Text

Subsequent License Renewal Application Environmental Review Supplemental Environmental Audit December 2, 2024 L-2024-182 10 CFR 54 Response to Requests for Confirmation of Information and Requests for Additional Information
	ML24337A109
Person / Time
Site:	Point Beach
Issue date:	12/02/2024
From:	Mack K; Point Beach
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	L-2024-182
	Download: ML24337A109 (1)
	v • d • e

NEXTeraM ENERGY~

~

Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE:

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 Renewed Facility Operating Licenses DPR-24 and DPR-27 Subsequent License Renewal Application Environmental Review Supplemental Environmental Audit December 2, 2024 L-2024-182 10 CFR 54 Response to Requests for Confirmation of Information and Requests for Additional Information

References:

1. NextEra Energy Point Beach, LLC (NextEra) Letter NRC 2020-0032 dated November 16, 2020, Application for Subsequent Renewed Facility Operating Licenses (ADAMS Package Accession No. ML20329A293)

2. NEPB Enclosure 3 Attachment 2 Appendix E, Environmental Report, Subsequent Operating License Renewal Point Beach Nuclear Plant Units 1 and 2 (ADAMS Package Accession No. ML20329A248)

3. NRC Letter dated October 31, 2024, Point Beach Nuclear Plant, Units 1 and 2 -

Summary of the 2024 Supplemental Environmental Audit Related to the Review of the Subsequent License Renewal Application (EPID Number: L-2020-SLE-0002) (Docket Numbers: 50-266 and 50-301) (ADAMS Package Accession No. ML24295A114)

4. Enclosure 2 to NRC Letter dated October 31, 2024, Point Beach Nuclear Plant, Units 1 and 2, Subsequent License Renewal Application Environmental Review, Supplemental Environmental Audit, Requests for Confirmation of Information and Requests for Additional Information (ADAMS Package Accession No. ML24295A118)

In Reference 1, NextEra submitted a subsequent license renewal (SLR) application for the Facility Operating Licenses for Point Beach Nuclear Plant (PBN) Units 1 and 2, which included Reference 2.

Reference 3 summarized the 2024 supplemental environmental audit and provided Reference 4, which requested NextEra responses within 30 days of the receipt of the NRC letter.

NextEra Energy Point Beach, LLC 6610 Nuclear Road, Two Rivers, WI 54241

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 The attachments to this letter provide responses to Reference 4 requests.

L-2024-182 Page 2 of 2 For ease of reference, the index of attached and enclosed information is provided on pages 3 and 4 of this letter.

Should you have any questions regarding this submission, please contact Ms. Maribel Valdez, Fleet Licensing Manager, at 561-904-5164.

I declare under penalty of perjury that the foregoing is true and correct.

l)hd Executed on the 1::::::..._ day of December 2024.

Sincerely, K~

Director, Licensing and Regulatory Compliance cc:

USNRC Regional Administrator, Region Ill Environmental Project Manager, Point Beach Nuclear Plant SLR USNRC Project Manager, USNRC, Point Beach Nuclear Plant Resident Inspector, USNRC, Point Beach Nuclear Plant Public Service Commission of Wisconsin

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 L-2024-182 Attachments Index Attachment No.

RCI Subject RAI Requests for Confirmation (RCls) 1 RCI ALT-1 2

RCI AQN-2 3

RCI NOl-1 4

RCI NOl-2 5

RCI NOl-3 6

RCI SW-1 7

RCI SW-2 8

RCI GW-1 9

RCI TER-1 10 RCI HCR-1 11 RCI SOC-1 12 RCI HH-1 13 RCI HH-2 14 RCI HH-3 15 RCI WM-1 16 RCI WM-2 17 RCI WM-3 18 RCI WM-4 19 RCI SNF-1 20 RCI GHG-CC-1 21 RCI GHG-CC-2 22 RCI Cl-1 23 RCI SAMA-1 Requests for Additional Information (RAls) 24 RAI GEN-1 25 RAI GEN-2 26 RAI LV-1 27 RAI FPE-1 28 RAI GHG-CC-3

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 L-2024-182 Enclosure Index Attachment Enclosure Subject No.

Number 25 1

Point Beach Nuclear Plant Units 1 and 2, SLRA Appendix E, Environmental Report Additional Information. Revision 1.

November 2024.

26 1

WDOA. 2021. Letter from Kate Angel, WCMP, to Richard Orthen,

Subject:

Wisconsin Coastal Management Program: Point Beach Consultation. March 2021.

28 1

PBN Average Monthly Intake Temperatures 2002-2024.

28 2

PBN Average Monthly Seasonal Intake Temperatures 2002-2024.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RCI No. RCI ALT-1 L-2024-182 Attachment 1 Page 1 of 1 Replacement Power Alternatives (ALT)

NRC RCI Number: AL T-1 As discussed during the virtual tour, confirm that (1) there have been no significant changes in the location of the Point Beach Solar installations since 2021, (2) Two Creek Solar became operational in November 2020, and (3) Point Beach Solar became operational in September 2021.

NEPB Response:

NEPB confirms.

References:

None.

Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RCI No. AQN-2 L-2024-182 Attachment 2 Page 1 of 1 Air Quality (AQN)

NRC RCI Number: AQN-2 Confirm that on February 7, 2024, the Wisconsin Department of Natural Resources (WDNR) identified a deviation with respect to Point Beach's air pollution control permit that involved the use of an ASTM standard for the determination of sulfur content not listed in Point Beach's permit 436034500-P40 and that the deviation was resolved by implementing the use of one of the ASTM standards defined in the most recent air permit ( 436034500-P40) dated 04/12/2023.

Additionally, confirm that NEPB has not received any notices of violation or non-compliances associated with Point Beach's air permit since 2022.

NEPB Response:

NEPB confirms.

References:

None.

Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RCI No. NOl-1 L-2024-182 Attachment 3 Page 1 of 1 Noise (NOi)

NRC RCI Number: NOl-1 Confirm that there have been no noise complaints regarding Point Beach operations since 2021.

NEPB Response:

NEPB confirms.

References:

None.

Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RCI No. NOl-2 L-2024-182 Attachment 4 Page 1 of 1 Noise (NOi)

NRC RCI Number: NOl-2 Confirm that there have been no changes in primary noise sources at Point Beach from those identified in the Point Beach 2021 draft SEIS.

NEPB Response:

NEPB confirms.

References:

None.

Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RC! No. NOl-3 L-2024-182 Attachment 5 Page 1 of 1 Noise (NOi)

NRC RCI Number: NOl-3 Confirm that there have been no changes to primary offsite noise sources in the vicinity of Point Beach from those identified in the Point Beach 2021 draft SEIS.

NEPB Response:

NEPB confirms.

References:

None.

Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RCI No. SW-1 L-2024-182 Attachment 6 Page 1 of 1 Water Resources - Surface Water (SW)

NRC RCI Number: SW-1 Confirm that the listed monthly surface water withdrawals for Point Beach (for the period January-July 2024) are accurate as reported:

Month January 2024 February 2024 March 2024 April 2024 May 2024 June 2024 July 2024 NEPB Response:

NEPB confirms.

References:

None.

Associated

Enclosures:

None.

Volume (Million gallons per month) 21,603 20,210 31 I 170 33,132 34,236 33,132 34,236

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RCI No. SW-2 L-2024-182 Attachment 7 Page 1 of 1 Water Resources - Surface Water (SW)

NRC RCI Number: SW-2 As contained within the response to audit need GEN-2 and based on review of information during the audit, confirm the following regarding Wisconsin Pollutant Discharge Elimination System (WPDES) exceedances over the last 5 years: there were documented exceedances for total suspended solids in December 2020, January 2021 and January 2022 associated with turbidity in Lake Michigan; and one exceedance for biochemical oxygen demand in March 2023.

All exceedances were associated with the sewage treatment plant. These exceedances were reported to WDNR and documented in discharge monitoring reports. NEPB has not received any notices of violation associated with Point Beach's WP DES permit over the last 5 years.

NEPB Response:

NEPB provides the following corrections and clarifications regarding the WPDES permit exceedance events.

There were documented exceedances for total suspended solids (TSS) in wastewater effluent in December 2020 and January 2021 associated with seasonal changes in Lake Michigan (intake water); one exceedance for TSS in sewage treatment plant effluent in January 2022; and one exceedance for biochemical oxygen demand in the sewage treatment plant in March 2023.

NEPB confirms these exceedances were reported to WDNR and documented in discharge monitoring reports. NEPB confirms it has not received any notices of violation associated with Point Beach's WP DES permit over the last 5 years.

References:

None.

Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RCI No. GW-1 L-2024-182 Attachment 8 Page 1 of 1 Water Resources - Groundwater Resources (GW)

NRC RCI Number: GW-1 Confirm that the listed monthly groundwater withdrawals for Point Beach (for the period January-July 2024) are accurate as reported:

Total EiC Well Main SBCC Warehouse Warehouse Total (average Month (gallons)

Well Well 6 well 7 well (gallons) gallons (gallons)

(gallons)

(gallons) per minute)

January 1,161 596,825 4,180 1,600 2,100 605,866 13.57 2024 February 1,632 372,200 4,539 1,500 2,100 381,971 9.15 2024 March 1,813 373,500 3,698 1,400 2,200 382,611 8.57 2024 April 2,750 345,300 3,588 1,600 2,100 355,338 8.23 2024 May 926 305,400 2,878 1,500 1,300 312,004 6.99 2024 June 1,577 411,300 3,284 1,400 400 417,961 9.68 2024 July 1,740 409,799 3,097 1,300 700 416,636 9.33 2024 NEPB Response:

NEPB confirms.

References:

None.

Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RCI No. TER-1 L-2024-182 Attachment 9 Page 1 of 1 Terrestrial Resources (TER)

NRC RCI Number: TER-1 Confirm the statement that NEPB is not aware of any wildlife or avian incidents, mortalities, injuries, nest relocations, or similar incidents that have occurred at Point Beach for the period 2019-2023 and that there have been no new wildlife or avian incidents since 2023.

NEPB Response:

NEPB confirms.

References:

None.

Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RCI No. HCR-1 L-2024-182 Attachment 10 Page 1 of 1 Historic and Cultural Resources (HCR)

NRC RCI Number: HCR-1 As discussed during the audit, confirm the following statements. NextEra Energy, lnc./NEPB retained Commonwealth Heritage Group, Inc. (Commonwealth) to conduct a National Register of Historic Places (NRHP) eligibility determination for Point Beach. Commonwealth determined that Point Beach does not meet the criteria for listing on the NRHP. This determination of NRHP eligibility has not been reviewed by the Wisconsin State Historic Preservation Office. In addition, NEPB has not conducted Historic American Building Survey and Historic American Engineering Record eligibility determinations for Point Beach.

NEPB Response:

NEPB confirms.

References:

None.

Associated

Enclosures:

None.

oint Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RCI No. SOC-1 L-2024-182 Attachment 11 Page 1 of 1 Socioeconomics (SOC)

NRC RCI Number: SOC-1 From information gathered during the audit (information need SOC-1 ), confirm that the following information for annual gross-receipts license fees (payable to the State of Wisconsin) on behalf of Point Beach for 2019-2023 are accurate:

Year 2019 2020 2021 2022 2023 NEPB Response:

NEPB confirms.

References:

None.

Payment($)

8,027,489 8,449,153 8,883,078 9,176,051 9,703,433 Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RCI No. HH-1 L-2024-182 Attachment 12 Page 1 of 1 Human Health (HH)

NRC RCI Number: HH-1 As discussed during the audit with respect to apparent changes in occupational exposure, confirm the following statement. The approximately 14 percent difference in occupational exposure occurred during 2019-2021 (presented in NUREG-0713, Vol 43) as compared to 2018-2020 (presented in NUREG-0713, Vol 42) for the following reasons: (1) there was an outage with additional Steam Generator and RTD work that was not performed during 2018-2020, and (2) a dry fuel campaign was performed in 2021 and was not performed during 2018-2020.

NEPB Response:

NEPB confirms.

References:

None.

Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RCI No. HH-2 L-2024-182 Attachment 13 Page 1 of 1 Human Health (HH)

NRC RCI Number: HH-2 Confirm the statement that NEPB plans no changes or future updates to Point Beach's safety program with respect to occupational and electrical safety.

NEPB Response:

NEPB confirms.

References:

None.

Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RCI No. HH-3 L-2024-182 Attachment 14 Page 1 of 1 Human Health (HH)

NRC RCI Number: HH-3 As discussed during the audit with respect to Point Beach's electrical safety program, confirm the following statements. NEPB's Electrical Safety Procedure does not reference or point to NESC (National Electrical Safety Code). However, the procedure points to Occupational Safety and Health Administration regulations.

NEPB Response:

NEPB confirms.

References:

None.

Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RCI No. WM-1 L-2024-182 Attachment 15 Page 1 of 1 Waste Management (WM)

NRC RCI Number: WM-1 Confirm that the following statements are accurate. NEPB has documented two inadvertent radioactive liquid or gaseous releases since 2020. One abnormal liquid release occurred in 2021 when a Unit 1 hotwell containing tritium was discharged directly to circulating water on 8/2/2021, and an abnormal gaseous release occurred in July 2023. There have not been any other reportable unplanned releases of radioactive materials that would trigger a notification requirement from 2019-2023 and since the 2023 effluent report was written.

NEPB Response:

As stated in the RC!, the two inadvertent radioactive releases since 2020 were documented.

The 2021 release is documented in PBN's Annual Monitoring Report 2021 (ADAMS Accession No. ML22104A074) and the 2023 release is documented in PBN's Annual Monitoring Report 2023 (ADAMS Accession No. ML24117A243). NEPB confirms there have not been any other reportable unplanned releases of radioactive materials that would trigger a notification requirement from 2019 through the audit session on September 17, 2024.

References:

None.

Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRG RGI No. WM-2 L-2024-182 Attachment 16 Page 1 of 1 Waste Management (WM)

NRC RCI Number: WM-2 Confirm that the following statements are accurate. NEPB has documented two reportable inadvertent nonradioactive releases since 2020. A reportable spill occurred in January 2021 when approximately eight gallons of diesel fuel was released due to a hose failure on a pickup truck. Information reviewed during the audit indicates that there have been no additional inadvertent nonradioactive releases that impacted soil or groundwater at Point Beach in 2020 through October 2023, and that no groundwater remediation activities for nonradioactive environmental concerns have been conducted since 2015 or are ongoing. No other reportable spills have occurred since October 2023.

NEPB Response:

NEPB confirms that this statement is correct as of the audit session on September 17, 2024.

References:

None.

Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RCI No. WM-3 L-2024-182 Attachment 17 Page 1 of 1 Waste Management (WM)

NRC RCI Number: WM-3 Confirm that the following statements are accurate. Between 2015 and 2021, there have been no reportable oil spills, within the scope of the reporting provision of 40 CFR 110 as it relates to the discharge of oil in such quantities as may be harmful pursuant to Section 311 (b )( 4) of the Federal Water Pollution Control Act. There have not been any reportable discharges that would trigger this notification requirement since 2021.

NEPB Response:

NEPB confirms that this statement is correct as of the audit session on September 17, 2024.

References:

None.

Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RCI No. WM-4 L-2024-182 Attachment 18 Page 1 of 1 Waste Management (WM)

NRC RCI Number: WM-4 Confirm that the following statements are accurate. Between 2015 and June 2021, there have been no reportable releases of a regulated substance from an underground storage tank containing a hazardous substance at Point Beach, within the scope of the reporting provisions of Wisconsin Administrative Code NR 706.11. There have not been any reportable releases at Point Beach that have triggered this notification requirement since June 2021.

NEPB Response:

NEPB confirms that this statement is correct as of the audit session on September 17, 2024.

References:

None.

Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RCI No. SNF-1 L-2024-182 Attachment 19 Page 1 of 1 Spent Nuclear Fuel (SNF)

NRC RCI Number: SNF-1 Section 3.1.4 of NEPB's 2020 Environmental Report (ML20329A248) states that, "If ISFSI

[independent spent fuel storage installation] expansion were needed, PBN expects that the expansion would occur generally west of the existing facility within the ISFSl-defined area and would cause no significant environmental impact." As documented in Section 2.1.4.4 of the 2021 draft SEIS, expansion would occur in the "ISFSl-defined area and... would cause no significant environmental impact.... " Based on statements made by NEPB staff during the audit, Point Beach has available space within the ISFSl-defined area should an expansion be needed during the SLR term. Please confirm that if expansion of the ISFSI pad is needed, there is previously disturbed land available to accommodate such expansion and no significant environmental impact would be anticipated.

NEPB Response:

NEPB confirms.

References:

None.

Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RCI No. GHG-CC-1 L-2024-182 Attachment 20 Page 1 of 1 Greenhouse Gas Emissions and Climate Change (GHG-CC)

NRC RCI Number: GHG-CC-1 With respect to the use of sulfur hexafluoride (SFs) at Point Bach, confirm the following:

SFs is used in circuit breakers, circuit switchers, and in condenser tube leak detection.

The total inventory of SFs in circuit breakers and switchers is 392. 7 kilograms and there is no requirement to record the weight or loss of SFs to reflect leakage and therefore annual greenhouse gas (GHG) emissions from circuit breaker and switches are not available.

Circuit breakers and switches are inspected in accordance with site routine maintenance procedures.

Water box condenser tube leak detection is performed in accordance with site procedures, has been performed in the past several years, and GHG emissions for 2023, 2022, and 2021, are 90 metric tons (MT) of carbon dioxide equivalents (C02eq),

50 MT of C02eq, and 127 MT of C02eq.

NEPB Response:

NEPB confirms with the following clarification. In addition to circuit breakers, circuit switchers, and condenser tube leak detection, SFs is also used in spare ABB poles.

References:

None.

Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RCI No. GHG-CC-2 L-2024-182 Attachment 21 Page 1 of 1 Greenhouse Gas Emissions and Climate Change (GHG-CC)

NRC RCI Number: GHG-CC-2 Confirm that Point Beach does not generate sufficient GHGs to trigger reporting by the State of Wisconsin, no requirement exists to report fugitive emissions from ozone depleting substances used in refrigeration appliances at Point Beach, and therefore NEPB does not track annual refrigerant fugitive emissions.

NEPB Response:

NEPB confirms.

References:

None.

Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RCI No. Cl-1 L-2024-182 Attachment 22 Page 1 of 1 Cumulative Effects (Cl)

NRC RCI Number: Cl-1 Confirm the statements from information reviewed during the audit that (1) NEPB is not aware of any projects or actions, either onsite or in the vicinity of the plant, that should be considered in the cumulative effects analysis, and (2) no SLR-related refurbishment activities or replacement actions for Point Beach have been identified.

NEPB Response:

NEPB confirms.

References:

None.

Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RCI No. SAMA-1 L-2024-182 Attachment 23 Page 1 of 1 Postulated Accidents/SAMA (SAMA)

NRC RCI Number: SAMA-1 As contained within the response to audit need SAMA-1 and as discussed during the audit, confirm that the following information is accurate with respect to NEPB's consideration of new and significant information for severe accidents:

PBN Internal Events includinQ Flood PBN Fire Core Damage Frequency (CDF)

PBN Seismic CDF NEPB Response:

NEPB confirms.

References:

None.

Associated

Enclosures:

None.

Unit 1 2023 Update Unit 2 2023 Update 1.9E-06 2.0E-06 6.4E-5 8.2E-5 6.2E-06 6.2E-06

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RAI No. GEN-1 L-2024-182 Attachment 24 Page 1 of 1 General (GEN)

NRC RAI Number: GEN-1 REQUIREMENT: Title 10 of the Code of Federal Regulations (10 CFR) Part 51.45(d) requires that environmental reports list all Federal permits, licenses, approvals and other entitlements which must be obtained in connection with the proposed action and describe the status of compliance with these requirements. The U.S. Nuclear Regulatory Commission's (NRC's) regulations in 10 CFR 51.71 (d), "Draft environmental impact statement-contents," require that, in part, the staff consider in its analysis compliance with environmental quality standards and requirements that have been imposed by Federal, State, regional, and local agencies having responsibility for environmental protection.

ISSUE: The staff must consider any changes in the status of compliance with respect to Point Beach operations as documented in Appendix B, Table B-2 in the draft supplemental environmental impact statement (SEIS) (NUREG-1437, Supplement 23; ML21306A226) and as previously included in Table 9.1 -1 of NextEra Energy Point Beach, LLC (NEPB's) 2020 Environmental Report for subsequent license renewal (SLR) (Agencywide Documents Access and Management System [ADAMS] ML20329A248). During the audit, NRC staff reviewed an update to the status of compliance information for Point Beach.

REQUEST: Provide the updated Table 9.1-1, "Environmental Authorizations for Current PBN Operations" for docketing. In addition, for all permits/authorizations slated to expire within the next 12 months, briefly summarize plans for renewing them, as applicable.

NEPB Response:

The requested information is provided in the response to RAI GEN-2. NEPB will follow applicable federal, state and local permit renewal requirements and timelines.

References:

None.

Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RAI No. GEN-2 L-2024-182 Attachment 25 Page 1 of 1 General (GEN)

NRC RAI Number: GEN-2 REQUIREMENT: 10 CFR 51.53©(iv) requires that environmental reports contain any new and significant information regarding the environmental impacts of license renewal of which the applicant is aware. Further, 10 CFR 51.41 requires that applicants submit information that may be useful in aiding the Commission in complying with section 102(2) of NEPA.

ISSUE: From the information gathered and discussed during the environmental audit, NEPB has prepared supplemental additional information to NEPB's November 2020 Environmental Report (ML20329A248) that, in part, evaluates new information and provides an assessment of applicable new/modified Category 2 issues resulting from NRC's issuance of NUREG-1437, Revision 2. As part of the NRC staff's preparation of its supplement to the 2021 draft SEIS, the NRC staff must consider and independently evaluate such information.

REQUEST: Provide the report, "Environmental Report Additional Information" (59 pages, dated August 2024, or as revised) for docketing.

NEPB Response:

The Point Beach Nuclear Plant Units 1 and 2, SLRA Appendix E, Environmental Report Additional Information report, Revision 1, dated November 2024, is provided in Enclosure 1.

References:

None.

Associated

Enclosures:

1. Point Beach Nuclear Plant Units 1 and 2, SLRA Appendix E, Environmental Report Additional Information. Revision 1. November 2024.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 L-2024-182 Attachment 25 Page 1 of 59 November 2024 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E Environmental Report Additional Information Revision 1

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 2 of 59 Table of Contents L-2024-182 Attachment 25 Page 2 of 59 Table of Contents........................................................................................................................ 2 List of Tables............................................................................................................................... 3 Abbreviations, Acronyms, and Symbols.......................................................................................4 1.0 Introduction........................................................................................................................ 6 2.0 Proposed Action Changes................................................................................................. 6 3.0 Updated Environmental Authorizations.............................................................................. ?

4.0 Category 1 Evaluation..................................................................................................... 12 5.0 Category 2 Evaluation..................................................................................................... 12 5.1 Groundwater Resources - Radionuclides Released to Groundwater........................... 15 5.2 Terrestrial Resources - Non-Cooling System Impacts on Terrestrial Resources......... 18 5.3 Aquatic Resources - Impingement Mortality and Entrainment of Aquatic Organisms (Plants with Once-Through Cooling Systems or Cooling Ponds)................................. 21 5.4 Aquatic Resources - Effects of Thermal Effluents on Aquatic Organisms (Plants with Once-Through Cooling Systems or Cooling Ponds).................................................... 23 5.5 Federally Protected Ecological Resources - Endangered Species Act: Federally Listed Species and Critical Habitats Under U.S. Fish and Wildlife Service Jurisdiction......... 25 5.6 Federally Protected Ecological Resources - Endangered Species Act: Federally Listed Species and Critical Habitats Under National Marine Fisheries Service Jurisdiction... 28 5.7 Federally Protected Ecological Resources - Magnuson-Stevens Act: Essential Fish Habitat......................................................................................................................... 30 5.8 Federally Protected Ecological Resources - National Marine Sanctuaries Act:

Sanctuary Resources.................................................................................................. 32 5.9 Historic and Cultural Resources.................................................................................. 34 5.10 Human Health - Microbiological Hazards to the Public................................................ 37 5.11 Human Health - Electric Shock Hazards......................................................................40 5.12 Environmental Justice - Impacts on Minority Populations, Low-income Populations, and Indian Tribes............................................................................................................... 42 5.13 Cumulative Impacts - Cumulative Effects................................................................... 51 5.14 Climate Change - Climate Change Impacts on Environmental Resources.................. 53 6.0 References...................................................................................................................... 57 Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 3 of 59 List of Tables L-2024-182 Attachment 25 Page 3 of 59 Table 3.0-1 Environmental Authorizations for Current PBN Operations (Sheet 1 of 4)............ 8 Table 5.0-1 Category 2 Issues Applicable to PBN SLR (Sheet 1 of 2)................................... 13 Table 5.12-1 Cities, Towns, and Villages Located Totally or Partially within a 50-Mile Radius of PBN (Sheet 1 of 3).............................................................................45 Table 5.12-2 2020 County Populations Totally or Partially within a 50-Mile Radius of PBN.................................................................................................... 48 Table 5.12-3 Wisconsin Minority Population by Census Category...........................................49 Table 5.12-4 Wisconsin Low-Income Population by Census Category.................................... 50 Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 L-2024-182 Attachment 25 Page 4 of 59 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 4 of 59 oc OF APE BGEPA BTA Ci CRMP CWA EFH EPA ER ESA GEIS GHG GWPP ISFSI kV LR MCL MSA NEPB NESC NHPA NMFS NMSA NOAA NPDES NRC pCi/L PAM PBN RCP ROW SEIS SFP SHPO SLR SSP USCB Revision 1 Abbreviations, Acronyms, and Symbols degrees Celsius degrees Fahrenheit area of potential effect Bald and Golden Eagle Protection Act best technology available curies Cultural Resource Management Plan Clean Water Act essential fish habitat U.S. Environmental Protection Agency environmental report Endangered Species Act Generic Environmental Impact Statement for License Renewal of Nuclear Plants. NUREG-1437, Volume 1, Revision 2, August 2024 greenhouse gas groundwater protection program independent spent fuel storage installation kilovolt license renewal maximum contaminant level Magnuson-Stevens Fishery Conservation and Management Act NextEra Point Beach, LLC National Electric Safety Code National Historic Preservation Act National Marine Fisheries Service National Marine Sanctuaries Act National Oceanic and Atmospheric Administration National Pollutant Discharge Elimination System U.S. Nuclear Regulatory Commission picocuries per liter primary amebic meningoencephalitis Point Beach Nuclear Plant Units 1 and 2 representative concentrations pathways right-of-way Generic Environmental Impact Statement for License Renewal of Nuclear Plants, NUREG-1437, Supplement 23, Second Renewal, Regarding Subsequent License Renewal for Point Beach Nuclear Plant Units 1 and 2, draft spent fuel pool State Historic Preservation Officer subsequent license renewal Shared Socioeconomic Pathway U.S. Census Bureau November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 5 of 59 USFWS USGCRP WDNR WPDES Revision 1 U.S. Fish and Wildlife Service U.S. Global Change Research Program Wisconsin Department of Natural Resources Wisconsin Pollutant Discharge Elimination System L-2024-182 Attachment 25 Page 5 of 59 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 6 of 59 1.0 Introduction L-2024-182 Attachment 25 Page 6 of 59 This supplemental additional information to the November 2020 Applicant's Environmental Report (ER) - Subsequent Operating License Renewal (SLR), Point Beach Nuclear Plant Units 1 and 2 (PBN) (NEPB 2020a) is prepared by NextEra Energy Point Beach, LLC (NEPB) to:

1. Provide an updated status of PBN permits, licenses, and authorizations.

2. Provide results of review of potentially new and significant information since the submittal of the 2020 Subsequent License Renewal Environmental Report (SLR ER) and the United States Nuclear Regulatory Commission's (NRC) audit concerning the SLR ER, conducted April 5-8, 2021, regarding Category 1 issues from NUREG-1437, Volume 1, Revision 2, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS).

3. Provide review of potentially new and significant information concerning NRC's findings in the November 2021 draft Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 23, Second Renewal Regarding Subsequent License Renewal for Point Beach Nuclear Plant Units 1 and 2 (draft SEIS) regarding Category 2 issues from the GEIS.

4. Provide an assessment of applicable new Category 2 issues from the GEIS.

2.0 Proposed Action Changes The following discussion provides the changes to plant structures, systems, or operations with environmental interfaces that have been undertaken or planned for future implementation since the preparation of the PBN SLR ER.

Since the PBN SLR ER, construction has been completed and the solar facilities on the PBN site, Point Beach Solar, and the Two Creeks Solar, are now operational.

The PBN SLR ER and the draft SEIS discussed the presence of four individual agricultural leases onsite, totaling approximately 357 acres. All four leases were allowed to expire in 2021 to allow for the construction and installation of the solar facility. PBN anticipates re-initiating individual agricultural leases with several of the previous lessees, although there are currently no agreements in place. The new leases, if pursued, would total approximately 67 acres of previously leased agriculture land. Portions of land previously held in agriculture leases are now encompassed by the solar facility, while other portions are being mowed and maintained or have been allowed to return to natural prairie. There have been no other land use changes onsite.

An emergency generator was added to a site radio tower in April 2023. This was added to the Title V Air Permit. This new source is listed on the current Air Permit as P26/S26, a Cummins 47GGFE LPG Emergency Generator.

PBN received a Wisconsin Department of Natural Resources (WDNR) permit for placing a crane pad partially on the bed of Lake Michigan in 2020. The crane pad was used to facilitate access to maintain shoreline erosion control structures that protect the facility's infrastructure.

Three stormwater outfall structures were also extended as part of the project. The crane pad Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301

Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 7 of 59 L-2024-182 Attachment 25 Page 7 of 59 was installed adjacent to the north discharge flume, and it measured approximately 115 feet long by 60 feet wide and up to 6.5 feet tall. The permit included placement of riprap along the perimeter of the crane pad and mandatory erosion control measures. (WDNR 2023) It is anticipated that an independent spent fuel storage installation (ISFSI) pad expansion may be needed by 2025 or 2026. Per the PBN SLR ER Section 3.1.4, and as discussed during the PBN SLR ER audit, if an ISFSI expansion were needed, the anticipated expansion would occur in the ISFSl-defined area, as identified in the PBN SLR ER (NEPB 2020a; NRC 2021a). In addition, this action would be addressed in separate license reviews conducted by the NRC.

3.0 Updated Environmental Authorizations Table 3.0-1 provides the status of authorizations for PBN operations for the PBN SLR ER Table 9.1-1.

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Agency Authority Requirement Number Expiration Date U.S.

Federal Resource Environmental Conservation and Notification of EPA ID Number:

Recovery Act [42 Regulated Waste NA Protection WID093422657 Agency (EPA)

USC 6912] Ch. 10.09 Activity Wisconsin Statutes NRC Atomic Energy Act PBN License to DPR-24 Expires

[10 CFR Part 49]

Operate Unit 1 10/5/2030 NRC Atomic Energy Act PBN License to DPR-27 Expires

[10 CFR Part 49]

Operate Unit 2 3/8/2033 General license for NRC 10 CRF Part 72 storage of spent fuel General Permit NA at power reactor sites U.S.

[49 CFR Part 107, Expires Department of Subpart G]; 49 U.S.C.

Registration 052623550096F 6/30/2025 Transportation 5108 State of Utah Department of R313-26 of the Utah Generator Site Expires 0906005280 Environmental Administrative Code Access Permit 7/26/2025 Quality Tennessee Expires Department of Tennessee Code License to ship 12/31/2024 Environment Annotated 68-202-206 radioactive material T-WI002-L24 Renewed and Annually Conservation L-2024-182 Attachment 25 Page 8 of 59 Authorized Activity Hazardous waste generation/transport.

Operation of PBN Unit 1.

Operation of PBN Unit 2.

Storage of power reactor spent fuel and other associated radioactive materials in an ISFSI.

Hazardous material shipment.

Authorizes waste generators, waste processors, and waste collectors to deliver radioactive wastes to a land disposal facility located in Utah.

Shipment of radioactive material to processing facility in Tennessee.

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Agency Authority Requirement Number Expiration Date Federal Resource Owner ID:

Wisconsin Conservation Act [42 Underground 1114232, Site ID:

Department of USC 6912], Ch.

Storage Tank 652382, Tank IDs:

NA Commerce 101.09 Wisconsin Registration 285454, 764837, Statutes 764843 Owner ID:

1114232, Site ID:

652382, Tank IDs:

206578, 206579, 206581, 206583, 206615, 206616, Wisconsin Ch. 101.09 Aboveground 206690, 455264, Department of Wisconsin Statutes Storage Tank

455274, NA Commerce Registration 1131794,1131800, 131801, 1131802, 131803, 1131804, 131805, 1131806, 131807, 1325478, 325484, 1370484, 1599013 WDNR Ch. 29.614 Wisconsin Scientific Collectors SCP-FM-2024-009 Expires Statutes Permit 12/31/2024 L-2024-182 Attachment 25 Page 9 of 59 Authorized Activity Storage of flammable materials in underground tanks.

Storage of flammable materials in underground tanks.

Collection of fish for scientific purposes.

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Agency Authority Requirement Number Expiration Date Clean Water Act [33 Individual Wisconsin USC Section 1251 et Pollutant Discharge WDNR seq.] Ch. 160 and Elimination System Wl-0000957-09-0 Expires 9/30/2029 283 Wisconsin (WPDES) permit Statutes Clean Water Act [33 General WPDES WDNR USC Section 1251 et industrial storm Wl-$067857-5 Expires 6/2/2025 seq.] Ch. 283 water discharge Wisconsin Statutes permit (Tier 2)

Federal Clean Air Act

[42 USC 7661-7671]

Renewed air Ch. 285 Wisconsin pollution control WDNR Statutes, NR operation permit, Air 436034500-P40 Expires 4/12/2028 407.09(4)(a) and Operation Permit 439.03(1 )(c)

Compliance Wisconsin Certification Administrative Code WDNR Ch. NR 809-810 Registration 61469 May 1, 2025 Wisconsin Statutes WDNR NR 149 Wisconsin Registration/License Laboratory ID:

Expires 8/31/2025 Administrative Code 436034500 L-2024-182 Attachment 25 Page 10 of 59 Authorized Activity PBN discharges to Lake Michigan.

Storm water runoff from industrial facilities.

Air emissions from gas turbines, boilers, generators, and fire pumps; certification that PBN complies with Wisconsin's administrative code.

Non-transient non-community water supply registration/

small water system (OTM/NN) ooerator certification.

Registers NEPB as a laboratory licensed to perform environmental sample analysis in support of covered environmental programs (Ch.

NR149.02).

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Agency Authority Requirement Number Expiration Date 36-3-0017, Ch. 280 and 281 Approval WDNR Wisconsin Statutes Registered Numbers: 52826, Issued 12/7/2011 68865, 52824, 71777, 01176 Registration to 281.346(5)(d) withdrawal water in an amount Wisconsin Statutes; averaging 100,000 WDNR Ch. NR 856.30 and gallons per day or 10208 Expires 12/8/2031 856.31 Wisconsin more in any 30-day Administrative Code period from the Great Lakes Basin Authorization to WDNR Ch. NR 114 Wisconsin operate a 23750 Expires 7/1/2027 Administrative Code wastewater treatment plant Authorization to Manitowoc Manitowoc County use property for an electric power plant 66-66 NA County Zoning Ordinance with variance for building height L-2024-182 Attachment 25 Page 11 of 59 Authorized Activity Approval for high capacity well with listing of previously approved wells.

Groundwater withdrawal for use as potable, process, and cooling water.

Wastewater treatment plant operating permit.

Use of property for electric power plant.

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Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 12 of 59 4.0 Category 1 Evaluation L-2024-182 Attachment 25 Page 12 of 59 NEPB conducted a new and significant information review for Category 1 issues following the process presented in PBN SLR ER Chapter 5, which included both the recategorized severe accidents issue and the new greenhouse gas impacts on climate change issue. NEPB did not identify any new and significant information regarding the Category 1 issues during their preparation of this supplemental information to the PBN SLR ER. Therefore, the conclusions regarding impacts of the Category 1 issues in the GEIS are considered appropriate for the PBN SLR, are incorporated herein by reference, and impacts related to Category 1 issues do not need further analysis.

5.0 Category 2 Evaluation NEPB conducted a new and significant information review for Category 2 issues previously reviewed in the PBN SLR ER. The Category 2 issues for plants with cooling towers or cooling ponds continue to be not applicable because PBN does not have cooling towers or cooling ponds. Also, the Category 2 issue of groundwater withdrawals of more than 100 gallons per minute continues to not be applicable to PBN, and groundwater withdrawals are not anticipated to increase above the reported quantities. In addition, NEPB conducted plant-specific environmental assessments for the new issues of impacts to national marine sanctuary resources and climate change impacts. The Category 2 issues are identified in Table 5.0-1. The results of the new and significant information review and new issue assessments are presented in the following sections.

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Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 13 of 59 L-2024-182 Attachment 25 Page 13 of 59 Table 5.0-1 Category 2 Issues Applicable to PBN SLR (Sheet 1 of 2)

New and PBN SLR ER Delta Significant Eval Resource Issue Section GEIS Rev1/2 to SEIS Y/N Y/N or New Issue Groundwater Resources Radionuclides released to groundwater 4.5.5 N

N Terrestrial Resources Non-cooling system impacts on terrestrial 4.6.5 ya N

resources Aquatic Resources Impingement mortality and entrainment of aquatic organisms (plants with once-4.6.1 y

N throuqh coolinq systems or coolinq ponds)

Effects of thermal effluents on aquatic organisms (plants with once-through cooling 4.6.2 ya N

systems or cooling ponds)

Federally Protected Ecological Resources Endangered Species Act: federally listed New species and critical habitats under U.S.

4.6.6 y

Issue Fish and Wildlife Service jurisdiction Endangered Species Act: federally listed species and critical habitats under National 4.6.4 y

N Marine Fisheries Service jurisdiction Magnuson-Stevens Act: essential fish 4.6.6 y

N habitat (EFH)

National Marine Sanctuaries Act:

New y

New sanctuary resources Issue Historic and Cultural Resources Historic and cultural resources 4.7 N

N Human Health Microbiological hazards to the public 4.9.1 y

N Electric shock hazards 4.9.2 N

N Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 14 of 59 L-2024-182 Attachment 25 Page 14 of 59 Table 5.0-1 Category 2 Issues Applicable to PBN SLR (Sheet 2 of 2)

New and PBN SLR ER Delta Significant Eval Resource Issue Section GEIS Rev1/2 to SEIS Y/N Y/N or New Issue Environmental Justice Impacts on minority populations, low-4.10.1 y

N income populations, and Indian Tribes Cumulative Impacts Cumulative effects 4.12 N

N Climate Change Climate change impacts on environmental New y

New resources Issue

a. Textual changes in the issue title or discussion that does not substantially change the context of the issue.

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Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 15 of 59 L-2024-182 Attachment 25 Page 15 of 59 5.1 Groundwater Resources - Radionuclides Released to Groundwater PBN SLR ER Section 4.5.5 5.1.1 Supplemental Information

5. 1. 1. 1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table 8-1 SMALL or MODERATE. Leaks of radioactive liquids from plant components and pipes have occurred at numerous plants. Groundwater protection programs have been established at all operating nuclear power plants to minimize the potential impact from any inadvertent releases.

The magnitude of impacts would depend on site-specific characteristics.

5.1.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(P)J An applicant shall assess the impact of any documented inadvertent releases of radionuclides into groundwater. The applicant shall include in its assessment a description of any groundwater protection program used for the surveillance of piping and components containing radioactive liquids for which a pathway to groundwater may exist. The assessment must also include a description of any past inadvertent releases and the projected impact to the environment (e.g.,

aquifers, rivers, lakes, ponds, ocean) during the license renewal term.

5.1.1.3 Background [GEIS Section 4.5.1.2. 7)

The issue is relevant to license renewal (LR) because all commercial nuclear power plants routinely release radioactive gaseous and liquid materials into the environment. These radioactive releases are designed to be planned, monitored, documented, and released into the environment at designated discharge points. However, numerous events at power reactor sites have involved unknown, uncontrolled, and unmonitored release of liquids containing radioactive material into the environment and have affected soil and/or groundwater.

The majority of the inadvertent liquid release events involved tritium, which is a radioactive isotope of hydrogen. However, other radioactive isotopes, such as cesium and strontium, have also been inadvertently released into the groundwater. The types of events have included, but have not been limited to, leakage from spent fuel pools (SFPs), storage tanks, buried piping, failed pressure relief valves on an effluent discharge line, and other nuclear power plant equipment.

In 2006, the NRC's Executive Director for Operations chartered a task force to conduct a lessons-learned review of these incidents. On September 1, 2006, the task force issued its report: Liquid Radioactive Release Lessons Learned Task Force Report.

The most significant conclusion dealt with the potential health impacts on the public from the inadvertent releases. Although there were numerous events where radioactive liquid was released to the groundwater in an unplanned, uncontrolled, and unmonitored fashion, based on the data available, the task force did not identify any instances where public health and safety was adversely impacted. The NRC task force did not find the referenced tritium releases to be a health risk to the public or onsite workers. The task force identified that under current NRC regulations the potential exists for unplanned, uncontrolled, and unmonitored releases of radioactive liquids to migrate offsite into the public domain. The NRC has continued its oversight Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 16 of 59 L-2024-182 Attachment 25 Page 16 of 59 and evaluation of inadvertent releases of liquids containing radioactive material from nuclear power plants, particularly those that result in groundwater contamination.

On the basis of the information about inadvertent releases at operating nuclear power plants, the NRG concluded that the impact on groundwater quality from the release of radionuclides could be SMALL or MODERATE during the initial LR and SLR terms, depending on the magnitude of the leak, radionuclides involved, hydrogeologic factors, the distance to receptors, and the response time of plant personnel to identify and stop the leak in a timely fashion. The NRG staff will consider whether the release has caused or could cause substantial impairment or noticeable alteration of groundwater quality in an aquifer with respect to designated use classification or applicable drinking water or other applicable standards.

5.1.1.4 Analysis Groundwater is monitored at PBN for tritium as part of its groundwater protection program (GWPP), which supports NEI 07-07, the nuclear industry's groundwater protection initiative (NEPB 2023). In the PBN SLR ER, groundwater monitoring well construction details are presented in Table 3.6-3, and well locations are presented in Figure 3.6-6 (NEPB 2020a). NEPB maintains procedures that define elements of the PBN GWPP and establish standards of quality that apply to sampling, analysis, data evaluation, and reporting for data as part of the PBN GWPP.

The PBN GWPP includes groundwater monitoring from onsite locations, including six groundwater monitoring wells, four potable water wells, four facade wells, intermittent stream and bog locations, yard electrical manholes, and the subsurface drainage system sump located in the Unit 2 facade. (NEPB 2020a; NEPB 2023).

As presented in Figure 3.6-7 of the PBN SLR ER, the groundwater gradient at PBN is eastward toward Lake Michigan. In 2015 through 2019, tritium was detected in groundwater monitoring wells near the power block, but all measurements were below the EPA drinking water maximum contaminant level (MGL) of 20,000 picocuries per liter (pGi/L) before reaching Lake Michigan.

(NEPB 2020a) Continued monitoring under the PBN GWPP in 2020 through 2022 indicates that there were no substantial changes from previous years and that tritium concentrations at PBN remain below the EPA MGL. (NEPB 2021; NEPB 2022; NEPB 2023)

Low levels of tritium occur in the soil below the plant foundation, as evidenced by results from the subsurface drainage system and the facade wells. In 2019, tritium was detected in facade well samples at concentrations ranging from non-detect to 254 +/- 89 pCi/L. Tritium was detected in samples collected from the subsurface drainage system at concentrations ranging from 808 +/-

110 to 10,877 +/- 318 pCi/L. In 2020 through 2022, tritium detections in facade wells ranged from non-detect to 57 4 +/- 109 pGi/L. Tritium detections in the subsurface drainage system ranged from 806 +/- 114 pGi/L to 6,496 +/- 257 pGi/L. These concentrations are far below the EPA MGL.

Gamma scans of groundwater samples originating within the power block found no plant-related gamma emitters. (NEPB 2020a; NEPB 2021; NEPB 2022; NEPB 2023)

Based on the groundwater gradient and results from the two monitoring wells west of the plant (GW-12 and GW-13), none of the tritium in the upper soil layer is migrating offsite. In 2019, tritium detections in these two wells ranged from non-detect to 157 +/- 85 pGi/L (NEPB 2020b ).

From 2020-2022, tritium concentrations in these two wells ranged from non-detect to 217 +/- 87 Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 17 of 59 L-2024-182 Attachment 25 Page 17 of 59 pCi/L. Groundwater samples from wells in the vicinity of the remediated former earthen retention pond (GW-15 and GW-16) continue to show low levels of tritium. In 2019, tritium concentrations in these wells ranged from 91 +/- 78 to 304 +/- 89 pCi/L (NEPB 2020b). In 2020 through 2022, tritium concentrations in these wells ranged from 115 +/- 81 pCi/L to 348 +/- 95 pCi/L. (NEPB 2021 ;

NEPB 2022; NEPB 2023). These concentrations are far below the EPA MCL.

Tritium has not been detected at concentrations above the minimum detectable concentration in drinking water samples from the potable water wells; therefore, tritium has not penetrated the drinking water aquifer. (NEPB 2020a; NEPB 2021; NEPB 2022; NEPB 2023)

There have been no unplanned radioactive liquid releases between 2015 and 2020 or in 2022.

(NEPB 2020a; NEPB 2021; NEPB 2023). An abnormal liquid release occurred on August 2, 2021, when a Unit 1 hotwell containing tritium was discharged directly to circulating water. A total of 4.4 x 10 -4 curies (Ci) were discharged during this release, which was 0.0008815% of the total tritium released in August 2021 (54.5 Ci). No offsite dose calculation manual limits were exceeded or challenged. (NEPB 2022) As this release was to the circulating water system, there was no impact to groundwater.

Groundwater monitoring data collected as part of the PBN GWPP demonstrate that radionuclides do not exceed regulatory limits, and that impact is limited to soil beneath the plant foundation and in shallow groundwater near the remediated former earthen retention pond.

Groundwater flow direction is eastward toward Lake Michigan. Radionuclides associated with plant operations have not been detected in the underlying drinking water aquifer. In addition, water from plant uses continues to be processed and monitored in compliance with licensing and permitting.

5.1.2 Conclusion NEPB did not identify any new and significant information for radionuclides in groundwater, and therefore concludes the PBN SLR ER assessment of SMALL remains valid for the SLR. Further, NEPB did not identify any new and significant information related to NRC's basis for concluding the impact of radionuclides released to groundwater as SMALL in the draft SEIS.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 18 of 59 L-2024-182 Attachment 25 Page 18 of 59 5.2 Terrestrial Resources - Non-Cooling System Impacts on Terrestrial Resources PBN SLR ER Section 4.6.5 5.2.1 Supplemental Information 5.2.1.1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table B-1 SMALL, MODERATE, or LARGE. The magnitude of effects of continued nuclear power plant operation and refurbishment, unrelated to operation of the cooling system, would depend on numerous site-specific factors, including ecological setting, planned activities during the license renewal term, and characteristics of the plants and animals present in the area. Application of best management practices and other conservation initiatives would reduce the potential for impacts.

5.2. 1.2 Requirement [10 CFR 51.53(c)(3)(ii)(E)J All license renewal applicants shall assess the impact of refurbishment, continued operations, and other license renewal-related construction activities on important plant and animal habitats.

Additionally, the applicant shall assess the impact of the proposed action on federally protected ecological resources in accordance with Federal laws protecting such resources, including but not limited to, the Endangered Species Act, the Magnuson-Stevens Fishery Conservation and Management Act, and the National Marine Sanctuaries Act.

5.2. 1.3 Background [GEIS Section 4.6.1. 1.1]

The GEIS has refined the title of this issue from "Effects on Terrestrial Resources (Non-cooling System Impacts)" to "Non-cooling System Impacts on Terrestrial Resources" for clarity and consistency with other ecological resource LR GEIS issue titles. This issue concerns the effects of nuclear power plant operations on terrestrial resources during an initial LR or SLR term that are unrelated to operation of the cooling system.

The NRC considered a typical nuclear power plant that has industrial use (typically maintained as modified habitats with lawns and other landscaped areas; however, these areas may also include disturbed early successional habitats or small areas of relatively undisturbed habitat, low diversity habitat). NRC considered activities that include landscape and grounds maintenance, stormwater management, elevated noise levels and vibration, and ground-disturbing activities.

These impacts are expected to be like past and ongoing impacts that terrestrial resources are already experiencing at the nuclear power plant site.

Because the plants and animals present on nuclear power plant sites are generally tolerant of disturbance and acclimated to human activity, continued operations during the license renewal term would not affect the composition of terrestrial communities or any current trends of change.

Activities that would require state or federal permits (e.g., Clean Water Act [CWA] Section 404 permit), and federal review (e.g., U.S. Fish and Wildlife Service [USFWS] and National Oceanic and Atmospheric Administration [NOAA]) would mitigate potential impacts. Typically, plants operate under environmental procedures, and proper implementation of these procedures and BMPs would minimize or mitigate potential effects on terrestrial resources during the license renewal term. Non-cooling system impacts would be SMALL at most nuclear power plants but may be MODERATE or LARGE at some plants.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 19 of 59 5.2.1.4 Analysis L-2024-182 Attachment 25 Page 19 of 59 The GEIS did not significantly change the scope of this issue to warrant site-specific analysis.

However, the issue was still evaluated for new and significant information since the PBN SLR ER.

Refurbishment Activities As discussed in the PBN SLR ER Section 2.3, no SLR-related refurbishment activities have been identified. Therefore, there would be no SLR-related refurbishment impacts to important plant and animal habitats, and no further analysis is required. (NEPB 2020a)

Operational Activities Terrestrial resources are described in Section 3.7.2 of the PBN SLR ER. No SLR-related construction activities or changes in operational practices have been identified that would involve disturbing habitats. PBN would continue to conduct ongoing plant operational and maintenance activities during the proposed SLR operating term. However, these activities are anticipated to occur within previously disturbed habitats. (NEPB 2020a)

Operational and maintenance activities that PBN might undertake during the renewal term, such as maintenance and repair of plant infrastructure (e.g., roadways, piping installations, fencing, and other security infrastructure), would likely be confined to previously disturbed areas of the site. Furthermore, as discussed in the PBN SLR ER Section 9.6, NEPB has administrative controls in place at PBN to provide reasonable assurance that operational changes or construction activities are reviewed, and the impacts minimized through implementation of best management practices, permit modifications, or acquisition of new permits as needed. In addition, regulatory programs that the site is currently subject to, such as stormwater management, spill prevention, dredging, and herbicide use, further serve to minimize impacts on terrestrial resources. (NEPB 2020a)

Based on its independent review in the 2021 draft SEIS, the NRC concluded that the landscape maintenance activities, stormwater management, elevated noise levels, and other ongoing operations and maintenance activities that NEPB might undertake during the SLR term would primarily be confined to already disturbed areas of the PBN site. These activities would not have noticeable effects on terrestrial resources or destabilize any important attributes of the terrestrial resources on or in the vicinity of the site. Accordingly, the NRC staff concluded that non-cooling system impacts on terrestrial resources from non-cooling system activities during the SLR term would be SMALL. (NRC 2021b)

NEPB did not identify any new and significant information related to landscape and grounds maintenance, stormwater management, elevated noise levels and vibrations, and ground-disturbing activities.

5.2.2 Conclusion The change for this issue in the GEIS was a title change, which did not require re-evaluation of the information contained in the PBN SLR ER. In addition, NEPB did not identify any new and significant information regarding non-cooling system impacts on terrestrial resources. Therefore, Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 20 of 59 L-2024-182 Attachment 25 Page 20 of 59 based upon the discussion above, NEPB concludes that the PBN SLR ER assessment of SMALL remains valid for the SLR term.

Further, NEPB did not identify any new and significant information related to NRC's basis for concluding that the impact of non-cooling system impacts on terrestrial resources would be SMALL in the draft SEIS.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 21 of 59 L-2024-182 Attachment 25 Page 21 of 59 5.3 Aquatic Resources - Impingement Mortality and Entrainment of Aquatic Organisms (Plants with Once-Through Cooling Systems or Cooling Ponds)

PBN SLR ER Section 4.6.1 5.3.1 Supplemental Information 5.3.1.1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table B-1 SMALL, MODERATE, or LARGE. The impacts of impingement mortality and entrainment would generally be small at nuclear power plants with once-through cooling systems or cooling ponds that have implemented best technology requirements for existing facilities under CWA Section 316(b). For all other plants, impacts could be small, moderate, or large depending on characteristics of the cooling water intake system, results of impingement and entrainment studies performed at the plant, trends in local fish and shellfish populations, and implementation of mitigation measures.

5. 3.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(B)J If the applicant's plant utilizes once-through cooling or cooling pond water intake and discharge systems, the applicant shall provide a copy of current Clean Water Act 316(b) best technology available determinations and, if applicable, a 316(a) variance in accordance with 40 CFR part 125, or equivalent State permits and supporting documentation. If the applicant cannot provide these documents, it shall assess the impact of the proposed action on fish and shellfish resources resulting from impingement mortality and entrainment and thermal discharges.

5.3. 1.3 Background [GEIS Section 4. 6.1.2. 1]

The NRC refines the title of this issue to include impingement mortality, rather than simply impingement. This issue pertains to impingement and entrainment of finfish and shellfish at nuclear power plants with once-through cooling systems or cooling ponds during an initial LR or SLR term. This includes plants with helper cooling towers that are seasonally operated to reduce thermal load to the receiving water body, reduce entrainment during peak spawning periods, or reduce consumptive water use during periods of low river flow. The potential effects of impingement and entrainment during an initial LR or SLR term depend on numerous site-specific factors, including the ecological setting of the plant; the characteristics of the cooling system; and the characteristics of the fish, shellfish, and other aquatic organisms present in the area (e.g., life history, distribution, population trends, management objectives, etc.).The NRC considered EPA's 2014 CWA Section 316(b) regulations and the EPA's assessment that impingement reduction technology is available, feasible, and has been demonstrated to be effective. CWA Section 316(b) regulations establish best technology available (BTA) standards for impingement mortality. If the National Pollutant Discharge Elimination System (NPDES) permitting authority has made BTA determinations for a nuclear power plant, and that plant has implemented any associated requirements (or those requirements would be implemented before the LR period), then the NRC assumes that adverse impacts on the aquatic environment would be minimized. In cases where the NPDES permitting authority has not made BTA determinations, the NRC analyzes the potential impacts of impingement mortality, entrainment, or both using a weight-of-evidence approach. The NRC concluded that the impacts of impingement mortality and entrainment of aquatic organisms during the license renewal term Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 22 of 59 L-2024-182 Attachment 25 Page 22 of 59 (initial LR or SLR) at nuclear power plants with once-through cooling systems or cooling ponds could be SMALL, MODERATE, or LARGE.

5.3.1.4 Analysis The GEIS expanded the scope of this issue from the 2013 GEIS. The Category 2 issue, "Impingement and Entrainment of Aquatic Organisms (Plants with Once-through Cooling Systems or Cooling Ponds)," and the impingement component of the Category 1 issue, "Losses from Predation, Parasitism, and Disease among Organisms Exposed to Sublethal Stresses,"

was consolidated into a single Category 2 issue: "Impingement Mortality and Entrainment of Aquatic Organisms (Plants with Once-through Cooling Systems or Cooling Ponds)."

As presented in Section 3.7.7 of the PBN SLR ER, impingement and entrainment have been studied in detail from 1975-1976 and in 2006 and 2017. The WP DES permit contains the 316(b) BTA determination (WDNR 2024a). There have been no impingement or entrainment studies conducted at PBN since the PBN SLR ER. The PBN facility has operated under a number of WPDES permits and has been withdrawing once-through, non-contact cooling water without any identified problems.

5.3.2 Conclusion NEPB did not identify any new and significant information for impingement mortality and entrainment of aquatic organisms, and therefore concludes the PBN SLR ER assessment of SMALL remains valid for the PBN SLR. Further, NEPB did not identify any new and significant information related to NRC's basis for concluding the impact as SMALL in the 2021 draft SEIS.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 23 of 59 L-2024-182 Attachment 25 Page 23 of 59 5.4 Aquatic Resources - Effects of Thermal Effluents on Aquatic Organisms (Plants with Once-Through Cooling Systems or Cooling Ponds)

PBN SLR ER Section 4.6.2 5.4.1 Supplemental Information 5.4. 1. 1 Findings from 10 CFR Parl 51, Subparl A, Appendix B, Table B-1 SMALL, MODERATE, or LARGE. Acute, sublethal, and community-level effects of thermal effluents on aquatic organisms would generally be small at nuclear power plants with once-through cooling systems or cooling ponds that adhere to State water quality criteria or that have and maintain a valid CWA Section 316(a) variance. For all other plants, impacts could be small, moderate, or large depending on site-specific factors, including ecological setting of the plant; characteristics of the cooling system and effluent discharges; and characteristics of the fish, shellfish, and other aquatic organisms present in the area.

5.4.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(B)J If the applicant's plant utilizes once-through cooling or cooling pond water intake and discharge systems, the applicant shall provide a copy of current Clean Water Act 316(b) Best Technology Available determinations and, if applicable, a 316(a) variance in accordance with 40 CFR part 125, or equivalent State permits and supporting documentation. If the applicant cannot provide these documents, it shall assess the impact of the proposed action on fish and shellfish resources resulting from impingement mortality and entrainment and thermal discharges.

5.4. 1.3 Background [GEIS Section 4.6.1.2.4]

The GEIS refines the title of this issue from "Thermal Impacts on Aquatic Organisms (Plants with Once-through Cooling Systems or Cooling Ponds)" to "Effects of Thermal Effluents on Aquatic Organisms (Plants with Once-Through Cooling Systems or Cooling Ponds)" for clarity and consistency with other ecological resource LR GEIS issue titles. This issue pertains to acute, sublethal, and community-level effects of thermal effluents on finfish and shellfish from operation of nuclear power plants with once-through cooling systems and cooling ponds during an initial LR or SLR term. This includes plants with helper cooling towers that are seasonally operated to reduce thermal load to the receiving water body, reduce entrainment in the during peak spawning periods, or reduce consumptive water use during periods of low river flow.

The potential effects of thermal effluent discharges during an initial LR or SLR term depend on numerous site-specific factors, including the ecological setting of the nuclear power plant; the characteristics of the cooling system and effluent discharges; and the characteristics of the fish, shellfish, and other aquatic organisms present in the area (e.g., life history, distribution, population trends, management objectives, etc.). The NRC relies on the expertise and authority of the NP DES permitting authority with respect to thermal impacts on aquatic organisms. If the NPDES permitting authority has made a determination under CWA Section 316(a) that thermal effluent limits are sufficiently stringent to assure the protection and propagation of a balanced, indigenous population of shellfish, fish, and wildlife in and on the receiving body of water, and the nuclear power plant has implemented any associated requirements, then the NRC assumes that adverse impacts on the aquatic environment will be minimized. In cases where the NPDES permitting authority has not granted a CWA Section 316(a) variance, the NRC analyzes the Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 24 of 59 L-2024-182 Attachment 25 Page 24 of 59 potential impacts of thermal discharges using a weight-of-evidence approach. The NRC concluded that the effects of thermal effluents on aquatic organisms during the license renewal term (initial LR or SLR) at nuclear power plants with once-through cooling or cooling ponds could be SMALL, MODERATE, or LARGE.

5. 4.1.4 Analysis The GEIS did not significantly change the scope of this issue to warrant site-specific analysis.

However, the issue was still evaluated for new and significant information since the PBN SLR ER.

The 316(a) determination under the WPDES permit Section 3.2.1.2 defines thermal effluent discharge limits that PBN adheres to in order to reduce impacts on aquatic organisms (WDNR 2024a).

There have been no new thermal studies at PBN since the PBN SLR ER. As discussed in the SLR ER, the operation of PBN appears to have little long-term impact on the aquatic community of Lake Michigan, and the thermal discharge associated with the PBN outflow has been demonstrated to be protective of the Lake Michigan aquatic community. Additionally, PBN is operating in conformance with its current WPDES permit.

5.4.2 Conclusion With exception to the title change for this issue in the 2024 GEIS, NEPB did not identify any new and significant information for the effects of thermal effluents on aquatic organisms, and therefore concludes the PBN SLR ER assessment of SMALL remains valid for the PBN SLR.

Further, NEPB did not identify any new and significant information related to NRC's basis for concluding the impact as SMALL in the GEIS.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 25 of 59 L-2024-182 Attachment 25 Page 25 of 59 5.5 Federally Protected Ecological Resources - Endangered Species Act: Federally Listed Species and Critical Habitats Under U.S. Fish and Wildlife Service Jurisdiction PBN SLR ER Section: 4.6.6 5.5.1 Supplemental Information 5.5.1. 1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table 8 -1 The potential effects of continued nuclear power plant operation and refurbishment on federally listed species and critical habitats would depend on numerous site-specific factors, including the ecological setting; listed species and critical habitats present in the action area; and plant-specific factors related to operations, including water withdrawal, effluent discharges, and other ground-disturbing activities. Consultation with the U.S. Fish and Wildlife Service under Endangered Species Act Section 7(a)(2) would be required if license renewal may affect listed species or critical habitats under this agency's jurisdiction.

5.5.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(E)J All license renewal applicants shall assess the impact of refurbishment, continued operations, and other license-renewal-related construction activities on important plant and animal habitats.

Additionally, the applicant shall assess the impact of the proposed action on federally protected ecological resources in accordance with Federal laws protecting such resources, including, but not limited to, the Endangered Species Act, the Magnuson-Stevens Fishery Conservation and Management Act, and the National Marine Sanctuaries Act.

5. 5. 1.3 Background [GEIS Section 4. 6.1.3.1)

This issue has been separated from the 2013 LR GEIS issue "Threatened, Endangered, and Protected Species and Essential Fish Habitat" into a distinct issue that addresses impacts specific to federally listed species and critical habitats under USFWS jurisdiction. This issue concerns the potential effects of continued nuclear power plant operation and any refurbishment during an initial LR or SLR term on federally listed species and critical habitats protected under the Endangered Species Act (ESA) and under the jurisdiction of the USFWS. The NRC considered the potential effects of particular concern for listed terrestrial species, including habitat loss, degradation, disturbance, or fragmentation resulting from construction, refurbishment, or other site activities (including site maintenance and infrastructure repairs);

noise and vibration and general human disturbance; and mortality or injury from collisions with plant structures and vehicles. The NRC considered the potential effects of particular concern for listed aquatic species including impingement (including entrapment) and entrainment, thermal effects, exposure to radionuclides and other contaminants, reduction in available food resources due to impingement mortality and entrainment or thermal effects on prey species, and effects associated with maintenance dredging. Section 7 of the ESA requires that federal agencies consult with the USFWS for actions that "may affect" federally listed species and critical habitats. A plant-specific impact assessment as part of each initial LR or SLR environmental review to determine the potential effects on these resources and informal or formal consultation with the USFWS is required.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 26 of 59 5.5.1.4 Analysis L-2024-182 Attachment 25 Page 26 of 59 The GEIS did not significantly change the scope of this issue to warrant site-specific analysis.

However, the issue was still evaluated for new and significant information since the PBN SLR ER.

Refurbishment Activities As discussed in Section 2.3 of the PBN SLR ER, no SLR-related refurbishment activities have been identified. Therefore, there would be no SLR-related refurbishment impacts to threatened, endangered, and protected species, or EFH, the last of which is not present in the Great Lakes.

No further analysis is required. (NEPB 2020a)

Operational Activities There are a total of eight federally protected species under the Bald and Golden Eagle Protection Act (BGEPA) or the ESA in Manitowoc and Kewaunee counties after the tricolored bat was listed as proposed endangered by the USFWS in September 2022 (USFWS 2023).

Of the eight federally protected species under the BG EPA and the ESA, seven are known to occur in Manitowoc County: the red knot, the piping plover, the rusty patched bumble bee, Pitcher's thistle, the northern long-eared bat, tricolored bat, and the bald eagle. Hine's emerald dragonflies, northern long eared and tricolored bats, and bald eagles are known to occur in Kewaunee County.

As stated above, the tricolored bat was listed as proposed endangered in 2022, after the PBN SLR ER. Tricolored bats have not been recorded as occurring on the PBN site in the last 5 years. However, PBN's building structures and forested areas surrounding the plant potentially provide suitable roosting and maternity habitat for this species. PBN does not currently have specific requirements to track bats onsite, and no specific assessment has been made of the extent or quality of tricolored bat habitat at the PBN site. However, given the general habitat requirements of this species, it can be conservatively assumed that suitable habitat to varying degrees is present within the forested areas of the site as well as man-made structures at the site. Potential impacts to the tricolored bat from the operations of PBN are discussed below:

Mortality or injury from collisions with plant structures: Bat collisions with plant structures at nuclear power plants are not well documented but are likely to be rare. There have been no observed mortality incidents of tricolored bats at the PBN site.

Loss, degradation, or disturbance of habitat: No construction, land clearing, or other ground-disturbing activities are proposed that would impact endangered species habitat or disturb endangered species during the proposed SLR term. Additionally, all plant operations are located in disturbed areas, and no tree clearing is proposed during the SLR term that would potentially impact the habitat for the tricolored bat.

Behavioral changes from refurbishment and/or construction activities: No construction, ground-disturbing activities, or license-related refurbishment activities have been identified or proposed at the PBN site during the SLR term. Any bat species, if present on the PBN site, has likely already acclimated to the noise, vibration, and general human disturbances associated with site maintenance, infrastructure repairs, and other site activities. Moreover, the undisturbed, forested areas surrounding the structures likely Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 27 of 59 L-2024-182 Attachment 25 Page 27 of 59 provide more suitable habitat; hence, it is unlikely that tricolored bats would establish a colony in the man-made structures at PBN. As such, behavioral changes from refurbishment and/or construction activities to tricolored bats during the SLR term are unlikely.

If necessary, NEPB would consult with USFWS to comply with the ESA. Compliance with all regulatory requirements associated with the federally listed species will continue to be an administrative control practiced by NEPB for the life of the facility. NEPB did not identify any new information related any threatened and endangered species except for the new listing of the tricolored bat.

5.5.2 Conclusion With the addition of the tricolored bat to the list of proposed endangered species, NEPB identified it as a new federally protected species in the vicinity of PBN. NEPB did not identify any significant issues related to threatened and endangered species and is not aware of any adverse impacts regarding threatened, endangered, and protected species (including the tricolored bat) attributable to the site. Maintenance activities necessary to support SLR likely would be limited to previously disturbed areas onsite, and there are no plans to alter plant operations during the proposed SLR operating term that would affect threatened, endangered, and protected species. PBN therefore concludes the SLR ER assessment of MAY AFFECT but NOT LIKELY ADVERSELY AFFECT any federally protected species remains valid for the PBN SLR.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 28 of 59 L-2024-182 Attachment 25 Page 28 of 59 5.6 Federally Protected Ecological Resources - Endangered Species Act: Federally Listed Species and Critical Habitats Under National Marine Fisheries Service Jurisdiction PBN SLR ER Section: N/A 5.6.1 Supplemental Information 5.6. 1. 1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table 8-1 The potential effects of continued nuclear power plant operation and refurbishment on federally listed species and critical habitats would depend on numerous site-specific factors, including the ecological setting; listed species and critical habitats present in the action area; and plant-specific factors related to operations, including water withdrawal, effluent discharges, and other ground-disturbing activities. Consultation with the National Marine Fisheries Service under Endangered Species Act Section 7(a)(2) would be required if license renewal may affect listed species or critical habitats under this agency's jurisdiction.

5.6. 1.2 Requirement [10 CFR 51.53(c)(3)(ii)(E)J All license renewal applicants shall assess the impact of refurbishment, continued operations, and other license-renewal-related construction activities on important plant and animal habitats.

Additionally, the applicant shall assess the impact of the proposed action on federally protected ecological resources in accordance with Federal laws protecting such resources, including, but not limited to, the Endangered Species Act, the Magnuson-Stevens Fishery Conservation and Management Act, and the National Marine Sanctuaries Act.

5.6. 1.3 Background [GEIS Section 4.6.1.3.2]

This issue has been separated from the 2013 LR GEIS issue "Threatened, Endangered, and Protected Species and Essential Fish Habitat" into a distinct issue that addresses impacts specific to federally listed species and critical habitats under National Marine Fisheries Service (NMFS) jurisdiction. This issue concerns the potential effects of continued nuclear power plant operation and any refurbishment during an initial LR or SLR term on federally listed species and critical habitats protected under the ESA and under the jurisdiction of NMFS. The NRC considered the potential effects of continued nuclear power plant operation during an initial LR or SLR term depend on numerous site-specific factors, including the ecological setting of the plant; the listed species and critical habitats present in the action area; and plant-specific factors related to operations, including water withdrawal, effluent discharges, and refurbishment and other ground-disturbing activities. Section 7 of the ESA requires that federal agencies consult with the NMFS for actions that "may affect" federally listed species and critical habitats. A plant-specific impact assessment as part of each initial LR or SLR environmental review to determine the potential effects on these resources and consultation with the NMFS may be required.

5.6.1.4 Analysis There are no ESA protected species or critical habitats under the NMFS jurisdiction either onsite or in the vicinity of PBN. Hence, this issue is not applicable to PBN.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 29 of 59 5.6.2 Conclusion L-2024-182 Attachment 25 Page 29 of 59 Given the absence of ESA protected species and critical habitats under NMFS jurisdiction in the vicinity of PBN, this issue is not applicable.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 30 of 59 L-2024-182 Attachment 25 Page 30 of 59

5. 7 Federally Protected Ecological Resources - Magnuson-Stevens Act: Essential Fish Habitat PBN SLR ER Section: 4.6.6 5.7.1 Supplemental Information 5.7.1.1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table 8-1 The potential effects of continued nuclear power plant operation and refurbishment on essential fish habitat would depend on numerous site-specific factors, including the ecological setting; essential fish habitat present in the area, including habitats of particular concern; and plant-specific factors related to operations, including water withdrawal, effluent discharges, and other activities that may affect aquatic habitats. Consultation with the National Marine Fisheries Service under Magnuson-Stevens Act Section 305(b) would be required if license renewal could result in adverse effects to essential fish habitat.

5.7.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(E)J All license renewal applicants shall assess the impact of refurbishment, continued operations, and other license-renewal-related construction activities on important plant and animal habitats.

Additionally, the applicant shall assess the impact of the proposed action on federally protected ecological resources in accordance with Federal laws protecting such resources, including, but not limited to, the Endangered Species Act, the Magnuson-Stevens Fishery Conservation and Management Act, and the National Marine Sanctuaries Act.

5.7.1.3 Background [GEIS Section 4.6.1.3.3]

This issue has been separated from the 2013 LR GEIS issue "Threatened, Endangered, and Protected Species and Essential Fish Habitat" into a distinct issue that addresses impacts specific to EFH. This issue concerns the potential effects of continued nuclear power plant operation and any refurbishment during an initial LR or SLR term on EFH protected under the Magnuson-Stevens Fishery Conservation and Management Act (MSA).

EFH is assessed in terms of impacts on the habitat of each EFH species, life stage, and their prey and each habitat area of particular concern. Importantly, EFH effect determinations characterize the effects on the habitat of the EFH species and their life stages. They do not characterize the effects on the species, or the life stages themselves. Similarly, effect determinations for EFH prey characterize the effects on the prey as a food resource rather than the effects on the prey species themselves. The NRC considered the potential effects of particular concern for EFH, including physical removal of habitat through cooling water withdrawals, physical alteration of habitat through heated effluent discharges, chemical alteration of habitat through radionuclides and other contaminants in heated effluent discharges, physical removal of habitat through maintenance dredging, and reduction in the prey base of the habitat. The NRC may be required to consult with NMFS under MSA Section 305(b). The NMFS has developed EFH conservation recommendations in connection with four initial LR and SLR environmental reviews conducted since the publication of the 2013 LR GEIS. A plant-specific impact assessment as part of each initial LR or SLR environmental review to determine the potential effects on these resources and consultation with the NMFS may be required.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 31 of 59

5. 7. 1. 4 Analysis L-2024-182 Attachment 25 Page 31 of 59 As discussed in Section 3.7.8.5 of the PBN SLR ER, no EFH exists at Lake Michigan and no habitat areas of particular concern or EFH areas protected from fishing are located on or adjacent to PBN. No EFH exists within any enclosed freshwater habitat, including the Great Lakes. Therefore, continued PBN operations during the SLR period will have no impacts on EFH. (NEPB 2020a) 5.7.2 Conclusion No EFHs exist within the affected area of PBN. As such, this issue is not applicable to the continued operation of the PBN site for the proposed operating term. NEPB finds that there would be no effects to EFHs during the proposed SLR term.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 32 of 59 L-2024-182 Attachment 25 Page 32 of 59 5.8 Federally Protected Ecological Resources - National Marine Sanctuaries Act:

Sanctuary Resources PBN SLR ER Section: New 5.8.1 Supplemental Information 5.8. 1. 1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table 8 -1 The potential effects of continued nuclear power plant operation and refurbishment on sanctuary resources would depend on numerous site-specific factors, including the ecological setting; national marine sanctuaries present in the area, and plant-specific factors related to operations, including water withdrawal, effluent discharges, and other activities that may affect aquatic habitats. Consultation with the Office of National Marine Sanctuaries under National Marine Sanctuaries Act Section 304(d) would be required if license renewal could destroy, cause the loss of, or injure sanctuary resources.

5.8.1.2 Requirement {10 CFR 51.53(c)(3)(ii)(E)J All license renewal applicants shall assess the impact of refurbishment, continued operations, and other license-renewal-related construction activities on important plant and animal habitats.

Additionally, the applicant shall assess the impact of the proposed action on federally protected ecological resources in accordance with Federal laws protecting such resources, including, but not limited to, the Endangered Species Act, the Magnuson-Stevens Fishery Conservation and Management Act, and the National Marine Sanctuaries Act.

5.8.1.3 Background [GEIS Section 4.6.1.3.4]

This issue concerns the potential effects of continued nuclear power plant operation and any refurbishment during an initial LR or SLR term on sanctuary resources protected under the National Marine Sanctuaries Act (NMSA). Impacts on marine sanctuaries are broad ranging because such resources include any living or nonliving resource of a national marine sanctuary.

With respect to ecological sanctuary resources, the NRC considered the potential effects of particular concern including impingement (including entrapment) and entrainment, thermal effects, exposure to radionuclides and other contaminants, reduction in available food resources due to impingement mortality and entrainment or thermal effects on prey species, and effects associated with maintenance dredging. Depending on the NRC's effect determinations, the NRC may be required to consult with the Office of National Marine Sanctuaries under NMSA Section 304(d). Depending on the NRC's effect determinations, the NRC may be required to consult with Office of National Marine Sanctuaries under NMSA Section 304(d). National marine sanctuary status is not static. The geographic extent of existing sanctuaries may change or expand in the future, and NOAA is likely to designate new sanctuaries as additional areas of conservation need are identified and assessed. Therefore, a generic determination of potential impacts on sanctuary resources during a nuclear power plant's LR term is not possible. A plant-specific impact assessment as part of each initial LR or SLR environmental review to determine the potential effects on these resources and consult with NMFS is required.

5.8.1.4 Analysis As described in Section 3.8.1.5 of the draft SEIS for PBN, NOAA designated a 962-square-mile area of Lake Michigan as the Wisconsin Shipwreck Coast National Marine Sanctuary in June Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 33 of 59 L-2024-182 Attachment 25 Page 33 of 59 2021. As discussed in the 2021 draft SEIS, the sanctuary resources of concern are a nationally significant collection of maritime cultural heritage resources, including 36 known shipwrecks and potentially approximately 59 shipwrecks yet to be discovered, as well as numerous other historic maritime-related features. There are two suspected shipwrecks mapped within the Wisconsin Shipwreck Coast National Marine Sanctuary that are within 2 miles of PBN. The Minnesota was a schooner that ran aground and broke-up during a storm in 1873 offshore somewhere in the vicinity of Two Creeks Road according to historical records. The remains of the ship have not been found. The Arrow was a schooner that ran aground in 1883, could not be freed, and was abandoned according to historical records. The exact location of this shipwreck has also not been determined, but it is currently mapped offshore of Irish Road. Given the suspected locations of these wrecks, the Minnesota is 1.25 miles north of PBN's intake and discharge structures, whereas the Arrow is approximately 2 miles south of these structures. Although known, and potential shipwrecks are located at least 1.25 miles from PBN and beyond the influence of either PBN's cooling water intake structure or the area affected by thermal effluent discharges, the continued operation of PBN would not affect these resources. NEPB has no shoreline stabilization or other in-water work planned during the proposed SLR term, and any work in the SLR period will undergo permitting reviews with the appropriate agencies.

Therefore, there are no activities associated with the proposed action that would have the potential to affect the environment within the boundaries of the sanctuary. (NRG 2021 b) 5.8.2 Conclusion Although this is a new issue in the GEIS, NEPB did not identify any new and significant information for PBN that would alter the NRC's conclusion that the continued operation of PBN during the SLR period has NO EFFECT on any sanctuary resources protected under the NMSA.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 34 of 59 5.9 Historic and Cultural Resources PBN SLR ER Section 4.7 5.9.1 Supplemental Information L-2024-182 Attachment 25 Page 34 of 59 5.9. 1. 1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table B-1 Impacts from continued operations and refurbishment on historic and cultural resources located onsite and in the transmission line ROW are analyzed on a plant-specific basis. The NRC will perform a National Historic Preservation Act (NHPA) Section 106 review, in accordance with 36 CFR Part 800, with consultation with the State and Tribal Historic Preservation Officers, Indian Tribes, and other interested parties.

5.9.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(K)J All applicants shall identify any potentially affected historic and cultural resources and historic properties and assess whether future plant operations and any planned refurbishment activities would affect these resources in accordance with Section 106 of the National Historic Preservation Act and in the context of the National Environmental Policy Act.

5.9.1.3 Background [GEIS Section 4. 7.1]

For the issue of historic and cultural resources, the NRC evaluated the impact of continued operations and refurbishment activities during the license renewal term on historic and cultural resources located onsite and in transmission line ROWs. This issue was addressed in the 2013 LR GEIS and it is a Category 2 issue (NRC 2013). The issue has been updated to include discussion of impacts on cultural resources that are not eligible for or listed in the National Register of Historic Places that would also need to be considered during license renewal reviews. The NRC will identify historic and cultural resources within a defined area of potential effect (APE). The LR APE is the area that may be impacted by land-disturbing or other operational activities associated with continued plant operations and maintenance during the renewal term and/or refurbishment. The APE typically encompasses the nuclear power plant site, its immediate environs, including viewshed, and the transmission lines within this scope of review. The APE may extend beyond the nuclear plant site and transmission lines when these activities may affect historic and cultural resources.

Continued operations during the renewal term and refurbishment activities at a nuclear power plant can affect historic and cultural resources through (1) ground-disturbing activities associated with plant operations and ongoing maintenance (e.g., construction of new parking lots or buildings), landscaping, agricultural or other use of plant property; (2) activities associated with transmission line maintenance (e.g., maintenance of access roads or removal of danger trees); and (3) changes to the appearance of nuclear power plants and transmission lines. License renewal environmental reviews have shown that the appearance of nuclear power plants and transmission lines has not changed significantly over time; therefore, additional viewshed impacts to historic and cultural resources are not anticipated.

The NHPA requires the NRC to conduct a plant-specific assessment to determine whether historic properties are present in the APE, and if so, whether the license renewal (initial LR or SLR) would result in any adverse effect upon such properties. There are three potential Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 35 of 59 L-2024-182 Attachment 25 Page 35 of 59 determinations (see 36 CFR 800.4) for plant-specific license renewal include: no historic properties present, the undertaking will have no effect to historic properties; historic properties present, the undertaking will have no adverse effect upon them; historic properties present, the undertaking will have an adverse effect upon one or more historic properties (see 36 CFR 800.5).

A historic property under the NHPA that does not meet the criteria, the NRC will assess whether any potential significant impacts on this resource through the NEPA process.

The NRC reviewed information from SEISs completed since development of the 2013 LR GEIS and concluded that potential impacts from continued operations and refurbishment activities on historic and cultural resources during the initial LR and SLR terms are unique to each nuclear power plant site.

5.9. 1.4 Analysis Although the GEIS did not change the scope of this resource area, a requirement for the Secretary of the Interior qualification was added. This section was prepared by a professional meeting this qualification per the requirements of 36 CFR Part 61.

As discussed in Section 3.8.6 of the draft SEIS, although no SLR-related ground-disturbing activities have been identified, NEPB has guidance in place for management of cultural resources ahead of any future ground-disturbing activities at the plant. These consist of a historic resources consultation guidance document to protect known cultural resources as well as unknown cultural resources. Established processes address the potential for impact to cultural resources by establishing procedures for all activities requiring a federal permit or using federal funding that have the potential to impact historic resources. Therefore, the continued operation of the PBN will not affect any known Historic Properties during the proposed SLR term.

An updated.cultural resource management plan (CRMP) was developed for PBN, which was reviewed and approved by the Wisconsin State Historic Preservation Officer (SHPO) on October 5, 2021. Further, the Wisconsin SHPO Office concurred that sites 47MN267, 47MN437, 47MN438, 47MN439, 47MN440, 47MN441, 47MN442, 47MN443, 47MN444, 47MN445, 47MN452 and 47MN454 were not eligible for listing on the National Register of Historic Places.

PBN retained Commonwealth Heritage Group, Inc. (Commonwealth) to prepare a Determination of Eligibility for PBN. The resulting report by Commonwealth recommend that PBN was not eligible for listing on the National Register of Historic Places. The Determination of Eligibility has not been reviewed by the Wisconsin SHPO's office.

A search of the Wisconsin Historic Preservation Geographic Information Systems Database in November 2023 for a 1-mile buffer around the PBN boundary did not identify any newly recorded archaeological sites or historic structures within the boundaries of the PBN site since the draft SEIS. A single new cultural resource assessment study was conducted in the area adjacent to the PBN. The Wisconsin Department of Transportation conducted an archaeological survey for proposed improvements to State Highway 42 along the western boundary of the PBN facility in 2021. No new archaeological sites were identified within the PBN boundary; however, the boundary of a previously recorded site 47MN185 (William Schroeder Farm) was adjusted, and a portion of this site now extends into the northwestern corner of PBN. Site 4 ?MN 185 was Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 36 of 59 L-2024-182 Attachment 25 Page 36 of 59 recorded as a single artifact find - a prehistoric grooved axe discovered somewhere within the 80-acre Schroeder Farm. Because the boundaries of site 47MN185 were originally recorded outside of the PBN boundary, it was not included in the CRMP update. As discussed in Section 2.0, PBN potentially has shoreline maintenance activities facilitated by the crane installed in Lake Michigan and potentially an ISFSI expansion would be constructed within the ISFSl-defined area. These activities would be well away from the northwest of the PBN site where the 47MN0185 is located. As presented in the PBN SLR ER Section 4.7.4.2, administrative procedural controls are in place for management of cultural resources ahead of any future ground disturbing activities at the plant.

5.9.2 Conclusion Based on the discussion above, NEPB concludes that the continued operation of the PBN will not affect any known Historic Properties during the SLR term. As PBN has a CRMP in place to protect historic and cultural resources, any impacts would be SMALL, and the conclusions in the draft SEIS remain valid.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 37 of 59 5.10 Human Health - Microbiological Hazards to the Public PBN SLR ER Section 4.9.1 5.10.1 Supplemental Information L-2024-182 Attachment 25 Page 37 of 59 5.10.1.1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table 8 -1 SMALL, MODERATE, or LARGE. These microorganisms are not expected to be a problem at most operating plants except possibly at plants using cooling ponds, lakes, or canals, or that discharge to waters of the United States accessible to the public. Impacts would depend on site-specific characteristics.

5.10.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(G)J If the applicant's plant uses a cooling pond, lake, or canal or discharges into waters of the United States accessible to the public, an assessment of the impact of the proposed action on public health from thermophilic organisms in the affected water must be provided.

5.10.1.3 Background [GEIS Section 4.9.1.1.3]

This renamed issue is an expansion of the issue "Microbiological Hazards to the Public (Plants with Cooling Ponds or Canals or Cooling Towers that Discharge to a River)" in the 2013 LR GEIS, because this issue is a concern wherever receiving waters are accessible to the public.

Specifically, members of the public could be exposed to microorganisms in thermal effluents at nuclear power plants that use cooling ponds, lakes, canals, or that discharge to publicly accessible surface waters. Microbiological hazards concern disease causing microorganisms, also known as etiological agents. Etiological agents associated with nuclear power stations include more than just thermophilic microorganisms and may be present in elevated numbers in unheated and heated water systems, as well as in cooling systems, receiving and source waterbodies, and site sewage treatment facilities. Microbiological organisms of concern for public and occupational health include enteric pathogens (bacteria that typically exist in the intestines of animals and humans e.g., Pseudomonas aeruginosa), thermophilic fungi, bacteria (e.g., Legionella spp. and Vibrio spp.), free-living amoebae (e.g., Naegleria fowleri and Acanthamoeba spp.), as well as organisms that produce toxins that affect human health (e.g.,

dinoflagellates [Karenia brevis] and blue-green algae). Some of these disease-causing organisms have been associated with the operation of nuclear power plant cooling systems.

Members of the public could be exposed to microorganisms in thermal effluents at nuclear plants that use cooling ponds, lakes, or canals that discharge to waters of the United States accessible to the public.

Changes in microbial populations and in the public use of water bodies might occur after the operating license is issued and the application for license renewal is filed. Other factors could also change, including the average temperature of the water, which could result from climate change that affected water levels and air temperature. Finally, the long-term presence of a power plant might change the natural dynamics of harmful microorganisms within a body of water.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 38 of 59

5. 10. 1.4 Analysis L-2024-182 Attachment 25 Page 38 of 59 The GEIS expanded the scope of this issue from to plants with discharges to a river to plants that discharge to any water of the United States that is accessible to the public. Also, the NRC expanded the microorganisms of concern to include toxins that affect human health (e.g.,

dinoflagellates [Karenia brevis] and blue-green algae), which are microorganisms that involve harmful algal blooms (NRC 2024).

Cooling water from PBN discharges to Lake Michigan through two flumes approximately 200 feet from the shoreline with a discharge velocity of less than 4 feet/second. It is expected that this configuration will promote mixing and a rapid reduction in temperature differences between the effluent and lake water. (NEPB 2020a) As per the stipulations of the PBN WPDES permit, discharge temperature is monitored continuously, and results are summarized and reported monthly to the WDNR. The Wisconsin Department of Health Services was contacted in November 2020 to consult on microorganisms of concern in relation to PBN SLR, but the state agency did not respond to provide any concerns.

The NRC concluded in the draft SEIS, Section 3.11.6.1, that impacts of thermophilic microorganisms on the public are SMALL for the proposed PBN SLR. NRC based this conclusion on (1) that PBN's thermal effluent discharge is below N. fowleri's optimal growth temperature of 115 degrees Fahrenheit (°F) (NRC 2021 b). Thus, PBN's thermal discharges are not high enough in temperature to facilitate proliferation of this microorganism or to cause a public health concern, and (2) there have been no known occurrences of primary amebic meningoencephalitis (PAM) from Lake Michigan. The maximum thermal discharge temperature recorded at PBN in 2021-2023 was 84°F, which is well below the optimal growth temperature for N. fowleri. Only 157 cases of PAM were reported to the CDC between 1962-2022, none of which were located in Wisconsin (CDC 2024 ). According to the Wisconsin Department of Health Services, no cases of PAM have ever been seen in Wisconsin (WDHS 2022). Further, PBN has not received notice, report, or correspondence from any state/local public health agencies relating to PBN's discharge to Lake Michigan since preparation of the SLR ER.

Annual reports from the Manitowoc County Health Department were reviewed for 2020, 2021, 2022, and 2023. Enteric disease includes both food and waterborne diseases; however, this data provides a sufficient analog to show trends in the category. Both Manitowoc County and the State of Wisconsin saw a steep drop in enteric infections in 2020, likely due to the reduction in social gatherings at locations where enteric agents could potentially be present. The number of enteric infections for 2021 and 2022 were higher than in 2020; however, they were aligned with numbers prior to 2020 (2016-2019). Enteric diseases declined in 2023 for Manitowoc County, following state trends. This data also supports the conclusion that cases of enteric disease in Manitowoc County are in line with the rates for the State of Wisconsin. (MCHD 2021; MCHD 2022; MCHD 2023; MCHD 2024; WDNR 2024b) In summary, there is no indication that PBN thermal effluent influences the number of cases of such diseases.

The WDNR and Manitowoc County Health Department have not reported the presence of harmful algal blooms near the portion of the coast of Lake Michigan, where PBN is situated (MCHD 2021 ; MCHD 2022; MCHD 2023, MCHD 2024, WDNR 2024b). Also, NEPB is not aware of any algal or bacteria blooms in Lake Michigan in the vicinity of the PBN discharge. As Lake Michigan is large enough to have sustained wave action and overall cooler temperatures, formation of harmful algal blooms is less likely than on smaller, stagnant bodies of water. PBN Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 39 of 59 L-2024-182 Attachment 25 Page 39 of 59 has a service/circulating water monitoring and biofouling program, which controls biofouling and corrosion in the water systems. Additionally, using biocides, this program controls microorganisms, bacteria, and algae that could have been disease-causing agents.

5.10.2 Conclusion NEPB did not identify any new and significant information for microbiological hazards, and therefore concludes the PBN SLR ER assessment of SMALL remains valid for the SLR. Further, NEPB did not identify any new and significant information related to NRC's basis for concluding microbiological hazards as SMALL in the draft SEIS.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 40 of 59 5.11 Human Health - Electric Shock Hazards PBN SLR ER Section 4.9.2 5.11.1 Supplemental Information L-2024-182 Attachment 25 Page 40 of 59 5.11.1.1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table 8-1 SMALL, MODERATE, or LARGE. Electrical shock potential is of small significance for transmission lines that are operated in adherence with the National Electrical Safety Code (NESC). Without a review of conformance with NESC criteria of each nuclear power plant's in-scope transmission lines, it is not possible to determine the significance of the electrical shock potential.

5. 11. 1. 2 Requirement [1 O CFR 51. 53( c)(3)(ii)(H)J If the applicant's transmission lines that were constructed for the specific purpose of connecting the plant to the transmission system do not meet the recommendations of the National Electrical Safety Code for preventing electric shock from induced currents, an assessment of the impact of the proposed action on the potential shock hazard from the transmission lines must be provided.

5.11.1.3 Background [GEIS Section 4.9.1.1.5]

The shock hazard issue is evaluated by referring to the NESC. Primary shock currents are produced mainly through direct contact with conductors and have effects ranging from a mild tingling sensation to death by electrocution. Tower designs preclude direct public access to the conductors. Secondary shock currents are produced when humans make contact with (1) capacitively charged bodies, such as a vehicle parked near a transmission line, or (2) magnetically linked metallic structures, such as fences near transmission lines. A person who contacts such an object could receive a shock and experience a painful sensation at the point of contact. The intensity of the shock depends on the electromagnetic field strength, the size of the object, and how well the object and the person are insulated from ground. Design criteria for nuclear power plants that limit hazards from steady-state currents are based on the NESC, which requires that utility companies design transmission lines so that the short-circuit current to ground produced from the largest anticipated vehicle or object is limited to less than 5 milliamperes.

With respect to shock safety issues and LR, three points must be made. First, in the licensing process for the earlier licensed nuclear plants, the issue of electrical shock safety was not addressed. Second, some plants that received operating licenses with a stated transmission line voltage may have chosen to upgrade the line voltage for reasons of efficiency, possibly without reanalysis of induction effects. Third, since the initial NEPA review for those utilities that evaluated potential shock situations under the provision of the NESC, land use may have changed, resulting in the need for a reevaluation of this issue. The electrical shock issue, which is generic to all types of electrical generating stations, including nuclear plants, is of SMALL significance for transmission lines that are operated in adherence with the NESC. Without a review of the conformance of each nuclear plant's transmission lines, within this scope of review with NESC criteria, it is not possible to determine the significance of the electrical shock potential generically.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 41 of 59 5.11.1.4 Analysis L-2024-182 Attachment 25 Page 41 of 59 In-scope transmissions lines at PBN include those that connect the PBN turbine building to the 345-kilovolt (kV) switchyard and 13.8-kV bus supply bunker. All in-scope transmission lines are located completely within the PBN site boundary, and within the protected area fence, as shown in Figure 2.2-4 of the PBN SLR ER. (NEPB 2020a) No modifications to the in-scope transmission lines have been made since the submittal of the SLR ER. All grounding devices at PBN are appropriately sized to carry the induced current and handle the anticipated fault current for the time necessary to clear the line, meaning the time required to resolve the condition that caused the fault. PBN electrical safety procedures detail the steps required prior to work on energized components, for example, information that only qualified employees work on these components, that proper personal protective equipment and tools specifically rated for the correct risk category are used, that lock out/tag out procedures are followed, and that boundaries are set based on voltage to maintain proper distance.

5.11.2 Conclusion NEPB did not identify any new and significant information for electric shock hazards, and therefore concludes the PBN SLR ER assessment of SMALL remains valid for the SLR term.

Further, NEPB did not identify any new and significant information related to NRC's basis for concluding electric shock hazards as SMALL in the draft SEIS.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 42 of 59 L-2024-182 Attachment 25 Page 42 of 59 5.12 Environmental Justice - Impacts on Minority Populations, Low-income Populations, and Indian Tribes PBN SLR ER Section 4.10.1 5.12.1 Supplemental Information 5.12.1.1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table 8-1 Impacts on minority, low-income populations, Indian Tribes, and subsistence consumption resulting from continued operations and refurbishment associated with license renewal will be addressed in nuclear plant-specific reviews.

5.12.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(N)J Applicants shall provide information on the general demographic composition of minority and low-income populations and communities (by race and ethnicity) and Indian tribes in the vicinity of the nuclear power plant that could be disproportionately affected by license renewal, including continued reactor operations and refurbishment activities.

5.12.1.3 Background [GEIS Section 4.10.1.1]

Disproportionately high and adverse environmental effects occur when an impact on the natural or physical environment significantly and adversely affects a minority population, low-income population, or Indian Tribe and exceeds those on the general population or other comparison group. Such effects may include ecological, cultural, socioeconomic, or social impacts. These environmental effects are discussed in this chapter for each of these and other resource areas.

The environmental justice impact analysis: (1) identifies minority populations, low-income populations, and Indian Tribes that could be affected by continued reactor operations during the LR term and refurbishment activities at a nuclear power plant, (2) determines whether there would be any human health or environmental effects on these populations, and (3) determines whether these effects may be disproportionately high and adverse. Minority and low-income populations, Indian Tribes, and environmental justice issues are different at each nuclear power plant site.

Continued reactor operations during the LR term and refurbishment activities at a nuclear power plant could affect land, air, water, and ecological resources, which could result in human health or environmental effects. Consequently, minority and low-income populations and Indian Tribes could be disproportionately affected. The environmental justice impact analysis must therefore determine whether continued reactor operations during the LR term and refurbishment activities at a nuclear power plant would result in disproportionately high and adverse human health or environmental effects on a minority population, low-income population, or Indian Tribe. In assessing the human health effects of LR, examine radiological risk from consumption of fish, wildlife, and local produce; exposure to radioactive material in water, soils, and vegetation; and the inhalation of airborne radioactive material during nuclear power plant operation.

5. 12. 1. 4 Analysis The PBN SLR ER utilized the 2010 Census data, the 2018 population estimates, and TIGER/line data from the U.S. Census Bureau (USCB) to characterize the demographics for communities and counties within the 6-mile vicinity and 50-mile region. The most recent Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 43 of 59 L-2024-182 Attachment 25 Page 43 of 59 decennial census data (2020) and the 2022 population estimates were used to identify changes since the PBN SLR ER. Upon review, there was no more recent updates of the Wisconsin state population projection information since the PBN SLR ER; therefore, no updated population projections are included (UVM 2024). Similarly, the U.S. Census of Agriculture has also not been updated; therefore, updated information for migrant workers is not available. The 2010 and 2018 population for cities, villages, towns, and some census designated places with centers located within a 50-mile radius of PBN were provided in the PBN SLR ER Table 3.11-1. Table 5.12-1, below, provides the 2020 census counts and 2022 population estimates for these communities There are two communities located within a 6-mile radius of PBN: Two Creeks and Mishicot. As noted in the PBN SLR ER, the town of Two Creeks had experienced a population decrease between 2010 and 2018. According to the 2020 Census, this trend continued as the town's population decreased approximately 10.5 percent from 2018 to 390 persons in 2020. The 2022 population estimate for the town shows a slight increase of 2 persons. Similarly, the PBN SLR ER noted that the population of the Village of Mishicot also had a decreasing population trend from 2010 and 2018, which continued through 2020, resulting in a 2020 population of 1,432 persons. The 2022 population estimate for the village shows a small increase to 1,449 persons. (NEPB 2020a; USCB 2020a; USCB 2022a; USCB 2022b)

As noted in the PBN SLR ER, the site is located in Manitowoc County, Wisconsin. The largest city in Manitowoc County is the City of Manitowoc, located approximately 15 miles south-southwest of PBN. As noted in Table 3.11-1 of the PBN SLR ER, the city of Manitowoc had experienced a decreasing population trend since 2000. According to the 2020 Census, this trend had changed, and the city's population increased by 6.1 percent to a total of 34,626 persons. The 2022 population estimates for Manitowoc demonstrates a minor decline to 34,500 persons. The USCB data also indicate that there is no change from the PBN SLR ER in the number of cities within a 50-mile radius with populations greater than 25,000 and 100,000.

(NEPB 2020a; USCB 2020a)

There are a total of 12 counties wholly or partially located within a 50-mile radius of the site.

Consistent with the PBN SLR ER, Table 5.12-2 shows that the two counties with the highest population within the PBN region are Brown County (2020 population of 268,740) and Outagamie County, Wisconsin (2020 population of 190,705). Between 2018 and 2022, Brown and Outagamie Counties experienced a small increase in population at 1.9 percent and 1.7 percent, respectively.

To evaluate changes in minority populations since the PBN SLR ER, Table 5.12-3 provides a summary of the Wisconsin minority populations by census categories. As noted in the PBN SLR ER, the largest minority group in the state was the Hispanic or Latino category, which, according to the 2022 USCB data, continues to be the largest category (e.g., 7.3 percent of the state population). As noted in Table 5.12-3, the demographic makeup of the state has not changed significantly since 2018, with the largest changes identified in the Aggregate of all Minority Races and Hispanic, which had a population increase of 1.6 percent. The next highest increase, at 3.1 percent, is in the Two or More Races and Aggregate of All Races categories. Between 2018 and 2022 timeframe, the remaining minority census categories reported minor changes of less than one percent. (NEPB 2020a; USCB 2020b; USCB 2022c)

NRC guidance defines "low-income" by using USCB statistical poverty thresholds (NRC 2020).

Poverty status for households and individuals within Wisconsin were derived from the ACS Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 44 of 59 L-2024-182 Attachment 25 Page 44 of 59 5-year estimates and decennial data for the years 2018, 2020 and 2022. Table 5.12-4 provides a summary of low-income individuals and families (e.g., households) for the state of Wisconsin.

As shown in the table, the percent of population for both the low-income individual and family categories decreased slightly between 2018 and 2022, at 1.2 and 0.1 percent, respectively.

Desktop level reviews for articles or reports of subsistence populations in the site vicinity were conducted; however, no publicly available studies were identified. PBN staff were interviewed who live and work in the PBN region to identify updates; however, no subsistence activities were identified.

5.12.2 Conclusion As demonstrated above, the demographic makeup of Wisconsin has not changed significantly since 2018. Additionally, there are no SLR-related refurbishment activities identified, nor are there changes to the operational activities described in the PBN SLR ER. Therefore, no new and significant information was identified that would result in a change to the anticipated impact of no disproportionately high and adverse impacts or effects on members of the public, including minority, low-income, or subsistence populations, as a result of SLR.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 45 of 59 L-2024-182 Attachment 25 Page 45 of 59 Table 5.12-1 Cities, Towns, and Villages Located Totally or Partially within a 50-Mile Radius of PBN (Sheet 1 of 3) 2020 Census 2022 Census City/TownNillage County Population Population Estimates Estimates Adell Sheboygan 498 462 Algoma Kewaunee 3,243 3,227 Allouez Brown 14,156 14,089 Appleton Outagamie 75,644 75,133 Ashwaubenon Brown 16,991 16,939 Bellevue Brown 15,935 16,086 Black Creek Outagamie 1,357 1,194 Brillion Calumet 3,262 3,294 Cascade Sheboygan 722 650 Casco Kewaunee 630 598 Chilton Calumet 4,080 4,017 Cleveland Manitowoc 1,579 1,686 Combined Locks Outagamie 3,634 3,620 De Pere Brown 25,410 25,373 Denmark Brown 2,408 2,400 Elkhart Lake Sheboygan 941 1,170 Forestville Door 482 558 Fox Crossing(b)

Winnebago 18,974 18,949 Francis Creek Manitowoc 659 687 Glenbeulah Sheboygan 451 409 Green Bay Brown 107,395 106,846 Harrison(b)

Calumet 12,418 12,872 Hilbert Calumet 1,248 1,108 Hobart Brown 10,211 10,130 Howard Brown 19,950 20,022 Howards Grove Sheboygan 3,237 3,241 Kaukauna Outagamie 17,089 17,111 Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 46 of 59 L-2024-182 Attachment 25 Page 46 of 59 Table 5.12-1 Cities, Towns, and Villages Located Totally or Partially within a SO-Mile Radius of PBN (Sheet 2 of 3) 2020 Census 2022 Census City/TownNillage County Population Population Estimates Estimates Kellnersville Manitowoc 307 255 Kewaunee Kewaunee 2,837 2,819 Kiel Manitowoc 3,932 3,878 Kimberly Outagamie 7,320 7,331 Kohler Sheboygan 2,195 2,142 Little Chute Outagamie 11,619 11,798 Luxemburg Kewaunee 2,685 2,686 Manitowoc Manitowoc 34,626 34,500 Maribel Manitowoc 336 379 Menasha Winnebago/Calumet 18,268 18,125 Mishicot Manitowoc 1,432 1,449 Mount Calvary Fond du Lac 548 675 Neenah Winnebago 27,319 27,309 New Holstein Calumet 3,195 3,141 Nichols Outagamie 290 251 Oconto Oconto 4,609 4,586 Oconto Falls Oconto 2,957 2,959 Oostburg Sheboygan 3,056 3,066 Plymouth Sheboygan 8,932 8,907 Potter Calumet 244 229 Pulaski Brown 3,870 3,861 Reedsville Manitowoc 1,195 1,166 Saint Cloud Fond du Lac 489 449 Saint Nazianz Manitowoc 714 857 Seymour Outagamie 1,501 1,356 Sheboygan Sheboygan 49,929 49,805 Sheboygan Falls Sheboygan 8,210 8,163 Sherwood Calumet 3,271 3,224 Stockbridge Calumet 678 857 Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 47 of 59 L-2024-182 Attachment 25 Page 47 of 59 Table 5.12-1 Cities, Towns, and Villages Located Totally or Partially within a SO-Mile Radius of PBN (Sheet 3 of 3) 2020 Census 2022 Census City/T ownNillage County Population Population Estimates Estimates Sturgeon Bay Door 9,646 9,620 Suamico Brown 12,820 12,878 Two Creeks Manitowoc 390 392 Two Rivers Manitowoc 11,271 11,252 Valders Manitowoc 952 880 Waldo Sheboygan 467 472 Whitelaw Manitowoc 737 871 Wrightstown Brown 3,179 3,196 (USCB 2020a; uses 2022a; USCB 2022b)

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 48 of 59 Table 5.12-2 2020 County Populations Totally or Partially within a 50-Mile Radius of PBN State and County 2020 Population Estimates Wisconsin (12 counties) Total 5,893,718 Brown 268,740 Calumet 52,442 Door 30,066 Fond du Lac 104,154 Kewaunee 20,563 Manitowoc 81,359 Marinette 41,872 Oconto 38,965 Outagamie 190,705 Shawano 40,881 Sheboygan 118,034 Winnebago 171,730 (USCB 2020c; USCB 2022d)

Revision 1 L-2024-182 Attachment 25 Page 48 of 59 2022 Population Estimates 5,890,543 268,393 52,361 30,038 104,027 20,570 81,242 41,827 39,048 190,611 40,848 117,741 171,197 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 49 of 59 Table 5.12-3 Wisconsin Minority Population by Census Category 2018 2020 Census Categories Population Population 5,778,394 5,893,718 Number Percent Number Percent Black or African American 368,744 6.4 376,256 6.4 American Indian or Alaska 50,422 0.9 60,428 1.0 Native Asian 159,356 2.8 175,702 3.0 Native Hawaiian/Other 1,975 0.0 2,199 0.0 Pacific Islander Some Other Race 115,941 2.0 182,054 3.1 Two or More Races 135,990 2.4 359,534 6.1 Aggregate of All Races 832,428 14.4 1,156,173 19.6 Hispanic or Latino 385,779 6.7 447,290 7.6 Aggregate of all Minority 832,428 14.4 1,156,173 19.6 Races and Hispanic (NEPB 2020a; USCB 2020b; USCB 2022c)

Revision 1 2022 Population 5,882,128 L-2024-182 Attachment 25 Page 49 of 59 2018-2022 Change in Percent of Number Percent Population 363,331 6.2

-0.2 43,759 0.7

-0.1 169,052 2.9 0.1 2,261 0.0 0.0 128,690 2.2 0.2 320,056 5.4 3.1 1,027,149 17.5 3.1 430,976 7.3 0.7 1,183,161 20.1 5.7 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 50 of 59 Table 5.12-4 Wisconsin Low-Income Population by Census Category 2018 2020 Population Population Census Category 5,628,213 5,893,718 Number Percent Number Percent Low Income - Number of Persons 668,220 11.9 620,947 10.5 Below Poverty Level (Individuals)

Low Income - Number of Families 267,846 4.8 254,996 4.3 Below Poverty Level (Households)

(NEPB 2020a; USCB 2020d; USCB 2022c)

Revision 1 2022 Population 5,882,128 Number Percent 617,037 10.5 278,541 4.7 L-2024-182 Attachment 25 Page 50 of 59 2018-2022 Change in Percent of Population

-1.4

-0.1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 51 of 59 5.13 Cumulative Impacts - Cumulative Effects PBN SLR ER Section 4.12

5. 13.1 Supplemental Information L-2024-182 Attachment 25 Page 51 of 59 5.13.1.1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table 8-1 Cumulative effects or impacts of continued operations and refurbishment associated with license renewal must be considered on a nuclear plant-specific basis. The effects depend on regional resource characteristics, the incremental resource-specific effects of license renewal, and the cumulative significance of other factors affecting the environmental resource.

5.13.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(O)J Applicants shall provide information about other past, present, and future reasonably foreseeable actions occurring in the vicinity of the nuclear plant that may result in a cumulative effect.

5.13.1.3 Background [GEIS Section 4.13]

Actions considered in the cumulative effects (impacts) analysis include the proposed LR action (initial LR or SLR) when added to past, present, and reasonably foreseeable actions, including projects and programs that are conducted, regulated, or approved by a federal agency. The analysis takes into account all actions, however minor, because the effects of individually minor actions may be significant when considered collectively over time. The goal of the cumulative effects analysis is to identify potentially significant impacts. The analysis considers the following factors with regards to the proposed action and past, present, and reasonably foreseeable actions:

The geographic region of influence on a resource which varies based upon resource or environmental effect that maybe experienced, as well as the distance.

The timeframe considers the incremental effects of the proposed action (license renewal) because these combined effects may accumulate or develop over time. Past and present actions include all actions up to and including the date of the license renewal request. The timeframe for the consideration of reasonably foreseeable actions is the 20-year license renewal (initial LR or SLR) term. Reasonably foreseeable actions include current and ongoing planned activities, approved, and funded for implementation.

The environmental effects from past and present actions are accounted for in baseline assessments presented in affected environment discussions and the incremental effects or impacts of the proposed action (license renewal).

The incremental effects of the proposed action (license renewal) when added to the effects from past, present, and reasonably foreseeable actions, and other actions result in the overall cumulative effect. A qualitative cumulative effects analysis is conducted in instances where the incremental effects of the proposed action (license renewal) and past, present, and reasonably foreseeable actions are uncertain or not well known.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 52 of 59 L-2024-182 Attachment 25 Page 52 of 59 For some resource areas (e.g., water resources, aquatic resources, and human health), the incremental contributions of ongoing actions within a region are managed and/or monitored through an established regulatory process (e.g., permitting process, NPDES) under State and/or Federal authority. In these cases, it may be assumed that cumulative effects are managed in their respective permits or licenses.

5. 13. 1.4 Analysis Cumulative effects may result when the environmental effects associated with the subsequent LR, the proposed action, are added to the environmental effects from other past, present, and reasonably foreseeable future actions, including project and programs that are conducted, regulated, or approved by a federal agency. Cumulative effects can result from individually minor, but collectively significant, actions taking place over a period of time. As discussed in the GEIS, the effects of the LR action, combined with effects of other actions, could generate cumulative effects on a given resource. For there to be a cumulative effect, the proposed action (LR) must have an incremental new, additive, or increased physical effect or impact on the resource or environmental condition beyond what is already occurring. The cumulative impacts analysis accounts for both geographic (spatial) and time (temporal) considerations of past, present, and reasonably foreseeable future actions to determine whether other potential actions are likely to contribute to the total environmental impact. (NRC 2024)

To determine projects or programs since the draft SEIS, a desktop review of relevant sites, including local government sites and newspapers, was performed to identify upcoming offsite projects in the PBN area.

As was discussed in the draft SEIS, two solar facilities, Two Creeks Solar Park, and Point Beach Solar, were being constructed or recently completed on the PBN site. Since the SEIS, construction has been completed and both solar facilities are operational as of November 2020 and September 2021, respectively. Although it is anticipated that an ISFSI pad expansion may be needed during the LR term, it will be within the ISFSl-defined area. In addition, no refurbishment activities have been identified to occur during the proposed SLR operating term.

There are no projects or programs identified that are planned in the vicinity of PBN that have the potential to result in a cumulative effect on the environment.

The draft SEIS discussed the effects of past actions that have already been described and accounted for in each resource-specific description of the affected environment, and any new effects since preparation of the SEIS, are provided with this supplemental information and serve as the environmental baseline for the cumulative effects analysis.

5.13.2 Conclusion In summary, no refurbishment has been identified that would occur during the proposed SLR operating term. In addition, no additional federal and non-federal projects have been identified as taking place in the vicinity of PBN. There are no projects or programs planned in the vicinity of PBN that have the potential to result in a cumulative effect on the environment, and thus the conclusion in the draft SEIS for continued operation of PBN for the renewal term is expected to have a SMALL impact remains valid.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 53 of 59 L-2024-182 Attachment 25 Page 53 of 59 5.14 Climate Change - Climate Change Impacts on Environmental Resources PBN SLR ER Section: New 5.14.1 Supplemental Information 5.14.1.1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table 8-1 Climate change can have additive effects on environmental resource conditions that may also be directly impacted by continued operations and refurbishment during the license renewal term. The effects of climate change can vary regionally and climate change information at the regional and local scale is necessary to assess trends and the impacts on the human environment for a specific location. The impacts of climate change on environmental resources during the license renewal term are location-specific and cannot be evaluated generically.

5.14.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(Q)J Applicants shall include an assessment of the effects of any observed and projected changes in climate on environmental resource areas that are affected by license renewal, as well as any mitigation measures implemented at the applicant's plant to address climate change impacts.

5.14. 1.3 Background [GEIS Section 4. 12.3]

Climate change is an environmental trend (i.e., change in climate indicators such as precipitation over time) that is irrespective of LR. Climate change could result in changes to the affected environmental resource baseline conditions. Future global greenhouse gas (GHG) emission concentrations (emission scenarios) and climate models are commonly used to project possible climate change. The Intergovernmental Panel on Climate Change and U.S. Global Change Research Program (USGCRP) indicate that over the longer term, the magnitude of temperature increases, and climate change related effects will depend on future global GHG emissions.

Climate parameters used as indications of climate change include temperature, precipitation, floods, storm frequency, and sea level rise. Trending of these climate parameters vary regionally and climate change information at the regional and local scale is necessary for assessing climate change impacts for LR. Climate change may impact the baseline environmental conditions (e.g., surface water temperature and levels) that are impacted by the proposed action (LR). For there to be a climate change impact on an environmental resource, the proposed action (LR) must have an incremental new, additive, or increased physical effect or impact on the resource or environmental condition beyond what is already occurring. The goal of the impacts of climate change on environmental resources analysis is to identify potentially significant impacts.

5.14.2 Analysis - Climate Change Climatic changes are occurring on a timescale of decades, rather than over millions of years as seen with prehistoric climates. Observed changes include increased surface water temperatures, decreased global glacier ice, increased sea levels, and changes in extreme weather events. Observed changes in climate and associated impacts have not been uniform across the United States. Globally, between 1901 and 2016, the average temperature increased by 1.8°F and precipitation increased by an average of 0.1 inch per decade. (NRC 2024)

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 54 of 59 5.14.2.1 National Trends in Climate Change L-2024-182 Attachment 25 Page 54 of 59 The USGCRP issued the Fourth National Climate Assessment, which contains climate model simulations of future conditions, which projects an increase in temperature and extreme precipitation. Climate models project climate change effects through the mid*21 st century and the late 21st century using representative concentrations pathways (RCP) scenarios. The RCP8.5 scenario, which is a "higher" scenario associated with more warming, most closely tracks with the U.S.'s current consumption of fossil fuels (USGCRP 2018). Climate model simulations of future conditions project an increase in temperature and extreme precipitation for both the RCP4.5, which is a "lower" scenario with less warming, and the RCP8.5 scenarios.

The Fifth National Climate Change Assessment illustrates that present temperatures are 1 to 1.5°F warmer than temperatures from the 1900-1950 time period. The projected changes in temperature are not presented temporally but rather as global warming scenarios. A global warming scenario presents spatial information based on a specific global warming level, which is the global average temperature change in degrees Celsius (°C) relative to preindustrial temperatures. Global temperature projections are presented as the year in which the 20-year global average temperature exceeds that of the preindustrial period by 2°C (3.6°F) or more.

Shared Socioeconomic Pathways (SSPs) are used instead of RCPs; the SSP scenarios are presented as SSP1-1.9 through SSP5-8.5 where the 1-1.9 and 5-8.5 pertain to a range of modeling inputs based on population growth and emission rates. Lower SSP values represent lower population growth and lower emission rates. Using the highest scenario (SSP5-85), the projected year in which the 20-year global average temperature exceed 2°c (3.6°F) is 2042.

(EPA 2017; USGCRP 2023)

All projection information in the Fifth National Climate Change Assessment uses the preindustrial period of 1850-1899 and the period of the first half of the last century (1900-1950) as a baseline for comparison, while the Fourth National Climate Change Assessment compares to the present day. (USGCRP 2018; USGCRP 2023) 5.14.2.2 Regional (Midwestern) Trends in Climate Change For the Midwest, by 2050, temperatures are expected to increase by 2°F to 3°F from the present-day values using the RCP4.5 scenario and by 3°F to 4°F for the RCP8.5 scenario (USGCRP 2018). Under the RCP4.5 scenario, average temperatures across Wisconsin would increase by over 4 °F by 2050. The University of Wisconsin has prepared models of climate change scaled to the state, rather than globally, to project how Wisconsin's climate has been changing and how it might change in coming years. The number of days with a maximum temperature of over 90°F is expected to increase to up to 20 days per year. Nights of minimum temperatures less than 0°F are expected to decrease from approximately 15 nights per year to 5 nights per year. (UW 2023) Temperatures are expected to exceed historical records, with the lowest projections predicted to be about 2°F warmer than the historical average by the year 2100. The hqttest projections are about 12°F warmer by the end of the century.

Extreme rainfall events have already increased in frequency and the numbers are expected to continue to climb. Observed average annual precipitation changed 10 to 15 percent more than the 1900-1950 time period. Projected precipitation change is expected to be 5 to 10 percent greater than preindustrial levels (1850-1899). (USGCRP 2023) Using higher emission models, precipitation in Wisconsin is expected to increase by 15 percent (NOAA 2022).

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 55 of 59 5.14.2.3 Potential Climate Change Impacts L-2024-182 Attachment 25 Page 55 of 59 Climate change may impact the environment in a way that affects resources important to continued reactor operations during the subsequent LR term. A climate change impact pathway exists if there is an incremental effect that is new, additive, or has an increased effect on a resource area beyond the baseline conditions. Changes in climate parameters and trends, such as temperature, precipitation, storm frequency, etc., can have an incremental effect on an environmental resource area. (NRC 2024)

In general, resource areas important to continued operations that can be affected by climate changes include air quality and water resources. Continued operation of the plant is not expected to have a reasonably foreseeable cumulative impact on other resource areas such as land use, visual resources, noise, geology, ecological resources, historic and cultural resources, human health, socioeconomics, environmental justice, and waste management.

Air Quality Climate change can impact air quality because of changes in meteorological conditions as air pollutant concentrations are sensitive to wind, temperature, humidity, and precipitation.

Ozone levels have been found to be particularly sensitive to climate change influences.

Sunshine, high temperatures, and air stagnation are favorable meteorological conditions leading to higher levels of ozone. As stated above, the number of days above 90°F is expected to increase, which could result in higher ozone levels. Although surface temperatures are expected to increase, ozone levels may not necessarily increase because ozone formation is also dependent on the number of precursors available. Manitowoc County is in attainment with the national ambient air quality standards for all criteria air pollutants with the exception of being classified as a maintenance area for 8-hour zone (2015) at the county's Lake Michigan shoreline (EPA 2023).

Because the fuel source for PBN does not produce carbon dioxide emissions or other GHG emissions including ozone precursors, the continued operation of PBN would avoid millions of tons of greenhouse gases from a fossil fuel-fired alternative such as the natural gas combined cycle alternative. As presented in PBN SLR ER Section 3.3.3.2, no future upgrade or replacement activities (e.g., diesel generators, diesel pumps) that would increase or decrease air emissions over the proposed SLR operating term were identified as necessary for plant operations (NEPB 2020a). PBN operates under Air Permit No. 436034500-P40. Appropriate permit conditions and air emissions regulatory requirements would regulate any future PBN activities.

PBN does not utilize cooling towers, or other cooling systems that rely on heat dissipation to the ambient air surrounding the PBN plant. As such, increased air temperature and humidity due to PBN is not a concern, and PBN is not expected to exacerbate conditions that allow for increased air pollutant concentrations at or around the plant. Even though climate change trends show an increasing number of days above 90°F, no changes to the cooling system, or other systems that would radiate heat, are anticipated during the SLR term, so continued operation of PBN would not cause a noticeable increase in ambient air temperature or humidity.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 56 of 59 Water Resources L-2024-182 Attachment 25 Page 56 of 59 Climate change can affect the availability of water resources due to changes in precipitation patterns; changes in surface water temperature; and additional competition for available resources (NRC 2013).

With the present and projected increase in temperature and precipitation and the increased frequency of extreme rainfall events, the potential of water resources impacts in the Midwest exists. However, due to the volume of water in Lake Michigan, water resource competition is not expected. Water levels in the Great Lakes fluctuate naturally, demonstrated by a period of low water levels from 1998 to early 2013, followed by a period of rapid water level rise; between January 2013 and December 2014, Lake Michigan's water level rose by approximately 3.3 feet.

Recent projections show, on average, a small drop in water levels over the 21st century, approximately 6 inches for Lake Michigan. (USGCRP 2018)

Summer surface water temperatures of the Great Lakes increased in many areas between 1994 and 2013. The greatest rates of increase in surface water temperatures occurred in deeper water, with smaller increases occurring near shorelines. Summer surface water temperatures have increased in many areas of the Great Lakes locally; however, summer surface water temperatures near PBN do not show an increasing or decreasing trend (USGCRP 2018).

PBN's thermal discharge is examined periodically through the WPDES permit renewal process.

PBN's WPDES permit establishes a thermal discharge limit in accordance with CWA 316(a) and PBN operates in compliance with the limit. PBN currently operates under WPDES Permit Wl-0000957-09-0, which limits waste heat rejected to Lake Michigan to a weekly average of 8,273 million British thermal units per hour (WDNR 2024a). As discussed in the PBN SLR ER Section 3.10.1, cooling water is introduced into the waters of Lake Michigan approximately 200 feet offshore. The momentum of the discharge velocity is sufficient to create a high degree of mixing with the lake surface water in the immediate vicinity. (NEPB 2020a) Adherence to these limits will avoid any potential impacts that would lead to surface water temperature increases in addition to that caused by regional climate change.

The size of Lake Michigan aids to mitigate the potential impacts due to changes in precipitation patterns, as well as reducing the likelihood that resource competition would occur. Additionally, PBN uses once-through cooling, which returns nearly all surface water withdrawals to Lake Michigan. As such, no significant impacts are expected from continued operation of PBN.

In addition to thermal discharge limits, PBN's WPDES permit also defines limits on discharge of chemicals and potential pollutants into Lake Michigan. Continued adherence to these limits would mitigate any potential impacts, regardless of how climate change affects Lake Michigan.

Any incremental changes due to water use and water quality impacts from PBN's discharge would not be discernable due to these factors.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 57 of 59 6.0 References L-2024-182 Attachment 25 Page 57 of 59 CDC (Center for Disease Control). 2024. Naegleria Fowleri - Case Reports by State of Exposure. Retrieved from <https://www.cdc.gov/parasites/naegleria/state-map.html> (accessed April 23, 2024).

EPA (U.S. Environmental Protection Agency). 2017. Updates to the Demographic and Spatial Allocation Models to Produce Integrated Climate and Land Use Scenarios (ICLUS) Version 2.

Retrieved from <https://assessments.epa.gov/iclus/document/&deid=3224 79> ( accessed January 15, 2024 ).

EPA. 2023. Nonattainment Areas for Criteria Pollutants (Green Book). Retrieved from

<https://www.epa.gov/green-book> (accessed January 15, 2024 ).

MCHD (Manitowoc County Health Department). 2021. Annual Report, 2020. Retrieved from

<https://manitowoccou ntywi.gov/wp-content/u ploads/2021 /05/M CH D-AN N UAL-REPORT-2020. docx. pdf> (accessed December 13, 2023).

MCHD. 2022. Annual Report, 2021. Retrieved from <https://manitowoccountywi.gov/wp-content/uploads/2022/03/MCHD-ANNUAL-REPORT-2021-1.pdf> (accessed December 13, 2023).

MCHD. 2023. Annual Report, 2022. Retrieved from <https://manitowoccountywi.gov/wp-content/uploads/2023/04/MCHD-ANNUAL-REPORT-2022.pdf> (accessed December 13, 2023).

MCHD. 2024. Annual Report, 2023. Retrieved from

<https://manitowoccountywi.gov/departments/health-department/reports/> ( accessed April 23, 2024).

NEPB. 2020a. Subsequent Operating License Renewal Point Beach Nuclear Plant Units 1 and 2, Appendix E, Applicant's Environmental Report. November 2020. ADAMS Accession No. ML20329A248.

NEPB. 2020b. Point Beach Nuclear Plant, Units 1 and 2, 2019 Annual Monitoring Report. April 2020. ADAMS Accession No. ML20119A481.

NEPB. 2021. Point Beach Nuclear Plant, Units 1 and 2, 2020 Annual Monitoring Report. April 2021. ADAMS Accession No. ML21119A257.

NEPB. 2022. Point Beach Nuclear Plant, Units 1 and 2, 2021 Annual Monitoring Report. April 2022. ADAMS Accession No. ML22104A074.

NEPB. 2023. Point Beach Nuclear Plant, Units 1 and 2, 2022 Annual Monitoring Report. April 2023. ADAMS Accession No. ML23101A021.

NOAA (National Oceanic and Atmospheric Administration). 2022. National Centers for Environmental Information. State Climate Summaries 2022. Wisconsin. Retrieved from

<https://statesummaries.ncics.org/chapter/fl/> (accessed January 4, 2024).

NRC. 2013. Generic Environmental Impact Statement for License Renewal of Nuclear Plants.

NUREG-1437, Vols. 1 and 2. Revision 1. June 2013. ADAMS Accession Package No.

ML13107A023.

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 L-2024-182 Attachment 25 Page 58 of 59 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 58 of 59 NRC. 2020. NRR Office Instruction No. LIC-203-Procedural Guidance for Preparing Categorical Exclusions, Environmental Assessments, and Considering Environmental Issues.

Revision 4. July 2020. ADAMS Accession No. ML20016A379.

NRC. 2021 a. Point Beach Nuclear Plant, Units 1 and 2 Subsequent License Renewal Application Requests for Confirmation of Information (RCI) Environmental Review. May 2021.

ADAMS Accession No. ML21134A061.

NRC. 2021 b. Draft Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Subsequent License Renewal for Point Beach Nuclear Plant Units 1 and 2. NUREG-1437 Supplement 23, Second Renewal. November 2021. ADAMS Accession No. ML21306A226.

NRC. 2024. Preparation of Environmental Reports for Nuclear Power Plant License Renewal Applications. Regulatory Guide 4.2, Supplement 1, Revision 2. August 2024. ADAMS Accession.

Package No. ML23201A144.

USCB (U.S. Census Bureau). 2020a. Place Data, PL 94-171 Retrieved from

<https://data.census.gov/cedsci/> (accessed January 25, 2024).

USCB. 2020b. Minority. Wisconsin. PL 94-171. Retrieved from

<https://data.census.gov/cedsci/> (accessed January 25, 2024 ).

USCB. 2020c. County Data. PL 94-171. Retrieved from <https://data.census.gov/cedsci/>

(accessed January 25, 2024).

USCB. 2020d. Low Income. Wisconsin. ACS 5-year 2020. Retrieved from

<https://data.census.gov/cedsci/> (accessed January 25, 2024).

USCB. 2022a. Place, ACS 5-Year 2022. Retrieved from <https://data.census.gov/cedsci/>

(accessed January 25, 2024).

USCB. 2022b. Two Creeks, Incorporated Places and Minor Civil Divisions. Retrieved from

<https://data.census.gov/cedsci/> (accessed January 24, 2024 ).

USCB. 2022c. Low Income and Minority. Wisconsin. ACS 5-Year 2022. Retrieved from

<https://data.census.gov/cedsci/> (accessed January 25, 2024).

USCB. 2022d. County Data. ACS 5-Year 2022. Retrieved from

<https://data.census.gov/cedsci/> (accessed January 25, 2024 ).

USFWS (U.S. Fish and Wildlife Service). 2023. Tricolored bat. Retrieved from

<https://www.fws.gov/species/tricolored-bat-perimyotis-subflavus> (accessed December 18, 2023).

USGCRP (U.S. Global Change Research Program). 2018. Fourth National Climate Assessment. Volume II Impacts, Risks, and Adaptation in the United States. Retrieved from

<nca2018.globalchange.gov> (accessed January 16, 2024).

USGCRP. 2023. Fifth National Climate Assessment. Chapter 2 (full), Chapter 24, Midwest (Key Messages). Retrieved from <https://nca2023.globalchange.gov/> (accessed January 16, 2024).

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Point Beach Nuclear Plant Units 1 and 2 SLRA Appendix E - Environmental Report Additional Information Page 59 of 59 L-2024-182 Attachment 25 Page 59 of 59 UVM (University of Wisconsin-Madison). 2024. Population Projections. Retrieved from

<https://apl.wisc.edu/services#estimates> (accessed January 24, 2024 ).

UW (University of Wisconsin). 2023. Wisconsin Initiative on Climate Change Impacts. Trends and Projections. Retrieved from <https://wicci.wisc.edu/wisconsin-climate-trends-and-projections/> (accessed January 10, 2024).

WDHS (Wisconsin Department of Health Services). 2022. Waterborne Illness: Primary Amebic Meningoencephalitis (PAM). Retrieved from

<https://www.dhs.wisconsin.gov/water/pam.htm#:-:text=No%20cases%20of%20PAM%20have

%20ever%20been%20seen%20in%20Wisconsin> (accessed January 4, 2024).

WDNR (Wisconsin Department of Natural Resources). 2023. Wisconsin Department of Natural Resource Water Permit Application Site. Crane Pad Permit. Retrieved from

<https://permits.dnr.wi.gov/water/SitePages/Permit%20Search.aspx> (accessed November 20, 2023).

WDNR. 2024a. Wisconsin Pollutant Discharge Elimination System. WPDES Permit. Retrieved from <https://apps.dnr.wi.gov/potw/> (accessed November 26, 2024).

WDNR. 2024b. Beach Reports. Retrieved from <https://apps.dnr.wi.gov/beachhealth/>

(accessed April 23, 2024).

Revision 1 November 2024

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RAJ No. LV-1 L-2024-182 Attachment 26 Page 1 of 1 Land Use and Visual Resources (LV)

NRC RAI Number: LV-1 REQUIREMENT: Section 307(c)(3)(A) of the Coastal Zone Management Act of 1972, as amended (CZMA) (16 U.S.C. 1456(c)(3)(A)) requires that applicants for Federal licenses who conduct activities in a coastal zone provide a certification to the licensing agency (here, the NRC) that the proposed activity complies with the enforceable policies of the State's coastal zone program. The CZMA implementation regulations are applicable to renewal of Federal licenses for actions not previously reviewed by the State (15 CFR 930.51 (b )(1 )).

ISSUE: Section 3.2.1.2 of the 2021 draft SEIS states, in part, that NextEra submitted a CZMA consistency certification package to the Wisconsin Coastal Management Program (WCMP) in support of Point Beach SLR. As of publication of the draft SEIS, the NRC had not been notified that the WCMP concurred with the submittal. During the audit, NRC staff reviewed a letter from the WCMP responding to NextEra's request.

REQUEST: Provide a copy of the letter from the WCMP (dated March 26, 2021) for docketing.

NEPB Response:

A copy of the letter from the State of Wisconsin Department of Administration (WDOA) regarding the WCMP, dated March 26, 2021, is provided as Enclosure 1.

References:

None.

Associated

Enclosures:

1. WDOA. 2021. Letter from Kate Angel, WCMP, to Richard Orthen,

Subject:

Wisconsin Coastal Management Program: Point Beach Consultation. March 2021.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 L-2024-182 Attachment 26 Page 1 of 1 STATE OF WISCONSIN DEPARTMENT OF ADMINISTRATION DEPARTMENT OF ADMINISTRATION Q£J March 26, 2021 Richard F. Orth en, Principal Licensing Engineer NextEra Energy, Inc.

Florida Power & Light Company 700 Universe Boulevard Juno Beach, Florida 33408 Tony Evers, Governor Joel Brennan, Secretary Dawn Vick, Division Administrator RE:

Wisconsin Coastal Management Program: Point Beach Consultation Mr. Orthen:

Thank you for contacting the Wisconsin Coastal Management Program {WCMP) about Point Beach Nuclear Plant' s license renewal with the Nuclear Regulatory Commission and the consultations you are undertaking with Wisconsin state agencies. Through its federal consistency process, WCMP reviews federally-affiliated projects that may affect coastal resources. As I mentioned in our correspondence, I have had conversations with staff at the Wisconsin Department of Natural Resources (DNR) and the Wisconsin State Historic Preservation Office (SHPO).

Provided that NextEra Energy and NRC continue to consult with SHPO to meet any of their conditions and that any discharges are covered by the WPDES permit (as communicated with DNR}, WCMP has no comments on the project and will not conduct a formal federal consistency review. This does not exempt the project from any other required state or local permits..

Please let me know if you have any questions or concerns. You can reach me at kathleen.angel@wisconsin.gov or 608-267-7988.

Sincerely, Kate Angel Wisconsin Coastal Management Program Tracy Brunner, ERM Wisconsin Coastal Management Program, PO Box 8944, Madison WI 53708 coastal@wisconsin.gov I (608) 267-7982 I coastal.wisconsin.gov

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RAI No. FPE-1 L-2024-182 Attachment 27 Page 1 of 2 Federally Protected Ecological Resources (FPE)

NRC RAI Number: FPE-1 REQUIREMENT: Licensees are required by 10 CFR 51.53(c)(3)(ii)(E) to assess the impact of refurbishment, continued operations, and other license renewal-related construction activities on important plant and animal habitats. Additionally, the applicant shall assess the impact of the proposed action on threatened or endangered species in accordance with Federal laws protecting wildlife, including but not limited to the Endangered Species Act (ESA). Additionally, the ESA regulations at 10 CFR 402.10 require Federal agencies to confer with the U.S. Fish and Wildlife Service (FWS) concerning species proposed for Federal listing under ESA Section

7.

ISSUE: In 2020, the FWS issued a 12-month finding announcing its intent to prepare a proposed rule to list the monarch butterfly as threatened (85 FR 81813). In 2022, the FWS identified the monarch butterfly listing action as a priority (87 FR 26152). This species' range includes Manitowoc County.

REQUEST: Provide an analysis of the potential impacts of Point Beach SLR on the monarch butterfly.

NEPB Response:

As requested, NEPB provides the following assessment for the Monarch butterfly (Danaus p/exippus).

The monarch butterfly is listed as a candidate species under the Endangered Species Act (ESA). Adult monarch butterflies are large and conspicuous, with bright orange wings surrounded by a black border and covered with black veins. The black border has a double row of white spots, present on the upper side of the wings. Adult monarchs feed on the nectar of many flowers during breeding and migration, but they only lay eggs on obligate milkweed host plants (primarily Asc/epias spp.). For overwintering monarchs, habitat with a specific microclimate is needed for protection from the elements, as well as moderate temperatures to avoid freezing. Monarch butterflies require healthy and abundant milkweed plants for laying eggs on and as a food source for larvae or caterpillars. By consuming milkweed plants, monarchs obtain toxins, called cardenolides, that provide a defense against predators.

Additionally, nectar from flowers is needed for adults throughout the breeding season, migration, and overwintering. Monarchs are native to North America and South America but have since spread to many other locations where milkweed and suitable temperatures exist. (USFWS 2024a)

The primary drivers affecting the health of the two North American migratory monarch populations are changes in breeding, migratory, and overwintering habitat (due to conversion of grasslands to agriculture, urban development, widespread use of herbicides, logging/thinning at

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RAI No. FPE-1 L-2024-182 Attachment 27 Page 2 of 2 overwintering sites in Mexico, unsuitable management of overwintering groves in California, and drought), continued exposure to insecticides, and effects of climate change. (USFWS 2024b).

According to the U.S. Fish and Wildlife Service (USFWS), the current known range of the monarch butterfly extends across the contiguous United States and overlaps with the PBN site.

(USFWS 2024a). A review of the Wisconsin Department of Natural Resources' (WDNR)

Wisconsin Natural Heritage Inventory species observation data yielded no observations of monarch butterflies or milkweed at the county level for Manitowoc and Kewaunee Counties (WDNR 2024). Although suitable milkweed habitat could be present in unmanaged areas of PBN, there have been no observations or records of these host plants onsite. Further, no construction, land clearing, or other ground-disturbing activities are planned for the proposed SLR term, and all PBN station operations are in already developed areas. Continued utilization of best management practices with respect to herbicide use (such as using licensed external contractors) will minimize impacts on any suitable habitats at PBN. Compliance with all regulatory requirements associated with protected species will continue to be an administrative control practiced by NextEra Energy for the licensed life of the PBN facility. Adherence to these controls, as well as compliance with applicable laws and regulations, should prevent potentially negative impacts to this species. Hence the continued operation of the PBN site for the proposed operating term will have NO EFFECT on the monarch butterfly.

References:

USFWS (U.S. Fish and Wildlife Service). 2024a. Monarch Butterfly. Retrieved from

<https://ecos.fws.gov/ecp/species/9743> (accessed on September 16, 2024).

USFWS. 2024b. Monarch Butterfly. Retrieved from

<https://www.fws.gov/initiative/pollinators/monarchs> (accessed on September 16, 2024 ).

WDNR (Wisconsin Department of Natural Resources). 2024. Natural Heritage Inventory County Data. Retrieved from <https://dnrx.wisconsin.gov/nhiportal/public/data/county> (accessed on September 16, 2024 ).

Associated

Enclosures:

None.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Response to NRC RAI No. GHG-CC-3 L-2024-182 Attachment 28 Page 1 of 1 Greenhouse Gas Emissions and Climate Change (GHG-CC)

NRC RAI Number: GHG-CC-3 REQUIREMENT: 10 CFR 51.53(c)(3)(ii)(Q) states that applicants shall include an assessment of the effects of any observed and projected changes in climate on environmental resource areas that are affected by license renewal.

ISSUE: During the audit, NRC staff reviewed and discussed additional information prepared in response to audit need GHG-CC-3, that indicates, in part, that summer surface water temperature near the plant shows no increasing or decreasing trend. However, site-specific data was not provided to support this finding.

REQUEST: Provide time-series figures of average monthly intake temperatures and average monthly seasonal intake temperatures for the available period of record. Additionally, provide a discussion and any relevant information as to whether any warming trend has been observed.

NEPB Response:

A time series figure of the PBN average monthly intake temperatures for 2002 through 2024 is provided in Enclosure 1. The PBN average monthly seasonal intake temperatures for 2002 through 2024 figure is provided in Enclosure 2.

The dataset has a few monthly gaps that can be seen in the graphs provided during 2005 and 2006. Summer intake temperatures fluctuate between years as much as 19 degrees F and the period of record is too short to be used for assessing climate change trends. As illustrated in the graphs, spring and fall intake temperatures demonstrate less fluctuation. A warming trend for PBN is not evident in the data.

References:

None.

Associated

Enclosures:

1. PBN Average Monthly Intake Temperatures 2002-2024.

2. PBN Average Monthly Seasonal Intake Temperatures for 2002-2024.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 L-2024-182 Attachment 28 Page 1 of 1 PBN Average Monthly Intake Temperatures 2002-2024 I

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Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 L-2024-1 82 Attachment 28 Page 1 of 1 PBN Average Monthly Seasonal Intake Temperatures 2002-2024 0

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L-2024-182, Subsequent License Renewal Application Environmental Review Supplemental Environmental Audit December 2, 2024 L-2024-182 10 CFR 54 Response to Requests for Confirmation of Information and Requests for Additional Information

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