAMA benefits and costs supports the general conclusion that the SAMA evaluations performed by STPNOC are reasonable and sufficient for the license renewal submittal.
The staff concurs with STPNOCs conclusion that none of the candidate SAMAs are potentially cost beneficial. This conclusion is based on the generally conservative treatment of costs and benefits. This conclusion is consistent with the low residual level of risk indicated in the STP PRA and the fact that STPNOC has already implemented the plant improvements identified from the IPE and IPEEE.
F.8 References 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, Domestic Licensing of Production and Utilization Facilities.
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.
10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, Reactor Site Criteria.
[ASME] American Society of Mechanical Engineers. 2002. Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications. ASME RA-S-2002, April 5, 2002.
[ASME] American Society of Mechanical Engineers. 2003. Addenda to ASME RA-S-2002, Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications. ASME RA-Sa-2003, December 5, 2003.
[ASME] American Society of Mechanical Engineers. 2005. Addenda to ASME RA-S-2002, Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications. ASME RA-Sb-2005, December 30, 2005.
[EPRI] Electric Power Research Institute. 1989. Probabilistic Seismic Hazard Evaluations at Nuclear Plant Sites in the Central and Eastern United States; Resolution of the Charleston Earthquake Issues. EPRI NP-6395-D, EPRI Project P101-53, Palo Alto, CA. April 1989.
[HL&P] Houston Lighting and Power Company. 1992. South Texas Project Electric Generating Station Level 2 Probabilistic Safety Assessment and Individual Plant Examination.
August 1992. ADAMS No. ML0617001702, ML0617001790, ML0617001850.
[NEI] Nuclear Energy Institute. 2005. Severe Accident Mitigation Alternative (SAMA) Analysis Guidance Document, NEI 05-01 (Rev. A). Washington, D.C. November 2005.
F-34
Appendix F
[NRC] U.S. Nuclear Regulatory Commission. 1988. Generic Letter 88-20, Individual Plant Examination for Severe Accident Vulnerabilities. November 23, 1988. ADAMS No. ML031150465
[NRC] U.S. Nuclear Regulatory Commission. 1989. Seismic Hazard Characterization of 69 Nuclear Plant Sites East of the Rocky Mountains. Washington DC: NRC.
NUREG/CR-5250, Volume 5. 1989.
[NRC] U.S. Nuclear Regulatory Commission. 1990. Severe Accident Risks: An Assessment for Five U.S. Nuclear Power PlantsFinal Summary Report. Washington DC: NRC.
NUREG-1150, Volume 1. 1990.
[NRC] U.S. Nuclear Regulatory Commission. 1991. Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities. Washington, DC: NRC. Generic Letter No. 88-20, Supplement 4. June 28, 1991. ADAMS No. ML031150485
[NRC] U.S. Nuclear Regulatory Commission. 1994a. Letter from Suzanne C. Black, Director, to William T. Cottle, Houston Lighting & Power Company.
Subject:
Issuance of Amendment Nos. 59 and 47 to Facility Operating License Nos. NPF-76 and NPF-80 and Related Relief RequestSouth Texas Project, Units 1 and 2 (TAC Nos. M76048 and M76049).
February 17, 1994. ADAMS No. ML021300134.
[NRC] U.S. Nuclear Regulatory Commission. 1994b. Memorandum to: Steven A. Varga (USNRC-NRR) to M. Wayne Hodges (USNRC-RES),
Subject:
Review of South Texas Project Individual Plant Examination (IPE) SubmittalInternal Events. December 1994.
[NRC] U.S. Nuclear Regulatory Commission. 1997a. Regulatory Analysis Technical Evaluation Handbook. Washington, DC: NRC. NUREG/BR-0184. ADAMS No. ML050190193.
[NRC] U.S. Nuclear Regulatory Commission (NRC). 1997b. Individual Plant Examination Program: Perspectives on Reactor Safety and Plant Performance. Washington, DC: NRC.
NUREG-1560. ADAMS No. ML063550244, ML063550228, and ML063470259.
[NRC] U.S. Nuclear Regulatory Commission. 1998. Letter from Thomas W. Alexion, U.S. NRC, to William T. Cottle, STP Nuclear Operating Company.
Subject:
Review of south Texas Project, Units 1 and 2 Individual Plant Examination of External Events (IPEEE) Submittal (JAC Nos. M83676 and M83677). Washington, D.C. December 15, 1998.
[NRC] U.S. Nuclear Regulatory Commission. 2003. SECPOP2000: Sector Population, Land Fraction, and Economic Estimation Program. Washington, DC: NRC. NUREG/CR-6525, Rev. 1. August 2003. ADAMS No. ML032310279.
[NRC] U.S. Nuclear Regulatory Commission. 2004. Regulatory Analysis Guidelines of the U.S.
Nuclear Regulatory Commission. Washington, DC: NRC. NUREG/BR-0058, Rev. 4. ADAMS No. ML003738939.
[NRC] U.S. Nuclear Regulatory Commission. 2005. EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities. Washington, DC: NRC NUREG/CR-6850. September 2005.
[NRC] U.S. Nuclear Regulatory Commission. 2007a. Letter from Mohan C. Thadani, U.S.
NRC, to James J. Sheppard, STPNOC.
Subject:
South Texas Project Units 1 and 2, Issuance of Amendments Re: Broad-scope Risk-informed Technical Specifications Amendments (TAC Nos. MD2341 and MD2342). Washington, D.C. July 13, 2007. ADAMS No. ML071780186.
[NRC] U.S. Nuclear Regulatory Commission. 2007b. An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities.
Regulatory Guide 1.200, Revision 1. Washington, D.C. January 2007. ADAMS No. ML063170035.
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Appendix F
[NRC] U.S. Nuclear Regulatory Commission. 2010. NRC Information Notice 2010-18: Generic Issue 199, Implications of Updated Probabilistic Seismic Hazard Estimates in Central and Eastern United States on Existing Plants. Washington, D.C. September 2, 2010. ADAMS No. ML101970221.
[NRC] U.S. Nuclear Regulatory Commission. 2011a. Letter from Tam Tran, Project Manager, to G.T. Powell, STPNOC.
Subject:
Requests for Additional Information for the Review of the South Texas Project, License Renewal Application. Washington, D.C. May 31, 2011. ADAMS No. ML11140A015.
[NRC] U.S. Nuclear Regulatory Commission. 2011b. Letter from Tam Tran, Project Manager, to G.T. Powell, STPNOC.
Subject:
Requests for Additional Information for the Review of the South Texas Project, License Renewal Application. September 1, 2011. ADAMS No. ML112360114.
[NRC] U.S. Nuclear Regulatory Commission. 2011c. Memorandum from Tam Tran, Project Manager.
Subject:
Summary of Telephone Conference Call Held on July 28, 2011 between the U.S. Nuclear Regulatory Commission and STP Nuclear Operating Company, Concerning Requests for Additional Information Pertaining to the South Texas Project, License Renewal Application. August 23, 2011. ADAMS No. ML11216A263.
[NRC] U.S. Nuclear Regulatory Commission. 2012. Memorandum from Tam Tran, Project Manager.
Subject:
Summary of Telephone Conference Call Held on January 31, 2012 between the U.S. Nuclear Regulatory Commission and STP Nuclear Operating Company, Concerning Requests for Additional Information Pertaining to the South Texas Project, License Renewal Application. February 14, 2012. ADAMS No. ML12033A134.
[STPNOC] South Texas Project Nuclear Operating Company. 2006. Letter from David W.
Rencurrel, STPNOC to USNRC Document Control Desk,
Subject:
South Texas Project Units 1 and 2, Docket Nos. STN 50-498, STN 50-499 Revised Broad Scope Risk-Informed Technical Specification Amendment Request. Wadsworth, Texas. June 6, 2006. ADAMS No. ML061630315.
[STPNOC] South Texas Project Nuclear Operating Company. 2007. Letter from Charles T.
Bowman, STPNOC, to U.S. Nuclear Regulatory Commission Document Control Desk,
Subject:
South Texas Project Units 1 and 2, Docket Nos. STN 50-498, STN 50-499, Response to NRC Requests for Additional Information on STPNOC Proposed Risk Managed Technical Specifications (TAC Nos. MD 2341 and MD 2342). Wadsworth, Texas. February 28, 2007.
ADAMS No. ML070670369.
[STPNOC] South Texas Project Nuclear Operating Company. 2009. South Texas Project Units 3 and 4 Combined License Application (COLA) (Environmental Report), Rev. 3.
September 2009. ADAMS No. ML092931600.
[STPNOC] South Texas Project Nuclear Operating Company. 2010. South Texas Project License Renewal Application, Applicants Environmental Report, Operating License Renewal Stage, South Texas Project, Units 1 and 2. September 2010. ADAMS No. ML103010263.
[STPNOC] South Texas Project Nuclear Operating Company. 2011a. Letter from G.T. Powell, STPNOC, to U.S. Nuclear Regulatory Commission Document Control Desk,
Subject:
South Texas Project Units 1 and 2, Docket Nos. STN 50-498, STN 50-499, Response to Request for Additional Information on South Texas Project License Renewal Application (TAC No. ME4938).
July 5, 2011. ADAMS No. ML11193A016.
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Appendix F
[STPNOC] South Texas Project Nuclear Operating Company. 2011b. Additional Information on South Texas Project License Renewal Application (TAC No. ME4938). August 23, 2011.
ADAMS No. ML11250A067.
[STPNOC] South Texas Project Nuclear Operating Company. 2012a. Letter from D.W.
Rencurrel, STPNOC, to U.S. Nuclear Regulatory Commission Document Control Desk,
Subject:
South Texas Project Units 1 and 2, Docket Nos. STN 50-498, STN 50-499, Supplemental Response to Request for Additional Information on South Texas Project License Renewal ApplicationSAMA (TAC Nos. ME4938 and ME5122). January 19, 2012. ADAMS No. ML12030A081.
[STPNOC] South Texas Project Nuclear Operating Company. 2012b. Letter from D.W.
Rencurrel, STPNOC, to U.S. Nuclear Regulatory Commission Document Control Desk,
Subject:
South Texas Project Units 1 and 2, Docket Nos. STN 50-498, STN 50-499, Clarification to Supplemental Response to Request for Additional Information on South Texas Project License Renewal ApplicationSAMA (TAC Nos. ME4938 and ME5122). February 16, 2012. ADAMS No. ML12053A259.
[TVA] Tennessee Valley Authority. 2010. Letter from Masoud Bajestani, TVA, to U.S. Nuclear Regulatory Commission Document Control Desk.
Subject:
Watts Bar Nuclear Plant (WBN)
Unit 2Request for Additional Information Regarding Severe Accident Management Alternatives (TAC No. MD8203). July 23, 2010. ADAMS No. ML102100588.
Texas State Data Center, 2006. Available at: <http://txsdc.utsa.edu/> (Accessed May 2012).
[USGS] U.S. Geological Survey. 2008. 2008 NSHM Gridded Data. Available at:
<http://earthquake.usgs.gov/hazards/products/conterminous/2008/data/#fileformat> (Accessed May 2012).
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, DC 20555-0001
OFFICIAL BUSINESS
NUREG-1437 Generic Environmental Impact Statement for License Renewal of Nuclear Plants November 2013 Supplement 48 Regarding South Texas Project, Units 1 and 2 Final