ML18206A521
| ML18206A521 | |
| Person / Time | |
|---|---|
| Site: | Consolidated Interim Storage Facility |
| Issue date: | 07/19/2018 |
| From: | Consolidated Interim Storage Facility |
| To: | Division of Spent Fuel Management |
| Shared Package | |
| ML18206A595 | List:
|
| References | |
| E-52247 | |
| Download: ML18206A521 (91) | |
Text
INTERIM STORAGE PARTNERS LLC CHAPTER 5 ENVIRONMENTAL REPORT Page 5-1 Revision 2 CHAPTER 5 MITIGATION MEASURES MITIGATION MEASURES 5.0 This chapter summarizes the anticipated impacts followed by proposed mitigation measures that would be in place to reduce adverse impacts that could occur during construction, routine, and non-routine operation of the CISF.
5.1 IMPACT
SUMMARY
This section summarizes the environmental impacts that may result from the construction and operation of the CISF. Complete details of these potential impacts are provided in Chapter 4 of this ER.
5.1.1 Land Use Land use impacts have been characterized in ER Section 4.1, Land Use Impacts. No substantial impacts would occur with regard to the following:
Land-use impacts at the CISF, and impacts from any related federal action that may have cumulatively significant impacts Area and location of land that would be disturbed on either a long-term or short-term basis Minor impacts related to erosion control on the CISF may occur, but would be short-term and limited. These potential impacts are discussed in ER Section 4.4, Water Resources Impacts.
5.1.2 Transportation Transportation impacts have been characterized in ER Section 4.2, Transportation Impacts.
With respect to construction-related transportation, no substantial impacts would occur. The analysis incorporated the following considerations:
No new access road would be required on Texas State Highway 176 to provide access to the facility. An existing roadway on the Waste Control Specialists property would be extended north to the CISF.
The transportation route and mode for conveying construction material to the facility currently exists.
INTERIM STORAGE PARTNERS LLC CHAPTER 5 ENVIRONMENTAL REPORT Page 5-2 Revision 2 The increase in traffic from heavy haul vehicles and construction worker commuting would not substantially change traffic patterns.
Impacts from construction transportation such as fugitive dust, scenic quality, and noise would be temporary.
Minor impacts related to construction traffic such as fugitive dust, noise, and emissions are discussed in ER Section 4.7. Additional information on noise impacts is contained in ER Section 3.7.
With respect to the transport of radioactive materials, no substantial impacts would occur. The analysis incorporated the following factors:
Mode of transportation (truck, rail, or barge) and routes from the originating site to the CISF Estimated transportation distance from the originating site to the CISF Treatment and packaging procedures for radioactive wastes Radiological dose equivalents for public and workers from incident-free scenarios Potential impacts of operating transportation vehicles on the environment (e.g., fire from equipment sparking)
Impacts related to the transport of radioactive materials are addressed in ER Section 3.2. The materials that would be transported to and from the CISF are well within the scope of the environmental impacts previously evaluated by the NRC in its GEIS for continued storage of spent nuclear fuel, NUREG-2157 (NRC, 2014a). Because these impacts have been addressed in a previous NRC EIS, no additional mitigation measures are proposed.
5.1.3 Geology and Soils The potential impacts to the geology and soils have been characterized in ER Section 4.3, Geology and Soils Impacts. No substantial impacts would occur from the following activities:
Soil re-suspension, erosion, and disruption of natural drainage Excavations to be conducted during construction
INTERIM STORAGE PARTNERS LLC CHAPTER 5 ENVIRONMENTAL REPORT Page 5-3 Revision 2 Impacts to geology and soils would be limited to surface runoff due to routine operation and low annual rainfall. Construction activities may cause some short-term increases in soil erosion at the CISF.
5.1.4 Water Resources The potential impacts to water resources have been characterized in ER Section 4.4, Water Resources Impacts. No substantial impacts are anticipated to the following:
Surface water and groundwater quality Consumptive water uses (e.g., groundwater depletion) on other water users and adverse impacts on surface-oriented water users resulting from facility activities. Site groundwater would not be utilized for any reason, and therefore, should not be impacted by routine CISF operations. The CISF water supply would be obtained from the same local publicly owned water system sources as the existing operations.
Hydrological system alterations or impacts Withdrawals and returns of ground and surface water Cumulative effects on water resources.
The CISF would not obtain any water from onsite surface or groundwater resources. Sanitary wastewater discharges would be made through sewerage to holding tanks and subsequently transported offsite to publicly owned treatment works. Storm water is not expected to contain any radiological effluents, and with a low annual rainfall, storm water runoff would be directed to natural drainage areas.
5.1.5 Ecological Resources The potential impacts to ecological resources have been characterized in ER Section 4.5, Ecological Resources Impacts. No substantial impacts are anticipated from the following factors:
Total area of land to be disturbed Area of disturbance for each habitat type Use of chemical herbicides, roadway maintenance, and mechanical clearing Areas to be used on a short-term basis during construction
INTERIM STORAGE PARTNERS LLC CHAPTER 5 ENVIRONMENTAL REPORT Page 5-4 Revision 2 Communities or habitats that have been defined as rare or unique or that support threatened and endangered species Impacts of elevated construction equipment or structures on species (e.g., bird collisions, nesting areas)
Impact on important biota Based on database searches and site inventories conducted by qualified ecologists, impacts to ecological resources would be minimal due to the absence of habitat for threatened and endangered species on the land proposed for the CISF.
5.1.6 Air Quality The potential impacts to the air quality have been characterized in ER Section 4.6, Air Quality Impacts. No substantial impacts from gaseous effluents would occur and visibility would not be impacted.
Impacts to air quality would be minimal. Construction and operational activities would result in interim increases in hydrocarbons and particulate matter due to vehicle emissions and dust.
During construction activities, best practices would be employed to reduce and control dust emissions.
5.1.7 Noise The potential impacts related to noise generated by the facility have been characterized in ER Section 4.7, Noise Impacts. No substantial impacts to sensitive receptors (e.g., hospitals, schools, residences, wildlife) from predicted typical noise levels at the facility perimeter are anticipated.
Noise levels would increase during construction and during operation of the CISF, but not to a level that would cause significant impact to nearby residents. The nearest residence is 6 km (3.8 mi) from the CISF.
5.1.8 Historic and Cultural Resources The potential impacts to historic and cultural resources have been characterized in ER Section 4.8, Historic and Cultural Resource Impacts. The archeological APE consists of the 216.6-acre footprint of the proposed CISF. No archeological materials of any kind were observed within the APE during a survey conducted in May 2015, and no further work is recommended within the
INTERIM STORAGE PARTNERS LLC CHAPTER 5 ENVIRONMENTAL REPORT Page 5-5 Revision 2 APE prior to construction of the proposed CISF. Since the area containing the proposed project footprint is devoid of any standing structures, the proposed project would not result in a direct impact to any non-archeological historic resources. The APE for indirect/visual impacts was defined as the area within a 1.6 km (1 mi) radius from the proposed project footprint. There do not appear to be any historic resources 45 years or older (dating to 1974 or earlier) within the 1.6 km (1 mi) indirect effects APE. The THC as well as the New Mexico Department of Cultural Affairs concurred that further cultural resource investigations are not warranted prior to construction.
5.1.9 Visual/Scenic Resources The potential impacts to visual/scenic resources have been characterized in ER Section 4.9, Visual/Scenic Resources Impacts. The proposed CISF construction would be visible only from fairly close vantage points and would be less of an impact than the adjacent URENCO NEF, which lies between the denser population of viewers in Eunice, NM and the proposed CISF, where the largest component would be the cask handling building.
The SIA characterizes the proposed CISF location as having a modest scenic quality that is pleasant to regard for its rural, undeveloped nature, but not dramatic, unique, or rare (Cox McLain Environmental Consulting, 2015). Facilities geared towards resources extraction, the Lea County Landfill, and oil well pump jacks exist in the project area, in addition to the URENCO facility, which have an equal or higher impact on the visual landscape compared to the proposed new CISF activities.
5.1.10 Socioeconomics The potential socioeconomic impacts to the community have been characterized in ER Section 4.10, Socioeconomic Impacts and in Appendix A, Socioeconomic Impacts of the Proposed Spent Nuclear Fuel Consolidated Interim Storage Facility Andrews, Texas. No substantial negative impacts are anticipated on the areas:
Population characteristics (e.g., ethnic groups and population density)
Housing, health and social services, or educational and transportation resources Tax structure and distribution The conclusions of the SIA showed positive direct, indirect, and final demand impacts to the economy for the construction and operation of the CISF. There would be no adverse direct
INTERIM STORAGE PARTNERS LLC CHAPTER 5 ENVIRONMENTAL REPORT Page 5-6 Revision 2 impacts to the nearby communities. There would be minimal demands on local social resources and infrastructure to meet housing and other social infrastructure needs, based on the anticipated increases in employment for the CISF.
INTERIM STORAGE PARTNERS LLC CHAPTER 5 ENVIRONMENTAL REPORT Page 5-7 Revision 2 5.1.11 Environmental Justice The potential impacts with respect to environmental justice have been characterized in the Environmental Justice section of the ER, Section 4.11. No substantial disproportionate impacts to low-income or minority persons are anticipated to result from the proposed project.
Based on the data analyzed and the NUREG-1748 guidance applicable to that analysis, ISP determined that no further evaluation of potential environmental justice concerns was necessary, as no Census Block Group within the 6.4 km (4 mi) radius, i.e., 128 km² (50 mi²), of the CISF site contained a minority or low-income population exceeding the NUREG-1748 "20%"
or "50%" criteria.
5.1.12 Public and Occupational Health This section describes public and occupational health impacts from both nonradiological and radiological sources.
5.1.12.1 Nonradiological-Normal Operations The potential impacts to public and occupational health for nonradiological sources have been characterized in ER Section 4.12.1, Nonradiological Impacts. No substantial impacts will exist to:
Members of the public from nonradiological discharge of liquid or gaseous effluents to water or air Facility workers as a result of occupational exposure to nonradiological chemicals, effluents, or wastes Public and occupational health from cumulative impacts Impacts to the public and workers from nonradiological gaseous and liquid effluents would be minimal.
5.1.12.2 Radiological-Normal Operations This subsection describes public and occupational health impacts from radiological sources. It provides a brief description of the methods used to assess the pathways for exposure and a summary of the potential impacts described in section 4.12.2 of the ER.
INTERIM STORAGE PARTNERS LLC CHAPTER 5 ENVIRONMENTAL REPORT Page 5-8 Revision 2 5.1.12.2.1 Pathway Assessment The potential for exposure to radiological sources included an assessment of pathways that could convey radioactive material to members of the public. Important ingestion pathways such as stored and fresh vegetables, milk, and meat, which were assumed to be grown or raised at the nearest resident location, were analyzed.
In addition, potential points or areas were characterized to identify the:
Nearest CISF boundary Nearest full time resident Location of the average member of the critical group There are no anticipated offsite releases to any surface waters or POTW.
5.1.12.2.2 Public and Occupational Exposure The potential impacts to public and occupational health for radiological sources have been characterized in ER Section 4.12, Public and Occupational Health Impacts. No substantial impacts exist for the public (as determined by the critical group) or the workforce (based on radiological and chemical exposures) based on the average annual concentration of radioactive and hazardous materials in gaseous and liquid effluents and on reasonably foreseeable (i.e.,
credible) accidents with the potential to result in environmental releases.
Routine operations at the CISF would create only an incremental increase in the potential for radiological and nonradiological public and occupational exposure. Potential radiation exposure would be due to the storage of spent nuclear fuel and the presence of associated fission products onsite. There would be no chemical substances, airborne particulates, or gases or liquid effluents that could contribute to offsite exposure.
5.1.12.3 Accidental Releases All credible accident sequences were considered during the Safety Analysis performed for the facility, this information can be found in Section 1.4.3, Accident Analysis, of the SAR.
5.1.13 Waste Management The potential impacts of waste generation and waste management have been characterized in ER Section 4.13, Waste Management Impacts. No substantial impacts would occur to:
INTERIM STORAGE PARTNERS LLC CHAPTER 5 ENVIRONMENTAL REPORT Page 5-9 Revision 2 The public, due to the composition and disposal of solid, hazardous, radioactive and mixed wastes Facility workers, due to storage, processing, handling, and disposal of solid, hazardous, radioactive, and mixed wastes Additionally, there would be no substantial cumulative impacts from waste generation and waste management.
Impacts related to waste management would be minimal.
5.2 MITIGATION This section summarizes the mitigation measures to minimize any anticipated impacts that may result from the construction and operation of the CISF.
5.2.1 Land Use The anticipated effects on the soil during construction activities would be limited to a potential short-term increase in soil erosion. However, the following proper construction BMPs would mitigate any impacts:
Minimizing the construction footprint to the extent possible Limiting site slopes to a horizontal-vertical ratio of three to one or less Protecting undisturbed areas with silt fencing and straw bales as appropriate Using site stabilization practices, such as placing crushed stone on top of disturbed soil in areas of concentrated runoff, to reduce the potential for erosion and sedimentation After construction is complete, the CISF would be stabilized with natural and low-water maintenance landscaping.
5.2.2 Transportation Mitigation measures would be in place to minimize potential impacts of construction-related transportation activities. To control fugitive dust production, all reasonable precautions would be taken to prevent particulate matter from becoming airborne, including the following actions:
Using water (controlled to minimize use) in clearing and grading operations and construction activities to control dust on dirt roads.
Using adequate containment methods during excavation and/or other similar operations.
INTERIM STORAGE PARTNERS LLC CHAPTER 5 ENVIRONMENTAL REPORT Page 5-10 Revision 2 Covering open-bodied trucks transporting materials that are likely to give rise to airborne dust when in motion.
Promptly removing earthen or other materials from paved roads when such material has been deposited on the paved roads by trucking or earth moving equipment, water or wind erosion, or other means.
Promptly stabilizing or covering bare areas once earth-moving activities are complete.
Operating construction equipment and related vehicles with standard pollution control devices in good working order.
Washing construction trucks with water (controlled to minimize use) only when required.
Designating personnel to monitor dust emissions and to direct increased surface watering where necessary.
Scheduling short-duration activities that may impact traffic (e.g., concrete trucks, multiple deliveries) to minimize traffic impacts, if such activities are required during the course of construction.
Scheduling work shifts throughout the construction period to minimize impacts to traffic in the CISF vicinity.
Encouraging car-pooling throughout the construction period to minimize impacts to traffic in the CISF vicinity.
5.2.3 Geology and Soils Mitigation measures would be in place to minimize any potential impact on geology and soils.
These include:
Mitigating erosional impacts due to site clearing and grading with construction and erosion control BMPs (some of which are further described below).
Using acceptable methods to stabilize disturbed soils during construction.
Using earthen berms, dikes, and sediment fences as necessary during all phases of construction to limit suspended solids in runoff.
Stabilizing cleared areas not covered by structures or pavement by acceptable means as soon as practical.
INTERIM STORAGE PARTNERS LLC CHAPTER 5 ENVIRONMENTAL REPORT Page 5-11 Revision 2 Watering (controlled to minimize use) to control fugitive construction dust.
Using standard drilling and blasting techniques, if required, to minimize impacts to bedrock, thereby reducing the potential for over-excavation, minimizing damage to the surrounding rock, and protecting adjacent surfaces that are intended to remain intact.
Stabilizing drainage culverts and ditches by lining them with rock aggregate/rip-rap or creating berms with silt fencing/straw bales to reduce flow velocity and prohibit scouring.
Stockpiling soil generated during construction in a manner that reduces erosion.
Reusing excavated materials whenever possible.
5.2.4 Water Resources Mitigation measures would be in place to minimize potential impact on water resources.
As discussed in ER Section 4.4, Water Resources Impacts, there is little potential to impact any groundwater or surface water resources. Nonetheless, the following controls would be implemented:
Maintenance of construction equipment in good repair without visible leaks of oil, greases, or hydraulic fluids.
Use of BMPs to ensure that storm water runoff related to these activities would not be released into nearby areas.
Use of BMPs for dust control associated with excavation and fill operations during construction.
Use of silt fencing and/or sediment traps.
Control of impacts to water quality during construction through compliance with the TPDES - Construction General Permit requirements and by applying BMPs as detailed in the CISF SWPPP.
Berming all above ground diesel storage tanks.
Handling sanitary wastes generated during CISF construction with portable systems until such time that plant sanitary facilities are available for site use. An adequate number of these portables systems would be provided.
Requiring control of surface water runoff for activities covered by the TPDES Construction General Permit.
INTERIM STORAGE PARTNERS LLC CHAPTER 5 ENVIRONMENTAL REPORT Page 5-12 Revision 2 As a result of implementing these controls, no impacts are expected to surface or groundwater bodies.
The CISF is designed to minimize the usage of natural resources as shown by the following measures:
Use of low-water consumption landscaping versus conventional landscaping to reduce water usage.
Installation of low flow toilets, sinks, and showers to reduce water usage when compared to standard flow fixtures.
Use of mops and self-contained cleaning machines for localized floor washing to reduce water usage, as compared to conventional washing with a hose twice per week.
5.2.5 Ecological Resources Mitigation measures would be in place to minimize any potential impacts on ecological resources. CISF construction features include:
Minimizing the construction footprint to the extent possible Using BMPs and site stabilization practices to reduce the potential for erosion and sedimentation.
Proposed wildlife management procedures to minimize impacts would include:
Managing unused open areas, including areas of native grasses and shrubs, for the benefit of wildlife (i.e. leave undisturbed).
Using native plant and grass species (i.e., low-water consuming plants and grasses) to re-vegetate disturbed areas to enhance wildlife habitat.
Using animal-friendly fencing around the CISF so that wildlife cannot be injured or entangled in the CISF security fence.
In addition to the proposed wildlife management practices above, ISP would consider all recommendations of appropriate state and federal agencies, including the United States Fish and Wildlife Service and the Texas Parks and Wildlife Department.
INTERIM STORAGE PARTNERS LLC CHAPTER 5 ENVIRONMENTAL REPORT Page 5-13 Revision 2 5.2.6 Air Quality Mitigation measures would be in place to minimize any potential impact on air quality.
Specifically, construction phase BMPs would be used to minimize fugitive dusts.
Air concentrations of the Criteria Pollutants for vehicle emissions and fugitive dust would be below the NAAQS (CFR, 2003w) and thus would not require further mitigation measures.
5.2.7 Noise Minimization of operational noise sources would be needed primarily during CISF construction and operations. Natural land contours, vegetation (such as scrub brush), and CISF buildings and structures would reduce the impact of equipment located outside of structures that could contribute to CISF noise levels. The buildings themselves would absorb the majority of the noise located within.
Noise from construction activities would have the highest sound levels, but the nearest home is located 6 km (3.8 mi) from the CISF. Due to the distance between the residence and the CISF, it is not expected that residents would perceive an increase in noise levels. All noise suppression systems on construction vehicles would be kept in proper operation.
5.2.8 Historical and Cultural Resources To minimize any potential impact on historical and cultural resources, accidental discovery procedures would be in place. In the event that any inadvertent discovery of human remains or other item of archeological significance is made during construction, the facility would immediately cease construction activities in the area around the discovery and notify the THC (the SHPO), to make the determination of appropriate measures to identify, evaluate, and treat these discoveries.
5.2.9 Visual/Scenic Resources Measures would be in place to minimize any potential impacts to visual and scenic resources.
These include the following items:
Use of accepted natural, low-water consumption landscaping techniques to limit any potential visual impacts. These techniques would incorporate, but not be limited to, the use of landscape plantings. As for aesthetically pleasing screening measures, planned landscape plantings would include indigenous vegetation.
INTERIM STORAGE PARTNERS LLC CHAPTER 5 ENVIRONMENTAL REPORT Page 5-14 Revision 2 Prompt natural re-vegetation or covering of bare areas would be used to mitigate visual impacts due to construction activities.
Minimization of any removal of natural barriers, screens or buffers.
INTERIM STORAGE PARTNERS LLC CHAPTER 5 ENVIRONMENTAL REPORT Page 5-15 Revision 2 5.2.10 Socioeconomics Socioeconomic impacts from the project would largely be positive, and no displacements would be required by the proposed project. Therefore, no socioeconomic mitigation measures are required.
5.2.11 Environmental Justice Given the lack of environmental justice impacts, no environmental justice mitigation measures are required. However, public involvement activities conducted for the CISF licensing would include wide outreach efforts to ensure full and fair participation by low-income and/or minority communities in the study area.
5.2.12 Public and Occupational Health This section describes the avoidance, minimization, and mitigation measures to minimize public and occupational health impacts, from both nonradiological and radiological sources.
5.2.12.1 Non-Radiological - Normal Operations Impacts to the public and workers from nonradiological gaseous and liquid effluents would be minimal. No specific mitigation measures for nonradiological impacts during normal operations are anticipated.
5.2.12.2 Radiological - Normal Operations Mitigation measures to minimize radiological exposure and release are listed below.
Radiological practices and procedures are in place to ensure compliance with ISPs Radiation Protection Program. This program is designed to achieve and maintain radiological exposure to levels that are ALARA. These measures include:
Conducting routine facility radiation surveys to characterize potential radiological exposure.
Monitoring of all radiation workers via the use of dosimeters to ensure that radiological doses remain within regulatory limits and are ALARA.
Providing radiation dosimeters at the fence line boundary to measure potential exposure to any member of the general public.
INTERIM STORAGE PARTNERS LLC CHAPTER 5 ENVIRONMENTAL REPORT Page 5-16 Revision 2 5.2.12.3 Accident Releases Mitigation measures would be in place to minimize any impact from a potential accidental release of radiological and/or nonradiological effluents. These measures include:
An onsite and offsite emergency plan spelling out the immediate actions to take to mitigate the impact of any accidental release.
Actions to contain sources of radiological or nonradiological effluents in such a manner as to mitigate the impact from an accidental release.
5.2.13 Waste Management Mitigation measures would be in place to minimize the generation and potential impact of facility wastes. Solid and liquid wastes would be controlled in accordance with regulatory limits.
Mitigation measures include:
Prohibition against onsite disposal of waste at the CISF.
Storage of waste in designated areas of the facility until an administrative limit is reached. When the administrative limit is reached, the waste would then be shipped offsite to the appropriate, adjacent, licensed LLRW treatment, storage and/or disposal facility.
Disposal of all industrial and municipal wastes at offsite waste disposal facilities.
Collection of different waste types in separate containers to minimize contamination of one waste type with another.
Storage of hazardous wastes in designated areas in carefully labeled containers.
Decontamination and/or re-use of radioactively contaminated wastes to reduce waste volume.
Implementation of administrative procedures and practices that provide for the collection, temporary storage, processing, and disposal of categorized solid waste in accordance with regulatory requirements.
Implementation of handling and treatment processes designed to limit wastes and effluents. Conduct sampling and monitoring to assure facility administrative and regulatory limits are not exceeded.
Sampling and/or monitoring of solid wastes prior to offsite treatment and disposal.
Recycling of construction debris to the extent possible.
INTERIM STORAGE PARTNERS LLC CHAPTER 6 ENVIRONMENTAL REPORT Page 6-1 Revision 2 CHAPTER 6 ENVIRONMENTAL MEASUREMENTS AND MONITORING PROGRAMS RADIOLOGICAL MONITORING 6.0 6.1 REGULATORY BASIS FOR RADIOLOGICAL MONITORING The NRC requires, pursuant to 10 CFR 20, that licensees conduct surveys necessary to demonstrate compliance with these regulations and to demonstrate that the amount of radioactive material present in effluent from the facility has been kept as low as reasonably achievable (ALARA). In addition, pursuant to 10 CFR 72, the NRC requires that licensees submit annual reports specifying the quantities of the principal radionuclides released to unrestricted areas and other information needed to estimate the annual radiation dose to the public from facility operations. The NRC has also issued Regulatory Guide 4.15, Quality Assurance for Radiological Monitoring Programs (Inception through Normal Operations to License Termination)Effluent Streams and the Environment that reiterates that concentrations of hazardous materials in effluent must be controlled and that licensees must adhere to the ALARA principal such that there is no undue risk to the public health and safety at or beyond the proposed CISF boundary (NRC, 2006).
Moreover, the NRC, in 10 CFR §20.1301, requires each licensee to conduct operations so that the total effective dose equivalent to individual members of the public from the licensed operation does not exceed 0.1 rem (1 mSv) in a year, exclusive of the dose contributions from background radiation. The dose in any unrestricted area from external sources may not exceed 0.002 rem (0.02 mSv) in any one hour.
6.2 ENVIRONMENTAL PATHWAYS The only pathway for public exposure to radiation from routine operations at the CISF is external exposure at the uncontrolled boundary from the spent fuel casks stored on the pad. There is no air pathway because the casks are sealed by being welded shut. There is no potential for a liquid pathway because the spent fuel contains no liquid component and the casks are sealed to prevent any liquids from contacting the spent fuel assemblies. Any surface contamination on the stored casks is well below regulatory limits.
INTERIM STORAGE PARTNERS LLC CHAPTER 6 ENVIRONMENTAL REPORT Page 6-2 Revision 2 Though no pathways exist for exposures due to liquid effluents, administrative investigation and action levels are established for monitoring surface water runoff as an additional step in the radiation control process. Because the surface water drainage paths are normally dry, it is not possible to monitor runoff in a continuous or batch mode basis. Even if surface water were sampled, the radionuclide levels would likely be so low as to be statistically insignificant. Instead, quarterly soil sampling coupled with weekly/monthly radiological surveys on the casks and storage pad would be conducted.
There are no connections to municipal sewer systems. Onsite sewage would be routed to holding tanks, which are periodically pumped; the sewage would then be sent offsite for disposal in a POTW. Each holding tank would be periodically sampled (prior to pumping) and analyzed for relevant radionuclides.
6.3 RADIOLOGICAL MONITORING PROGRAM The Radiological Monitoring Program includes the collection of data during pre-operational years in order to establish baseline radiological information that would be used in determining and evaluating potential impacts from CISF operations on the local environment. The Radiological Monitoring Program would be initiated at least one year prior to CISF operations. The early initiation of the Radiological Monitoring Program provides assurance that a sufficient environmental baseline has been established for the CISF before the arrival of the first cask shipment. Radionuclides in environmental media would be identified using technically appropriate, accurate, and sensitive analytical instruments (e.g., liquid scintillation or gamma/alpha spectrometry). Data collected during the operational years would be statistically compared to the baseline generated by the pre-operational data. Such comparisons provide a means of assessing the magnitude of potential radiological impacts on members of the public and in demonstrating compliance with applicable radiation protection standards.
Direct radiation in offsite areas emanating from fuel stored on the dry cask storage pad or resulting from cask handling operations is expected to be minimal, see Section 4.12.2 of this ER. However, TLDs or OSLs would be placed strategically around the CISF perimeter to measure these potential exposures and demonstrate regulatory compliance.
INTERIM STORAGE PARTNERS LLC CHAPTER 6 ENVIRONMENTAL REPORT Page 6-3 Revision 2 Detection of radionuclide impacts to surface water runoff would be conducted in a two-step process. First, all casks would be checked for surface contamination during weekly surveys and all storage pads would be checked for surface contamination during monthly surveys. Second, soil samples would be collected on a quarterly basis at the culverts leading to the CISF outfalls. Monitored radioactive contaminants exceeding the action levels, as established in written procedures, would cause an immediate investigation and would require corrective action to protect human health and prevent future recurrences.
During the course of facility operations, revisions to the Radiological Monitoring Program may be necessary and appropriate to assure reliable sampling and collection of environmental data. The rationale and actions behind such revisions to the program would be documented and reported to the NRC and other appropriate regulatory agency, as required. Sampling focuses on locations proximate to the facility, but may also include distant locations as control sites. Potential sample locations have been identified, but are subject to change based on NRC guidance, meteorological information, ISP joint venture member Waste Control Specialists extensive experience in environmental sampling in the area, and current land use, see figure 6.1-1.
6.4 COMPLIANCE WITH REGULATORY REQUIREMENTS Compliance with 10 CFR §20.1301 is demonstrated using a calculation of the TEDE to the individual who is likely to receive the highest dose in accordance with 10 CFR 20.1302(b)(1). Appropriate models, codes, and assumptions that accurately represent the facility, the site and the surrounding area support the determination of the TEDE by pathway analysis.
Compliance is demonstrated through boundary monitoring and environmental sampling data. If a potential release should occur, then routine operational environmental data would be used to assess the extent of the release.
The offsite impact from the CISF storage has been evaluated and is discussed in Section 4.12 of this ER. The conservative evaluation shows that an annual dose equivalent of < 0.011 mSv (11 mrem) is expected at the highest impacted area at the facility perimeter fence. Because the offsite dose equivalent rate from stored casks is expected to be very low and difficult to distinguish from the variance in normal
INTERIM STORAGE PARTNERS LLC CHAPTER 6 ENVIRONMENTAL REPORT Page 6-4 Revision 2 background radiation beyond the CISF boundary, demonstration of compliance would rely on a system that combines direct dose equivalent measurements and computer modeling to extrapolate the measurements. The direct dose equivalent at offsite locations would be measured using TLD/OSL data from the highest impacted offsite areas.
Appropriate investigation and action levels are specified for CISF surface water runoff.
Data analysis methods and criteria used in evaluating and reporting environmental sample results are appropriate and would indicate when an action level is being approached in time to take corrective actions.
6.5 QUALITY ASSURANCE The Radiological Monitoring Program is included in the facility's QA program. Key parts of the program are the written procedures that ensure representative sampling; proper use of appropriate sampling methods and equipment; proper locations for sampling points; and proper handling, storage, transport, and analyses of environmental samples.
In addition, written procedures ensure that sampling and measuring equipment are properly maintained and calibrated at regular intervals. Moreover, the Radiological Monitoring Program implementing procedures include functional testing and routine checks to demonstrate that monitoring and measuring instruments are in working condition. The instrument maintenance and calibration program is tailored to the given instrumentation, in accordance with manufacturers' recommendations.
A qualified independent laboratory would analyze environmental samples. Monitoring and sampling activities, laboratory analyses, and reporting of facility-related radioactivity in the environment would be conducted in accordance with industry-accepted and the NRC approved methodologies. Monitoring procedures would employ well-known analytical methods and instrumentation.
The QC procedures used by the laboratories performing the facilitys Radiological Monitoring Program would be adequate to validate the analytical results and would conform to the guidance in Regulatory Guide 4.15 (NRC, 2006). These QC procedures include the use of established standards such as those provided by the National Institute of Standards and Technology, as well as standard analytical procedures such as those established by the National Environmental Laboratory Accreditation Conference.
INTERIM STORAGE PARTNERS LLC CHAPTER 6 ENVIRONMENTAL REPORT Page 6-5 Revision 2 ISP would ensure that any contractor laboratory used to analyze CISF samples participates in third-party laboratory intercomparison programs appropriate to the media and analytes being measured. Examples of these third-party programs include but are not limited to: (1) Mixed Analyte Performance Evaluation Program; and (2) Analytics Inc.,
Environmental Radiochemistry Cross-Check Program. ISP would require that all radiological and non-radiological laboratory vendors be certified by the National Environmental Laboratory Accreditation Program or an equivalent state laboratory accreditation agency for the analytes being tested.
ISP would ensure that only individuals trained in accordance with written procedures will be permitted to calibrate analytical sampling equipment. Sampling equipment would be inspected for defects, obstructions, and cleanliness. Calibration intervals and methods would be developed based on applicable industry standards and in accordance with procedures.
The radiation monitoring program falls under the oversight of the ISP Radiation Safety Program. Therefore, it is subject to periodic audits conducted by facility QA personnel.
Written procedures would be in place to ensure the collection of representative samples; use of appropriate sampling methods and equipment; proper locations for sampling points; and proper handling, storage, transport, and analyses of environmental samples.
In addition, the facilitys written procedures also ensure that sampling and measuring equipment, including ancillary equipment, are properly maintained and calibrated at regular intervals, if required. Employees involved in implementation of this program will be trained in the program procedures.
6.6 REPORTING PROCEDURES Reporting procedures would comply with the requirements of 10 CFR 72.44(d)(3) and the guidance specified in Regulatory Guide 4.16. Reports of the concentrations of any radionuclides released to unrestricted areas would be provided and would include the Minimum Detectable Concentration (MDC) for the analysis and the error for each data point.
Each year, ISP would submit a summary report of the environmental sampling program to the NRC, including all associated data as required by 10 CFR 72.44(d)(3). The report would include the types, numbers, and frequencies of environmental measurements and
INTERIM STORAGE PARTNERS LLC CHAPTER 6 ENVIRONMENTAL REPORT Page 6-6 Revision 2 the identities and activity concentrations of facility-related nuclides found in environmental samples. The report would also include the MDC for the analyses and the error associated with each data point. Significant positive trends in activities, if any, would also be noted in the report, along with any adjustment to the program, unavailable samples, and deviation to the sampling program.
6.7 PHYSIOCHEMICAL MONITORING Chemicals are not anticipated to be stored at the CISF and therefore, no physicochemical monitoring would be required.
6.8 ECOLOGICAL MONITORING Ecological monitoring would not be required given that threatened or endangered species would not be impacted during construction, operation, and decommissioning of the CISF as discussed in Section 4.5.8.
INTERIM STORAGE PARTNERS LLC CHAPTER 6 ENVIRONMENTAL REPORT Page 6-7 Revision 2
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-1 Revision 2 CHAPTER 7 BENEFIT-COST ANALYSIS BENEFIT-COST ANALYSIS 7.0 The proposed action is expected to generate substantial cost savings for the federal government, as well as substantial benefits to the private sector. The analysis in this chapter will focus on estimating the value of benefits and costs from relocating and storing spent nuclear fuel at the proposed CISF. The analysis is performed by using cost data from eight, selected shutdown nuclear power plants in the United States and then extrapolating these data for the CISFs full 40,000 MTU capacity. Section 7.1 provides background information, primarily to explain the economic benefits of the proposed action. Section 7.2 outlines the anticipated benefits of the proposed action and the assumptions used to quantify their economic value.
Likewise, Section 7.3 identifies and quantifies the costs of the proposed action. Section 7.4 provides a discussion of the results and summarizes the major findings of the analysis. Section 7.5 discusses the environmental benefits and costs of the proposed action and 7.6 discusses the benefits and costs at evaluated alternative sites. As with NUREG-1714, the individual benefits and costs estimated in this analysis are identified as public or private, as appropriate, but the overall impacts are considered societal in nature. The study horizon is a 40-year period that starts with the granting of the site license in 2019. The values reported are in 2015 dollars and have not been discounted.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-2 Revision 2
7.1 BACKGROUND
The successful construction and operation of the proposed action has the potential to greatly reduce U.S. government expenditures for the storage and management of spent nuclear fuel, prior to the development of a permanent disposal site. The Nuclear Waste Policy Act of 1982 (NWPA) obligated the federal government to dispose of spent fuel from the nations nuclear power plants. Additionally, the Act provided a mechanism to fund disposition of commercial spent nuclear fuel in the form of payments by utilities into the Nuclear Waste Fund. The NWF also receives taxpayer payments from the Department of Defense for defense-related waste that will go into a repository, including spent nuclear fuel from the U.S. Navy. Under the NWPA, utilities signed contracts with the Department of Energy (DOE) and paid annual fees into the Nuclear Waste Fund in exchange for a federal commitment to begin accepting spent fuel for disposal by January 31, 1998. This funding structure was intended to ensure that commercial nuclear generators (and their ratepayers) - not taxpayers - would pay the necessary monies (upfront) to construct and operate storage and disposal facilities. Beginning in 1983, monies were collected from electricity consumers, as part of their monthly bill, and deposited into the Nuclear Waste Fund. According to the Nuclear Waste Funds 2015 Financial Audit Statement, the net value of the fund was $37.4 billion.
The NWPA also created a process for establishing a permanent, underground repository by the mid-1990s. Congress assigned responsibility to the DOE to site, construct, operate, and close a repository for the disposal of spent nuclear fuel. In December 1987, Congress amended the NWPA to designate Yucca Mountain, Nevada as the permanent repository site for the nations nuclear waste. In 2010, the Obama Administration stopped the Yucca Mountain license review and empaneled a study commission to recommend a new policy for the long-term management of spent nuclear fuel and high-level radioactive waste. In January 2012, the Blue Ribbon Commission on Americas Nuclear Future published its final recommendations to the Secretary of Energy. In January 2013, the DOE issued its used fuel management strategy to implement the Blue Ribbon Commissions recommendations.
As a consequence of federal actions (and inaction), there is presently no disposal site for tens of thousands of metric tons of spent nuclear fuel and high-level radioactive waste, no alternate site to Yucca Mountain, and a continued obligation for the disposal of spent nuclear fuel by the federal government. The unfulfilled federal obligation to dispose of spent nuclear fuel has become an increasingly expensive liability for the Federal government. Since 1998, when the
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-3 Revision 2 NWPA committed the federal government to dispose of spent nuclear fuel, operators of nuclear plants have had to retain, store, and manage spent nuclear fuel on-site. A recent DOE estimate of the federal governments liability for these costs was $21.4 billion through 2071. This figure was an increase from a 2006 estimate of $6.9 billion, which assumed that the permanent storage of spent nuclear fuel would be complete in 2055 (Government Accountability Office
[GAO], 2014).
As the expense of ongoing storage of spent nuclear fuel has compounded for nuclear power plant operators, it has become common practice for them to either file lawsuits against the federal government or to negotiate for reimbursement of their storage costs. The reimbursements come from the U.S. Department of Treasurys Judgment Fund, which is used to pay for judgments against the United States. The Judgment Fund is permanent, has an indefinite appropriation, and is exempt from annual congressional approval. The payments are made to the plant operators because of the DOEs partial breach of contract, stemming from its failure to take possession of spent fuel (starting Jan. 31, 1998), as required by the NWPA and the Standard Contract it signed with utilities. According to an article in The National Law Journal, in 2015 alone, the federal government paid approximately $650 million to utility companies for expenses related to storing spent fuel. The same article estimates that the total expenditure over the past five years has been $4 billion (Greene, 2015). Similarly, the Congressional Budget Office reported in their December 2015 testimony before the U.S. House Subcommittee on Environment and the Economy (part of the Committee on Energy and Commerce), that $4.3 billion in damages have been paid out of the taxpayer-funded U.S.
Judgment Fund to date, and that remaining liabilities will total $23.7 billion, even if legislation and sufficient appropriations are enacted that will enable the DOE to begin accepting waste within the next 10 years (Congressional Budget Office, 2015). Further delays in implementing an interim storage site beyond 2025 will increase this liability, which will ultimately be borne by the nations taxpayers.
In late 2013, a federal court ruled that the DOE must stop collecting fees for nuclear spent fuel disposal, until it again complies with the NWPA (as it is currently written) or until Congress enacts an alternate waste management plan (National Association of Regulatory Utility Commissioners v. United States Department of Energy, 2013). Substantial concerns also exist regarding the future of the Nuclear Waste Fund, given the entanglement of budget rules and reimbursement issues facing the fund.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-4 Revision 2 7.2 BENEFITS ANALYSIS The primary economic benefit associated with the proposed action would be the net reduction of federal reimbursements to the operators of nuclear power plants for their costs associated with prolonged storage of spent fuel. If there is no action to build a CISF, the DOEs ongoing violation of the NWPA means it will continue to incur substantial and ongoing costs related to litigation, settlements, and unfavorable judgments with each individual power plant ISFSI.
However, even if the proposed action is implemented, the expenditures for storage will continue to accrue until the spent fuel is removed from the plants. The total CISF capacity will be 40,000 MTU and the eight sites listed in Table 7.2-1 collectively contain approximately 3,464 MTU of spent nuclear fuel in 279 dry storage canisters and an additional 17 canisters of Greater-than-Class C (GTCC) waste. These sites were selected because they all use either TN Americas or NAC International dry fuel storage systems and, therefore, would all be candidate sites that could be de-inventoried in the earliest stages of the proposed action. It is also assumed that spent fuel being stored in the dry casks at other decommissioning nuclear power plants across the nation will be removed and sent to the proposed CISF, but those subsequent transfers were not explicitly calculated in this analysis. Rather, the benefits and costs determined from analyzing the initial eight sites were extrapolated through the entire period of the initial site license. Going forward, it was assumed that additional reactor sites would shut down as they reached their End-of-Life or encountered unfavorable economic conditions, and that the CISF would take spent fuel preferentially from these shut down sites. By 2053 (the 34th year of the License Period), there will be a total of 71 shutdown reactor sites in the United States, according to NRC data. Given the available rolling stock and the 40-year duration of the NRC License, the total number of additional plants that could have their spent fuel removed (assuming 72 canisters per site) was 43 which equates to an additional ~36,200 MTU of spent fuel shipped to the site. The value of 72 canisters per shutdown site was conservatively chosen to reflect the fact that future shutdown sites would have had longer operating lives than the initial set of 8 decommissioning plant sites, and would therefore have larger inventories of spent fuel.
Therefore, in its 40th year of licensure, the CISF would hold 39,687 MTU of spent fuel from approximately 51 shutdown sites. Other anticipated economic benefits from the proposed action are related to the repurposing of land at most of the plant sites, as well as other benefits that were identified but cannot be readily quantified.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-5 Revision 2 Table 7.2-1: Selected Decommissioning Plant Sites Used Site Location Operating Period MTU Spent Fuel Canisters GTCC Canisters Total Canisters Connecticut Yankee Middlesex County, CT 1968-1996 412.3 40 3
43 Crystal River Citrus County, FL 1977-2009 583.6 39 2
41 Kewaunee Kewaunee County, WI 1974-2013 513.3 38 2
40 La Crosse Vernon County, WI 1969-1987 38.0 5
0 5
Maine Yankee Lincoln County, ME 1972-1996 542.3 60 4
64 Rancho Seco Sacramento County, CA 1975-1989 228.4 21 1
22 Yankee Rowe Franklin County, MA 1961-1991 127.1 15 1
16 Zion Lake County, IL (1)1973-1997 1,019.4 61 4
65 (2)1974-1996 TOTAL 3,464 279 17 296 Source: STOREFuel, Vol. 18, No. 211; TN Americas and NAC estimates.
7.2.1 Eliminated Storage Costs The implementation of the proposed action would allow the federal government to eliminate a sizeable portion of its projected payments to the eight referenced shutdown plant operators storing spent nuclear fuel, along with 43 additional plants. These savings would be the primary economic benefit of the proposed action. Table 7.2-2 provides the assumed annual cost of operating an independent spent fuel storage installation (ISFSI) at each shutdown plant. The assumed annual operating costs were derived from the generic range of cost estimates reported
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-6 Revision 2 in the 2012 Blue Ribbon Commission report. The 2012 Blue Ribbon Commission report estimated the annual cost of an ISFSI to be between $4.5 and $8 million. For this analysis, the assumed annual cost for maintaining an ISFSI at each facility was near the mid-point of this range or $6.475 million in 2015 dollars. Another source of information was a 2012 Government Accountability Office (GAO) report, which estimated the annual cost to operate an ISFSI to be between $3 and $7 million (GAO, 2012).
Table 7.2-2 also shows the estimated federal government expenditures to shutdown plant operators under two scenarios over the CISFs 40-year license: implementing the proposed action and the no action alternative. The first scenario assumes that the proposed action is implemented and begins receiving spent fuel canisters two years after being licensed by the NRC. This two-year period accounts for the time required to build the CISF, as well as completing the required operational readiness reviews. Planning studies for transporting the casks; the procurement of transportation casks, rail rolling stock, and cask moving equipment; the construction of or improvements to transportation infrastructure at the decommissioned plant sites could and should all proceed in parallel with the CISF design and licensing process. The scenario also assumes that during the first six years of transportation operations (2021-2026),
three trains, each with three cask cars, will be used to collect the spent fuel and that there will be six trips for each train per year. In the seventh year (2027) of transportation operations (once the initial eight shutdown sites have been emptied), two additional trains will be added for a total of five trains in service. The travel assumptions are based upon Maheras et al.s (2014) estimations that repositioning the empty cask cars from the CISF to the decommissioned plant could require approximately a month of travel without expedited service and the return trip would take about two weeks, depending upon the distance from the CISF. In this analysis, additional time was assumed for loading and unloading the casks, locomotive and rail car maintenance, and unforeseen delays. Beginning in the 16th year (2034) of the license through the 21nd year (2039), canister transportation will halt, as stored spent fuel at the shutdown plants is left to cool. It is assumed in the analysis that all spent fuel will be allowed to cool for at least 10 years before it is transported to the CISF. In the 22nd year of the license (2040), the transport of fuel will resume and three more sets of rolling stock will be added to the inventory, for a total of 8 operating trains transporting the spent fuel canisters. Their activity will continue until the 39th year of the license (2057), when the CISF will approach its licensed capacity. The assumed order of canister pick-up (in a generic sense) is shown below in Table 7.2-3.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-7 Revision 2 Typically in a benefit-cost analysis, the valuation of benefits and costs are adjusted to their net present value (NPV) using a discount rate. This practice permits all amounts to be adjusted to a valuation in a common year. However, because there are substantial labor, technological, and regulatory compliance expenditures related to the operation of the CISF and the ISFSIs, it was assumed that these expenses would likely appreciate over time, at least at the rate of inflation.
Therefore, the expenditures for storing the spent fuel were not discounted over time, but were assumed to stay relatively constant (i.e. 2015 dollars). In addition to the ISFSIs annual operating costs, once the canisters exceed 20 years of service life, a site will be required by the NRC to implement an Aging Management Program (AMP). The AMP will involve periodic inspections of a sample population of canisters at each site at regular intervals. Full requirements of the AMP are not yet fully detailed and, due to the general assumptions of this analysis, the benefits estimates did not account for the potential $750,000 of additional annual savings related to the AMP for each ISFSI site.
Table 7.2-2: Assumed Costs of Continued ISFSI Storage at Each Shutdown Site over the 40-year License Period Assumed Total Cost of Spent Fuel Storage over the 40-Year License Period (2015$)
Not Discounted Site Assumed Annual Cost of Spent Fuel Storage Per Site (2015$)
Proposed Action (With CISF)
No Action (Without CISF)
All Nuclear Power Plants
$6,437,500
$3,708,250,000
$9,109,312,500
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-8 Revision 2 Table 7.2-3: Assumed Number of Rail Trips to Remove Spent Fuel Canisters in the Benefit-Cost Analysis Site Number of Canisters Assumed Number of Rail Trips Loaded Canisters Duration of Shipments (months)
Assumed Year of Complete Canister Removal Initial Decommissioning Sites of WCS CISF Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Avg. Site 1 36 12 6
6 0
0 0
0 24 4
Avg. Site 2 36 12 6
6 0
0 0
0 24 4
Avg. Site 3 36 12 6
6 0
0 0
0 24 4
Avg. Site 4 36 12 0
0 6
6 0
0 24 6
Avg. Site 5 36 12 0
0 6
6 0
0 24 6
Avg. Site 6 36 12 0
0 6
6 0
0 24 6
Avg. Site 7 36 12 0
0 0
0 6
6 24 8
Avg. Site 8 36 12 0
0 0
0 6
6 24 8
TOTAL CISF Phase 1 288 96 18 18 18 18 12 12 AVG CISF Phase 1 36.0 12.0
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-9 Revision 2 The net estimated difference for federal government payments to shutdown sites between the no action alternative and implementing the proposed action (i.e. subtracting the total expenditures shown over the 40-year period in Table 7.2-2 for the proposed action from the total expenditures from the no action scenario), assuming no discount rate, was $5,401,062,500.
Figure 7.2-1 is a graphical representation of these figures on an annualized basis.
7.2.2 Repurposed Land Once the decommissioning of a nuclear power plant is complete and its license terminated, the NRC places no restrictions on the future use of the land. A nuclear power plants future uses can include industrial activities, but it can also be used for other commercial or societally-beneficial purposes, such as farming or housing (NRC, 2016). The pace at which a decommissioned site can be reused is, in part, determined by the operators decommissioning strategy. When a utility decides to shut down a nuclear power plant, it must choose between one of three decommissioning strategies: DECON, SAFSTOR, or ENTOMB. The DECON strategy requires that all parts of the plant (equipment, structures, and other portions of the facility with radioactive contaminants) be removed or decontaminated. When the facility is considered adequately decontaminated, the NRC releases the property and terminates its license. Under the SAFSTOR option, the facility is maintained while the radioactivity decays to lower levels for subsequent decontamination and dismantlement, as with the DECON strategy.
The third option is ENTOMB, where all radioactive contaminants are encased in concrete. The facility is monitored and maintained until the radioactivity decays to a level that allows the facility to undergo a restricted release. No NRC-licensed facility has used the ENTOMB strategy to date (NRC, 2015).
The precise value of land at a particular decommissioned nuclear power plant is difficult to estimate. Readapting the land to nature preserves or parks is a frequent consideration for former plant sites. Table 7.2-4 identifies two instances where a former site has been repurposed. The first is the Maine Yankee site, which has 400 acres committed as an industrial park for local economic development. A review of recent aerial photography shows the pace of redevelopment has been limited to date. The second example is 62 acres of the 2,400-acre Rancho Seco site, which will be used for a solar energy facility. Several of the shutdown nuclear power plants are co-located with fossil fuel plants, which are not being decommissioned concurrently with the nuclear reactor. These locations include the former Crystal River and the
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-10 Revision 2 La Crosse plant sites. Other facilities continue to undergo the process of decommissioning and will not be available on the real estate market for a number of years.
Table 7.2-4 provides a listing of each of the eight facilities covered in this analysis, the number of acres on the site, the plants decommissioning strategy, its expected date to be released from its license or when it received a release, and the sites current and future land use
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-11 Revision 2 Table 7.2-4: Site Size, Regulatory Status, and Land Use Potential at Decommissioned Nuclear Power Plants Site Location Approximate Site Acreage License Status Estimated Closure Date Sites Current/Future Use Connecticut Yankee Middlesex County, CT 544 DECON Completed 2007 Vacant, available Crystal River Citrus County, FL 4,700 SAFSTOR In progress 2074 Continued use for fossil fuel power plants during decommissioning Kewaunee Kewaunee County, WI 900 SAFSTOR In progress TBD Continues to undergo decommissioning La Crosse Vernon County, WI 163 SAFSTOR TBD Continued use for fossil fuel power plants Maine Yankee Lincoln County, ME 820 DECON Completed 2005 200 acres donated for conservation and education; 400 acres for economic development Rancho Seco Sacramento County, CA 2,400 DECON In progress N/A 62 acres planned for solar facility Yankee Rowe Franklin County, MA 2,200 DECON Completed 2007 Vacant, available Zion Lake County, IL 257 DECON In Progress 2020 Continues to undergo decommissioning Sources: NRC, 2016; Maine Yankee, 2016; Connecticut Yankee, 2016; Content, 2015; Joyce, 2015; Wernau, 2015; Maheras et al., 2014; Abel, 2013; Broncaccio, 2013; Penn, 2013; Friedman and Diskin, 2006; Libow, 2001; and Peyton, 1999.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-12 Revision 2 One of the challenges to reusing the site of a fully decommissioned nuclear power plant is that the facility may retain a public perception of risk, even after the NRC has determined that the site is safe for reuse, Pasqualetti and Pijawka (1996)1 surveyed residents within eight kilometers of the Humboldt nuclear power plant in 1992 and found that public perceptions of risk remain throughout a plants decommissioning stage. However, the perceived risks from a decommissioned plant do diminish once its spent fuel is removed from the site. Nonetheless, even if the spent fuel is moved offsite and all parts of the decommissioned plant removed, almost 17 percent of the survey respondents believed the facility still presented a high level of risk. While such fears are not scientifically sound, they can still create some negative impacts on the value of land at a decommissioned site.
Another factor that can affect the value of land at a shutdown nuclear power plant has been the response of some local governments to decommissioning. Nuclear power plants are often located in rural areas that are away from population centers and not always economically robust. In many communities, local governments have been dependent upon the power plants, with their large workforce of well-paid employees and contributions to local governments, to support their local economies. When a facility is shut down and later fully decommissioned, it can lead to substantial loss of jobs and public revenue in the community, especially if the site is not redeveloped soon after its decommissioning.
The closing of the Kewaunee nuclear power plant in Carlton, Wisconsin led to the loss of 550 jobs and $350,000 of revenue for the municipal government (Bosman, 2015). Initially, the town of Carlton appraised the value of the plants 900-acre tract at $10 million for the 2013 tax roll.
However, in 2014, the same 900-acre tract was appraised at $457 million (Yancey, 2015), as local officials try to generate new revenue. The owner of the plant has since sued the town of Carlton to reduce the appraised value. The valuation of the land at the Kewaunee plant is further complicated because the owner has up to 60 years to restore the site (Content, 2015).
Situations like these further complicate the valuation of land at a decommissioned site.
The estimated value of the land at shutdown nuclear plants in this analysis was based upon the typical price of brownfield industrial property in the area surrounding the site (see Table 7.2-5).
Unfortunately, none of the listings for industrial properties near the shutdown facilities were 1 Pasqualetti, Martin J. and K. David Pijawka. 1996. Unsiting Nuclear Power Plants: Decommissioning Risks and Their Land Use Context. Professional Geographer, 48(1), 57-69.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-13 Revision 2 described as brownfield properties, so comparable parcels of industrial property were identified from recent local property listings and the assumed price per acre for this land was discounted by 50 percent. The 50 percent valuation discount is consistent with the findings of several studies of brownfield properties. Page and Rabinowitz (1993) found that the value of brownfield properties had prices that were 10 to 50 percent lower than similar properties. Patchin (1994) found the discounted price of commercial and industrial brownfield land between 21 and 94 percent lower than more pristine property. Finally, Howland (2010) found that parcels with historic uses that gave reasons to suspect contamination sold at an average discount of 65 percent.
Table 7.2-5: Estimated Value of Land at Decommissioned Nuclear Power Plants Site Approximate Site Acreage Estimated Value per Acre (2015$)
Acres Available for Redevelopment Estimated Value of Land (2015$)
Connecticut Yankee 544
$40,500 544
$22,032,000 Crystal River 4,700 Kewaunee 900
$10,485 900
$9,436,500 La Crosse 163 Maine Yankee 820
$9,500 620
$5,890,000 Rancho Seco 2,400
$24,500 2,338
$57,281,000 Yankee Rowe 2,200
$25,500 2,200
$56,100,000 Zion 257
$22,500 257
$5,782,500 Subtotal 11,984 6,859
$156,522,000 Average 1,997
$22,164 1,143
$26,087,000 Note: Crystal River, Kewaunee, La Crosse sites are assumed to continue as fossil fuel power plants.
Source: Loopnet.com, 2016 and Maine Commercial Association of Realtors, 2016.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-14 Revision 2 The total estimated value of land returned to the market at 6 of the 8 currently decommissioned plants and the 43 generic plants with their fuel removed was estimated to be $1.27 billion dollars. The site acreage and the value of land at each generic decommissioned plant was assumed to be equal to the average values of the six decommissioned nuclear power plants that will return land to the market.
Table 7.2-6: Total Estimated Value of Land at Decommissioned Nuclear Power Plants Served by the Proposed Action Source Value Estimated Value of Land at 8 Currently Decommissioned Plants
$156,522,000 Assumed Value of Land at 43 Generic Decommissioned Plants
$1,121,741,000 Total Estimated Value of Repurposed Land
$1,278,263,000 7.2.3 Other Economic Benefits Not Quantified In addition to the economic benefits identified above, there are other tangible economic benefits that were not quantified in this analysis, due to the lack of specific information, the data necessary to make an estimate, or uncertainty about future conditions.
The GAO estimates the federal government has spent an additional $219.5 million through December 2013 defending the DOE against lawsuits brought by plant operators over the cost of storing spent fuel. These ongoing legal defense costs would be reduced and eventually be eliminated once the federal government meets its obligations under the NWPA.
Another avoided cost will be eliminating the need for studies and programs designed to find an immediate solution for the storage of spent fuel.
There will be various indirect and induced economic benefits from developing the CISF, its operation, and professional and transportation services. While the direct expenditures could not be counted as benefits, the indirect and induced impacts could.2 2 See the Socioeconomic Impact Assessment appendix in this document for a discussion of the indirect and induced impacts resulting from the construction and operation of the proposed action.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-15 Revision 2 A licensed CISF would also eliminate the need for the DOE to undergo a separate consent-based siting program for a CISF. Likewise, the generic TSAR (Technical Safety Analysis Report), that DOE has solicited proposals for, would not be needed, as a CISF would already be licensed.3 While each of these avoided costs is likely to save the DOE from substantial expenditures, those savings were not quantified in this analysis.
Improvements to transportation corridors between the shutdown nuclear plants could create positive economic impacts for other users of the transportation infrastructure.
7.3 COSTS ANALYSIS Development of the CISF and the relocation of the spent nuclear fuel to this facility will incur substantial upfront costs, as well as ongoing annual operating expenditures. Most of the upfront costs for planning and permitting will be borne initially by the private sector. However, prior to commencing construction, operation, and receipt of licensed material at the WCS CISF, ISP expects to enter into a contract(s) with DOE or the SNF Title Holder(s) that will provide the funding for facility construction, operation, and decommissioning. Due to the limited amount of information on this topic, this analysis incorporates assumptions and cost estimates from the Electric Power Research Institutes (EPRI) 2009 report, Cost Estimate for an Away-From-Reactor Generic Interim Storage Facility (GISF) for Spent Nuclear Fuel adjusting them to 2015 dollars using the CPI and adjusting values where appropriate for the circumstances of the proposed action. In addition to using the information for this discussion, ISP has also relied substantially upon the EPRI figures to develop internal planning information for the project.
7.3.1 Planning, Permitting, and Constructing the Proposed Project The initial planning stage of the project requires various studies to assess the technical feasibility of the project, the consideration of various alternatives, and the impacts of the alternatives on the human and natural environment for the projects environmental report.
Additionally, ISP must inform the public about the proposed facility and engage local stakeholders. Prior to the submission of an application for an NRC license, ISP will also develop a preliminary design for the facility and a safety analysis. The estimated cost for these activities is $19.9 million (See Table 7.3-1, as derived from the 2009 EPRI report).
3 The DOEs RFP was issued on April 15, 2016.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-16 Revision 2 After the initial submittal of the license application, ISP will pay fees to the NRC to review its application, as well as for the preparation of an environmental impact statement (EIS) and the public hearing process, as necessary. There will also be costs associated with state and local government review of the project. Additionally, it will be necessary for ISP to continue providing public information and engaging stakeholders as the project progresses. During the review of the license application, technical and legal support will be retained and a detailed engineering design will be prepared for the CISF and the sites transportation infrastructure. The total estimated cost for the license application review stage is $44.3 million, as derived from the 2009 EPRI report.
The initial source of this funding for planning and permitting is ISP and other project team members, including in-kind contributions of time and expertise. However, ISP would seek to recover these costs through a future contract with DOE or the SNF Title Holder(s).
After receiving the license, the CISFs construction will begin to move forward, which will require the services of engineers and construction personnel. As the site is constructed, it will be necessary to ensure and confirm the quality of construction. The total cost for this phase is estimated to be approximately $9.9 million, as derived from the 2009 EPRI report. As explained in the license application, funding of construction is expected to be primarily through a future contract with DOE or the SNF Title Holder(s).
Overall, the initial phase of developing the CISF is expected to cost approximately $74.1 million, as derived from the 2009 EPRI report. This expense also includes project management costs and a contingency assumption of 30 percent.
Table 7.3-1: CISF Design, Engineering, Licensing, and Startup Professional Services Cost Category Estimated Cost (Millions 2015$)
Pre-Licensing Phase Project Management
$3.30 Public Information and Stakeholder Involvement
$1.65 Geotechnical Investigations and Environmental Report Development
$2.20 Preliminary Design, Safety Analysis, and Preparation of License Application
$8.14 Subtotal Pre-Licensing Phase
$15.29
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-17 Revision 2 Cost Category Estimated Cost (Millions 2015$)
Contingency: 30%
$4.59 Total CISF Pre-License Submittal Phase:
$19.88 License Application Review Stage Project Management
$2.75 Public Information and Stakeholder Involvement
$1.65 NRC Fees for LA Review, EIS, and Hearing Process
$17.60 Technical and Legal Support during LA Review and Hearing Process
$6.60 Detailed Design for CISF Facilities and Transportation Infrastructure
$4.95 State and Local Authority Review
$0.55 Subtotal: CISF License Application Review Phase
$34.10 Contingency: 30%
$10.23 Total CISF License Application Review Phase
$44.33 Initial Construction/Pre-Operations Phase Project Management
$1.54 Public Information and Stakeholder Involvement
$1.65 Engineering and Legal Support during Construction
$2.53 System Start-up, Dry-Run Testing
$1.87 Subtotal CISF Initial Construction/Pre-Operations Phase
$7.59 Contingency: 30%
$2.28 Total CISF Initial Construction/Pre-Operations Phase
$9.87 Total CISF Design, Engineering, Licensing, and Startup Professional Services
$74.08 Source: Derived from EPRI, 2009.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-18 Revision 2 7.3.2 CISF Capital Costs Under ISP's approach, DOE or the SNF Title Holder(s) would be responsible for transportation, including associated costs. As explained in the license application, funding of construction is expected to be primarily through a future contract with DOE or the SNF Title Holder(s).
7.3.2.1 Transportation Capital Costs The development of the CISF facility will require transportation improvements and the purchase of rolling stock that will be used to bring the spent fuel from the shutdown nuclear power plants to the CISF. The CISF site is already well served by roads and a rail spur, so fewer transportation improvements will likely be needed than would be assumed at EPRIs generic facility or any of the alternative CISF sites that have been considered. The estimates in Table 7.3-2 reflect adjustments for these conditions. The cost analysis also assumes the purchase of rolling stock for eight trains. This rolling stock includes eight rail escort cars (at $3.7 million each) that will hold personnel (including security), and 24 rail cask cars that will carry the transportation casks (at $0.9 million apiece, plus $6.0 million apiece for 40 transportation casks), as well as 16 rail buffer cars (at $0.5 million apiece). One rail buffer car rides on either side of the group of rail cask cars to protect the crew from radiation. The cost estimate also includes $25 million for the development of railcars (cask, buffer, and escort cars) that are compliant with the American Association of Railroads S-2043 standards for carrying radioactive materials (GAO, 2014). Locomotives and their crews were assumed to be provided by the railroad providing the service.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-19 Revision 2 Table 7.3-2: Estimated Costs of Transportation Infrastructure Description Cost Estimate (Millions 2015$)
Access Road Improvements
$1.5 Rail Spur / Rail Siding Construction
$2.0 Land Improvements
$5.0 Rail Escort Cars @ $3.7 million: 8
$29.6 Rail Buffer Cars @ $0.5 million: 16
$8.0 Cask Rolling Stock Rail Cask Car @ $0.9 million: 24 Transportation Casks @ $6.0 million: 40 Associated transport equipment (impact limiters, etc.)
$261.6 Rail Car Design and Development
$25.0 Subtotal Transportation Infrastructure
$332.7 Contingency: 30%
$99.8 Total Transportation Infrastructure
$432.5 Source; Derived from EPRI, 2009.
7.3.2.2 CISF Infrastructure Development of the CISF will require the construction of various buildings to support activities at the site. The assumed facilities include a combined administrative and security and health physics building and a canister handling building. Maintenance and operations activities will be carried out at existing buildings on the site. It is also assumed, over the 40-year license, that all the equipment and building furnishings will need a one-time replacement. The assumed cost for building construction is $37.0 million, and with a 30 percent contingency, totals costs are estimated to be $48.1 million (See Table 7.3-3).
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-20 Revision 2 Table 7.3-3: Estimated Costs of CISF Infrastructure CISF Capital Cost Elements Cost Estimate Millions (2015$)
Administrative, Security, and Health Physics Building Building construction
$2.6 Furnishings, equipment, emergency diesel generator, vehicles (with one-time replacement)
$7.0 Total Administrative, Security, and Health Physics Building
$9.6 Canister Handling Building Building construction
$5.9 Canister transfer cells and equipment: 3
$8.3 Heavy lifting equipment and heavy haul equipment (with one-time replacement)
$13.2 Total Canister Handling Building
$27.4 Subtotal CISF Infrastructure
$37.0 Contingency: 30%
$11.1 Total CISF Infrastructure
$48.1 Source; Derived from EPRI, 2009.
7.3.2.3 Spent Fuel Storage Facility Storage of the spent fuel canisters will require the construction of new storage pads and security features. Multiple canisters will sit on large concrete pads that will have an average cost of
$100,000 per canister, along with $3.3 million expended for site preparation (See Table 7.3-4).
For security, the facility is assumed to have a fenced inner and outer perimeter that will cost $1 million. Other security features will include lighting, intrusion detection, close-circuit television, and other types of monitoring equipment. It was estimated that the electronics portion of this expense is approximately $2.5 million and that it would be replaced four times over the 40-year period to remain in good working order and to take advantage of new technological advances.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-21 Revision 2 All these items will have a collective cost of almost $364.0 million and, with a $109.2 million contingency, will total $473.2 million.
Table 7.3-4: Spent Fuel Storage Facility Costs CISF Fuel Storage Facility Costs Cost Estimate Millions (2015$)
Evacuation and Grading
$3.30 Concrete Storage Pads Large concrete pads estimated to cost $100,000 per canister @
3,392 canisters stored
$339.2 Security Fence 1500 ft. x 1600 ft. - 6,200 linear feet Inner and outer security fences - 12,400 linear feet
$1.02 Fencing: $82.50/linear foot Security System Lighting, intrusion detection, CCTV, monitoring equipment (with four updates to the electronic equipment)
$20.45 Subtotal: Fuel Storage Facility
$364.0 Contingency: 30%
$109.2 Total Fuel Storage Facility
$473.2 Source: Derived from EPRI, 2009.
7.3.3 CISF Operating Costs As explained in the license application, ISP will obtain funds to operate the CISF pursuant to a future contract with DOE or the SNF Title Holder(s). ISP also intends to collect funds for the decommissioning of equipment, facilities, and land at the CISF pursuant to a future contract with DOE.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-22 Revision 2 7.3.3.1 Recurring Administrative Costs Table 7.3-5 shows estimates of various recurring administrative operating expenses for the proposed action. Travel and living expenses for the security crews who will pick-up the spent fuel canisters is estimated to be approximately $4.35 million. This expense assumes 1,131 rail shipments that will remove 3,392 casks of spent fuel. There will be an annual office expense of
$1.1 million (over 40 years that totals $44.0 million) that includes communications and reproduction, office supplies, office equipment and leases, office equipment maintenance and repair, postage, dues and subscriptions, and insurance. The total expenditure including contingency is $62.9 million.
Table 7.3-5: Administrative Operating Costs CISF Administrative Operating Costs Cost Estimate (Millions 2015$)
Travel and Living Expenses Security crew 1,131 rail shipments for 3,392 casks
$4.35
$3,850 per rail shipment Annual Office Expenses Communications and reproduction, office supplies, office equipment and leases, office equipment maintenance and repair, postage, dues and subscriptions, insurance
$44.00 Subtotal: Annual Administrative Operating Costs
$48.35 Contingency: 30%
$14.51 Total Administrative Operating Costs
$62.86 Total over the 40-year licensure period in 2015$
Source: Derived from EPRI, 2009.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-23 Revision 2 7.3.3.2 Concrete Overpacks Upon relocation to the CISF, each shipment will arrive in a dual purpose canister and will need to be placed into a concrete overpack and set on a pad. Each concrete overpack is expected to cost $220,000 (See Table 7.3-6). The total expenditure for placing all the spent fuel canisters relocated from the eight shutdown plants and the 43 generic plants, including contingency costs, is estimated to be $970.1 million in 2015 dollars.
Table 7.3-6: Costs for Concrete Overpack Concrete Overpack Costs Cost Estimate (Millions 2015$)
Concrete Overpack Costs
$220,000 per overpack: 3,392 canisters
$746.2 Contingency: 30%
$223.9 Total Costs
$970.1 Source: Derived from EPRI, 2009.
7.3.3.3 Transportation Planning and Transport at Shutdown Plant Sites The EPRI study did not discuss the potential costs related to moving the casks from the shutdown nuclear power plants to a railroad transloading location, which in some cases might be within the boundaries of the plant property or for others, many miles away. Reaching these transloading locations could require moving the cask from the plant by barge or heavy-haul truck, depending upon the circumstances. The EPRI study also did not identify costs for the extensive transportation and safety planning that would be necessary along each route between the shutdown plant and the CISF. A detailed discussion of the activities that must occur before and during the transfer of the casks is provided in Maheras et. al. (2014). However, that report does not provide cost estimations for any of these activities. A 2014 GAO report, entitled Spent Nuclear Fuel Management: Outreach Needed to Help Gain Public Acceptance for Federal Activities that Address Liability, did give estimates for some of the local transportation costs.
Table 7.3-7 shows general approximations of the identified expenditures for all 51 spent fuel sites.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-24 Revision 2 Table 7.3-7: Assumed On-site Transportation Planning and Transport Costs On-Site Transportation Planning and Transport Costs Cost Estimate Millions (2015$)
Assemble Project Organization Assemble management teams
$76.5 Identify shutdown site existing infrastructure, constraints, &
transportation resource needs and develop interface procedures.
$102.0 Conduct Preliminary Logistics Analysis and Planning Develop specs, solicit bids, issue contracts, & initiate preparations for shipping campaigns
$12.8 Revisions to certificates of compliance as may be needed
$25.5 Conduct Preliminary Logistics Analysis and Planning Determine fleet size, transport requirements, and modes of transport for shutdown site
$10.2 Coordinate with Stakeholders Assess and select routes & modes of transport
$15.3 Support training of emergency response personnel
$100.0 Develop Campaign Plans Develop plans, policies, & procedures for at-site operational interfaces, support operations, and in-transit security operations
$46.0 Conduct Readiness Activities Assemble & train at-site operations interface team & shutdown site workers
$51.0 Includes readiness reviews, tabletop exercises, and dry run operations
$76.5 Local Transportation Portable transportation equipment - 8 sets @ $2.0 million
$16.0 Local transportation improvements - 51 sites @ $1.0 million
$51.0 Transfer cask to site to railroad - $250,000 per cask: 3,392 casks
$848.0 Subtotal: On-Site Transportation Planning and Transport Costs
$1,430.8 Contingency: 30%
$429.2 Total Transportation Planning and Transport Costs
$1,860.0 Note: Values are for all 51 sites.
Source: Derived from GAO (2014)
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-25 Revision 2 7.3.3.4 Rail Costs from Shutdown Plants to CISF For cost and safety reasons, the preferred mode for transporting the casks of spent fuel is rail (DOE, 2013)4. In some cases, the locations with spent fuel have an existing rail spur in the facility, which connects to a short line or a regional or Class I railroad. However, in a number of cases, it will be necessary for the cask to be transported by truck or barge to a rail head capable of handling the cargo.
Regardless of which part of the country the casks will be transported from, they will eventually need to travel on the Union Pacific (UP) rail line that is parallel to Interstate Highway (IH) 20, known as the TP Line. In the Texas town of Monahans, the train will interchange with the Texas
& New Mexico Railway (TNMR), which is a short line railroad. The TNMR is a modern facility that can handle 286,000 lbs. rail cars and is the same capacity as the UPs TP Line. The TNMR connects to ISP joint venture member Waste Control Specialistss internal rail spur.
Table 7.3-8 shows the estimated distances of rail trips needed to remove the casks from existing, decommissioned facility. In a 2011 MIT Study, it was estimated that the transportation cost of moving a train with three casks was $75 per mile. That amount was adjusted to $82.50, based upon the change in the CPI. The distance by rail from each facility to the WCS CISF was based upon the shortest route of the train, which considered track weight capacity, but none of the other factors that might influence the routing of the train.
4 Department of Energy. 2013. Office of Fuel Cycle and Research Development, A Project Concept for Nuclear Fuels Storage and Transportation. FCRD-NFST-2013-000132 Rev. 1 (June 15, 2013).
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-26 Revision 2 Table 7.3-8: Estimated Distances of Rail Transportation to CISF Site Estimated Distance Connecticut Yankee 2,337 Crystal River 1,672 Kewaunee 1,509 La Crosse 1,443 Maine Yankee 2,435 Rancho Seco 1,498 Yankee Rowe 2,293 Zion 1,404 AVERAGE 1,824 Source: Derived from EPRI, 2009.
7.3.3.5 Other Operating Costs There will be additional recurring expenses to operate the CISF that are shown in Table 7.3-9.
The largest expense shown will be the transport of the spent fuel by rail to the CISF, estimated to be approximately $340.4 million. Other assumed annual expenses include: state inspection fees (estimated at $44 million); equipment, spare parts, and maintenance (estimated at $84 million over the 40-year license); regulatory fees and license fees (estimated at $32 million over the 40-year license); utilities (estimated at $32 million over the 40-year license); and the disposal of low-level nuclear waste (LLW) (estimated at $3 million over the 40-year license).
Total expenditures for other operating costs, with contingencies, is approximately $696.0 million.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-27 Revision 2 Table 7.3-9: Assumptions for Other Operating Costs Assumptions for Other Operating Costs Cost Estimate (Millions 2015$)
Railroad Freight Fees Estimated cost for 1,131 shipments of 3 SNF transport casks by dedicated train @ $82.50 per mile round-trip; average trip length 1,824 miles
$340.4 State Inspection Fees
$44.0 Equipment, spare parts, and maintenance
$84.0 Regulatory fees and license fees
$32.0 Utilities
$32.0 LLW Disposal (50 cubic feet per year; $1,500 per cubic foot)
$3.0 Subtotal: Other Operating Costs
$535.40 Contingency: 30%
$160.62 Total: Other Operating Costs
$696.02 Total over the 40-year licensure period in 2015$
Source: Derived from EPRI, 2009.
7.3.4 Labor Costs Labor costs at the proposed facility are likely to be lower than estimated in the EPRI study, since many of the job functions identified for the CISF are currently performed by existing staff at the LLW facility located on the same site. Therefore, it was assumed that the labor requirements for the CISF would be similar to the caretaker status, with a reduction made to the number of administrative personnel. However, five teams of two workers were included for each reactor site where fuel was being removed. The estimated payroll, including the 40 percent for fringe benefits and contingency, was $180.8 million over the 40-year period (See Table 7.3-10).
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-28 Revision 2 Table 7.3-10: Assumed CISF Annual Labor Costs Labor Categories during Caretaker Period Estimated Annual FTE Average Cost per FTE ($000s)
Cost Estimate (Millions 2015$)
Administrative Staff: General manager, administrative assistants, public relations, financing and purchasing, accounting and payroll, governmental affairs 3
$98.2
$0.29 Security staff: assumes 5 staff per shift, 4 shifts, 7 days per week 20
$60.5
$1.22 Engineering and technical staff: Nuclear and licensing engineers, health physics managers and technicians, quality assurance managers and technicians, transportation specialist, training 7
$88.0
$0.62 Maintenance and equipment operating staff:
Mechanical and electrical maintenance, crane and equipment operators, general plant workers, fire and EMT 6
$57.0
$0.34 At-reactor loading crews: 2 per site, 5 sites per month 10
$77.0
$0.77 Subtotal: Labor during Caretaker 46
$70.4
$3.23 Fringe benefits and contingency: 40%
$1.29 Total Annual Labor Costs
$4.52 Over 40-Year Licensure
$180.8 Source: Derived from EPRI, 2009.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-29 Revision 2 7.4 DISCUSSION AND
SUMMARY
7.4.1 Proposed Action Alternative Implementation of the proposed action is assumed to create a number of economic benefits, two of which were quantifiable with existing information. The first quantifiable benefit would be the avoided reimbursements to power plant operators for storing spent fuel the government is obligated to dispose of under the NWPA. Because the federal government does not have a storage or disposal facility for spent nuclear fuel, the DOE has been successfully sued by plant operators to reimburse them for their storage costs. The estimated benefit of the proposed action was measured as the cost of continuing to reimburse operators of shutdown plants for storing spent nuclear fuel over the next 40 years under a no action scenario and subtracting the reduced reimbursement schedule, if the CISF is built. Based upon the very conservative assumptions in this benefit-cost analysis, the proposed action would create a benefit to the federal government of $5,401,062,500 (not discounted), as shown in Table 7.4-1. The second quantifiable benefit was the value of land at shutdown nuclear power plants that is currently undevelopable. The overall value of land that could be returned to an economic use, if the sites spent fuel was removed, was estimated to be worth $1,278,263,000 (not discounted). The total economic benefits from implementing the proposed action are $6,679,325,000 (not discounted).
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-30 Revision 2 Table 7.4-1: Summary of Quantified Benefits from CISF over 40-Year Licensure (Not Discounted)
Benefit Category Cost Estimate (Millions 2015$)
Avoided Reimbursements to Utilities for Storing Spent Fuel
$5,401.1 Value of Land Potentially Returned to Economic Use
$1,278.3 Total Benefit
$6,679.4 A summary of the estimated economic costs of the proposed action, which were discussed in Section 7.3 and detailed in Tables 7.3-1 through 7.3-10, is provided in Table 7.4-2. The figures demonstrate various costs to build and operate the CISF facility, as well as to transfer the spent nuclear fuel from the shutdown nuclear power plants. Table 7.4-2 also includes an estimate of the decommissioning costs, which is $375.2 million. EPRIs cost estimate of site decommissioning is based upon 20 percent of the cost for the fuel storage facility ($94.6 million) and 20 percent of the cost for the concrete overpacks ($194.0 million), plus a 30 percent contingency. Cumulatively, over the 40-year license period, the assumed cost of the proposed action was approximately $5,172.9 million. Considering both the benefits of the Federal Government in avoiding liability costs and the land value, the net benefit of the proposed action would be approximately $1,506.5 million. Under the assumptions presented in this chapter, the benefits of the proposed action exceed its costs.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-31 Revision 2 Table 7.4-2: Summary of Costs for CISF over 40-Year Licensure (Not Discounted)
Cost Category Cost Estimate (Millions 2015$)
Design, Engineering, Licensing and Startup Professional Services
$74.1 Transportation Infrastructure
$432.5 CISF Infrastructure
$48.1 Fuel Storage Facility
$473.2 Administrative Operating Costs
$62.9 Concrete Overpacks
$970.1 On-site Transportation Planning and Transportation Costs
$1,860.0 Other: Transportation, License Fees
$696.0 Annual Operating Labor Costs
$180.8 Decommissioning
$375.2 Total Costs for CISF over 40-Year Licensure
$5,172.9 7.4.2 Eliminated Alternatives In addition to the location in Andrews County, three other locations were considered for the proposed CISF, but eliminated as viable alternatives. These locations were in: Loving County, TX; Lea County, NM, and Eddy County, NM. It is assumed that implementing a CISF at one of the three eliminated alternative locations would create the same overall benefits as the proposed alternative and all the same expenses. The eliminated alternatives would also require additional expenditures that would not be required for the proposed alternative. Specifically, these additional costs would be: construction of an operations and maintenance building that was not assumed for the proposed action alternative, because an existing building at the site would be used; a larger number of staff, since there would be no existing staff to handle some tasks; and additional road and rail infrastructure that would be needed for a greenfield facility.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-32 Revision 2 The cost of the operations and maintenance building was estimated to be $14.73 million based upon EPRI estimates, adjusted by the CPI, contingency costs, and assuming that the buildings furnishings and equipment would require a one-time replacement over the 40-year license period (See Table 7.4-3).
Table 7.4-3: Estimated Costs of an Operations and Maintenance Building at an Eliminated Alternative Site CISF Capital Cost Elements Cost Estimate Millions (2015$)
Operations and Maintenance Building Building construction
$1.87 Furnishings, equipment (with one-time replacement)
$2.86 Heavy lifting equipment (with one-time replacement)
$6.60 Subtotal: Operations and Maintenance Building
$11.33 Contingency: 30%
$3.40 Total: Operations and Maintenance Building
$14.73 Source: Derived from EPRI, 2009.
The assumed labor force required to handle activities at the eliminated alternative sites was 77 full-time employees (FTEs) (See Table 7.4-4). The eliminated alternative sites would require more administrative staff, engineering and technical staff, and maintenance and operating staff than the proposed alternative. The total annual labor cost is estimated to be $7.97 million and over 40 years would total $318.8 million (in unadjusted 2015 dollars).
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-33 Revision 2 Table 7.4-4: Assumed CISF Annual Labor Costs for Alternative Locations Labor Categories during Caretaker Period Estimated Annual FTE Average Cost per FTE ($000s)
Cost estimate (Millions 2015$)
Administrative Staff: General manager, administrative assistants, public relations, financing and purchasing, accounting and payroll, governmental affairs 10
$90.8
$0.91 Security staff: assumes 4 staff per shift, 3 shifts 20
$60.5
$1.21 Engineering and technical staff: Nuclear and licensing engineers, health physics managers and technicians, quality assurance managers and technicians, transportation specialist, training 18
$88.0
$1.58 Maintenance and equipment operating staff:
Mechanical and electrical maintenance, crane and equipment operators, general plant workers, fire and EMT 19
$64.1
$1.22 At-reactor loading crews: 2 per site, 6 sites per month 10
$77.0
$0.77 Subtotal: Labor during Caretaker 77
$74.2
$5.69 Fringe benefits and contingency: 40%
$2.28 Total Annual Labor Costs during Caretaker
$7.97 Over 40-Year Licensure
$318.8 Source: Derived from EPRI, 2009.
Specific sites for the rejected alternative CISFs were not identified, so generic locations were chosen to estimate the costs of transportation infrastructure. Table 7.4-5 shows the assumed distance and the estimated cost of connecting the eliminated alternative sites to the existing rail and road network, as well as constructing the transportation infrastructure within the facility. It
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-34 Revision 2 assumed that the Loving County and Eddy County facilities would be connected directly to the Union Pacific TP line, while the Lea County facility would likely be connected and located in close proximity to the TNMR.
Table 7.4-5: Estimated Distances and Costs of Transportation Infrastructure Required for the Eliminated Alternatives Loving County, TX Lea County, NM Eddy County, NM Rail Distance 35 miles 4 miles 56 miles Rail Cost @ $1.5 million per mile
$52.5 million
$6.0 million
$84 million Road Distance 4 miles 2 lanes 4 miles 2 lanes 4 miles 2 lanes Road cost at $6.0 million per lane mile
$48.0 million
$48.0 million
$48.0 million The final costs of the eliminated alternatives shown in Table 7.4-6 are moderately higher than the proposed alternative, ranging from $5.38 billion to $5.45 billion.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-35 Revision 2 Table 7.4-6: Summary of Costs for Eliminated Alternative CISFs over 40-Year Licensure (Not Discounted)
Cost Category Cost Estimate (Millions 2015$)
Loving County, TX Lea County, NM Eddy County, NM Design, Engineering, Licensing and Startup Professional Services
$74.1
$74.1
$74.1 Transportation Infrastructure
$529.5
$483.0
$561.0 CISF Infrastructure
$62.8
$62.8
$62.8 Fuel Storage Facility
$473.2
$473.2
$473.2 Administrative Operating Costs
$62.9
$62.9
$62.9 Concrete Overpacks
$970.1
$970.1
$970.1 On-site Transportation Planning and Transportation Costs
$1,860.0
$1,860.0
$1,860.0 Other: Transportation, License Fees
$696.0
$696.0
$696.0 Annual Operating Labor Costs
$318.8
$318.8
$318.8 Decommissioning
$375.2
$375.2
$375.2 Total Costs for CISF over 40-Year Licensure
$5,422.6
$5,376.1
$5,454.1
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-36 Revision 2 7.5 ENVIRONMENTAL BENEFITS AND COSTS If the No Action alternative is selected, spent nuclear fuel would remain in storage at decommissioned reactors, which would result in ongoing and escalating costs of storing and managing the spent fuel at existing reactor sites. Benefits to reactor site communities would not occur, if consolidated interim spent fuel storage continues to be unavailable.
7.5.1 Environmental Benefits of the Proposed Action Because there are economies of scale with the proposed action, a CISF could incorporate and maintain more sophisticated security, lighting, and intrusion detection equipment and maintain a larger and more highly trained security force to safeguard the spent nuclear fuel. Finally, because there is a relatively low population density surrounding the proposed CISF and the geological characteristics of the preferred site minimize the likelihood of harm to the natural environment, if a highly unlikely incident were to occur, a smaller population and fewer natural resources would be affected than at many of the decommissioned plant sites.
Under the proposed action, the CISF would also benefit the local economy through employment opportunities associated with the construction and operation of the proposed CISF. As detailed in Chapter 4 (and in the Socioeconomic Impact Assessment appendix), the socioeconomic model estimates that the CISF would create 912 person-years of employment over a ten-year period through the direct, indirect, and induced effects of the facilitys operations. Additional financial resources for ISP would offer expanded opportunities for local social, educational, and economic development. Various tax benefits would accrue to state and local governments, based on the economic activity associated with constructing the CISF facility. Overall, anticipated state and local tax revenues that would result from the WCS CISF facility would have a moderate, positive impact on the overall county tax revenues, based on recent data.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-37 Revision 2 7.5.2 Environmental Costs of the Proposed Action The environmental costs of the proposed action that are directly related to the potential environmental impacts of the proposed action are discussed extensively in Chapter 4. A few key environmental costs are discussed below.
Industrial construction at the CISF site would create a short-term risk with regard to a variety of operations and constituents used in construction activities. Best Management Practices (BMPs) would assure storm water runoff related to construction activities would be detained prior to release to the surrounding land surface. BMPs would also be used for dust control associated with excavation and fill operations during construction. Impact from storm water runoff generated during plant operations is not expected to differ substantially from impacts currently experienced at the site. The water quality of the discharge from the site storm water detention basin would be typical of runoff from building roofs and paved areas from any industrial facility.
Except for small amounts of oil and grease typically found in runoff from paved roadways and parking areas, the discharge is not expected to contain contaminants.
The CISF would be designed and constructed in manner that would minimize the quantity of radioactive wastes and contaminated equipment, and facilitate the removal of radioactive wastes and contaminated materials at the time the CISF is permanently decommissioned pursuant to 10 CFR 72.130, Criteria for decommissioning.
The environmental impacts to the affected areas would be attributable to radiation doses received by members of the public along the transportation routes. Over the next several years, the DOE is expected to commission new transportation systems desirable for transportation of SNF from existing commercial reactor sites, including the shutdown reactor sites, to a CISF or a permanent geologic repository. Other environmental impacts would be attributable to upgrades that would be required to the railroads, roads, or barge docks and channels leading from the former reactor sites to a CISF or a geologic repository. The connected environmental impacts potentially associated with the transportation of SNF and upgrades required to support the removal of SNF from the shutdown and decommissioned reactor sites are discussed in Section 4.2.
Several practices and procedures have been designed to minimize adverse impacts to the ecological resources of the proposed CISF. These practices and procedures include the use of BMPs, minimizing the construction footprint to the extent possible, avoiding all direct discharge
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-38 Revision 2 (including storm water) to any waters of the United States, the protection of all undisturbed naturalized areas, and site stabilization practices to reduce the potential for erosion and sedimentation. The use of native plant species to re-vegetate disturbed areas will enhance and maximize the opportunity for native wildlife habitat to be reestablished at the site.
The other location sites for a proposed CISF discussed in Chapter 2 would experience similar environmental costs and benefits as those described here. However, with regard to costs, the proposed green field sites themselves would experience greater environmental impacts when compared to the WCS CISF, where substantial infrastructure currently exists. This site infrastructure would support the additional proposed permitted use on part of the site controlled by Waste Control Specialists. Environmental costs from establishing a new CISF site on previously undeveloped land would potentially result in higher impacts to ecological and cultural resources when compared to the WCS CISF. Additionally, a greenfield site would potentially take longer to develop due to an extended environmental review, uncertainties in permitting and more extensive construction work. These potential delays in facility commissioning and operation could result in delays or reductions in the avoided federal government liability costs (at least in the near term) from removing spent nuclear fuel from shutdown sites.
7.6 ENVIRONMENTAL BENEFITS AND COSTS AT EVALUATED ALTERNATIVE SITES Environmental impacts of developing the WCS CISF site versus the alternative sites in Loving County, Lea County, or Eddy County were analyzed in Chapter 2 and summarized in Table 2.3-
- 3. With respect to environmental benefits and costs, there are both similarities and differences among the sites considered.
The full process of relocating SNF includes current storage sites and alternative CISF sites. For any CISF location selected, once the site is opened, key beneficiaries would include the decommissioned and other power plants that could begin to move their SNF to the CISF, which could potentially open up some land area to redevelopment.
The socioeconomic benefits that would occur at any of the alternative site locations would be similar in terms of direct, indirect, and induced economic benefits. Both the construction and operations phases of the CISF would bring economic benefits to the host community to the extent that some labor and materials could be sourced locally. The Andrews County CISF site already has some infrastructure and personnel on site, so the potential economic benefits to the other sites in Lea County, Loving County, and Eddy County could be slightly higher because
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-39 Revision 2 more infrastructure and more construction and specialty labor would be utilized for site mobilization. Construction and operational labor force considerations, along with community amenities, for all four sites were summarized in Table 2.3-2. Substantially fewer labor resources and community amenities would be available for the Loving County site, making the site more challenging to develop.
Another key component of the operational comparison was transportation routes. Andrews County was followed by Eddy County then Lea County when assessed for site railhead, access to highways, traffic capacity, and efficient access. Loving County had the least transportation infrastructure to support development of the CISF. Any new transportation infrastructure required to transport SNF from the source sites to a CISF would have additional environmental impacts or costs.
For areas where criteria differed from site to site, a brief summary is shown below. Each of the alternative sites received equal ratings with regard to no RAD contamination, not CERCLA or RCRA, no remediation needed, floodplains, ponding, environmental permits, facility discharges, and airports. All sites were considered equal in terms of air quality and ease of decommissioning. For a more in-depth discussion of these environmental considerations see Chapter 2.0. The discussion for each alternative site in Table 7.5-1 provides a brief, relative, and qualitative description of the potential for costs to be incurred for the site with respect to addressing the particular criterion. The score that each site received in Table 2.3-3 is included here and where a site received lower than a 10, the potential costs associated with addressing that issue are briefly described.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-40 Revision 2 Table 7.6-1 Screening Matrix Results: Environmental Selection Summary and Potential Environmental Costs Criterion Sub-Criteria Andrews County Loving County Lea County Eddy County Criterion 11 - Environmental Protection Existing Site Characterization Data - It is highly preferable that site characterization surveys are available for hydrology, meteorology (rain, wind, tornadoes, temperatures, etc.),
topography, archeology and protected species.
10 1 - substantial costs would be required to characterize site data 6 - some costs would be required to characterize site data 6 - some costs would be required to characterize site data Documentation - It is highly preferable that the site have existing, well-documented site surveys and monitoring studies for radiological, chemical, and hazardous material contamination, and that the site not be contaminated.
10 3 - substantial costs would be required to document absence of contamination at site 9 - limited costs would be required to document absence of contamination at site 5 - some costs would be required to document absence of contamination at site Neighboring Plume-Within the area that includes the site, it is highly preferable that no facility has existing release plumes (air or water) of hazardous material or radiation.
10 10 8 - some indication of existing release plumes; costs would be incurred to evaluate 10
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-41 Revision 2 Criterion Sub-Criteria Andrews County Loving County Lea County Eddy County Criterion 11 - Environmental Protection Future Migration The potential for future migration of contamination from adjoining or nearby sites should be negligible.
10 10 8 - some potential for migration of contamination; costs would be incurred to evaluate 10 Protected Species - The site should not be habitat for protected species (USFWS federally listed threatened or endangered species). Also, adjacent properties should have no areas designated as wildlife refuges, critical habitat, or vegetation such as rare plant species that would be adversely affected by the facility.
10 10 8 - some potential cost to assess wildlife and vegetation conditions 10 Archeological and Cultural Resources -
The site should have a low probability of containing archeological/cultural resources.
10 5 - some costs would be incurred to determine the potential for site to contain archeological/
cultural resources 5 - some costs would be incurred to determine the potential for site to contain archeological/
cultural resources 5 - some costs would be incurred to determine the potential for site to contain archeological/
cultural resources Environmental Justice - The site should have a low probability of disproportionate, adverse impacts to low-income or minority communities.
10 7 Limited costs would need to be invested to initiate EJ investigations.
7 Limited costs would need to be invested to initiate EJ investigations.
7 Limited costs would need to be invested to initiate EJ investigations.
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-42 Revision 2 Criterion Sub-Criteria Andrews County Loving County Lea County Eddy County Criterion 12 -
Discharge Routes Differentiation - For sites with extant nuclear facilities, facility discharges are readily identifiable from extant facility discharges.
9 - some costs potentially associated with addressing discharges 10 10 10 Criterion 13 - Proximity of Hazardous Operations/ High-Risk Facilities Hazardous Chemical Sites - ISP will consider the distance of the site from any facility storing, handling, or processing large quantities of hazardous chemicals.
8 - proximity to NEF uranium hexafluoride plant poses minimal risks 10 10 10 Gas Pipelines - ISP will consider the distance of the site from one or more large propane or natural gas pipelines.
10 10 8 - potential cost/risk associated with proximity to natural gas transmission pipeline 8 -potential cost/risk associated with proximity to WIPP Emergency Area - The site should be outside the general emergency area for any nearby hazardous operations facility (other than an extant nuclear-related facility).
8 -Some costs could be incurred addressing adjacency to NEF 10 10 10 Criterion 14 - Ease of Decommissioning Adjacent Site's Medium/Long-Term Plans - It is desirable that planned major construction and heavy industrial activities in adjacent sites within 1.6 km (1 mi) of the site boundary are minimal over the reasonably anticipated period of CISF decommissioning.
8 - some costs may be incurred associated with accommodating major construction projects within one mile of the site 10 10 10
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-43 Revision 2 Criterion Sub-Criteria Andrews County Loving County Lea County Eddy County Criterion 15 -
Disposal of LLRW Proximity to and Availability of Disposal Options - Site-specific issues (e.g.,
availability/access to nearby facilities for disposal of low-level waste, transportation modes, etc.) do not impede disposal of low-level waste.
10 8 - some costs could be incurred associated with preparing to handle LLRW 8 - some costs could be incurred associated with preparing to handle LLRW 8 - some costs could be incurred associated with preparing to handle LLRW
INTERIM STORAGE PARTNERS LLC CHAPTER 7 ENVIRONMENTAL REPORT Page 7-44 Revision 2 Figure 7.2-1: Comparison of Cumulative Federal Expenditures for Spent Fuel Storage Liabilities at Stranded Sites between the Proposed Action and the No Action Scenarios
$0.0
$1.0
$2.0
$3.0
$4.0
$5.0
$6.0
$7.0
$8.0
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$10.0 2018 2020 2022 2024 2026 2028 2030 2032 2034 2036 2038 2040 2042 2044 2046 2048 2050 2052 2054 2056 Billions Proposed Action No Action
INTERIM STORAGE PARTNERS LLC CHAPTER 8 ENVIRONMENTAL REPORT Page 8-1 Revision 2 CHAPTER 8
SUMMARY
OF ENVIRONMENTAL CONSEQUENCES
SUMMARY
OF ENVIRONMENTAL CONSEQUENCES 8.0 8.1 UNAVOIDABLE ADVERSE ENVIRONMENTAL IMPACTS Section 102(2)(C)(ii) of NEPA requires that an EIS include information about any adverse environmental effects that cannot be avoided if the proposal is implemented.
8.1.1 Geology, Minerals, and Soils Unavoidable soil erosion from both wind and water will occur during construction activities. Dust control and stormwater control measures, as well as revegetation of disturbed areas, will minimize soil erosion. With these mitigations, the resulting levels of soil erosion by wind and water should be similar to the levels that currently exist in Andrews County.
Disturbing the existing soil profile and using aggregate in construction are unavoidable adverse impacts of the proposed action. However, only a very small amount of soil is permanently lost in project construction, and aggregate materials could be recovered after decommissioning.
Economic mineral resources located beneath the CISF would be unavailable for exploitation during the life of the project. These impacts, however, would be small.
8.1.2 Water Resources Unavoidable impacts to surface water are not a concern since there are no surface waters near the facility; however, there may be increased stormwater runoff from the CISF due to the presence of impervious surfaces (e.g., buildings, asphalt, concrete, etc.). Such runoff would be directed to natural drainage networks and controlled under the appropriate permits.
No unavoidable adverse impacts on groundwater are expected as a result of construction or operation of the CISF because the groundwater beneath the facility is neither of the proper quality nor quantity to be used. Therefore of potable water may be brought in from the existing potable water system at ISP joint venture member Waste Control Specialists.
8.1.3 Air Quality Unavoidable impacts to air quality from construction and decommissioning of the CISF would be associated with earth moving activities that create airborne dust. Through the use of adequate
INTERIM STORAGE PARTNERS LLC CHAPTER 8 ENVIRONMENTAL REPORT Page 8-2 Revision 2 control measures, such as treating disturbed areas with dust suppressants, the potential impacts to air quality due to suspended particulate matter would be minimal.
8.1.4 Ecological Resources The CISF would eventually require the commitment of 130 ha (320 acres) for the life of the facility. The loss of wildlife habitat in these areas would be unavoidable. In areas lost for the life of the project, the existing vegetation, with the exception of invasive annuals, would not be restored unless revegetation is undertaken as part of decommissioning and closure of the CISF.
Currently, this land is sparsely vegetated and supports a low amount of wildlife. Small areas of animal habitat would be unavoidably lost in the disturbed areas during construction activities. It is likely that individual animals of less mobile species would be lost during construction.
The impacts to vegetation and wildlife are expected to be small, especially considering the other available land areas in west Texas and southeastern New Mexico that are comparable to the potentially affected area.
8.1.5 Socioeconomic and Community Resources Because of the size of the regional employment force and the relatively small number of workers to be employed on the proposed project, no adverse socioeconomic impacts are expected.
8.1.6 Cultural Resources Based on available data, construction, operation, and decommissioning of the CISF would have no adverse impacts on historic properties. In the unlikely event that buried cultural resource sites or artifacts are encountered during construction activities, the significance and potential for adverse impacts would be evaluated at that time.
8.1.7 Human Health Impacts The impacts of radiation from the casks during transport and storage at the CISF cannot be avoided. However, the radiation doses that would occur as a result of the proposed action are well below NRC regulatory limits specified in 10 CFR 20 and represent a small fraction of the existing background levels of radiation. Thus, the radiological health risk is considered to be small.
INTERIM STORAGE PARTNERS LLC CHAPTER 8 ENVIRONMENTAL REPORT Page 8-3 Revision 2 8.2 OTHER IMPACTS 8.2.1 Noise Increased noise will accompany construction, operation, and decommissioning of the proposed CISF; however, the anticipated noise levels will not create adverse impacts.
8.2.2 Scenic Qualities Because the proposed CISF will be located next to the current Waste Control Specialists facility and URENCO, the impacts to scenic qualities would be minimal.
8.2.3 Recreation There are no recreational facilities near the site other than a small picnic area along Texas State Highway 176 that is not visible from the CISF. There would be no adverse impacts to recreational activities in the vicinity of the CISF.
8.3 GENERIC ENVIRONMENTAL IMPACT STATEMENT The NRC completed a Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel (NUREG-2157) that addressed, among other things, the unavoidable adverse environmental impacts attributable to continued storage of SNF (NRC, 2014a). ISP is proposing an operational time period of 40 years. However, the environmental impacts analyzed in NUREG-2157 include those related to short-term (60 years), long-term (an additional 100 years), and indefinite storage of SNF at existing commercial nuclear power plants, as well as at an away-from-reactor storage facility. The NRC has concluded that the most likely outcome is that a repository will become available to accept SNF within the short-term timeframe, or about 60 years after the end of the reactors licensed life for operation.
For an away-from-reactor storage facility such as the CISF, the NRC concluded in its GEIS that the unavoidable adverse environmental impacts for each resource area were small except for air quality, terrestrial ecology, aesthetics, waste management, and transportation; the impacts to these resources could range from small to moderate. Socioeconomic impacts would range from small to beneficial and large. Historic and cultural impacts could be small, moderate, or large, depending on a variety of local conditions. The potential moderate impacts to air quality, terrestrial wildlife, and transportation were based on construction-related potential fugitive dust emissions, terrestrial wildlife direct and indirect mortalities, and temporary construction traffic impacts. The potential moderate impacts to aesthetics and waste
INTERIM STORAGE PARTNERS LLC CHAPTER 8 ENVIRONMENTAL REPORT Page 8-4 Revision 2 management were based on noticeable changes to the viewshed from constructing a new ISFSI. The volume of nonhazardous solid waste generated by assumed ISFSI and dry transfer system replacement activities would be minimal. Potential large positive impacts to socioeconomics would be due to local economic tax revenue increases from the CISF. The GEIS potential large impacts to historic and cultural and special status species apply to assumed site-specific circumstances at an away-from-reactor ISFSI involving the presence of these resources during construction activities and the absence of effective protection measures.
Specifically, these potential historic and cultural impacts vary depending on whether resources are present, the extent of proposed land disturbance, and whether the licensee has management plans and procedures in place that are protective of historic and cultural resources. For the WCS CISF, the land disturbance area is relatively small and the impact on threatened or endangered species is very small. ISP joint venture member Waste Control Specialists has implemented management plans to be protective of the ecology.
In developing NUREG-2157, NRC referred to the previous environmental analyses that supported issuance of the FEIS for the PFS facility in Toole, Utah. In that FEIS, the NRC concluded that issuance of a license to PFS authorizing construction and operation of an ISFSI in Toole County, Utah, would not result in significant impacts adverse to the environment.
Overall, the unavoidable adverse environmental impacts of the CISF are very small, except for the socioeconomic impact, which has been determined to be moderate to large and beneficial rather than adverse.
No cultural resources impacts are anticipated based on the work done for the site. Aesthetic impacts would be low because the facility would not be built in an undeveloped area, but would be screened by existing buildings at the current plant site. Although some wildlife could be impacted, there are no impacts to threatened or endangered species are anticipated. In addition, measures have been put in place in the management plan to prevent adverse impacts.
One area where it seems clear that impacts would occur would be land use, geology, and soils within the physical footprint of the CISF since it is currently undeveloped. For those impacts, mitigation would not be necessary.
8.3.1 Irreversible and Irretrievable Commitments of Resources Section 102(2)(C)(v) of NEPA requires that an EIS include information about irreversible and irretrievable commitments of resources that would occur if the proposed actions were implemented. The NRC guidance in NUREG1748, Environmental Review Guidance for
INTERIM STORAGE PARTNERS LLC CHAPTER 8 ENVIRONMENTAL REPORT Page 8-5 Revision 2 Licensing Actions Associated with NMSS Programs, defines an irreversible commitment as the commitment of environmental resources that cannot be restored (NRC, 2003). In addition, an irretrievable commitment refers to the commitment of material resources that once used cannot be recycled or restored for other uses by practical means.
For an away-from-reactor ISFSI, the NRC concluded in its GEIS that there would be no irreversible and irretrievable commitments of resources during continued storage for most resources. However, impacts on land use, aesthetics, historic and cultural resources, waste management, and transportation would result in irreversible and irretrievable commitments. As finite resources, the loss of historic and cultural resources would constitute irreversible and irretrievable impacts. For the indefinite storage timeframe, land and visual resources allocated for SNF storage would be committed in perpetuity as continued operations would preempt other productive land uses and permanently affect the viewshed. Waste-management activities involving waste treatment, storage, and disposal would result in the irreversible commitment of capacity for waste disposal. Transportation activities would involve the irreversible and irretrievable commitment of resources, including vehicle fuel for commuting workers and shipping activities.
Certain activities associated with the proposed CISF, especially those involving construction of ISFSI facilities and the operation of heavy equipment would result in the irreversible commitment of certain fuels, energy, building materials, capacity for waste disposal, and process materials. Because an ISFSI would be in operation for as long as 60 years under the license renewal scenario, land commitments for the ISFSI could be protracted, but not irreversible or irretrievable assuming the facility is closed, decommissioned, and dismantled at the end of its life.
8.4 SHORT-TERM AND LONG-TERM IMPACTS The proposed initial operating period for the CISF is 40 years with a possible license extension of 20 years for an extended operating period of 60 years. Assuming the facility is closed and decommissioned at the end of the 60-year license period, the impacts from the facility would be short-term (i.e., no more than 60 years). Impacts during the short term would be limited to small impacts on land use and air quality related to dust and fossil fuel emissions. Long-term impacts could result if the CISF lifetime were extended indefinitely or if the facility were not decommissioned at the end of its life as is planned.
INTERIM STORAGE PARTNERS LLC CHAPTER 8 ENVIRONMENTAL REPORT Page 8-6 Revision 2 8.5 SHORT-TERM USES OF THE ENVIRONMENT AND THE MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY Section 102(2)(C)(iv) of NEPA requires that an EIS include information about the relationship between local short-term uses of the environment and the maintenance and enhancement of long-term productivity. The NRC guidance in NUREG1748 (NRC, 2003) further clarifies that the short-term use period represents the period of the action under review and the long-term productivity period represents the period extending beyond the end of the action under review.
The proposed CISF would occupy land that is presently undeveloped rangeland. A limited amount of grazing currently occurs on this land. This land does not have any other current agricultural or productive uses. The use of this land for the proposed project would reduce the amount of such land available, but the reduction would not be a significant amount. The proposed project would replace this land with an industrial development which has its own infrastructure. The addition of such infrastructure to the area would increase the productivity and usefulness of the land far above its current use and could potentially increase the opportunities for further economic development in the area.
In the Waste Confidence GEIS, NRC examined the relationship of short-term uses and long-term productivity and concluded that the maximum impact on long-term productivity of the land occupied by an ISFSI would result if the CISF is not dismantled after the short-term storage period ends (NRC, 2013). Under the indefinite storage scenario, therefore, the loss of productivity in the location would be indefinite and other productive uses of the site would be foregone. Long-term productivity of those lands needed for waste disposal would also be impacted.
Once storage ends and the decommissioning is complete, the NRC license may be terminated and the site would be available for other uses. Other potential long-term impacts on productivity include the commitment of land and consumption of disposal capacity necessary to meet waste disposal needs. This commitment of land for disposal would remove land from other productive use. A small contribution to greenhouse gas emissions would add to the atmospheric burden of emissions that could contribute to potential long-term impacts. Impacts to long-term productivity can be eliminated under the short-term storage scenario once the ISFSI operations cease and the associated facilities are decommissioned.
Though greenhouse gas emissions of the CISF proposal would be very small, those emissions could contribute to long-term impacts associated with climate change (NRC, 2013).
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INTERIM STORAGE PARTNERS LLC CHAPTER 10 ENVIRONMENTAL REPORT Page 10-1 Revision 2 CHAPTER 10 LIST OF PREPARERS LIST OF PREPARERS 10.0 The organizations and individuals listed below are the principal contributors to the preparation of this ER.
10.1 WASTE CONTROL SPECIALISTS LLC J. Scott Kirk, CHP Vice President of Licensing & Regulatory Affairs Renee Murdock, MBA Regulatory Compliance Analyst Miranda Vesely Regulatory Compliance Analyst Roy King Manager of Facility Compliance Annette Haynes Senior Project Manager Ben Mason, P.E.
Director of Engineering Jenny Caldwell, P.G.
Geologist Jay Cartwright Director of Health and Radiation Safety and Radiation Safety Officer Travis Matthews Health Physicist Sheila Parker Director of Environmental John Hultman Geologist Richard Wyckoff Environmental Manager
INTERIM STORAGE PARTNERS LLC CHAPTER 10 ENVIRONMENTAL REPORT Page 10-2 Revision 2 10.2 JACOBI CONSULTING L. Richard Jacobi, P.E., J.D Consultant 10.3 EASTON CONSULTING Earl Easton Transportation Consultant 10.4 TN AMERICAS Michael McMahon Vice President Jack Boshoven Senior Project Engineer 10.5 NAC INTERNATIONAL INC.
Jeff Dargis Project Manager 10.6 RISK ASSESSMENT CORPORATION John Till, Ph.D.
President Helen Grogan, Ph.D.
Senior Technical Director Kathleen Meyer, Ph.D.
Environmental Science Specialist Justin Mohler, MS Data Program Manager Art Rood, MS Data Analyst and Environmental Manager James Rocco GIS Specialist 10.7 COXlMCLAIN ENVIRONMENTAL CONSULTING, INC.
Michael Bomba, Ph.D.
Senior Economist
INTERIM STORAGE PARTNERS LLC CHAPTER 10 ENVIRONMENTAL REPORT Page 10-3 Revision 2 Bob Bryant Word Processor/Editor Chris Dayton, Ph.D., RPA Senior Archeologist Sara Laurence GIS Analyst Tom Ludwig, MLA Environmental Scientist Jesus Mares Environmental Scientist L. Ashley McLain, AICP Senior Planner, Socioeconomics Task Manager Emily F. Reed Historian Haley Rush, MA, RPA Project Archeologist/Lab Director Steven Schooler, MA Archeologist Heather Stettler, Ph.D., RPA Technical Editor David M. Young Senior Project Manager Courtney H. Filer, AICP Senior Planner 10.8 BOSTON GOVERNMENT SERVICES Ruth Weiner, Ph.D.
Transportation Consultant 10.9 AECOM Ivan Wong Principal Seismologist/Vice-President Patricia Thomas, Ph.D.
Senior Earthquake Engineer
INTERIM STORAGE PARTNERS LLC CHAPTER 10 ENVIRONMENTAL REPORT Page 10-4 Revision 2 Mark Dober Project Seismologist Melanie Walling, Ph.D.
Senior Earthquake Engineer Jacqueline Bott Senior Seismologist Eliza Nemser, Ph.D.
Senior Seismic Geologist Melinda Lee Project Administrator Katrina Anderson Nuclear Quality Assurance Manager 10.10 PACIFIC ENGINEERING & ANALYSIS Walter Silva, Ph.D.
Principal Seismologist Bob Darragh, Ph.D.
Senior Seismologist 10.11 UNIVERSITY OF TEXAS Kenneth H. Stokoe, Ph.D.
Department of Civil Engineering 10.12 COOK JOYCE INC.
Cathy McGee, P.E.
President 10.13 INTERIM STORAGE PARTNERS Jack Boshoven Chief Engineer CISF Licensing and Engineering