RS-24-105, Attachment: Peach Bottom Atomic Power Station Units 2 and 3 Subsequent License Renewal Environmental Report Additional Information

Attachment: Peach Bottom Atomic Power Station Units 2 and 3 Subsequent License Renewal Environmental Report Additional Information

ML24319A076
Person / Time
Site:	Peach Bottom
Issue date:	11/14/2024
From:	Constellation Energy Generation
To:	Office of Nuclear Reactor Regulation
Shared Package
ML24319A074	List: ML24319A075 RS-24-105, Attachment: Peach Bottom Atomic Power Station Units 2 and 3 Subsequent License Renewal Environmental Report Additional Information
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RS-24-105
Download: ML24319A076 (1)

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Peach Bottom Atomic Power Station Units 2 and 3 Subsequent License Renewal Environmental Report Additional Information November 2024

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 1 of 78 Table of Contents Table of Contents........................................................................................................................ 1 List of Tables............................................................................................................................... 2 List of Figures.............................................................................................................................. 2 Abbreviations, Acronyms, and Symbols....................................................................................... 3 1.0 Introduction........................................................................................................................ 5 2.0 Proposed Action Changes................................................................................................. 5 3.0 Updated Environmental Authorizations.............................................................................. 6 4.0 Category 1 Evaluation..................................................................................................... 11 5.0 Category 2 Evaluation..................................................................................................... 11 5.1 Surface Water Resources - Surface Water Use Conflicts (Plants with Cooling Ponds or Cooling Towers Using Makeup Water from a River)........................ 14 5.2 Groundwater Resources - Groundwater Use Conflicts (Plants with Closed-Cycle Cooling Systems That Withdraw Makeup Water from a River).............. 20 5.3 Groundwater Resources - Radionuclides Released to Groundwater.......................... 22 5.4 Terrestrial Resources - Water Use Conflicts with Terrestrial Resources (Plants with Cooling Ponds or Cooling Towers Using Makeup Water from a River)................ 27 5.5 Terrestrial Resources - Non-Cooling System Impacts on Terrestrial Resources........ 29 5.6 Aquatic Resources - Impingement Mortality and Entrainment of Aquatic Organisms (Plants with Once-Through Cooling Systems or Cooling Ponds)............... 31 5.7 Aquatic Resources - Effects of Thermal Effluents on Aquatic Organisms (Plants with Once-Through Cooling Systems or Cooling Ponds)............................................. 34 5.8 Aquatic Resources - Water Use Conflicts with Aquatic Resources (Plants with Cooling Ponds or Cooling Towers Using Makeup Water from a River)................ 37 5.9 Federally Protected Ecological Resources - Endangered Species Act:

Federally Listed Species and Critical Habitats Under U.S. Fish and Wildlife Service Jurisdiction...................................................................................................... 39 5.10 Federally Protected Ecological Resources - Endangered Species Act:

Federally Listed Species and Critical Habitats Under National Marine Fisheries Service Jurisdiction...................................................................................................... 43 5.11 Federally Protected Ecological Resources - Magnuson-Stevens Act:

Essential Fish Habitat.................................................................................................. 45 5.12 Federally Protected Ecological Resources - National Marine Sanctuaries Act:

Sanctuary Resources.................................................................................................. 47 5.13 Historic and Cultural Resources.................................................................................. 49 5.14 Human Health - Microbiological Hazards to the Public............................................... 51 5.15 Human Health - Electric Shock Hazards..................................................................... 54

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 2 of 78 5.16 Environmental Justice - Impacts on Minority Populations, Low-income Populations, and Indian Tribes.................................................................................... 57 5.17 Cumulative Effects....................................................................................................... 65 5.18 Climate Change - Climate Change Impacts on Environmental Resources................. 69 6.0 References...................................................................................................................... 74 List of Tables Table 3.0-1 Environmental Authorizations for Current PBAPS Operations.............................. 7 Table 5.0-1 GEIS Category 2 Issues Applicable to PBAPS SLR ER..................................... 12 Table 5.1-1 Average and Peak Daily Withdrawal Rates (MGD) by Month in 2018-2023...................................................................................................... 18 Table 5.1-2 Average and Peak Daily Consumptive Use Rates (MGD) by Month in 2018-2023...................................................................................................... 19 Table 5.3-1 RGPP Groundwater Monitoring Well and Yard Drain Sump Sampling............... 24 Table 5.16-1 Minority Populations........................................................................................... 62 Table 5.16-2 Low-Income Populations.................................................................................... 63 List of Figures Figure 5.15-1 PBAPS In-Scope Transmission Lines............................................................... 56

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 3 of 78 Abbreviations, Acronyms, and Symbols T

change in temperature

°C degrees Celsius

°F degrees Fahrenheit 7Q10 7-day average flow occurring every ten years ACS American Community Survey APE area of potential effect AREOR Annual Radiological Environmental Operating Report BTA best technology available CEG Constellation Energy Generation, LLC cfs cubic feet per second CO2 carbon dioxide CUMP consumptive use mitigation plan CWA Clean Water Act DOE U.S. Department of Energy EFH essential fish habitat EGC Exelon Generation Company, LLC EPA U.S. Environmental Protection Agency EPU extended power uprate ER environmental report ESA Endangered Species Act FERC Federal Energy Regulatory Commission GEIS Generic Environmental Impact Statement for License Renewal of Nuclear Plants. NUREG-1437, Volume 1, Revision 2, Final, August 2024 GHG greenhouse gas GWL global warming level gpm gallons per minute HAPC habitat area of particular concern IM&E impingement mortality and entrainment ISFSI independent spent fuel storage installation LLD lower limits of detection LR license renewal MCL maximum contaminant level MGD million gallons per day MW Megawatts NCA National Climate Assessment NEI 07-07 Nuclear Energy Institute Industry Groundwater Protection Initiative, Final Guidance Document NESC National Electric Safety Code NHPA National Historic Preservation Act NMFS National Marine Fisheries Service NMSA National Marine Sanctuaries Act NOAA National Oceanic and Atmospheric Administration

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 4 of 78 NPDES National Pollutant Discharge Elimination System NRC U.S. Nuclear Regulatory Commission OSHA Occupational Safety and Health Administration ONMS Office of National Marine Sanctuaries PA DEP Pennsylvania Department of Environmental Protection PBAPS Peach Bottom Atomic Power Station pCi/L picocuries per liter RGPP radiological groundwater protection program ROW right-of-way SBO station blackout SEIS Generic Environmental Impact Statement for License Renewal of Nuclear Plants, NUREG-1437, Supplement 10, Second Renewal, Regarding Subsequent License Renewal for Peach Bottom Atomic Power Station Units 2 and 3 SLR subsequent license renewal SRBC Susquehanna River Basin Commission STP sewage treatment plant USCB United States Census Bureau USFWS U.S. Fish and Wildlife Service USGCRP U.S. Global Change Research Program

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 5 of 78 1.0 Introduction This document serves to provide additional information to the July 2018 Applicants Environmental Report - Subsequent Operating License Renewal Stage, Peach Bottom Atomic Power Station Units 2 and 3 (PBAPS) is provided by Constellation Energy Generation, LLC (CEG) to:

Provide an updated status on the PBAPS Units 2 and 3 permits, licenses, and authorizations.

Provide results of the review of potentially new and significant information since the submittal of the 2018 PBAPS Subsequent License Renewal (SLR) Environmental Report (ER), and the United States Nuclear Regulatory Commissions (NRC) audit concerning the SLR ER, conducted November 2018, regarding Category 1 issues, and to compare to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Revision 2, Final (GEIS).

Provide review of potentially new and significant information since the submittal of the SLR ER and NRCs audit concerning the SLR ER regarding Category 2 issues contained in the GEIS.

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

A point of reference for the PBAPS 2018 SLR ER has been provided after each Chapter 5 section heading.

2.0 Proposed Action Changes Since the PBAPS SLR ER and the NRCs Supplemental Environmental Impact Statement (SEIS), there have been no changes in onsite land use or leases. CEG continues to have no plans for refurbishment activities at PBAPS. There have been no changes or upgrades to plant systems implemented in 2018 and later or that are currently planned that would increase or decrease plant emissions (air or water) or waste quantities. The following are changes to plant structures, systems, or operations planned, ongoing, or completed.

Completed project at the in-scope transmission line, 3SU, to install buried cable Ongoing installation of a packaged sewage treatment plant (STP) near the current treatment plant To accommodate spent fuel beyond 2034, a third independent spent fuel storage installation (ISFSI) pad would be needed if the U.S. Department of Energy (DOE) has not begun taking ownership of commercial spent fuel by the time the additional storage is needed. An expansion of the ISFSI was not considered as a project in the cumulative impacts analysis in ER Section 4.12 because the need had not yet been determined. Should CEG need to go forward with a third ISFSI pad, CEG would conduct a siting study to identify candidate sites within PBAPSs site licensed by the NRC (the host area required by 10 CFR 72.106, for an ISFSI general license under 10 CFR 72.210). The site selection process would consider regulations for, and commitments to, the protection of endangered species, wetlands, and archeological findings.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 6 of 78 3.0 Updated Environmental Authorizations Table 3.0-1 provides an update to the PBAPS SLR ER Table 9.1-1.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 7 of 78 Table 3.0-1 Environmental Authorizations for Current PBAPS Operations Agency Authority Requirement Number Expiration Date Authorized Activity NRC Atomic Energy Act

[10 CFR Part 50]

License to operate DPR-44 (Unit 2) 8/8/2033 Operation of PBAPS Unit 2 NRC Atomic Energy Act

[10 CFR Part 50]

License to operate DPR-56 (Unit 3) 7/2/2034 Operation of PBAPS Unit 3 NRC Atomic Energy Act

[10 CFR Part 72, Subpart K]

License to operate under General License Not applicable Included under Units 2 and 3 operation licenses Operation of PBAPS ISFSI Pennsylvania Department of Environmental Protection (PA DEP)

Clean Water Act Section 402 [33 USC 1341],

Pennsylvania Clean Streams Law (35 Pennsylvania Statutes Section 691.1 et seq.), 25 Pa. Code Chapters 92a and 93 Individual Discharge Permit PA 0009733 9/30/2014, administratively extended; NPDES permit renewal application was submitted in 2019 Discharge into Susquehanna River under the Pennsylvania NPDES permit PA DEP Water and Wastewater Systems Operators Certification Act (63 P.S. §§ 1001 to 1015.1)

Operator License S24890 9/20/2026 Authorized to operate Class B wastewater system

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 8 of 78 Table 3.0-1 Environmental Authorizations for Current PBAPS Operations Agency Authority Requirement Number Expiration Date Authorized Activity PA DEP Clean Water Act Section 401 [33 USC 1341]

Certification of water quality standards PA DEP File No. EA 67-024 Issued on 7/23/2014 for EPU; PA DEP confirmed it is valid for the SLR (see correspondence in PBAPS SLR ER Appendix D)

Compliance with applicable state water quality standards Federal Energy Regulatory Commission Federal Power Act (16 USC Section 10(a)(1))

Authorization for use of Conowingo Hydroelectric Project lands and waters 152 FERC 62,142 Issued 9/2/2015.

Indefinite until system is modified Non-project consumptive use of Conowingo Reservoir water Susquehanna River Basin Commission Susquehanna River Basin Compact (PL91-575). 18 CFR 803 Authorization for consumptive water use Docket 20061209-1 7/3/2034 Consumptive use of Conowingo Pond water PA DEP Clean Air Act (42 USC 7661 et seq.)

Air Pollution Control Act (25 Pa.

Code Chapter 127)

PA State Only Operating Permit -

Synthetic Minor 67-05020 3/31/2025 Operation of air emission sources PA DEP Storage Tank and Spill Prevention Act (Act 32) (25 Pa.

Code Chapter 245)

Pennsylvania Registration 67-60412 Renewed annually Use of storage tanks located at PBAPS (gasoline, used oil, hazardous substances, unlisted materials)

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 9 of 78 Table 3.0-1 Environmental Authorizations for Current PBAPS Operations Agency Authority Requirement Number Expiration Date Authorized Activity PA DEP Pennsylvania Safe Drinking Water Act (35 Pennsylvania Statutes Sections 7.21.1-7.21-17)

(25 Pa. Code Chapter 109)

Operator License W23604 9/30/2027 Authorized to operate Class A, E water system PA DEP Pennsylvania Safe Drinking Water Act (35 Pennsylvania Statutes Sections 7.21.1-7.21-17)

(25 Pa. Code Chapter 109)

Permit for public water supply 6709503 Issued: 9/22/2011 Indefinite (valid until system is modified)

Public Water Supply PA DEP Submerged Lands License Agreement (25 Pa. Code Chapter 105)

License to occupy submerged land in the Susquehanna River E67-503 Indefinite (valid until system is modified)

Occupation of Submerged Lands of the Commonwealth PA DEP Resource Conservation and Recovery Act (42 U.S.C. 6901 et seq.), 40 CFR 262.12, 25 Pa.

Code 262.12 Hazardous Waste Generator Registration PAD000798132 One time issuance Hazardous waste generation

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 10 of 78 Table 3.0-1 Environmental Authorizations for Current PBAPS Operations Agency Authority Requirement Number Expiration Date Authorized Activity U.S. Department of Transportation

[49 USC 5180 (49 CFR Part 107, Subpart G)]

Registration 051022550113EG 6/30/2025 Hazardous material shipments Utah Department of Environmental Quality U.A.C. R313-26, U.A.C. R313 100 Permit to Deliver Radioactive Material 0112001213 5/23/2025; Renewed annually Radioactive waste shipments to land disposal facility in Utah Tennessee Department of Environment and Conservation TDEC Rule 0400-20-10-.32 License to ship radioactive material T-PA005-L24 12/31/2024 Shipment of radioactive material to a licensed disposal/processing facility in Tennessee

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 11 of 78 4.0 Category 1 Evaluation CEG conducted a new and significant information review for Category 1 issues, including the new issue of greenhouse gas (GHG) impacts on climate change and the recategorized severe accidents issue. CEG did not identify any new and significant information regarding the Category 1 issues during its preparation of this Supplement to the 2018 Environmental Report.

Therefore, the conclusions regarding impacts of the Category 1 issues in the GEIS are considered appropriate for the PBAPS SLR ER, are incorporated herein by reference, and impacts related to Category 1 issues do not need further analysis.

5.0 Category 2 Evaluation CEG conducted a new and significant information review for Category 2 issues previously reviewed in the PBAPS SLR ER. The Category 2 issue of groundwater quality degradation due to cooling ponds as revised by the GEIS continues to be not applicable. In addition, the Category 2 issue of groundwater conflicts for plants that withdraw more than 100 gallons per minute (gpm) continues to be not applicable. The new Category 2 issue of impacts to National Marine Sanctuaries is not applicable because PBAPS is not a coastal plant. CEG conducted a plant-specific environmental assessment for the new Category 2 climate change impacts issue.

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.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 12 of 78 Table 5.0-1 GEIS Category 2 Issues Applicable to PBAPS SLR ER Resource Issue ER Section Delta GEIS Rev 1/2 Y/N/NA N&S Info Y/N/NEW Surface Water Resources Surface Water Use Conflicts (Plants with Cooling Ponds or Cooling Towers Using Makeup Water from a River) 4.5.1 N

N Groundwater Resources Groundwater Use Conflicts (Plants that Withdraw More Than 100 gpm) 4.5.2.1 N

N Groundwater Use Conflicts (Plants with Closed-Cycle Cooling Systems that Withdraw Makeup Water from a River) 4.5.2.2 N

N Radionuclides Released to Groundwater 4.5.2.4 N

N Terrestrial Resources Non-Cooling System Impacts on Terrestrial Resources 4.6.1.1 N

N Water Use Conflicts with Terrestrial Resources (Plants with Cooling Ponds or Cooling Towers Using Makeup Water from a River) 4.6.1.2 N

N Aquatic Resources Impingement Mortality and Entrainment of Aquatic Organisms (Plants with Once-Through Cooling Systems or Cooling Ponds) 4.6.2.1 Y

N Effects of Thermal Effluents on Aquatic Organisms (Plants with Once-Through Cooling Systems or Cooling Ponds) 4.6.2.2 N

N Water Use Conflicts with Aquatic Resources (Plants with Cooling Ponds or Cooling Towers Using Makeup Water from a River) 4.6.2.3 N

N

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 13 of 78 Table 5.0-1 GEIS Category 2 Issues Applicable to PBAPS SLR ER Resource Issue ER Section Delta GEIS Rev 1/2 Y/N/NA N&S Info Y/N/NEW Federally Protected Ecological Resources Endangered Species Act: Federally Listed Species and Critical Habitats under U.S. Fish and Wildlife Service Jurisdiction 4.6.3 Y

N Endangered Species Act: Federally Listed Species and Critical Habitats under National Marine Fisheries Service Jurisdiction 4.6.3 Y

N Magnuson-Stevens Act: Essential Fish Habitat 4.6.3 Y

N National Marine Sanctuaries Act: Sanctuary Resources NEW NEW NEW 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 Environmental Justice Impacts on Minority Populations, Low-income Populations, and Indian Tribes 4.10.1 Y

N Cumulative Effects Cumulative Effects 4.12 N

N Greenhouse Gas Emissions and Climate Change Climate Change Impacts on Environmental Resources NEW NEW NEW

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 14 of 78 5.1 Surface Water Resources - Surface Water Use Conflicts (Plants with Cooling Ponds or Cooling Towers Using Makeup Water from a River)

PBAPS SLR ER Section 4.5.1 5.1.1 Supplemental Information 5.1.1.1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table B-1 SMALL or MODERATE. Impacts could be of small or moderate significance, depending on makeup water requirements, water availability, and competing water demands.

5.1.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(A)]

If the applicant's plant utilizes cooling towers or cooling ponds and withdraws makeup water from a river, an assessment of the impact of the proposed action on water availability and competing water demands, the flow of the river, and related impacts on stream (aquatic) and riparian (terrestrial) ecological communities must be provided. The applicant shall also provide an assessment of the impacts of the withdrawal of water from the river on alluvial aquifers during low flow.

5.1.1.3 Background [GEIS Section 4.5.1.1.9]

Nuclear power plant cooling systems may compete with other users relying on surface water resources, including downstream municipal, agricultural, or industrial users. Nuclear plant cooling system configurations vary across different plant sites, requiring consideration of the site-and plant-specific factors affecting consumptive water use and which could result in surface water use conflicts.

This issue concerns consumptive water use impacts from nuclear power plants using closed-cycle (also known as recirculating) cooling systems. Closed-cycle cooling is not completely closed, because the system discharges blowdown water to a surface water body and withdraws water for makeup of both the consumptive water loss due to evaporation and drift (for cooling towers) and blowdown discharge. For plants using cooling towers, while the volume of surface water withdrawn is substantially less than once-through systems for a similarly sized nuclear power plant, the makeup water needed to replenish the consumptive loss of water to evaporation can be substantial. Consumptive water use in thermoelectric power plants with recirculating cooling systems can be up to 74 percent of the withdrawal flow rate. Cooling ponds will also require makeup water as a result of naturally occurring evaporation, evaporation of the warm effluent, the potential need for periodic blowdown to maintain pond chemistry, and possible seepage to groundwater.

Consumptive use by plants with cooling ponds or cooling towers using makeup water from a river during the license renewal term is not expected to change unless power uprates, with associated increases in water use, occur. Such uprates would normally require a separate environmental review by the NRC. Any river, regardless of size, can experience low flow conditions of varying severity during periods of drought and changing conditions in the affected watershed, such as upstream diversions and use of river water. However, the potential for direct impacts on instream flow and potential availability for other users from nuclear power plant surface water withdrawals are greater for smaller (i.e., low flow) rivers.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 15 of 78 Increased temperatures and/or decreased rainfall would result in lower river flows, increased cooling pond evaporation, and lowered water levels in lakes or reservoirs. Regardless of overall climate change, droughts could result in problems with water supplies and allocations. Conflicts might arise due to competing agricultural, municipal, and industrial user demands for surface water with power plants. Closed-cycle cooling systems are more susceptible to these issues than once-through cooling systems because they consume more water per unit volume of water withdrawn from the water source. For this reason, climate change is more of a potential concern for water use conflicts associated with nuclear power plants with closed-cycle cooling systems.

Population growth around nuclear power plants has caused increased demand on municipal water systems, including systems that rely on surface water. Municipal intakes located downstream from a nuclear power plant could experience water shortages, especially in times of drought. Similarly, water demands upstream from a plant could impact the water availability at the plants intake.

Potential water use conflicts have been documented for nuclear power plants with closed-cycle cooling systems. State regulatory agencies have imposed surface water withdrawal limits on a number of operating nuclear power plants with cooling towers and cooling ponds.

Water use conflicts associated with plants with cooling ponds or cooling towers using makeup water from a river are considered to vary among sites because of differing site-specific factors, such as makeup water requirements, water availability (especially in terms of varying river flow rates), changing or anticipated changes in population distributions, or changes in agricultural or industrial demands.

Based on this evaluation, the NRC concludes that surface water use conflicts from the continued operation of nuclear power plants with cooling ponds or cooling towers using makeup water from a river could be SMALL or MODERATE during the initial LR and SLR terms, depending on factors such as plant-specific design characteristics affecting consumptive water use, the characteristics of the waterbody serving as the source for makeup water, and the amount of competing use for that water.

5.1.1.4 Analysis PBAPS operates an open-cycle, once-through circulating water system equipped with helper open-cycle cooling towers (EGC 2018). The PBAPS National Pollutant Discharge Elimination System (NPDES) permit requires operating one or more cooling towers each year on June 15 through August 31 based on intake temperatures. In addition, PBAPS will operate the towers September 1 through September 30 per agreement with PA DEP based on 48-hour averages as follows: operate one tower when the river temperature is equal to or greater than 81°F, operate two towers when the river temperature is equal to or greater than 83°F, and operate three towers when the river temperature is equal to or greater than 86°F. As much as 60 percent of cooling water may be diverted through forced-draft helper (open-cycle) cooling towers for cooling prior to discharge. Consumptive use by the open-cycle system increases during times of cooling tower operation, primarily from cooling tower evaporation and drift.

Instream evaporation also occurs and may be reduced by cooling tower operation. (EGC 2018)

The Susquehanna River Basin Commission (SRBC) manages waters of the Susquehanna River Basin Watershed. SRBC Docket No. 20061209-1, issued on December 5, 2006, modified on June 23, 2011, and reissued from Exelon Generation Company, LLC (EGC) to CEG on May 10,

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 16 of 78 2022, authorizes PBAPS for withdrawal of up to 2,363.62 million gallons per day (MGD) (3,657 cubic feet per second [cfs]) from Conowingo Pond and a peak day consumptive water use of up to 49 MGD (75.8 cfs). The docket expires on July 3, 2034. (SRBC 2022) In the PBAPS SLR ER, the average and peak monthly rates for surface water withdrawals and consumption for each month in 2012 through 2016 are presented in Tables 2.2-1 and 2.2-2, respectively (EGC 2018).

The withdrawal and consumptive water use permit limits were not exceeded during this period.

Consumptive use at PBAPS represents approximately 0.2 percent of the 39,500 cfs average annual flow from the Susquehanna River into Conowingo Pond. It also represents 2 percent of the lowest 7-day average flow occurring every 10 years (7Q10) of 3,785 cfs (NRC 2020a). The average and peak daily rates for surface withdrawals and consumption by month for 2018 through 2023 are presented in Table 5.1-1 and 5.1-2, respectively. Permit withdrawal and consumption limits were not exceeded during this period. The SRBC docket also states that PBAPSs consumptive water use is subject to water mitigation requirements (SRBC 2022). The consumptive use mitigation plan (CUMP) for PBAPS was completed in 2012, and there have been no changes to this plan since then. The CUMP specifies that consumptive water use at PBAPS will be mitigated during August, September, and October, when natural river flows at the U.S. Geological Survey Marietta gauging station are below current Federal Energy Regulatory Commission flow requirements. The CUMP trigger values are daily average flows of 5,000 cfs for August and September 1 through September 14 and 3,500 cfs for September 15 through October. CEG mitigates consumptive use by 220 cfs of leakages through the Conowingo Hydro Station.

The PBAPS provides an annual report to both the SRBC and FERC that summarizes the dates when consumptive use mitigation thresholds were reached, and mitigation was required (EGC 2018). As reported in the PBAPS SLR ER, CUMP mitigation thresholds were not exceeded in 2012 through 2015, but CUMP mitigations thresholds were reached on September 12-14, 2016, and Conowingo Dam provided 220 cfs to the Susquehanna River on behalf of PBAPS via dam leakage. (EGC 2018) For the period of 2018 through 2023, the CUMP mitigation threshold was met in 2022 on August 15-22 and September 2-3. In accordance with commitments in the SRBC docket, PBAPS coordinated with Conowingo Hydro Station, which was able to release 220 cfs leakage through the dam on behalf of PBAPS during these periods.

As described in the PBAPS SLR ER, a thermal variance study was completed prior to an extended power uprate (EPU) and submitted to the PA DEP in 2014 (EGC 2018). The PA DEP issued a renewed NPDES permit (effective October 1, 2014) that granted a Clean Water Act (CWA) Section 316(a) variance requiring operation of cooling towers during certain times of the year and performance of a post-EPU biological and thermal study. The EPU was implemented in 2016 followed by four years of thermal and biological monitoring which was submitted to PA DEP as part of the NPDES renewal application.

As reported in the PBAPS SLR ER, four surface water users in Conowingo Pond were identified: the Muddy Run Pumped Storage facility, the York Energy Center, the City of Baltimore, and the City of Chester (EGC 2018). The SRBC Water Application and Approval Viewer listed the Wildcat Point Generation facility with a peak daily withdrawal of 8.7 MGD, and the City of Chester was not listed as a surface water user of Conowingo Pond (SRBC 2024).

The SRBC is responsible for managing the water resources of Conowingo Pond and the Lower Susquehanna River Basin. Compliance with withdrawal and consumptive use limits in the SRBC

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 17 of 78 docket and use of mitigation measures during low-flow conditions, as defined in the PBAPS CUMP, ensure that adverse impacts of surface water at PBAPS on other surface water users of Conowingo Pond will remain SMALL during the SLR term.

5.1.2 Conclusion CEG did not identify any new and significant information for surface water use impacts and therefore concludes the PBAPS SLR ER assessment of SMALL remains valid for the SLR.

Further, CEG did not identify any new and significant information related to NRCs basis for concluding surface water use impacts as SMALL in the SEIS.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 18 of 78 Table 5.1-1 Average and Peak Daily Withdrawal Rates (MGD) by Month in 2018-2023 Month 2018 2019 2020 2021 2022 2023 Average Maximum Average Maximum Average Maximum Average Maximum Average Maximum Average Maximum January 1,801.13 2,241.63 1,941.55 2,242.58 2,240.83 2,242.28 2,113.08 2,242.01 1,767.07 2,241.49 1,973.55 2,240.90 February 1,938.65 2,241.58 1,857.01 2,251.39 2,240.79 2,241.38 2,176.48 2,241.19 1,678.12 1,882.61 2,240.77 2,241.73 March 2,158.30 2,254.47 2,240.89 2,244.01 2,240.90 2,242.26 2,241.01 2,243.51 2,155.55 2,242.31 2,240.86 2,242.56 April 2,214.01 2,244.20 2,240.87 2,242.67 2,240.84 2,242.09 2,240.98 2,243.90 2,152.76 2,242.15 2,240.80 2,241.53 May 2,234.80 2,243.57 2,240.83 2,242.03 2,241.76 2,248.49 2,224.83 2,241.50 2,237.53 2,249.95 2,240.98 2,242.17 June 2,235.16 2,246.62 2,282.08 2,290.11 2,241.38 2,246.98 2,249.89 2,261.11 2,240.76 2,241.46 2,251.39 2,262.16 July 2,207.12 2,285.04 2,281.46 2,285.44 2,276.63 2,282.68 2,241.10 2,243.52 2,240.83 2,242.86 2,240.68 2,241.11 August 2,260.98 2,262.29 2,284.04 2,318.28 2,276.63 2,282.68 2,243.57 2,253.71 2,240.67 2,240.84 2,281.22 2,285.19 September 2,255.21 2,266.72 2,281.82 2,290.16 2,276.88 2,282.80 2,281.54 2,286.26 2,241.26 2,245.13 2,272.51 2,284.94 October 1,722.07 2,267.74 1,909.50 2,286.83 1,801.64 2,283.24 2,041.52 2,283.05 1,806.65 2,242.55 1,746.79 2,241.19 November 2,240.87 2,242.47 2,123.03 2,241.96 1,998.59 2,242.72 2,060.97 2,244.67 2,177.43 2,242.10 2,242.90 2,247.24 December 2,234.55 2,242.40 2,241.03 2,242.54 2,241.03 2,242.97 2,240.76 2,242.03 2,061.13 2,243.82 2,240.80 2,241.82

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 19 of 78 Table 5.1-2 Average and Peak Daily Consumptive Use Rates (MGD) by Month in 2018-2023 Month 2018 2019 2020 2021 2022 2023 Average Maximum Average Maximum Average Maximum Average Maximum Average Maximum Average Maximum January 14.89 21.26 15.07 19.62 15.48 19.79 14.91 16.65 14.70 19.68 15.78 19.06 February 15.57 21.77 14.65 16.98 15.63 18.66 14.25 16.88 14.84 18.75 15.63 19.58 March 15.71 21.21 16.07 22.29 17.67 22.65 16.97 23.77 16.97 22.57 16.47 19.62 April 18.04 22.83 21.27 27.04 19.49 25.58 20.03 25.73 18.83 23.00 21.11 25.49 May 25.72 28.85 25.16 30.22 22.65 29.73 22.39 29.67 22.30 29.48 22.44 26.11 June 28.02 36.07 28.72 32.30 29.46 32.89 30.04 33.33 29.20 31.71 27.57 32.14 July 30.84 38.97 33.12 35.14 34.57 37.38 31.86 33.59 32.31 35.05 32.86 34.12 August 30.00 38.72 33.15 36.26 35.02 36.38 32.25 35.71 32.99 34.66 31.41 33.65 September 23.06 37.86 26.70 29.91 25.81 30.56 25.98 30.81 27.24 32.65 25.24 28.80 October 5.58 19.25 16.22 28.25 14.37 22.62 18.10 24.05 18.10 24.05 13.96 24.23 November 17.46 25.08 13.97 19.47 11.00 21.06 12.71 20.88 18.71 27.00 19.30 26.12 December 15.94 23.03 15.89 28.05 15.20 19.44 15.66 20.73 15.17 19.24 15.99 20.04

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 20 of 78 5.2 Groundwater Resources - Groundwater Use Conflicts (Plants with Closed-Cycle Cooling Systems That Withdraw Makeup Water from a River)

PBAPS SLR ER Section 4.5.2.2 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. Water use conflicts could result from water withdrawals from rivers during low-flow conditions, which may affect aquifer recharge. The significance of impacts would depend on makeup water requirements, water availability, and competing water demands.

5.2.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(A)]

If the applicants plant utilizes cooling towers or cooling ponds and withdraws makeup water from a river, an assessment of the impact of the proposed action on water availability and competing water demands... must be provided. The applicant shall also provide an assessment of the impacts of the withdrawal of water from the river on alluvial aquifers during low flow.

5.2.1.3 Background [GEIS Section 4.5.1.2.4]

In the case of plants with cooling towers or cooling ponds that rely on a river for makeup of consumed (evaporated) cooling water, it is possible water withdrawals from the river could lead to groundwater use conflicts with other groundwater users. This situation could occur because of the interaction between groundwater and surface water, especially in the setting of an alluvial aquifer in a river valley. Consumptive use of the river water, if significant enough to lower the rivers water level, would also influence water levels in the alluvial aquifer. Shallow wells of nearby groundwater users could therefore have reduced water availability or go dry. During times of drought, the effect would be occurring naturally, although withdrawals for makeup water would increase the effect.

The NRC concluded that groundwater use conflicts for nuclear plants with closed-cycle cooling systems that withdraw makeup water from a river could have SMALL, MODERATE, or LARGE impacts during the initial LR and SLR terms, depending on site-specific characteristics (e.g., the amount of surface water decline, well pump rates, well locations, and hydrogeologic conditions).

5.2.1.4 Analysis As presented in PBAPS SLR ER Section 2.1, PBAPS operates as a once-through cooling system September 1 through June 14 each year, and the PBAPS NPDES permit requires operating one to three helper cooling towers each year, June 15 through August 31, based on intake temperatures. In addition, PBAPS will operate the towers September 1 through September 30 per agreement with PA DEP based on 48-hour averages as follows: operate one tower when the river temperature is equal to or greater than 81°F, operate two towers when the river temperature is equal to or greater than 83°F, and operate three towers when the river temperature is equal to or greater than 86°F. As much as 60 percent of cooling water may be diverted through forced-draft helper (open-cycle) cooling towers prior to discharge. Surface water withdrawals and consumptive water use are reported, and a CUMP is used to mitigate

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 21 of 78 consumptive water use during low-flow conditions. The SRBC issues dockets to water users as part of the comprehensive planning process for managing the regions water resources.

In general, stratigraphy at PBAPS comprises fill, unconsolidated deposits, and weathered and competent Peters Creek Schist bedrock. Groundwater in the overburden soils and fill occur under unconfined conditions. No overburden materials are present at the western end of the station. Overburden and fill material thicken eastward toward Conowingo Pond. Alluvial deposits that could support local aquifers along the Conowingo Pond portion of the Susquehanna River are limited. The predominant surficial deposits consist of schist bedrock and colluvial regolith along and immediately adjacent to the river. Groundwater flow in the regolith and bedrock is toward Conowingo Pond. The pond does not recharge the aquifer; rather, the pond receives baseflow from the bedrock aquifer. Groundwater use conflicts are not expected from continued surface water withdrawals and consumptive use from Conowingo Pond. (NRC 2020a) 5.2.2 Conclusion CEG did not identify any new and significant information for groundwater use conflicts from surface water withdrawals and low consumptive use rate and therefore concludes the PBAPS SLR ERs assessment of SMALL remains valid for the SLR. Further, CEG did not identify any new and significant information related to NRCs basis for concluding the potential for groundwater use conflicts associated with PBAPS operations as SMALL in the SEIS.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 22 of 78 5.3 Groundwater Resources - Radionuclides Released to Groundwater PBAPS SLR ER Section 4.6.5 5.3.1 Supplemental Information 5.3.1.1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table B-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.

5.3.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(P)]

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.

5.3.1.3 Background [GEIS Section 4.5.1.2.7]

The issue is relevant to license renewal because all commercial nuclear power plants routinely release radioactive gaseous and/or 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 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, storage tanks, buried piping, failed pressure relief valves on an effluent discharge line, and other nuclear power plant equipment.

In 2006, the NRCs 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 and evaluation of inadvertent releases of liquids containing radioactive material from nuclear power plants, particularly those that result in groundwater contamination.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 23 of 78 The NRC 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 such factors as the magnitude of the leak or spill, radionuclides involved and concentrations, hydrogeologic factors, the distance to receptors, and the response time of plant personnel to identify and stop the leak in a timely fashion. The NRC 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.

5.3.1.4 Analysis The overburden material beneath the PBAPS site primarily consists of reworked residual soils, crushed rock, and engineered backfill. The groundwater in this material and in the underlying bedrock is not a source of drinking water and is not proposed for drinking water use during the SLR term. (NRC 2020a) Groundwater flow in the overburden is eastward toward Conowingo Pond or the discharge canal. The Peters Creek Schist is used for domestic water supply in the area surrounding PBAPS. There are domestic wells upgradient of PBAPS; however, there are no domestic wells between the PBAPS and discharge points. The bedrock beneath the station does not readily store or transmit groundwater. There are no known deep aquifers of any extent in the region. The potential for groundwater flow inland from the station is improbable; therefore, it is unlikely that offsite water supply wells could be impacted from a potential tritium release to groundwater. Groundwater flow in the bedrock aquifer is eastward.

Groundwater is monitored at PBAPS as part of its Radiological Groundwater Protection Program (RGPP), which is consistent with the Nuclear Energy Institute Industry Groundwater Protection Initiative final guidance document (NEI 07-07). In 2020, CEG updated the RGPP and modified sample location designations to align with the 2019 revision to NEI 07-07. The RGPP sample designations are defined as follows:

Background:

Hydrogeologically upgradient groundwater monitoring wells at a distance from potential sources of licensed material Source: Wells installed close to higher-risk systems or components Mid-Field: Wells installed between source wells and the downgradient perimeter of the stations higher-risk systems or components Idle/Standby: Groundwater monitoring locations that are not actively sampled but are available for future use Long-Term Shutdown: Wells used to monitor systems, structures, or components of a facility where the licensee has initiated the decommissioning process Perimeter: Wells installed along the downgradient and cross-gradient perimeter of areas with higher-risk systems or components The PBAPS RGPP monitoring well and yard drain sump sampling designations, sampling frequencies, and analytes are listed in Table 5.3-1. The RGPP monitoring locations are depicted in Annual Radiological Environmental Operating Reports (AREORs). (CEG 2022; CEG 2023; CEG 2024)

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 24 of 78 Table 5.3-1 RGPP Groundwater Monitoring Well and Yard Drain Sump Sampling Designation Sampling Frequency Analytes Locations

Background

Annually H3 annually, G 2 years MW-PB-1, MW-PB-2, MW-PB-5 Perimeter Annually H3 annually, G 2 years MW-PB-3, MW-PB-6, MW-PB-7 Mid-Field Semiannually H3 semiannually, G 2 years MW-PB-4, MW-PB-12, MW-PB-13, MW-PB-22, MW-PB-24 Long-Term Shutdown Quarterly H3 quarterly, G 2 years, GA 2 years, HTD annually, Sr annually MW-PB-8, MW-PB-10, MW-PB-15, MW-PB-16 Idle NA NA MW-PB-14, MW-PB-21 Source Quarterly H3 quarterly, G 2 years, GA 2 years, HTD 5 years, Sr annually MW-PB-19, MW-PB-20, MW-PB-25*, MW-PB-26, MW-PB-27, MW-PB-28, MW-PB-29, MW-PB-30, MW-PB-31, Unit 2 Yard Drain Sump, Unit 3 Yard Drain Sump

• Well MW-PB-25 is also analyzed for select transuranics annually H3: Tritium GA: Gross alpha G: Gamma Sr: Sr-89/Sr-90 HTD: Hard-to-detect Fe-55 and Ni-63 NA: Samples are not collected or analyzed

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 25 of 78 The PBAPS SLR ER includes a description of the April 2015 steam leak in the Unit 3 moisture separator room that resulted in elevated tritium concentrations in MW-PB-25 and subsequent corrective actions (EGC 2018). After the leak was repaired, tritium concentrations steadily decreased until November 27, 2018, when tritium concentrations for samples collected from MW-PB-25 increased to 14,300 picocuries per liter (pCi/L). Monitoring wells MW-PB-25, MW-PB-24, MW-PB-26, and MW-PB-27 were monitored monthly through 2022. Tritium concentrations in MW-PB-25 increased to a maximum of 23,000 pCi/L in May 2019. Tritium concentrations in MW-PB-25 decreased to 4,820 pCi/L in September 2019. In 2020, tritium activity in MW-PB-25 ranged from 839 to 12,800 pCi/L (CEG 2021). In 2021, tritium concentrations in this well ranged from 193 to 10,900 pCi/L (CEG 2022). In 2022, tritium concentrations in MW-PB-25 ranged from non-detect to 17,100 pCi/L (CEG 2023). These concentrations detected in 2020 through 2022 are below the U.S. Environmental Protection Agency (EPA) maximum contaminant level (MCL) of 20,000 pCi/L.

Tritium activity detected in Unit 3 turbine building monitoring wells MW-PB-24 through MW-PB-27 is the result of legacy licensed material under the turbine building transported by natural hydrogeologic groundwater flow. The plume is bounded on the north by wells MW-PB-12 and MW-PB-22 and on the south by wells MW-PB-20 and MW-PB-21. (CEG 2023) The tritium plume boundaries do not extend beyond the station boundaries.

During the December 2020 sampling event, tritium concentrations in MW-PB-28 increased from

<200 pCi/L to 1,540 pCi/L and in the Unit 3-yard drain sump from <200 pCi/L to 1,670 pCi/L.

Tritium concentrations at these locations steadily increased through 2021 to a maximum concentration of 12,200 pCi/L in MW-PB-28 and 3,680 pCi/L in the Unit 3-yard drain sump. The source of tritium for MW-PB-28 was found to be a packing leak in the torus dewatering tank moat and cracks in the moat surface floor, which was discovered in January 2021. Tritiated water was removed from the moat and the packing leak and surface floor cracks were sealed.

Tritium concentrations declined steadily in MW-PB-28 through 2023 with concentrations ranging from non-detect to 907 pCi/L. (CEG 2023; CEG 2024)

During the fourth quarter of 2022, a sample collected from MW-PB-30 increased from 683 pCi/L to 19,100 pCi/L. An additional sample was collected from MW-PB-30 in March 2023 and the concentration increased to over 37,000 pCi/L. Station personnel performed an investigation, and a steam leak was identified in the Unit 2 moisture separator room. Station personnel constructed a containment around the sump to stop condensate from entering a pit. Tritium concentrations in MW-PB-30 have been decreasing since the containment was installed around the sump in the Unit 2 moisture separator room. As of November 2023, the tritium concentration decreased to 7,690 pCi/L. (CEG 2023; CEG 2024)

Gamma-emitting target radionuclides and Sr-89/90 were not detected during sampling events from 2018 through 2022 above laboratory lower limits of detection (LLDs). Some naturally occurring radionuclides were detected above LLDs, but these concentrations were considered background. No samples were analyzed for gamma radionuclides in 2023. Per the RGPP, samples will be analyzed for gamma radionuclides in 2024. (CEG 2023; CEG 2024)

Although tritium has been detected in onsite groundwater monitoring locations, concentrations detected in 2020 and 2021 were below the EPA MCL of 20,000 pCi/L. Tritium was detected in 2022 and 2023 above the MCL; however, these detections were confined to one area (MW-PB-

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 26 of 78

30) on the station site, and groundwater impacted by tritium above the MCL does not extend beyond station boundaries. Groundwater in the overburden aquifer is not used as drinking water. The Peters Creek Schist is used for drinking water in the PBAPS area; however, there are no drinking water wells between PBAPS and discharge points. Impacts to groundwater from radionuclide releases are expected to remain SMALL during the SLR term.

5.3.2 Conclusion CEG did not identify any new and significant information for radionuclides in groundwater, and therefore concludes the PBAPS SLR ER assessment of SMALL remains valid for the SLR.

Further, CEG did not identify any new and significant information related to NRCs basis for concluding the impact of radionuclides released to groundwater as SMALL in the SEIS.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 27 of 78 5.4 Terrestrial Resources - Water Use Conflicts with Terrestrial Resources (Plants with Cooling Ponds or Cooling Towers Using Makeup Water from a River)

PBAPS SLR ER Section 4.6.1.2 5.4.1 Supplemental Information 5.4.1.1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table B-1 SMALL or MODERATE. Nuclear power plants could consume water at rates that cause occasional or intermittent water use conflicts with nearby and downstream terrestrial and riparian communities. Such impacts could noticeably affect riparian or wetland species or alter characteristics of the ecological environment during the license renewal term. The one plant where impacts have occurred successfully mitigated the impact. Impacts are expected to be small at most nuclear power plants but could be moderate at some.

5.4.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(A)]

If the applicant's plant utilizes cooling towers or cooling ponds and withdraws makeup water from a river, an assessment of the impact of the proposed action on water availability and competing water demands, the flow of the river, and related impacts on... riparian (terrestrial) ecological communities must be provided.

5.4.1.3 Background [GEIS Section 4.6.1.1.6]

This issue concerns water use conflicts that may arise at nuclear power plants with cooling ponds or cooling towers that use makeup water from a river and how those conflicts could affect terrestrial resources during an initial LR or SLR term. Nuclear power plant cooling systems may compete with other users relying on surface water resources, including downstream municipal, agricultural, or industrial users. Closed-cycle cooling is not completely closed because the system discharges blowdown water to a surface water body and withdraws water for makeup of both the consumptive water loss due to evaporation and drift (for cooling towers) and blowdown discharge. For plants using cooling towers, while the volume of surface water withdrawn is substantially less than once-through systems for a similarly sized nuclear power plant, the makeup water needed to replenish the consumptive loss of water to evaporation can be significant. Cooling ponds also require makeup water. The NRC considered water use conflicts with terrestrial resources, especially to riparian communities, which could occur when water that supports these resources is diminished by a combination of anthropogenic uses. However, consumptive use by nuclear power plants with cooling ponds or cooling towers using makeup water from a river during the license renewal term is not expected to change unless power uprates, with associated increases in water use, occur. Water use conflicts with terrestrial resources would be SMALL at most nuclear power plants with cooling ponds or cooling towers that withdraw makeup from a river but may be MODERATE at some plants.

5.4.1.4 Analysis As discussed in Section 4.5.1 of the PBAPS SLR ER, PBAPS does not utilize either a cooling pond or closed-cycle cooling towers that require makeup water. Rather, PBAPS operates an open-cycle, once-through circulating water system. Therefore, this issue as specified does not apply to PBAPS. However, during specified times and under certain circumstances, as much as

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 28 of 78 approximately 60 percent of the cooling water flow must be diverted through forced draft, helper (open cycle) cooling towers for preliminary cooling prior to discharge, which results in some consumptive use. (EGC 2018)

Section 5.1 of this report addresses surface water use conflicts associated with PBAPS operations. SRBC Docket No. 20061209-1, reissued on May 10, 2022, authorizes PBAPS for water withdrawal from Conowingo Pond. As of 2023, withdrawal and consumptive use limits set by SRBC docket have not been exceeded and represent approximately 0.2 percent of the 39,500 cfs average annual flow from the Susquehanna River into Conowingo Pond. The SRBC docket also requires PBAPS to provide consumptive use mitigation. PBAPS monitors and mitigates consumptive use via the CUMP, as described in Section 5.1 of this report.

Because PBAPS provides consumptive use mitigation, withdrawals of surface water for the operation of PBAPS would have a minimal impact on surface water use conflicts. Similarly, impacts to riparian ecological communities around Conowingo Pond and along the Susquehanna River would be small, if discernible, even in low-flow conditions. These communities have adapted to the normally fluctuating water levels and flow conditions of the river. As discussed in Section 3.6.2 of the PBAPS SLR ER, wildlife species in the vicinity of the PBAPS site are those typically found in similar habitats in southern Pennsylvania. Wildlife and plant species in the site vicinity are not restricted to or dependent on the riparian communities around Conowingo Pond. (EGC 2018)

Section 4.5.1.1 of the SEIS addresses surface water use conflicts and concluded that the potential impacts on surface water resources and downriver water availability from PBAPSs consumptive water use during the SLR term would be SMALL because of PBAPSs very low consumptive use relative to river flow. The SRBC also imposes water withdrawal restrictions through a consumptive water use permit to further ensure adequate instream and downstream flows. Section 4.7.1.1 of the SEIS also addresses water use conflicts with aquatic resources and determined that PBAPS consumes a very small amount of the Susquehanna Rivers flow each year and that the impacts of water use conflicts would be SMALL for aquatic resources. The NRC concluded that there are no other impacts that terrestrial or riparian habitats or species would uniquely experience beyond those already discussed in these sections. Accordingly, the NRC concluded that the impacts of water use conflicts on terrestrial resources from the SLR would be SMALL. (NRC 2020a) No changes in operating conditions have taken place that would change the conclusions reached in the PBAPS SLR ER or SEIS.

5.4.2 Conclusion CEG did not identify any new and significant information for water use conflicts with terrestrial resources (plants with cooling ponds or cooling towers using makeup water from a river) and therefore concludes the PBAPS SLR ER assessment of SMALL remains valid for the SLR.

Further, CEG did not identify any new and significant information related to NRCs basis for concluding that the potential for surface water use conflicts with terrestrial resources associated with PBAPS operations is SMALL.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 29 of 78 5.5 Terrestrial Resources - Non-Cooling System Impacts on Terrestrial Resources PBAPS SLR ER Section 4.6.1.1 5.5.1 Supplemental Information 5.5.1.1 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.

5.5.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(E)]

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 4.6.1.1.1]

The 2024 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. GEIS Section 4.6.1.1.1 states: Industrial-use portions of nuclear power plant sites are 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. 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., CWA Section 404 permit), and federal review (e.g., USFWS [U.S. Fish and Wildlife Service] 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.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 30 of 78 5.5.1.4 Analysis Refurbishment Activities As described in Section 4.6.1.1 of the PBAPS SLR ER, no refurbishment or changes to plant or transmission line operational activities that would change effects on terrestrial resources are expected to occur during operation under the SLR. Wildlife and plant species on the developed parts of the PBAPS property are common species adapted to industrial sites and able to tolerate industrially generated noise and human activity. The characteristics of terrestrial communities on less developed parts of the property have been influenced by years of PBAPS operations and maintenance activities occurring in close proximity. Undeveloped areas of the plant property have been disturbed historically by activities such as logging and farming with the possible exception of the steeper slopes where such land uses were not practicable. (EGC 2018)

Operational Activities Section 3.6.2 of the PBAPS SLR ER describes the existing terrestrial communities on the PBAPS property. No known sensitive terrestrial habitats exist within the PBAPS property boundaries, and operations and maintenance activities during the SLR term are expected to be similar to current activities. Furthermore, existing procedures provide a process for screening proposed activities to determine if further evaluation for environmental impacts and risk is needed. Pursuant to this process, applicable environmental requirements, if any, are identified for each proposed activity, and as needed, mitigation measures are considered. (EGC 2018)

On December 14, 2023, CEG submitted an application for Wildlife Habitat Council Conservation Certification for the PBAPS site. This certification allows PBAPS to demonstrate a voluntary long-term commitment to managing quality habitat for wildlife, conservation education, and community outreach initiatives.

As described in Section 4.6.1.1 of the SEIS, the NRC concluded that site and landscape maintenance activities, stormwater management, elevated noise levels, and other general operations and maintenance activities that CEG may undertake during the SLR term would primarily be confined to already disturbed areas of the PBAPS site. If any such activities have the potential to affect terrestrial resources, CEG maintains procedures to ensure that personnel consider how to minimize such impacts prior to performing work. The NRC did not identify any activities that would have noticeable effects on terrestrial resources or that would destabilize any important attributes of the terrestrial environment. Accordingly, the NRC staff concluded that non-cooling system impacts on terrestrial resources during the SLR term would be SMALL.

(NRC 2020a) 5.5.2 Conclusion CEG did not identify any new and significant information for non-cooling system impacts on terrestrial resources and therefore concludes the PBAPS SLR ER assessment of SMALL remains valid for the SLR. Further, CEG did not identify any new and significant information related to NRCs basis for concluding that the potential for non-cooling system impacts on terrestrial resources associated with PBAPS operations is SMALL.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 31 of 78 5.6 Aquatic Resources - Impingement Mortality and Entrainment of Aquatic Organisms (Plants with Once-Through Cooling Systems or Cooling Ponds)

PBAPS SLR ER Section 4.6.2.1 5.6.1 Supplemental Information 5.6.1.1 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.

5.6.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(B)]

If the applicants plant utilizes once-through cooling or cooling pond water intake and discharge systems, the applicant shall provide a copy of current CWA 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.

5.6.1.3 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 EPAs 2014 CWA Section 316(b) regulations and the EPAs 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 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 license renewal 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 (IM&E) of

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 32 of 78 aquatic organisms during the license renewal term (initial LR or SLR) at nuclear power plants with once-through cooling systems or cooling ponds could be SMALL, MODERATE, or LARGE.

5.6.1.4 Analysis As part of the NPDES permit renewal application submitted in 2019, PBAPS included a 316(b)

Cooling Water Intake Structure Report. According to this report, the following conclusions and recommendations were made regarding entrainment and impingement:

Entrainment The PBAPS cooling water system is BTA for entrainment because:

The ichthyoplankton density data indicates a net increase in organisms returned to the Conowingo Reservoir across the existing system. Ichthyoplankton density at the discharge canal outfall (1.6 billion ichthyoplankton) are higher than at the intake structure (963 million ichthyoplankton), indicating potential entrainment survival and spawning is occurring within the intake canals and the discharge canal.

The disproportionately high social costs compared to the social benefits of entrainment reduction technologies.

Issues with construction feasibility and adverse environmental impacts of cooling towers.

Large in-river footprint and associated impacts of narrow-slot wedgewire screens.

Cooling water intake structures on a lake or reservoir have a low propensity for causing significant entrainment impacts.

Decades of studies demonstrate minimal adverse impact to the Conowingo Reservoir fish population.

The results of the engineering, biological, and economic evaluations of entrainment reduction technologies indicate that the current cooling water system at PBAPS is BTA for minimizing impacts from entrainment and no further entrainment reduction technologies are warranted.

Impingement The PBAPS intake structure is designed and configured with the express intent of reducing impingement. Conowingo Reservoir biological studies were completed, aquatic species were identified and researched, and a representative species (white crappie) was selected to establish intake/approach velocity design criteria. More specifically, the structure was designed based on the results of numerous fish swim speed studies that found that juvenile white crappie was particularly fragile and susceptible to impingement mortality. By protecting white crappie, the rest of the aquatic community was also protected. Additionally, the outer intake structure was designed flush to the shoreline to avoid eddies and velocity traps, allowing lateral fish escape routes. This configuration of the cooling water intake structure results in a hydraulic zone of influence (as defined by the 0.5 feet-per-second contour) located between the trash racks and the outer intake structure traveling water screens. It does not extend beyond the cooling water intake structure into the Conowingo Reservoir. In addition, an air bubbler system is used on the outer intake structure for breaking up surface ice formations at the inlet side of the structure, which may encourage fish avoidance behavior.

According to Section 4.7.1.1 of the SEIS, the NRC concluded that there is no evidence of noticeable or detectable ecological impairment resulting from impingement or entrainment of aquatic organisms at PBAPS. During the SLR, the NRC expects that impacts would be similar

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 33 of 78 (i.e., not noticeable, or detectable) because continued operation would neither intensify existing effects nor introduce any new effects. The PA DEP is currently reviewing CEGs NPDES permit renewal application. In its application, CEG proposes to install fish-friendly modified traveling screens and a fish return system to meet the BTA standard for impingement mortality. Although the PA DEP has yet to render a BTA determination for IM&E at PBAPS, the NRC assumes that the renewed NPDES permit will specify the conditions necessary to minimize adverse effects in accordance with EPAs final 2014 Phase II Rule. The NRC staff also assumes that the PA DEP would impose any requirements that it deems appropriate as conditions in a future renewed NPDES permit that would take effect prior to the proposed SLR term. The NRC staff further assumes that any additional requirements that the PA DEP imposes would further reduce the impacts of impingement and entrainment over the course of the SLR term. For these reasons, the NRC concluded that the impacts of impingement and entrainment of aquatic organisms resulting from the SLR of PBAPS would be SMALL. (NRC 2020a) 5.6.2 Conclusion CEG did not identify any new and significant information for IM&E of aquatic organism (plants with once-through cooling systems or cooling ponds) and therefore concludes the PBAPS SLR ER assessment of SMALL remains valid for the SLR. Further, CEG did not identify any new and significant information related to NRCs basis for concluding that the potential for impacts of IM&E of aquatic organisms associated with PBAPS operations is SMALL.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 34 of 78 5.7 Aquatic Resources - Effects of Thermal Effluents on Aquatic Organisms (Plants with Once-Through Cooling Systems or Cooling Ponds)

PBAPS SLR ER Section 4.6.2.2 5.7.1 Supplemental Information 5.7.1.1 Findings from 10 CFR Part 51, Subpart 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.

5.7.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(B)]

If the applicants plant utilizes once-through cooling or cooling pond water intake and discharge systems, the applicant shall provide a copy of current CWA 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.

5.7.1.3 Background [GEIS Section 4.6.1.2.4]

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 depends 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 NPDES 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 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.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 35 of 78 5.7.1.4 Analysis As indicated in Section 2.2.3 of the PBAPS SLR ER, PBAPS operates an open-cycle, once-through circulating water system equipped with forced draft, helper (open-cycle) cooling towers.

Thermal discharges are regulated by NPDES permit (PA0009733), which authorizes releases from PBAPS to Conowingo Pond. The PBAPS NPDES permit grants a CWA Section 316(a) variance requiring operation of the PBAPS cooling towers during specific times and conditions, as well as performance of a post-EPU biological and thermal study, which was in progress through 2016. The 2016 post-EPU thermal and biological study found that cooling tower operation, as specified in the current NPDES permit, effectively mitigates the additional heat discharged as a result of the EPU. Based on results of the PBAPS CWA Section 316(a) variance study and the post-EPU biological and thermal study, EGC concluded that thermal discharges from PBAPS are consistent with state water quality standards and will result in SMALL impacts to aquatic organisms in Conowingo Pond. (EGC 2018)

According to Section 4.7.1.2 of the SEIS, the NRC concluded that during most of the year and in most areas of Conowingo Pond, the thermal effluent would not noticeably affect the aquatic community and would be SMALL. However, during summer months, a narrow 12-acre (4.9-hectare) band of shallow water habitat downstream of the discharge canal would exhibit short-term, observable changes, including reduced macroinvertebrate community health (i.e., lower Index of Biotic Integrity scores) and lower fish diversity. Seasonal impacts in this region would be MODERATE because water temperatures would result in thermal stress and avoidance behaviors. CEGs operation of its cooling towers in accordance with NPDES permit conditions and voluntary agreements with the PA DEP would help minimize the duration and frequency of these seasonal impacts. Additionally, the PA DEP could impose additional requirements related to PBAPSs thermal effluent to assure the protection of a balanced, indigenous aquatic community. The NRC assumes that the PA DEP would impose any additional requirements that it deems appropriate as conditions in a future renewed NPDES permit. The NRC staff also assumes that any such requirements would further reduce thermal impacts on aquatic organisms over the course of the SLR term. However, absent information indicating that PBAPSs operation could be effectively conditioned to reduce or mitigate existing impacts, the NRC conservatively concluded that the thermal impacts to aquatic resources in Conowingo Pond during the PBAPS SLR term would be SMALL to MODERATE. (NRC 2020a)

From 2016-2020, PBAPS participated in a water temperature monitoring plan for Conowingo Pond as required by FERC Order Modifying and Approving Non-Project Use of Project Lands and Waters, 152 FERC 62,142, Project No. 405-113, issued on September 2, 2015. This monitoring plan verified that operating the PBAPS cooling towers under the PA DEP-issued NPDES permit requirements adequately reduces discharge temperatures during warm weather months, and that the thermal plume disseminates locally, as predicted by the extensive modeling studies previously performed. Based on the results under this monitoring plan, it was concluded that there is adequate protection of the fish and benthic community in relation to thermal effluents.

5.7.2 Conclusion Though the NRC conservatively concluded that thermal impacts to aquatic resources in Conowingo Pond during the SLR term would be SMALL to MODERATE, CEGs review of recent

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 36 of 78 information, including the 2016-2020 monitoring plan results, concludes that the PBAPS SLR ER assessment of SMALL for effects of thermal effluents on aquatic organisms during the SLR term remains valid.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 37 of 78 5.8 Aquatic Resources - Water Use Conflicts with Aquatic Resources (Plants with Cooling Ponds or Cooling Towers Using Makeup Water from a River)

PBAPS SLR ER Section 4.6.2.3 5.8.1 Supplemental Information 5.8.1.1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table B-1 SMALL or MODERATE. Nuclear power plants could consume water at rates that cause occasional or intermittent water use conflicts with nearby and downstream aquatic communities.

Such impacts could noticeably affect aquatic plants or animals or alter characteristics of the ecological environment during the license renewal term. The one plant where impacts have occurred successfully mitigated the impact. Impacts are expected to be small at most nuclear power plants but could be moderate at some.

5.8.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(A)]

If the applicants plant utilizes cooling towers or cooling ponds and withdraws makeup water from a river, an assessment of the impact of the proposed action on water availability and competing water demands, the flow of the river, and related impacts on stream (aquatic)ecological communities must be provided.

5.8.1.3 Background [GEIS Section 4.6.1.2.10]

The issue concerns water use conflicts that may arise at nuclear power plants with cooling ponds or cooling towers that use makeup water from a river and how those conflicts could affect aquatic resources during an initial LR or SLR term. Nuclear power plant cooling systems may compete with other users relying on surface water resources, including downstream municipal, agricultural, or industrial users. Closed-cycle cooling is not completely closed because the system discharges blowdown water to a surface water body and withdraws water for makeup of both the consumptive water loss due to evaporation and drift (for cooling towers) and blowdown discharge. For plants using cooling towers, while the volume of surface water withdrawn is substantially less than once-through systems for a similarly sized nuclear power plant, the makeup water needed to replenish the consumptive loss of water to evaporation can be significant. Cooling ponds also require makeup water. The NRC considered water use conflicts with aquatic resources that could occur when water that supports these resources is diminished by a combination of anthropogenic uses. However, consumptive use by nuclear power plants with cooling ponds or cooling towers using makeup water from a river during the license renewal term is not expected to change unless power uprates, with associated increases in water use, occur. The NRC concluded that water use conflicts on aquatic resources during the license renewal term (initial LR or SLR) could be SMALL or MODERATE at nuclear power plants with cooling ponds or cooling towers using makeup water from a river.

5.8.1.4 Analysis As described in Section 2.2.3 of the PBAPS SLR ER, PBAPS operates as an open-cycle, once-through circulating water system with three helper cooling towers that do not require makeup water. Consumptive water use at PBAPS includes evaporation through the power generation and cooling systems, including evaporation in the helper cooling towers when the towers are in

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 38 of 78 operation, and evaporation of water withdrawn from Conowingo Pond due to the thermal loading from water discharged from the facility. This consumptive use represents approximately 0.2 percent of the 39,500 cfs average annual flow from the Susquehanna River into Conowingo Pond and represents only 2 percent of the 7Q10 flow of 3,785 cfs at the Marietta gaging station.

The effect on the water elevation would be indiscernible given daily fluctuations of as much as 25 percent of Conowingo Ponds volume due to operation of the Muddy Run Pumped Storage Facility and the managed nature of the Conowingo Pond because of Conowingo Dam operation.

(EGC 2018)

As stated in Section 4.6.2.3 of the PBAPS SLR ER, impacts to aquatic ecological communities in Conowingo Pond and the Susquehanna River would be small, if discernible, even in low-flow conditions because of the controls placed on water elevation in Conowingo Pond. These communities have adapted to the normally fluctuating water levels and flow conditions of the river. Any incremental change attributable to PBAPS cooling tower operation would be SMALL.

Because impacts are not demonstrable, CEG also concludes that further mitigation would be unwarranted. (EGC 2018)

According to Section 4.7.1.3 of the SEIS, the average annual flow from the Susquehanna River into Conowingo Pond is 39,500 cfs. PBAPS is authorized to withdraw 3,657 cfs of water from the Conowingo Pond. Consumptive use is 75.8 cfs, which is equivalent to about 0.02 percent of the flow within Conowingo Pond. The amount of water PBAPS consumes (0.02 percent) is minor in comparison to the flow of water past the plant. In addition, the withdrawal of water by PBAPS and other water users is regulated by the SRBC. In setting consumptive use limits, the SRBC considers the cumulative amount of water from all water users in Conowingo Pond.

Therefore, PBAPS does not consume an amount that would be harmful to aquatic biota during low flow conditions. The NRC did not identify any information that indicates that the Susquehanna River biota are affected by the loss of river water consumed by PBAPSs makeup water withdrawals. The NRC concluded that water use conflicts would not occur during the SLR term or would be so minor that the effects on aquatic resources would be undetectable. Thus, the NRC staff concluded that the impacts of water use conflicts on aquatic resources during the SLR term would be SMALL. No changes in operating conditions have taken place that would change the conclusions reached in the PBAPS SLR ER or SEIS.

5.8.2 Conclusion CEG did not identify any new and significant information for water use conflicts with aquatic organisms (plants with cooling ponds or cooling towers using makeup water from a river) and therefore concludes the PBAPS SLR ER assessment of SMALL remains valid for the SLR.

Further, CEG did not identify any new and significant information related to NRCs basis for concluding that the potential for impacts related to water use conflicts with aquatic organisms associated with PBAPS operations is SMALL.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 39 of 78 5.9 Federally Protected Ecological Resources - Endangered Species Act:

Federally Listed Species and Critical Habitats Under U.S. Fish and Wildlife Service Jurisdiction PBAPS SLR ER Section: 4.6.3 5.9.1 Supplemental Information 5.9.1.1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table B-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 agencys jurisdiction.

5.9.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(E)]

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.

5.9.1.3 Background [GEIS Section 4.6.1.3.1]

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. GEIS Section 4.6.1.3.1 states: The NRC would need to perform 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 the FWS [USFWS], as appropriate.

5.9.1.4 Analysis As discussed in Section 3.6.2.3.1 of the PBAPS SLR ER, the USFWS considers four federally listed species to potentially occur in the 6-mile vicinity of PBAPS if suitable habitats are present:

Indiana bat (Myotis sodalis), northern long-eared bat (Myotis septentrionalis), bog turtle

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 40 of 78 (Clemmys muhlenbergii), and rufa red knot (Calidris canutus rufa). Both species of bat roost in trees in summer and could potentially occur in forested areas of the site. The bog turtle utilizes spring-fed bogs and marshes as habitat, but suitable habitat was not observed during an August 2017 bog turtle habitat survey on PBAPS. While the rufa red knot may be observed in the vicinity of PBAPS during its migration, suitable habitat does not exist on or near the site.

Operations and maintenance activities during the license renewal term are expected to be similar to current activities. The only ground-disturbing activity planned at the PBAPS site is the implementation of a packaged STP that would be placed on previously disturbed land (i.e., an existing parking lot). Thus, CEG is not aware of any PBAPS activities to be conducted during the license renewal term that would adversely impact these federally listed species, or any others, that may occur at the site. In addition, there are no critical habitats for these or other federally listed species in the vicinity of PBAPS that would be affected by its continued operation. (EGC 2018)

The state-listed Chesapeake logperch (Percina bimaculata) is currently under USFWS review.

As discussed in Section 3.6.1.4.2 of the PBAPS SLR ER, Chesapeake logperch has been found in Conowingo Pond. Section 4.6.3 of the PBAPS SLR ER discusses impingement, entrainment, thermal discharge, and operations and maintenance activity effects to Chesapeake logperch. In summary, the PBAPS SLR ER concluded that these issues may affect but are not likely to adversely affect the Chesapeake logperch as PBAPS has existing procedures, policies, and restoration programs in place to limit effects associated with these issues. Further, future mitigation measures, as determined through the NPDES permit renewal process, will help to decrease impacts related to these issues. (EGC 2018)

According to Section 3.8.1.2 of the SEIS, the NRC staff concluded that two federally listed species under USFWS jurisdiction may occur in the action area: northern long-eared bat and Indiana bat. An additional species that is currently under USFWS review for listing, the Chesapeake logperch, also occurs in the action area. The NRC also determined that the bog turtle and rufa red knot do not occur in the action area, and the there are no proposed or designated critical habitat that occur within the PBAPS action area. The NRC analyzed the potential impacts of the PBAPS SLR on these federally listed and under review species and concluded the PBAPS SLR may affect but is not likely to adversely affect the northern long-eared bat and Indiana bat, may affect Chesapeake logperch, and would have no effect on bog turtle or rufa red knot. (NRC 2020a)

Since the PBAPS SLR ER and 2020 SEIS, three species have been added for proposed federal listing that are under USFWS jurisdiction and have potential to occur within the 6-mile vicinity of PBAPS: tricolored bat (Perimyotis subflavus; proposed endangered), green floater (Lasmigona subviridis; proposed threatened), and Monarch butterfly (Danaus plexippus; candidate for listing).

Tricolored bat (Perimyotis subflavus)

The tricolored bat is a proposed endangered species at the federal level. Tricolored bats are a small, insectivorous bat that are distinguished by their unique tricolored fur and often appear yellowish to nearly orange. During winter, tricolored bats are often found in caves and abandoned mines. In the spring, summer, and fall, the species are found in forested habitats where they roost in trees, primarily among leaves of live or recently deceased deciduous

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 41 of 78 hardwood trees. They may also be found in Spanish moss, pine trees, and human structures.

The current known range of the tricolored bat overlaps with the PBAPS action area. No critical habitat has been designated for the tricolored bat. (USFWS 2024a)

Potential stressors for northern long-eared bat and Indiana bat during the SLR term were analyzed by the NRC in the 2020 SEIS. The NRC concluded that continued operations of PBAPS are unlikely to result in effects to these species for the following reasons (NRC 2020a):

1. Bat collisions with nuclear power plant structures in the U.S. are rare, and none have been reported at PBAPS. Vehicle collisions attributable to the proposed action are also unlikely, and none have been reported at PBAPS.

2. The proposed action would not involve any construction, land clearing, or other ground-disturbing activities.

3. Bats, if present in the action area, have likely already acclimated to the noise, vibration, and general human disturbances associated with site maintenance, infrastructure repairs, and other site activities. During the SLR term, such disturbances and activities would continue at current rates and would be limited to the industrial-use portions of the site.

The only ground-disturbing activity planned at the PBAPS site is the implementation of a packaged STP that would be placed on an existing parking lot. Further, PBAPS has policies and procedures in place to mitigate any associated impacts.

Based on the information reviewed by CEG, the continued operations at PBAPS during the SLR term may affect but is not likely to adversely affect the tricolored bat.

Green floater (Lasmigona subviridis)

The green floater is a proposed threatened species at the federal level. Green floaters are small freshwater mussels found in small streams and large rivers in the eastern U.S. The species prefers streams with slow to medium flows and good water quality and are often found in sand or small gravel substrates where they establish a foothold and bury themselves as deep as 15 inches. They have limited mobility, and fast-flowing currents or high-water events can cause them to be washed downstream. When green floaters occur in larger streams or rivers, they are found in quieter pools and eddies, away from strong currents. The current known range of the green floater overlaps with the PBAPS action area. (USFWS 2024b) Though there is proposed critical habitat for the species, it does not overlap with the PBAPS action area or the 6-mile vicinity of the site (USFWS 2024c).

The reach of the Conowingo Pond near PBAPS has generally greater depths and slower water velocities compared to the upstream reach. Lentic conditions result in more fine-grained, silty substrates and lack habitat for species requiring sandy or cobble sediments. Conowingo Pond is characterized by steep banks and few in-river features. Poor mussel habitat occurs in the Conowingo Pond for most of the mussel species that are native to the Susquehanna River and tend to be found below the Conowingo Dam. (EGC 2018) It is therefore unlikely that quality habitat for the green floater is present within the PBAPS action area.

Based on the information reviewed by CEG coupled with the policies, procedures, and NPDES permit requirements, the continued operations of PBAPS during the SLR term would have no

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 42 of 78 effect on green floater. Further, the continued operations of PBAPS would have no effect on the proposed critical habitat for green floater.

Monarch butterfly (Danaus plexippus)

The Monarch butterfly is an ESA candidate for federal listing. 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. For overwintering monarchs, habitat with a specific microclimate is needed for protection from the elements, as well as moderate temperatures to avoid freezing. The current known range of the Monarch butterfly overlaps with the PBAPS action area. No critical habitat has been designated for the Monarch butterfly. (USFWS 2024d)

Suitable habitat for the monarch butterfly is likely present in undeveloped portions of the PBAPS site that are not maintained by mowing. No construction, land clearing, or other ground-disturbing activities are proposed during the SLR term that would potentially impact habitat for the monarch butterfly. The only ground-disturbing activity planned at the PBAPS site is the implementation of a new STP that would be placed on an existing parking lot. An erosion control plan was developed prior to conducting any work associated with the new STP. Any other potential ground-disturbing activities associated with general operations and maintenance would undergo an environmental review that includes an evaluation of potential impacts to protected species prior to the activity occurring. Existing regulatory programs the site is subject to, including management of herbicide applications, ensure that terrestrial habitat is protected. As such, the continued operation of the PBAPS site during the proposed SLR term would have no effect on the monarch butterfly.

5.9.2 Conclusion Since the PBAPS SLR ER and 2020 SEIS, three new species under USFWS jurisdiction have been proposed for listing under the ESA: tricolored bat (ESA proposed endangered), green floater (ESA proposed threatened), and Monarch butterfly (ESA candidate for listing). Based on CEGs review of information, the continued operations of PBAPS over the SLR term may affect but is not likely to adversely affect the tricolored bat, have no effect on the green floater or the proposed green floater critical habitat, and have no effect on the Monarch butterfly.

Compliance with all regulatory requirements associated with protected species will continue to be an administrative control practiced by CEG for the licensed life of the PBAPS facility.

Adherence to these controls, as well as compliance with applicable laws and regulations, would prevent any potentially negative impacts to the ESA listed species and birds protected under the Migratory Bird Treaty Act.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 43 of 78 5.10 Federally Protected Ecological Resources - Endangered Species Act:

Federally Listed Species and Critical Habitats Under National Marine Fisheries Service Jurisdiction PBAPS SLR ER Section: 4.6.3 5.10.1 Supplemental Information 5.10.1.1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table B-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 agencys jurisdiction.

5.10.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(E)]

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.

5.10.1.3 Background [GEIS Section 4.6.1.3.2]

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 the National Marine Fisheries Service (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. The NRC would need to perform 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, as appropriate.

5.10.1.4 Analysis As described in Section 3.8.1.3 of the SEIS, there are no federally listed endangered or threatened species under NMFS jurisdiction that occur within Conowingo Pond. Two federally listed species under the NMFS jurisdiction may occur below the Conowingo Dam within the lower Susquehanna River: Atlantic sturgeon (Acipenser oxyrinchus oxyrinchus) and shortnose sturgeon (Acipenser brevirostrum). Although both species occur in the lower Susquehanna River, Conowingo Dam physically prevents individuals from entering Conowingo Pond. Thus, the Susquehanna River below Conowingo Dam within the dams tailwaters is the closest region

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 44 of 78 of the river in which both Atlantic sturgeon and shortnose sturgeon may occur. This region of the river is outside of the PBAPS action area. Accordingly, the NRC staff concluded that Atlantic sturgeon and shortnose sturgeon are not present in the PBAPS action area. Therefore, as stated in Section 4.8.1.2 of the SEIS, the NRC concluded that continued operations under the PBAPS SLR would have no effect on these species. (NRC 2020a) 5.10.2 Conclusion CEG did not identify any new and significant information for federally listed species and critical habitats under NMFS jurisdiction and therefore concludes the PBAPS SLR ER assessment of NO EFFECT remains valid for the SLR. Further, CEG did not identify any new and significant information related to NRCs basis for concluding that continued operations under the PBAPS SLR would have NO EFFECT on Atlantic sturgeon and shortnose sturgeon.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 45 of 78 5.11 Federally Protected Ecological Resources - Magnuson-Stevens Act: Essential Fish Habitat PBAPS SLR ER Section: 4.6.3 5.11.1 Supplemental Information 5.11.1.1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table B-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.

5.11.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(E)]

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.

5.11.1.3 Background [GEIS Section 4.6.1.3.3]

This issue concerns the potential effects of continued nuclear power plant operation and any refurbishment during an initial LR or SLR term on essential fish habitat (EFH) protected under the 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 (HAPC). 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. The NRC would need to perform 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 as appropriate.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 46 of 78 5.11.1.4 Analysis No HAPC is present in the PBAPS action area (NOAA 2024). In Section 3.8.2 of the SEIS, the NRC establishes that EFH is not designated within Conowingo Pond. However, the NMFS and Atlantic States Marine Fisheries Commission have designated EFH near the mouth of the Susquehanna River for the following six federally managed species and life stages (NRC 2020a):

Atlantic herring (Clupea harengus) - juveniles and adults clearnose skate (Raja eglanteria) - juvenile and adults little skate (Leucoraja erinacea) - adults red hake (Urophycis chuss) - all life stages windowpane flounder (Scophthalmus aquosus) - adults winter skate (Leucoraja ocellata) - juveniles and adults.

As described in Section 4.8.1 of the SEIS, the NRC concluded that the PBAPS SLR would have no direct effects on the EFH of any species because no designated EFH is present in Conowingo Pond. All potential adverse impacts on EFH would be limited to loss of prey for those EFH species that consume anadromous prey species that migrate through Conowingo Pond. Atlantic herring, clearnose skate, and red hake do not consume anadromous prey fish.

Therefore, PBAPS SLR would result in no effects on the designated EFH of these species.

(NRC 2020a)

Although the remaining EFH species - little skate, windowpane flounder, and winter skate -

consume anadromous prey fish, these fish constitute a minor portion of the three EFH species diet. Some anadromous prey fish are present in Conowingo Pond. The gizzard shad is common in the pond, while all Alosa species have been rare in collections associated with Conowingo Pond aquatic studies. None of the available studies or other information indicates that impingement, entrainment, thermal effects, or indirect impacts to the habitat of these anadromous species would be noticeably affected as a result of PBAPS operations during the SLR term. Accordingly, no adverse effects to EFH would result from loss of prey, and the NRC staff concluded that the proposed action would have no adverse effects on the designated EFH for little skate, windowpane flounder, or winter skate. (NRC 2020a) Since the publication of the SEIS in 2020, no changes in operating conditions have taken place at PBAPS that would change the conclusions reached in the SEIS.

5.11.2 Conclusion CEG did not identify any new and significant information for EFH or EFH species and therefore concludes the PBAPS SLR ER assessment of no adverse effects remains valid for the SLR.

Further, CEG did not identify any new and significant information related to the NRCs basis for concluding that continued operations under the PBAPS SLR would have no adverse effects on EFH or EFH species.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 47 of 78 5.12 Federally Protected Ecological Resources - National Marine Sanctuaries Act:

Sanctuary Resources PBAPS SLR ER Section: New 5.12.1 Supplemental Information 5.12.1.1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table B-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 (ONMS) under National Marine Sanctuaries Act Section 304(d) would be required if license renewal could destroy, cause the loss of, or injure sanctuary resources.

5.12.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(E)]

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.

5.12.1.3 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 IM&E or thermal effects on prey species, and effects associated with maintenance dredging. Depending on the NRCs effect determinations, the NRC may be required to consult with the ONMS 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 plants license renewal term is not possible. Section 4.6.1.3.4 of the GEIS states: The NRC would need to perform 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, as appropriate.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 48 of 78 5.12.1.4 Analysis No national marine sanctuaries are located within the 6-mile radius of the PBAPS site. The nearest national marine sanctuary is Mallows Bay-Potomac River National Marine Sanctuary, an 18-square-mile area of waters and submerged lands encompassing and surrounding the Mallows Bay area of the tidal Potomac River. The area is located entirely within Maryland state waters, adjacent to the Nanjemoy Peninsula of Charles County, Maryland, 40 miles south of Washington, D.C. (FR 2019) 5.12.2 Conclusion No national marine sanctuaries are located within the affected area of PBAPS. As such, this issue is not applicable to the continued operation of the PBAPS site for the proposed operating term. Thus, CEG finds that there would be no effect to sanctuary resources during the proposed SLR term.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 49 of 78 5.13 Historic and Cultural Resources PBAPS SLR ER Section 4.7 5.13.1 Supplemental Information 5.13.1.1 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 right-of-way (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 which includes consultation with the State and Tribal Historic Preservation Officers, Indian Tribes, and other interested parties.

5.13.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(K)]

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.

5.13.1.3 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. 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 SLR APE is the area that may be impacted by land-disturbing or other operational activities associated with continued plant operations and maintenance during the LR 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 and refurbishment activities during the renewal term (i.e., initial LR and SLR) 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 in 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 on 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

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 50 of 78 determinations (see 36 CFR 800.4) for plant-specific license renewal which 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 Part 800.5).

For a historic property under the NHPA that does not meet the criteria, the NRC will assess whether there are 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.

5.13.1.4 Analysis As stated in the PBAPS SLR ER Section 3.7, there are no known historic or archaeological resources at the PBAPS site. In addition, ER Section 3.7.2 states that there were procedures in place which applied to land disturbing activities to minimize the potential adverse effects to unidentified archaeological or historic resources. PBAPS continues to have these procedures in place.

There has been no correspondence with the Pennsylvania State Historic Preservation Officer, Indian Tribes or interested parties regarding historic properties or sites of religious or cultural significance to any Tribes with regards to PBAPS since the PBAPS SLR ER.

A review of the Pennsylvanias Historic & Archaeological Resource Exchange Geographic Information Systems database, conducted in April 2024, found there have been no new cultural resource studies or archaeological or historic sites recorded within the 769-acre PBAPS site since the PBAPS SLR ER was submitted.

As presented in Section 2.3 of the PBAPS SLR ER, no SLR-related refurbishment activities have been identified and, therefore, there would be no SLR-related refurbishment impacts to historic and cultural resources. In addition, no SLR-related construction activities or changes in operational practices have been identified. Section 2.0 discusses the installation of an STP and an ISFSI expansion. As previously mentioned, the STP installation project is located on previously disturbed ground. The site selection process of an ISFSI expansion would follow station environmental procedures, including those that outline the requirements for cultural, historic, and paleontological resource evaluation.

5.13.2 Conclusion Based on the discussion above, CEG concludes that there will be no adverse effects to historic or cultural resources during the SLR term. PBAPS has procedures in place to protect previously unidentified historic and cultural resources, any impacts would be SMALL, and the conclusions in the 2018 ER remain valid. Further, CEG did not identify any new and significant information related to NRCs basis for finding in the 2020 SEIS that continuing operations during the SLR term would not adversely affect any known historic properties or historic and cultural resources.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 51 of 78 5.14 Human Health - Microbiological Hazards to the Public PBAPS SLR ER Section 4.9.1 5.14.1 Supplemental Information 5.14.1.1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table B-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, canals, or that discharge to publicly accessible surface waters. Impacts would depend on site-specific characteristics.

5.14.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(G)]

If the applicant's plant uses a cooling pond, lake, canal or discharges publicly accessible surface waters, an assessment of the impact of the proposed action on public health from thermophilic organisms in the affected water must be provided.

5.14.1.3 Background [GEIS Section 4.9.1.1.3]

Members of the public could be exposed to microorganisms in thermal or cooling system effluents at nuclear power plants that use cooling ponds, lakes, canals, or that discharge to publicly accessible surface waters. Microbiological hazards occur when the public come into contact with disease-causing microorganisms, also known as etiological agents. Etiological agents associated with nuclear power stations may include more than just thermophilic microorganisms that may be present in elevated numbers in cooling ponds, lakes, canals, or surface waters. Microbiological organisms of concern for the public 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). See additional detail in GEIS Section 3.9.2.2.

SEISs published since 2013 were reviewed to determine the level of thermophilic microbiological organism enhancement in waters accessible to the public. Although reviews to date note that health departments did not have concerns related to microbiological hazards, changes in microbial populations and in the public use of waterbodies might occur after the operating license is issued and the application for initial LR or SLR is filed. The severity of the potential public health impacts associated with thermal enhancement of thermophilic organisms during the initial LR and SLR terms could be SMALL, MODERATE, or LARGE, depending on plant-specific conditions.

5.14.1.4 Analysis To determine whether the continued operations of PBAPS could promote increased growth of thermophilic microorganisms and thus have an adverse effect on the public, the NRC considered several factors in the SEIS: the thermophilic microorganisms of concern, thermal effluent characteristics, the recreational use of the Susquehanna River near the discharge structure, and the Pennsylvania Department of Healths input.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 52 of 78 The 2024 GEIS added cyanobacteria associated harmful algal blooms to the list of microorganisms of concern. Pennsylvania has a program for monitoring harmful algal blooms and reports blooms since 2018 through an online Harmful Algal Bloom Dashboard. No harmful algal blooms have been reported for the Susquehanna River, Conowingo Pond, or in the vicinity of PBAPS from 2018 to November 8, 2024. (PA DH 2024)

PBAPS continues to have a thermal discharge to Conowingo Pond, and the thermal discharges may affect a very small area of Conowingo Pond along the west shore near the discharge structure (not within the discharge canal). This area is accessible to the public and may be accessed by fishermen by boat.

In the PBAPS SLR ER Sections 3.9.1 and 4.9.1, a 2010-2013 thermal study by EGC characterized the temperature of Conowingo Pond approximately 1,600 and 2,100 ft from the discharge canals outlet as approximately 6.5 to 11.5 degrees Fahrenheit (°F) cooler than at the end of the canal, corresponding to temperatures of 93.7°F to 88.7°F during summer without cooling towers in operation.

PBAPS implemented a Measurement Uncertainty Recapture uprate in mid-January 2018. The uprate was anticipated to increase the PBAPS condenser discharge temperature a maximum of 0.4°F. A temperature monitoring study was requested by PA DEP to validate the assumption of a change in temperature (T) following implementation of the uprate. The water temperature monitoring study measured and recorded water temperature at onsite and Conowingo locations post uprate in 2018, 2019, and 2020. Temperature loggers were installed in Conowingo Pond within the thermal plume along shallow shoreline areas (five locations) and at several buoy transects across Conowingo Pond (five locations). Temperature data from 2018, 2019, and 2020 indicated that measured T was within the predicted value of 0.4°F increase with noted exceptions being during winter months. Therefore, the water temperature in the small area of Conowingo Pond along the west shore near the discharge structure that is accessible to fishermen by boat could experience water temperatures up to 0.4°F greater than those presented in the PBAPS SLR ER.

PBAPS continues to operate one to three cooling towers as part of its cooling water system June 15 to September 30 as requested by PA DEP in 2017. PBAPS proposed to initiate cooling tower operation based on temperate and flow conditions, rather than the date of June 15, in current NPDES permit application submitted March 29, 2019. The extended use of the cooling towers and initiation of use based on temperature and flow conditions would not be expected to alter the public exposure to aerosolized Legionella. As stated in the SEIS Section 4.11.1.3, public exposure to aerosolized Legionella would not be likely because such exposure would be confined to a small area of the site where public access is restricted.

Waterborne disease in the U.S. is reported by local health departments to the National Outbreak Reporting System. According to the National Outbreak Reporting System, which is current through 2021, there were no incidences of waterborne disease associated with untreated recreational water in in Pennsylvania 2018-2021 (CDC 2022). The Center for Disease Control and Prevention reported no cases of Naegleria fowleri in Pennsylvania through 2022 (CDC 2023)

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 53 of 78 5.14.2 Conclusion CEG did not identify any new and significant information for microbiological hazards and therefore concludes the PBAPS SLR ER assessment of SMALL remains valid for the SLR.

Further, CEG did not identify any new and significant information related to NRCs basis for concluding microbiological hazards as SMALL in the SEIS.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 54 of 78 5.15 Human Health - Electric Shock Hazards PBAPS SLR ER Section 4.9.2 5.15.1 Supplemental Information 5.15.1.1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table B-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.

5.15.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(H)]

If the applicants 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.

5.15.1.3 Background [Section 4.9.1.1.5]

In-scope transmission lines are those lines that connect the plant to the first substation of the regional electric grid. This substation is frequently, but not always, located on the plant property.

The greatest hazard from a transmission line is direct contact with the conductors. Tower designs preclude direct access to the conductors. However, electrical contact can be made without physical contact between a grounded object and the conductor. 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 would depend on the electromagnetic field strength, size of the object, and how well the object and person were insulated from ground.

Design criteria for nuclear power plants that limit hazards from steady-state currents are based on the NESC, adherence to which requires that power 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 mA. This issue 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. A review of the nuclear plants transmission lines conformance with NESC criteria is necessary to determine the significance of the electrical shock potential generically during the initial LR or SLR term: it could be SMALL, MODERATE, or LARGE.

5.15.1.4 Analysis The PBAPS SLR ER Section 3.9.2 identified the in-scope transmission lines (EGC 2018). The transmission lines identified in the PBAPS SLR ER as in-scope continue to be in-scope, and there are no additions or removal of electrical lines or voltage changes since submittal of the PBAPS SLR ER. The in-scope transmission lines are depicted in Figure 5.15-1 and the figure legend identifies each of these lines using the description from PBAPS SLR ER Section 3.9.2.

As stated in PBAPS SLR ER Section 3.9.2, with the exception of the 34.5-kilovolt (kV) submarine cable, the routes traversed by these in-scope transmission lines are onsite and not

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 55 of 78 accessible to the general public. The 34.5-kV submarine cable supplies offsite power to PBAPS in the event of station blackout (SBO). This transmission line, the Conowingo-PBAPS SBO line, extends from the Conowingo hydroelectric facility located adjacent to the Susquehanna River downstream from PBAPS to the PBAPS SBO substation. The line is all submarine cable or underground cable, except within the non-publicly accessible Conowingo and PBAPS SBO substations.

PBAPS continues to have a comprehensive industrial safety program that adheres to Occupational Safety and Health Administration (OSHA) standard 29 CFR Part 1910 Subpart R, Special Industries, as it relates to Electric Power Generation, Transmission and Distribution (29 CFR Part 1910.269) as well as many other OSHA standards.

The NRC reviewed the in-scope transmission lines with regard to the electrical shock Category 2 issue in Section 4.11.1.2 of the SEIS (NRC 2020a). Because the in-scope transmission lines are onsite and therefore there are no potential impacts to members of the public and because PBAPS maintains an occupational safety program for its workers in accordance with OSHA regulations, which includes protection from acute electric shock, NRC concluded that the potential impacts from acute electric shock during the SLR term would be SMALL.

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

Further, CEG did not identify any new and significant information related to NRCs basis for concluding electric shock hazards as SMALL in the SEIS.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 56 of 78 Legend 34.5 Kv Submarine Cable (from Conowingo Hydroelectric Facility)

Bus 3SU - 13 kV Transmission Line Bus 343SU - 13 kV Transmission Line Unit 2 - 500 kV Transmission Line Unit 3 - 500 kV Transmission Line Nottingham-Cooper - 220 kV Transmission Line Note: Dashed lines denotes buried/submarine segments.

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======::::i Feet 0

500 1,000 Figure 5.15-1 PBAPS In-Scope Transmission Lines

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 57 of 78 5.16 Environmental Justice - Impacts on Minority Populations, Low-income Populations, and Indian Tribes PBAPS SLR ER Section 4.10.1 5.16.1 Supplemental Information 5.16.1.1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table B-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 plant-specific reviews.

5.16.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(N)]

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.

5.16.1.3 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 license renewal 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 license renewal 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 license renewal 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. NRC considers the means by which these populations could be disproportionately affected by examining potential human health and environmental effects from continued reactor operations and refurbishment activities at nuclear power plants.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 58 of 78 5.16.1.4 Analysis The PBAPS SLR ER utilized the American Community Survey (ACS) 2010-2015 5-year block group data from the U.S. Census Bureau (USCB) to characterize the minority and low-income demographics for communities and counties within the 50-mile region. In order to provide updates for minority and low-income populations and identify changes since the PBAPS SLR ER, this supplement examines the most recent decennial 2020 population counts, and ACS 2018-2022 5-year population estimates of the USCB. The PBAPS SLR ER provided results of block group counts and did not offer population data. Therefore, this supplement provides state and county population data for 2010, 2015, 2020, and 2022 to show population growth since the development of the PBAPS SLR ER. The geographic locations included in this study are the State of Pennsylvania, York County, as it is the county in which PBAPS is located, and Lancaster County because it is the closest adjacent county to the plant.

State and County As shown in Table 5.16-1, minority population totals for the State of Pennsylvania in 2010 were 12,702,379 and increased by 0.61 percent to 12,779,559 in 2015. This trend continued as the population for Pennsylvania increased from 2015 to 2020 by 223,141 persons, which resulted in an increase of 1.75 percent over the 5-year period. There was a slight decrease in Pennsylvanias population from 2020-2022 of 13,492 people, resulting in a 0.10 percent decrease. (USCB 2010a; USCB 2015; USCB 2020a; USCB 2022) According to Pennsylvanias Commonwealth Foundation, this decrease from 2020-2022 is possibly due to the outmigration of citizens to find lower cost of living, lower taxes, and better jobs and opportunities (CF 2023).

Overall, the state of Pennsylvania experienced an increase of 286,829 persons (2.26 percent) from 2010-2022. (USCB 2010a; USCB 2022)

As listed in Table 5.16-1, in 2010, Lancaster County consisted of 519,445 individuals, which accounted for 4.09 percent of Pennsylvanias total minority population. Lancaster County experienced a 2.07 percent increase in population from 2010 to 2015. By 2020, the number of people residing in Lancaster County had grown another 4.38 percent to a total population of 552,984. Overall, there was a continuous increase in the population of Lancaster County from 2010-2022. (USCB 2010a; USCB 2015; USCB 2020a; USCB 2022)

The total population of York County in 2010 accounted for 3.4 percent of Pennsylvanias population. According to Table 5.16-1, York County had a minority population of 434,972 persons in 2010, which grew by 4,688 people in 2015 to a total of 439,660, resulting in a 1.08 percent growth in population from 2010 to 2015. Similar to Lancaster County, York County experienced a 3.82 percent growth in population from 2015 to 2020. This trend continued as the population for York County increased by 613 persons from 2020 to 2022, which resulted in an increase of 0.13 percent over the 2-year period. Overall, there was a 5.08 percent increase in the total population of York County from 2010 to 2022. (USCB 2010a; USCB 2015; USCB 2020a; USCB 2022)

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 59 of 78 Minority Populations As noted in the PBAPS SLR ER, the most prevalent minority population throughout the state of Pennsylvania are Black or African American individuals. In 2010, Black or African American individuals represented 10.85 percent of the population of Pennsylvania, with a total population of 1,377,689. By 2022, the number of Black or African American individuals had grown by 30,125 people, resulting in a 2.19 percent change in population for that minority group from 2010 to 2022. In 2022, the Black or African American population represented 10.84 percent of the population of Pennsylvania. Consistent with the PBAPS SLR ER, the second most common group of minority populations in the State of Pennsylvania are Hispanic individuals. In 2010, the Hispanic population in the State of Pennsylvania consisted of 719,660 persons, which accounted for 5.67 percent of the states population. Similar to the Black or African American population, there was an overall increase of 335,448 Hispanic individuals in Pennsylvania from 2010 to 2022, resulting in a 46.61 percent increase in Hispanic population over the 12-year period. In 2022, Hispanic individuals represented 8.12 percent of the population of Pennsylvania. (USCB 2010a; USCB 2015; USCB 2020a; USCB 2022)

The Black or African American population consisted of 19,035 persons in Lancaster County for 2010, which accounted for 3.66 percent of the total population. By 2022, the Black or African American population accounted for 4.03 percent of the population. In 2010, the Hispanic Ethnicity category accounted for 8.65 percent of the total population in Lancaster County which, as mentioned in the PBAPS SLR ER, exceeded the state average for Hispanic individuals. By 2022, the Hispanic population represented 11.23 percent of the total population in Lancaster County. (USCB 2010a; USCB 2015; USCB 2020a; USCB 2022)

In York County, the Black or African American population consisted of 24,344 persons in 2010, which accounted for 5.60 percent of the total population. By 2022, the Black or African American population had increased to 6.01 percent of the countys total population. In 2010, the Hispanic Ethnicity category accounted for 5.61 percent of the total population in York County, which did not exceed the state average for Hispanic individuals as mentioned in the PBAPS SLR ER. By 2022, the Hispanic population represented 8.52 percent of the total population in York County.

(USCB 2010a; USCB 2015; USCB 2020a; USCB 2022)

Low-Income Populations NRC guidance defines low-income by using USCB statistical poverty thresholds (NRC 2020b).

Poverty status for households and individuals within Pennsylvania were derived from the ACS 5-Year estimates and decennial data for the years 2010, 2015, 2020 and 2022. Table 5.16-2 provides a summary of low-income individuals and families (e.g., households) for the state of Pennsylvania. The percent of population for both the low-income individual and family categories decreased slightly between 2010 and 2022, from 12.10 percent to 11.89 percent for families and from 12.38 percent to 11.78 percent for individuals. (USCB 2010b; USCB 2015; USCB 2020b; USCB 2022)

In 2010, Lancaster County had a total of 191,474 households, of which 17,382 households were classified as low-income populations that account for 9.08 percent of the total household population in the county. By 2015, the number of low-income households for Lancaster County had increased to 195,330 households. In 2022, the total households in Lancaster County had increased to 208,988 households, of which 17,068 households were considered low-income,

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 60 of 78 resulting in 8.17 percent of households in poverty. According to Table 5.16-2, in 2010 the total number of individuals in poverty, in Lancaster County, was 48,018, or 9.67 percent of the population. There was an increase of 7,354 individuals in poverty from 2010 to 2015 and an increase of 367 individuals in from 2015 to 2020, resulting in 9.11 percent of the population for 2020. Contrarily, there was a decline of 447 low-income individuals from 2020-2022, resulting in 8.18 percent of individuals in poverty in 2022. (USCB 2010b; USCB 2015; USCB 2020b; USCB 2022)

Table 5.16-2 shows that, in York County, the 2010 total household population was 166,600 households, of which 8.84 percent of the total household population was considered to be low-income. There was an increase in the number of households in poverty for York County between 2010 and 2015 from 14,734 households or 8.84 percent to 16,562 households or 9.89 percent. Additionally, there was a decrease of 1,629 households in poverty from 2015 to 2020 in York County. In 2022, the number of households increased to 15,852 households or 8.88 percent. In 2010, low-income individuals accounted for 9.01 of the total individual population in York County. By 2020, the percentage of low-income individuals decreased to 8.74 percent. In 2022, the population of low-income individuals was 338,540 or 8.60 percent. (USCB 2010b; USCB 2015; USCB 2020b; USCB 2022)

Tribal Populations There are no federal or state recognized native American Indian tribes with reservations or identified lands located in the 50-mile region. However, several groups, such as the Lenape (Delaware) Tribe, continue to have a modern presence in the state and are working to revitalize the indigenous heritage of Eastern Pennsylvania. (NPS 2024)

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

As stated in PBAPS SLR ER, EGC queried PBAPS staff, government organizations, and social welfare organizations to identify the existence of subpopulations near PBAPS (York and Lancaster counties) that engage in a subsistence-like lifestyle. This would include groups in which hunting, gathering, fishing, and gardening constituted a larger fraction of the subpopulations food sources than those of the general population. Several of the telephone interviewees mentioned the Amish population as a possible subsistence group. No other subpopulations were identified. (EGC 2018)

The presence of Amish communities was identified in southeastern York County along the country roads in the Delta-Peach Bottom area. State Line Flowers is an Amish nursery selling various plants and is located 5.6 miles from the plant. These characteristics may be perceived by the general population as indicative of a subsistence way of life (SLF 2024). However, as stated in the PBAPS SLR ER, about two thirds of the Amish community support themselves by working in more than 12,000 Amish-owned small businesses or non-Amish shops and factories.

The Amish maintain large gardens for their own use, which may constitute a significant part of their food supply. However, they also buy many food items from traditional stores. Therefore, it

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 61 of 78 was determined that they use gardening as a supplement to their food source by choice, not by necessity. The Amish hunt with guns as well as bow and arrow and often travel out of state to find the best hunting grounds. As a result of the use of gardening as a supplement to their food source and a recreational approach to hunting, it was concluded that their lifestyle behaviors reflect a self-sufficiency philosophy instead of subsistence behavior. Other plain-dressing communities such as Mennonites in Lancaster and York counties have similar practices.

Therefore, it was concluded that no subpopulations near PBAPS engage in a subsistence-like lifestyle. (EGC 2018)

As part of the PBAPS Radiological Environmental Monitoring Program (REMP) program, an annual land use census to assess the contribution of radionuclides to the environment resulting from PBAPS operation. The results are compared to historical data to determine if there are any observable trends and are provided in the publicly available AREOR. Within the last five years, no values have exceeded the limits set by the NRC. As such, the PBAPS REMP program has not identified any significant effects to the environment, therefore no potential impact pathways would have an effect on any human population.

Migrant Workers Migrant labor, or a migrant worker, is defined by the U.S. Department of Agriculture as a farm worker whose employment required travel that prevented the migrant worker from returning to his/her permanent place of residence the same day. In 2022, Lancaster County reported that 1,700 out of 4,680 total farms employed farm labor. An estimated total of 8,377 farm laborers were hired, of which 4,862 were estimated to work fewer than 150 days per year. The 2022 Census of Agriculture reported that there were 47 Lancaster County farms that employed migrant farm labor. York County reported that 430 out of 1,929 farms employed farm labor. An estimated 2,277 farm laborers were hired, of which 1,282 were estimated to work fewer than 150 days per year. Additionally, the 2022 Census of Agriculture reported that 22 farms employed migrant farm labor in the County of York. (USDA 2022)

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 62 of 78 Table 5.16-1 Minority Populations Year Location Total Population American Indian or Alaskan Native Asian Native Hawaiian

/ Other Pacific Islander Black or African American Some Other Race Two or More Races Aggregate of all Minority Races Aggregate of all Minority Races and Hispanic Ethnicity Hispanic Ethnicity 2010 Pennsylvania 12,702,379 26,843 349,088 3,653 1,377,689 300,983 237,835 2,296,091 2,607,727 719,660 2015 Pennsylvania 12,779,559 23,641 392,595 4,279 1,403,143 253,070 272,689 2,349,417 2,799,805 815,538 2020 Pennsylvania 13,002,700 31,052 510,501 4,276 1,423,169 508,531 774,484 3,252,013 3,449,283 1,049,615 2022 Pennsylvania 12,989,208 20,570 473,192 4,256 1,407,814 405,422 667,575 2,978,829 3,318,060 1,055,108 2010 Lancaster County 519,445 1,195 9,860 164 19,035 18,819 10,201 59,274 78,476 44,930 2015 Lancaster County 530,216 751 10,836 31 21,375 16,890 10,813 60,696 87,878 50,765 2020 Lancaster County 552,984 1,322 14,147 169 22,394 27,367 34,939 100,338 112,371 61,171 2022 Lancaster County 553,202 930 13,133 112 22,284 20,123 29,631 86,213 109,480 62,108 2010 York County 434,972 942 5,407 123 24,344 10,326 8,695 49,837 60,193 24,397 2015 York County 439,660 406 5,989 68 25,769 6,963 9,923 49,118 66,041 28,334 2020 York County 456,438 1,116 6,675 182 27,999 18,626 28,640 83,238 91,085 39,360 2022 York County 457,051 715 6,713 177 27,481 11,342 23,746 70,174 86,526 38,943 (USCB 2010a; USCB 2015; USCB 2020a; USCB 2022)

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 63 of 78 Table 5.16-2 Low-Income Populations Total Population Low-Income Population 2010 Total Household Population Total Individual Population Household Population Individual Population State of Pennsylvania 4,940,581 12,199,544 597,952 1,509,858 Lancaster County 191,474 496,623 17,382 48,018 York County 166,600 419,833 14,734 37,810 2015 Household Total Population Individual Total Population Low-Income Household Low-Income Individual State of Pennsylvania 4,958,859 12,365,782 638,442 1,666,569 Lancaster County 195,330 515,777 19,160 55,372 York County 167,416 430,380 16,562 46,124 2020 Household Total Population Individual Total Population Low-Income Household Low-Income Individual State of Pennsylvania 5,106,601 12,387,061 602,145 1,480,430 Lancaster County 204,003 531,134 17,515 48,385 York County 174,425 438,276 14,933 38,299 2022 Household Total Population Individual Total Population Low-Income Household Low-Income Individual State of Pennsylvania 5,193,727 12,582,125 617,593 1,482,439 Lancaster County 208,988 540,062 17,068 44,195 York County 178,543 448,114 15,852 38,540 (USCB 2010b; USCB 2015; USCB 2020b; USCB 2022)

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 64 of 78 5.16.2 Conclusion As demonstrated above, the demographic makeup of Pennsylvania, Lancaster and York counties have not changed significantly since the PBAPS SLR ER was written. Additionally, there are no SLR-related refurbishment activities identified, nor are there changes to the operational activities described in the PBAPS 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.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 65 of 78 5.17 Cumulative Effects PBAPS SLR ER Section 4.12 5.17.1 Supplemental Information 5.17.1.1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table B-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.

5.17.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(O)]

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.

5.17.1.3 Background [GEIS Section 4.13]

Actions considered in the cumulative effects (impacts) analysis include the proposed license renewal 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 cumulative effects or impacts analysis only considers resources and environmental conditions that could be affected by the proposed license renewal action, including the effects of continued reactor operations during the license renewal term and any refurbishment activities at a nuclear power plant. In order for there to be a cumulative effect, the proposed action (license renewal) must have an incremental new, additive, or increased physical effect or impact on the resource or environmental condition beyond what is already occurring. 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 may be experienced, as well as 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 and the incremental effects or impacts of the proposed action (license renewal).

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 66 of 78 The incremental effects of the proposed action (license renewal) when added to the effects from past, present, and reasonably foreseeable actions, and other actions (including trends such as global climate change) 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.

For some resource areas (e.g., water and aquatic resources), the incremental contributions of ongoing actions within a region are regulated and monitored through a regulatory process (e.g., permitting process, NPDES) under state or federal authority. In these cases, it may be assumed that cumulative effects are managed in their respective permits.

The NRC reviewed information from SEISs (for initial LRs and SLRs) completed since development of the 2013 LR GEIS. Based on the information reviewed and the preceding discussion, the NRC concludes that cumulative effects during the initial LR and SLR terms and refurbishment are unique to each nuclear power plant. Therefore, the cumulative effects of license renewal cannot be determined generically.

5.17.1.4 Analysis Cumulative effects may result when the environmental effects associated with SLR, the proposed action, are added to the environmental effects from other past, present, and reasonably foreseeable future actions, including projects 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 or SLR action, combined with effects of other actions, could generate cumulative effects on a given resource. The goal of the cumulative effects analysis is to identify potentially significant impacts. The cumulative effects or impacts analysis only considers resources and environmental conditions that could be affected by the proposed LR action, including the effects of continued reactor operations during the license renewal term and any refurbishment activities at a nuclear power plant. For there to be a cumulative effect, the proposed action (SLR) 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)

For the purposes of analysis, past actions are those that occurred since the commencement of reactor operations and prior to the submittal of the SLR application, present actions are those that are occurring during current power plant operations, and reasonably foreseeable future actions are those that would occur through the end of power plant operation, including the period of extended operation. (NRC 2024) Therefore, the cumulative impacts analysis considers potential effects through the end of the current license term, as well as through the 20-year renewal license term.

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

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 67 of 78 Offsite construction activities that were completed and became operational since the SEIS include Wildcat Point, Calpine Mid-Merit (York 2 Energy Center), Atlantic Sunrise Pipeline, and Eurofins BioPharma Services Lancaster Laboratory expansion. Wildcat Point became operational in the spring of 2018 and is a natural gas-fired power plant, in Cecil County, MD, approximately 6.5 miles southeast of PBAPS. The facility generates approximately 1,000 megawatts (MW) of electricity. (DBN 2024) In addition, Calpine Mid-Merit, LLC, constructed the York 2 Energy Center in Peach Bottom Township. The power plant, generating approximately 830 MW, is a dual-fueled, combined-cycle technology using natural gas and diesel that became operational in March 2019 (Calpine 2024). The Atlantic Sunrise pipeline project was an expansion of the Transco natural gas pipeline was placed in service in October 2018 (Williams 2024). As stated in the PBAPS SLR ER, the pipeline traverses the vicinity. In 2019, Eurofins BioPharma Services, Eurofins Lancaster Labs in Lancaster County completed the expansion of its existing facility, adding 350 jobs (CDNMedia 2024; EBS 2024).

Since the PBAPS SLR ER and SEIS, construction began on a Commerce Center in York County, Manchester Township in December 2023. The project will create 1,600 operational and construction jobs. (ABC27 2024) This center, which will be located in York, Pennsylvania (approximately 40 miles from PBAPS) will consist of two buildings with 673,920 square feet, rated Class A core industrial. (ECP 2024)

With the exception of the York commerce center, each of the actions discussed above are completed. No other new and significant information was identified during the review of available information.

The packaged STP installation project onsite southeast of the current treatment plant required an erosion control plan.

As stated in the PBAPS SLR ER and SEIS, additional ISFSI storage capacity will be needed to accommodate spent nuclear fuel generated during the second renewal term beyond 2034. A third pad would go north of the existing pads and north of the 500kV lines. This location would require site preparation similar to the second pad. Some initial scoping was performed during design of the second pad; however, there are no current plans to initiate the installation. The scope of any such expansion cannot be determined at this time, as it would depend on the status of the DOEs future performance of its obligation to accept spent nuclear fuel or the availability of other interim storage options. CEG has plans and procedures in place to mitigate environmental impacts from construction and would obtain the necessary permits.

As previously stated, no refurbishment or major construction activities have been identified to occur during the proposed SLR operating term. Further, there are no projects or programs identified that are planned in the vicinity of PBAPS that have the potential to result in a cumulative effect on the environment.

The 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 in this supplement and serve as the environmental baseline for the cumulative effects analysis.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 68 of 78 5.17.2 Conclusion In summary, no refurbishment or major construction activities have been identified that would occur during the proposed SLR operating term. In addition, no federal and non-federal projects have been identified as taking place in the vicinity of PBAPS that have the potential to result in a cumulative effect on the environment. Therefore, the conclusion in the SEIS, that continued operation of PBAPS during the renewal term is expected to have a SMALL impact, remains valid.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 69 of 78 5.18 Climate Change - Climate Change Impacts on Environmental Resources PBAPS SLR ER Section: New 5.18.1 Supplemental Information 5.18.1.1 Findings from 10 CFR Part 51, Subpart A, Appendix B, Table B-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.

5.18.1.2 Requirement [10 CFR 51.53(c)(3)(ii)(Q)]

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.

5.18.1.3 Background [GEIS Section 4.12.2]

Climate change is an environmental trend (i.e., change in climate indicators such as precipitation over time) that is irrespective of license renewal. Climate change could result in changes to the affected environmental resource baseline conditions. Future global GHG emission concentrations (emission scenarios) and climate models are commonly used to project 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, 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 license renewal. Climate change may impact the baseline environmental conditions (e.g., surface water temperature and levels) that are impacted by the proposed action (license renewal). In order for there to be a climate change impact on an environmental resource, the proposed action (license renewal) 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.

5.18.1.4 Analysis 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 1901-2016, the average temperature increased by 17 degrees Celsius (°C) (1.8°F), and precipitation increased by an average of 0.1 inch per decade. (NRC 2024)

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 70 of 78 Climate Change Observations The USGCRP issued the Fifth National Climate Assessment (NCA), which contains summaries of climate indicators and climate model simulations of future conditions. The Fifth NCA uses global warming level (GWL), which is the average global temperature change in °C relative to preindustrial temperatures, to project climate change scenarios. 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. Projections of global average surface temperature primarily depend on two factors, estimated future emissions and sensitivity of the climate system. In a very high scenario, the world is likely to exceed a GWL of 2°C between 2033 and 2054, depending on the climate sensitivity to greenhouse gas emissions. By contrast, in a low scenario the world is unlikely to cross this threshold. (USGCRP 2023)

PBAPS is located in the northeast portion of the United States. The Fifth NCA illustrates that present-day temperatures in the Pennsylvania area are at least 2°F higher than temperatures from 1901-1960. The number of days with nighttime minimums over 70°F has increased by 2.1, and extreme heat days (over 95°F) have decreased by 1.3 (USGCRP 2023).

Pennsylvania has undergone a long-term warming of more than 1°C (1.8°F) over the past 110 years (PA DEP 2024a). On the county level, summer temperatures in York and Lancaster Counties are increasing. On average, York County sees 2 days per year in excess of 35°C (95°F) and Lancaster County sees 3 days per year in excess of 35°C (95°F). (LCPA 2024; YCPA 2024)

Since 1901, precipitation in the Northeast has increased in all seasons, extreme precipitation events have increased by approximately 60 percent, and the frequency of droughts has decreased overall. Annual precipitation has increased 10-20 percent since the first half of the 20th century (1901-1960). The largest increase in the number of extreme precipitation days (defined as the top 1 percent of heaviest precipitation events) has occurred in the Northeast with an increase of approximately 60 percent. (USGCRP 2023). According to the U.S. Drought Monitor, Pennsylvania is currently experiencing drought conditions, with 45.9 percent of the state classified as abnormally dry, 19.3 percent in a moderate drought, and 5.9 percent in a severe drought. (NIDIS 2024)

Intake water temperatures at PBAPS prior to 2017, which would show the natural temperature of Conowingo Pond near the intake structure, were recorded on paper; thus, the dataset is not available in a format suitable for analysis. Datasets spanning only a few years (e.g., 7 years) are insufficient to detect long-term trends, making them unsuitable for climate change analysis, which requires a more extended period of observation.

Climate Change Projections The most recent national climate assessment is summarized in the Fifth NCA report.

Simulations of future climate conditions project increases in temperature and extreme precipitation across all scenarios at the 2°C GWL. The projections estimate that the 2°C GWL could be reached as early as 2033 under the highest scenario, while the lowest scenario projects a slightly later arrival, around 2041, but with a lower confidence level (5 percent). The average projected year for these scenarios ranges from not at all for the lowest scenario to 2042 for the highest scenario. (USGCRP 2023)

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 71 of 78 As presented in PBAPS SLR ER Section 1.1, the SLR terms would end on August 8, 2053, and July 2, 2054. By 2050, the Northeast is projected to warm up to 3-5°F (16-15°C) above preindustrial temperatures, using a GWL of 2°C, except in the lowest-emissions scenario (shared socioeconomic pathway 1-2.6). For southeastern Pennsylvania, average temperatures are modeled to increase 4-5°F (15.6-15°C) by 2050. The number of days with a maximum temperature of over 95°F (35°C) is estimated to increase by up to 10 days per year and nights of minimum temperatures less than 32°F (0°C) are expected to decrease by 20 nights per year.

(USGCRP 2023)

By 2050, precipitation is projected to increase by 8 percent above current levels. (PA DEP 2024b). Heavy precipitation can be produced by thunderstorms, tropical storms, and tropical cyclones. Projections indicate that storms are expected to produce more intense rainfall with higher GWLs. The storm season will likely lengthen, and the amount of heavy precipitation will increase. Projections indicate a 10-20 percent increase in heavy precipitation, and a 5-10 percent increase in annual maximum daily precipitation relative to the period 1991-2020.

(USGCRP 2023).

PA DEP has prepared a Climate Impact Assessment to evaluate climate projections and assess potential risk. These climate change projections predicted higher annual statewide average temperatures, more frequent and extreme heat events, greater total rainfall occurring less frequently, and increased flooding. Potential consequences could include flood damage, heat related energy capacity reductions due to a higher energy demand, and higher water temperatures that could decrease the availability of cooling water. (PA DEP 2021a)

In response, Pennsylvania developed a Climate Action Plan. The Climate Action Plan lists strategies used to reduce climate-related risk and slow climate change. Pennsylvania is undertaking a rulemaking process to increase clean energy. Currently, Pennsylvania heavily relies on nuclear power and is the second largest producer of energy via nuclear generation in the United States. Pennsylvania plans to maintain nuclear power generation at its current level.

By 2050, Pennsylvania expects to produce nearly all its electricity using nuclear and renewable energy sources. Pennsylvania assumes that, if needed, it would intervene to keep nuclear units operational for their full lifetime, preventing early retirements. Pennsylvania expects PBAPS Units 2 and Unit 3 to be operational through 2053 and 2054, respectively. (PA DEP 2021b)

Potential Climate Change Impacts The NRC is evaluating climate change effects by examining the impact of greenhouse gas emissions and how continuing operations may gradually affect environmental resource areas vulnerable to climate change impacts (NRC 2024). The potential for GHG emissions from plant operations during the license renewal term to affect climate change was assessed in the GEIS and determined to be SMALL for all plants. CEG is not aware of new and significant information that affects this GEIS conclusion.

The GEIS Section 4.12.2 states: Climate change may impact the affected environment in a way that alters the environmental resources that are impacted by the proposed action (license renewal). and... climate change impacts can occur across all resource areas that could be affected by the proposed action... In order for there to be a climate change impact on an environmental resource, the proposed action... must have an incremental new, additive, or

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 72 of 78 increased physical effect or impact on the resource or environmental condition beyond what is already occurring. (NRC 2024).

For PBAPS, two environmental resource areas may experience incremental impacts due to climate change and the continued operation of the plant, beyond baseline conditions. These environmental resource areas are air and surface water. Other environmental resource areas are not expected to experience combined impacts of plant operations and climate change.

Air Quality Climate change can impact air quality as air pollutant concentrations are sensitive to changes in 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. Although surface temperatures are expected to increase, ozone levels will not necessarily increase because ozone formation is also dependent on the concentration of precursors available. The combination of higher temperatures, stagnant air masses, sunlight, and emission of precursors may make it difficult to meet ozone national ambient air quality standards. Regardless, states must continue to comply with the Clean Air Act and ensure air quality standards are met. (NRC 2015)

As stated above, the number of days above 95°F (35°C) is expected to increase, which could result in higher ozone levels. The fuel source for PBAPS does not produce carbon dioxide (CO2) or other GHG emissions including ozone precursors, so continued operation of PBAPS would avoid millions of tons of GHG emissions as compared to a fossil fuel-fired alternative such as a Natural Gas Combined Cycle plant.

As presented in PBAPS SLR ER Section 4.2, no future upgrade or replacement activities (e.g.,

diesel generators, diesel pumps) that would increase or decrease air emissions over the proposed SLR term were identified as necessary for plant operations. PBAPS operates under air permit No. 67-05020 from the PA DEP. Appropriate permit conditions and air emissions regulatory requirements would regulate any future PBAPS activities.

PBAPS contributes only small amounts of GHGs and criteria air pollutants from minor air emission sources and is expected to remain in compliance with associated permits. As a result, continued operation would contribute only minor amounts of criteria air pollutants and GHGs.

Water Resources Climate change can affect the availability of water resources due to changes in precipitation patterns and surface water temperatures, and increased resource competition (NRC 2024).

According to the USGCRP, temperatures and precipitation are expected to increase over the next few decades.

As described in PBAPS SLR ER Section 3.5.1.2.1, the SRBC authorizes PBAPS withdrawals and consumption from Conowingo Pond authorized by SRBC Docket 20061209-1. In issuing the docket, the SRBC determined that PBAPS water consumption did not impact the basins water resources and that it was protective of instream flows and receiving waters of the Chesapeake Bay. (EGC 2018) Surface water use for non-cooling purposes at PBAPS is negligible compared to the volume of surface water used for cooling purposes.

Peach Bottom Atomic Power Station Units 2 and 3 SLRA Appendix E - ER Additional Information Page 73 of 78 Environmental conditions for using the mechanical draft cooling towers are defined in the PBAPS NPDES permit and are based on the date and the average river water temperature (EGC 2018). A 316(a)-demonstration study was submitted with the NPDES permit renewal application in 2019. Model verification was conducted, and temperature data were compared to modeled temperature results, illustrating that discharge temperatures decreased with increased cooling towers use and observed temperatures fell to or below the modeled values. Field observations confirmed that operation of the cooling towers mitigated the additional heat generated by PBAPS during summer months.

Climate models for Pennsylvania project that precipitation will increase, reducing the likelihood of water resource competition. The downstream temperature is not currently affected by PBAPS operations. Continued compliance with the SRBC docket and NPDES permit limits would mitigate PBAPSs impacts to water temperature and availability. Any incremental changes due to PBAPS water use, the temperature of PBAPSs effluent, and climate change would be mitigated by compliance and would have a negligible impact on water resources.

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