ML13328A002

{{Adams | number = ML13328A002 | issue date = 11/30/2013 | title = NUREG-1437 Supp 50 Dfc Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Grand Gulf Nuclear Station, Unit 1 (Draft for Comment) | author name = Drucker D M | author affiliation = NRC/NRR | addressee name = | addressee affiliation = | docket = 05000416 | license number = | contact person = Beltz G | document report number = NUREG-1437 S50, NUREG-1437 Supp 50 DFC | document type = NUREG | page count = 381 | project = | stage = Draft Other }}

Text

{{#Wiki_filter:Generic Environmental Impact Statement for License Renewal of Nuclear Plants

Supplement 50 Regarding Grand Gulf Nuclear Station, Unit 1 Draft Report for Comment Office of Nuclear Reactor Regulation NUREG-1437 Supplement 50

!NRC Reference Material As of November 1999, you may electronically access NUREG-series publications and other NRC records at NRCs Public Electronic Reading Room at http://www.nrc.gov/reading -rm.html. Publicly released records include, to name a few, NUREG -series publications; Federal Register notices; applicant, licensee, and vendor documents and correspondence; NRC correspondence and internal memoranda; bulletins and information notices; inspection and investigative reports; licensee event reports; and Commission papers and their attachments. NRC publications in the NUREG series, NRC regulations, and Title 10, Energy , in the Code of Federal Regulations may also be purchased from one of these two sources.

1. The Superintendent of Documents U.S. Government Printing Office Mail Stop SSOP Washington, DC 20402 0001 Internet: bookstore.gpo.gov Telephone: 202

-512-1800 Fax: 202-512-2250 2. The National Technical Information Service Springfield, VA 22161 0002 www.ntis.gov 18005536847 or, locally, 703 6056000 A single copy of each NRC draft report for comment is available free, to the extent of supply, upon written request as follows: Address: U.S. Nuclear Regulatory Commission Office of Administration

Publications Branch Washington, DC 20555 -0001 E-mail: DISTRIBUTION.RESOURCE@NRC.GOV Facsimile: 301 4152289 Some publications in the NUREG series that are posted at NRCs Web site address http://www.nrc.gov/reading -rm/doc-collections/nuregs are updated periodically and may differ from the last printed version. Although references to material found on a Web site bear the date the material was accessed, the material available on the date cited may subsequently be removed from the site. N on-NRC Reference Material Documents available from public and special technical libraries include all open literature items, such as books, journal articles, transactions, Federal Register notices, Federal and State legislation, and congressional reports. Such documents as theses, dissertations, foreign reports and translations, and non -NRC conference proceedings may be purchased from their sponsoring organization. Copies of industry codes and standards used in a substantive manner in the NRC regulatory process are maintained at Ñ The NRC Technical Library Two White Flint North 11545 Rockville Pike Rockville, MD 20852 2738 These standards are available in the library for reference use by the public. Codes and standards are usually copyrighted and may be purchased from the originating organization or, if they are American National Standards, fromÑ American National Standards Institute 11 West 42 nd Street New York, NY 10036 8002 www.ansi.org 2126424900 !AVAILABILITY OF REFERENCE MATERIALS IN NRC PUBLICATION S Legally binding regulatory requirements are stated only in laws; NRC regulations; licenses, including technical specifications; or orders, not in NUREG -series publications. The views expressed in contractor -prepared publications in this series are not necessarily those of the NRC. The NUREG series comprises (1) technical and administrative reports and books prepared by the staff (NUREGXXXX) or agency contractors (NUREG/CR XXXX), (2) proceedings of conferences (NUREG/CP XXXX), (3) reports resulting from international agreements (NUREG/IA XXXX), (4) brochures (NUREG/BRXXXX), and (5) compilations of legal decisions and orders of the Commission and Atomic and Safety Licensing Boards and of Directors decisions under Section 2.206 of NRCs regulations (NUREG 0750). DISCLAIMER: This report was prepared as an account of work sponsored by an agency of the U.S. Government. Neither the U.S. Government nor any agency thereof, nor any employee, makes any warranty, expressed or implied, or assumes any legal liability or responsibility for any third partys use, or the results of such use, of any information, apparatus, product, or process disclosed in this publication, or represents that its use by such third party would not infringe privately owned rights.

Generic Environmental Impact Statement for License Renewal of Nuclear Plants

Supplement 50 Regarding Grand Gulf Nuclear Station, Unit 1 Draft Report for Comment Manuscript Completed: October 2013 Date Published: November 2013

Office of Nuclear Reactor Regulation NUREG-1437 Supplement 50

COMMENTS ON DRAFT REPORT Any interested party may submit comments on this report for consideration by the NRC staff. Comments may be accompanied by additional relevant information or supporting data. Please specify the report number NUREG-1437, Supplement 50, in your comments, and send them by the end of the comment period specified in the Federal Register notice announcing the availability of this report. Addresses: You may submit comments by any one of the following methods. Please include Docket ID NRC-2011-0262 in the subject line of your comments. Comments submitted in writing or in electronic form will be posted on the NRC website and on the Federal rulemaking website http://www.regulations.gov. Federal Rulemaking Website

Go to http://www.regulations.gov and search for documents filed under Docket ID NRC-2011-0262. Address questions about NRC dockets to Carol Gallagher at 301

-287-3422 or by e-mail at Carol.Gallagher@nrc.gov. Mail comments to

Cindy Bladey, Chief , Rules, Announcements , and Directives Branch (RADB), Division of Administrative Services , Office of Administration , Mail Stop:

3WFN-06-A44MP , U.S. Nuclear Regulatory Commission , Washington, DC 20555 -0001. For any questions about the material in this report, please contact David Drucker, NRC Environmental Project Manager, at 1 -800-368-5642, extension 6223, or by e -mail at david.drucker@nrc.gov Please be aware that any comments that you submit to the NRC will be considered a public record and entered into the Agencywide Documents Access and Management System (ADAMS). Do not provide information you would not want to be publicly available.

iii ABSTRACT 1 This supplemental environmental impact statement (SEIS) has been prepared in response to an 2 application submitted by Entergy Operations, Inc. (Entergy) to renew the operating license for 3 Grand Gulf Nuclear Station, Unit 1 (GGN S), for an additional 20 years. 4 This SEIS includes the preliminary analysis that evaluates the environmental impacts of the 5 proposed action and alternatives to the proposed action. Alternatives considered include: new 6 nuclear generation, natural gas -fired combined -cycle generation, supercritical coal -fired 7 generation, combination alternative, and no renewal of the license (the no -action alternative ). 8 The U.S. Nuclear Regulatory Commission's (NRC's) preliminary recommendation is that the 9 adverse environmental impacts of license renewal for GGNS are not great enough to deny the 10 option of license renewal for energy -planning decisionmakers. This recommendation is based 11 on the following: 12 the analysis and findings in NUREG -1437, Volumes 1 and 2, Generic 13 Environmental Impact Statement for License Renewal of Nuclear Plants, 14 the Environmental Report submitted by Entergy, 15 consultation with Federal, State, local, and Tribal government agencies, 16 the NRC's environmental review, and 17 consideration of public comments received during the scoping process. 18

v TABLE OF CONTENTS 1 ABSTRACT .............................................................................................................................. iii 2 TABLE OF CONTENTS

............................................................................................................

v 3 FIGURES .................................................................................................................................. xi 4 TABLES ................................................................................................................................. xiii 5 EXECUTIVE

SUMMARY

.........................................................................................................

xv 6 ABBREVIATIONS AND ACRONYMS

....................................................................................

xxi 7 1.0 PURPOSE AND NEED FOR ACTION .......................................................................... 1-1 8 1.1 Proposed Federal Action

.....................................................................................

1-1 9 1.2 Purpose and Need for the Proposed Federal Action

...........................................

1-1 10 1.3 Major Environmental Review Milestones

.............................................................

1-2 11 1.4 Generic Environmental Impact Statement

...........................................................

1-3 12 1.5 Supplemental Environmental Impact Statement

..................................................

1-6 13 1.6 Cooperating Agencies

.........................................................................................

1-6 14 1.7 Consultations

......................................................................................................

1-6 15 1.8 Correspondence

................................................................................................. 1-7 16 1.9 Status of Compliance
..........................................................................................

1-7 17 1.10 References

.........................................................................................................

1-7 18 2.0 AFFECTED ENVIRONMENT

........................................................................................

2-1 19 2.1 Facility Description

..............................................................................................

2-1 20 2.1.1 Reactor and Containment Systems

........................................................

2-1 21 2.1.2 Radioactive Waste Management

............................................................

2-5 22 2.1.3 Nonradiological Waste Management

......................................................

2-6 23 2.1.4 Plant Operation and Maintenance

..........................................................

2-8 24 2.1.5 Power Transmission System

..................................................................

2-9 25 2.1.6 Cooling and Auxiliary Water Systems

.....................................................

2-9 26 2.1.7 Facility Water Use and Quality

.............................................................

2-10 27 2.2 Surrounding Environment

.................................................................................

2-14 28 2.2.1 Land Use .............................................................................................. 2-16 29 2.2.2 Air Quality and Meteorology

................................................................. 2-17 30 2.2.3 Geologic Environment
..........................................................................

2-25 31 2.2.4 Surface Water Resources

....................................................................

2-30 32 2.2.5 Groundwater Resources

......................................................................

2-32 33 2.2.6 Aquatic Resources

...............................................................................

2-37 34 2.2.7 Terrestrial Resources

...........................................................................

2-45 35 2.2.8 Protected Species and Habitats

...........................................................

2-52 36 2.2.9 Socioeconomics

...................................................................................

2-63 37 2.2.10 Historic and Archaeological Resources

................................................

2-76 38 Table of Contents vi 2.3 Related Federal and State Activities

................................................................. 2-80 1 2.4 References
.......................................................................................................

2-81 2 3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT

................................................

3-1 3 3.1 References

.........................................................................................................

3-2 4 4.0 ENVIRONMENTAL IMPACTS OF OPERATION

..........................................................

4-1 5 4.1 Land Use ............................................................................................................ 4-1 6 4.2 Air Quality

...........................................................................................................

4-2 7 4.3 Geologic Environment

.........................................................................................

4-2 8 4.3.1 Geology and Soils

..................................................................................

4-2 9 4.4 Surface Water Resources

...................................................................................

4-3 10 4.5 Groundwater Resources

.....................................................................................

4-3 11 4.5.1 Generic Groundwater Issues

..................................................................

4-3 12 4.5.2 Groundwater Use Conflicts (Ranney Wells)

...........................................

4-4 13 4.5.3 Radionuclides Released to Groundwater

...............................................

4-4 14 4.6 Aquatic Resources

..............................................................................................

4-5 15 4.6.1 Exposure of Aquatic Organisms to Radionuclides

..................................

4-6 16 4.7 Terrestrial Resources

..........................................................................................

4-6 17 4.7.1 Generic Terrestrial Resource Issues

......................................................

4-7 18 4.7.2 Exposure of Terrestrial Organisms to Radionuclides

..............................

4-7 19 4.7.3 Effects on Terrestrial Resources (Non -cooling System Impacts)

............

4-8 20 4.8 Protected Species and Habitats

..........................................................................

4-8 21 4.8.1 Correspondence with Federal and State Agencies

................................. 4-9 22 4.8.2 Species and Habitats Protected Under the Endangered Species 23 Act ..........................................................................................................

4-9 24 4.8.3 Species Protected by the State of Mississippi

......................................

4-12 25 4.8.4 Species Protected Under the Bald and Golden Eagle Protection 26 Act ........................................................................................................ 4-13 27 4.8.5 Species Protected Under the Migratory Bird Treaty Act

........................

4-13 28 4.9 Human Health

...................................................................................................

4-13 29 4.9.1 Generic Human Health Issues

..............................................................

4-13 30 4.9.2 Radiological Impacts of Normal Operations

..........................................

4-14 31 4.9.3 Electromagnetic Fields -Acute Effects

.................................................

4-17 32 4.9.4 Electromagnetic Field s-Chronic Effects

..............................................

4-18 33 4.10 Socioeconomics

................................................................................................

4-18 34 4.10.1 Generic Socioeconomic Issues

............................................................

4-19 35 4.10.2 Housing ................................................................................................ 4-19 36 4.10.3 Public Services -Public Utilities

...........................................................

4-20 37 4.10.4 Public Services -Transportation

..........................................................

4-20 38 4.10.5 Offsite Land Use

..................................................................................

4-21 39 4.10.6 Historic and Archaeological Resources

................................................

4-22 40 4.10.7 Environmental Justice

..........................................................................

4-23 41 Table of Contents vii 4.11 Evaluation of New and Potentially Significant Information

................................. 4-29 1 4.12 Cumulative Impacts
..........................................................................................

4-30 2 4.12.1 Air Quality

............................................................................................

4-31 3 4.12.2 Water Resources

.................................................................................

4-33 4 4.12.3 Aquatic Resources

...............................................................................

4-35 5 4.12.4 Terrestrial Resources

...........................................................................

4-38 6 4.12.5 Human Health

......................................................................................

4-40 7 4.12.6 Socioeconomics

...................................................................................

4-41 8 4.12.7 Historic and Archaeological Resources

................................................

4-42 9 4.12.8 Summary of Cumulative Impacts

..........................................................

4-42 10 4.13 References

.......................................................................................................

4-44 11 5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS .................................. 5-1 12 5.1 Design-Basis Accidents

......................................................................................

5-1 13 5.2 Severe Accidents

................................................................................................

5-2 14 5.3 Severe Accident Mitigation Alternatives

..............................................................

5-3 15 5.3.1 Overview of SAMA Process

...................................................................

5-3 16 5.3.2 Estimate of Risk

.....................................................................................

5-3 17 5.3.3 Potential Plant Improvements

................................................................. 5-5 18 5.3.4 Evaluation of Risk Reduction and Costs of Improvement s......................

5-7 19 5.3.5 Cost-Benefit Comparison

.....................................................................

5-10 20 5.3.6 Conclusions

.........................................................................................

5-11 21 5.4 References

.......................................................................................................

5-12 22 6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE, 23 SOLID WASTE MANAGEMENT, AND GREENHOUSE GAS EMISSIONS .................. 6-1 24 6.1 The Uranium Fuel Cycle

.....................................................................................

6-1 25 6.2 Greenhouse Gas Emissions

...............................................................................

6-3 26 6.2.1 Existing Studies

......................................................................................

6-3 27 6.2.2

Conclusions:

Relative Greenhouse Gas Emissions

...............................

6-8 28 6.3 References

.......................................................................................................

6-10 29 7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING

.............................................

7-1 30 7.1 Decommissioning

................................................................................................

7-1 31 7.2 References

.........................................................................................................

7-2 32 8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES

....................................................

8-1 33 8.1 New Nuclear Generation

.....................................................................................

8-4 34 8.1.1 Air Quality

..............................................................................................

8-5 35 8.1.2 Groundwater Resources

........................................................................

8-6 36 8.1.3 Surface Water Resources

......................................................................

8-7 37 8.1.4 Aquatic Ecology

.....................................................................................

8-7 38 8.1.5 Terrestrial Ecology

.................................................................................

8-8 39 8.1.6 Human Health

........................................................................................

8-8 40 Table of Contents viii 8.1.7 Land Use ................................................................................................ 8-8 1 8.1.8 Socioeconomics

.....................................................................................

8-9 2 8.1.9 Transportation

........................................................................................

8-9 3 8.1.10 Aesthetics

............................................................................................

8-10 4 8.1.11 Historic and Archaeological Resources

................................................

8-10 5 8.1.12 Environmental Justice

..........................................................................

8-11 6 8.1.13 Waste Management

.............................................................................

8-11 7 8.1.14 Summary of Impacts of New Nuclear Generation

................................. 8-12 8 8.2 Natural Gas

-Fired Combined -Cycle Generation

................................................

8-12 9 8.2.1 Air Quality ............................................................................................ 8-13 10 8.2.2 Groundwater Resources

......................................................................

8-15 11 8.2.3 Surface Water Resources .................................................................... 8-16 12 8.2.4 Aquatic Ecology

...................................................................................

8-16 13 8.2.5 Terrestrial Ecology

...............................................................................

8-17 14 8.2.6 Human Health

......................................................................................

8-17 15 8.2.7 Land Use .............................................................................................. 8-18 16 8.2.8 Socioeconomics

...................................................................................

8-18 17 8.2.9 Transportation

......................................................................................

8-19 18 8.2.10 Aesthetics

............................................................................................

8-19 19 8.2.11 Historic and Archaeological Resources

................................................

8-19 20 8.2.12 Environmental Justice

..........................................................................

8-20 21 8.2.13 Waste Management

.............................................................................

8-21 22 8.2.14 Summary of Impacts of NGCC Alternative

...........................................

8-21 23 8.3 Supercritical Pulverized Coal -Fired Generation

.................................................

8-21 24 8.3.1 Air Quality

............................................................................................

8-23 25 8.3.2 Groundwater Resources

......................................................................

8-25 26 8.3.3 Surface Water Resources

....................................................................

8-26 27 8.3.4 Aquatic Ecology

...................................................................................

8-26 28 8.3.5 Terrestrial Ecology

...............................................................................

8-27 29 8.3.6 Human Health

......................................................................................

8-28 30 8.3.7 Land Use .............................................................................................. 8-28 31 8.3.8 Socioeconomics

...................................................................................

8-29 32 8.3.9 Transportation

......................................................................................

8-29 33 8.3.10 Aesthetics

............................................................................................

8-30 34 8.3.11 Historic and Archaeological Resources

................................................

8-30 35 8.3.12 Environmental Justice

..........................................................................

8-31 36 8.3.13 Waste Management

.............................................................................

8-31 37 8.3.14 Summary of Impacts of SCPC Alternative

............................................

8-32 38 Table of Contents ix 8.4 Combination Alternative

....................................................................................

8-32 1 8.4.1 Air Quality

............................................................................................

8-34 2 8.4.2 Groundwater Resources

......................................................................

8-36 3 8.4.3 Surface Water Resources

....................................................................

8-37 4 8.4.4 Aquatic Ecology

...................................................................................

8-37 5 8.4.5 Terrestrial Ecology

...............................................................................

8-38 6 8.4.6 Human Health

......................................................................................

8-39 7 8.4.7 Land Use .............................................................................................. 8-40 8 8.4.8 Socioeconomics

...................................................................................

8-41 9 8.4.9 Transportation

......................................................................................

8-42 10 8.4.10 Aesthetics

............................................................................................

8-42 11 8.4.11 Historic and Archaeological Resources

................................................

8-43 12 8.4.12 Environmental Justice

..........................................................................

8-44 13 8.4.13 Waste Management

.............................................................................

8-45 14 8.4.14 Summary of Impacts of Combination Alternative

..................................

8-45 15 8.5 Alternatives Considered But Dismissed

............................................................

8-46 16 8.5.1 Demand-Side Management

..................................................................

8-46 17 8.5.2 Wind Power

..........................................................................................

8-47 18 8.5.3 Solar Power

.........................................................................................

8-48 19 8.5.4 Hydroelectric Power

.............................................................................

8-48 20 8.5.5 Wave and Ocean Energy

.....................................................................

8-49 21 8.5.6 Geothermal Power

...............................................................................

8-49 22 8.5.7 Municipal Solid Waste

..........................................................................

8-49 23 8.5.8 Biomass ............................................................................................... 8-50 24 8.5.9 Oil-Fired Power

....................................................................................

8-51 25 8.5.10 Fuel Cells

.............................................................................................

8-51 26 8.5.11 Purchased Power

.................................................................................

8-51 27 8.5.12 Delayed Retirement.............................................................................. 8-52 28 8.6 No-Action Alternative

........................................................................................

8-52 29 8.6.1 Air Quality

............................................................................................

8-52 30 8.6.2 Groundwater Resources

......................................................................

8-52 31 8.6.3 Surface Water Resources

....................................................................

8-53 32 8.6.4 Aquatic Ecology

...................................................................................

8-53 33 8.6.5 Terrestrial Ecology

...............................................................................

8-53 34 8.6.6 Human Health

......................................................................................

8-53 35 8.6.7 Land Use .............................................................................................. 8-53 36 8.6.8 Socioeconomics

...................................................................................

8-53 37 8.6.9 Transportation

......................................................................................

8-54 38 8.6.10 Aesthetics

............................................................................................

8-54 39 8.6.11 Historic and Archaeological Resources

................................................

8-54 40 Table of Contents x 8.6.12 Environmental Justice

..........................................................................

8-54 1 8.6.13 Waste Management

.............................................................................

8-54 2 8.6.14 Summary of Impacts of Combination Alternative

..................................

8-54 3 8.7 Alternatives Summary

.......................................................................................

8-55 4 8.8 References

.......................................................................................................

8-58 5

9.0 CONCLUSION

..............................................................................................................

9-1 6 9.1 Environmental Impacts of License Renewal

........................................................

9-1 7 9.2 Comparison of Alternatives

.................................................................................

9-1 8 9.3 Resource Commitments

......................................................................................

9-2 9 9.3.1 Unavoidable Adverse Environmental Impacts

........................................

9-2 10 9.3.2 Short-Term Versus Long -Term Productivity

...........................................

9-2 11 9.3.3 Irreversible and Irretrievable Commitments of Resources

......................

9-3 12 9.4 Recommendations

..............................................................................................

9-3 13 10.0 LIST OF PREPARERS

...............................................................................................

10-1 14 11.0 LIST OF AGENCI ES, ORGANIZATIONS, AND PERSONS TO WHOM 15 COPIES OF THIS SEIS ARE SENT

...........................................................................

11-1 16 12.0 INDEX ......................................................................................................................... 12-1 17 APPENDIX A COMMENTS RECEIVED ON THE GGNS ENVIRONMENTAL 18 REVIEW ......................................................................................................... A-1 19 APPENDIX B NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR 20 LICENSE RENEWAL OF NUCLEAR POWER PLANTS

................................ B-1 21 APPENDIX C APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS
...................... C-1 22 APPENDIX D CONSULTANT CORRESPONDENCE
........................................................... D-1 23 APPENDIX E CHRO NOLOGY OF ENVIRONMENTAL REVIEW 24 CORRESPONDENCE
.................................................................................... E-1 25 APPENDIX F U.S. NUCLEAR REGULATORY COMMISSION STAFF 26 EVALUATION OF SEVERE ACCIDENT MITIGATION 27 ALTERNATIVES FOR GRAND GULF NUCLEAR STATION IN 28 SUPPORT OF LICENSE RENEWAL APPLICATION REVIEW
..................... F-1 29 Table of Contents xi FIGURES 1 Figure 1-1. Environmental Review Process
........................................................................ 1-2 2 Figure 1-2. Environmental Issues Evaluated During License Renewal
............................... 1-5 3 Figure 2-1. Location of GGNS, 50

-mi (80-km) Vicinity

........................................................ 2-2 4 Figure 2-2. Location of GGNS, 6

-mi (10-km) Vicinity

.......................................................... 2-3 5 Figure 2-3. GGNS, General Site Layout
............................................................................. 2-4 6 Figure 2-4. Plan (Map) View and Cross Section View of Ranney Well at GGNS
.............. 2-12 7 Figure 2-5. GGNS Ranney Well Locations
....................................................................... 2-13 8 Figure 2-6. GGNS Upland Complex Aquifer Permitted Wells
............................................ 2-15 9 Figure 2-7. Topographic Map of GGNS Facility
................................................................ 2-16 10 Figure 2-8. GGNS Wind at 33

-ft (10-m) and 162 -ft (50-m), 2006-2011 ............................ 2-19 11 Figure 2-9. Location Map for Geologic Cross -Sections A-A' and B-B' ............................... 2-27 12 Figure 2-10. Geologic Cross Section A-A' .......................................................................... 2-28 13 Figure 2-11. Geologic Cross Section B-B' .......................................................................... 2-29 14 Figure 2-12. GGNS Surface Water Features ...................................................................... 2-31 15 Figure 2-13. Most Recent GGNS Tritium Contaminated Well Data from 16 February 2012 ................................................................................................ 2-36 17 Figure 2-14. GGNS Property Habitat Types ....................................................................... 2-47 18 Figure 4-1. 2010 Census Minority Block Groups Within a 50 -mi Radius of GGNS

............ 4-26 19 Figure 4-2. 2010 Census Low

-Income Block Groups Within a 50 -mi Radius of 20 GGN S ............................................................................................................ 4-27 21

Table of Contents xiii TABLES 1 Table ES-1. NRC Conclusions Relating to Site -Specific Impacts of License 2 Renewal ........................................................................................................... xvii 3 Table 2-1. Permitted Maximum Allowable Emission Limits for Criteria Air 4 Pollutants and Volatile Organic Compounds (VOCs) and Estimated 5 Annual CO 2e Emission Rate at GGNS

............................................................ 2-22 6 Table 2-2. National Ambient Air Quality Standards (NAAQS)
.......................................... 2-23 7 Table 2-3. Dominant Vegetation by Habitat Type
............................................................ 2-48 8 Table 2-4. Most Common or Abundant Wildlife Documented on GGNS
.......................... 2-50 9 Table 2-5. Transmission Line Corridor Land Use by Area

................................................ 2-52 10 Table 2-6. Federally and State -Listed Species

................................................................ 2-55 11 Table 2-7. 2009 GGNS Employee Residence by County
................................................. 2-64 12 Table 2-8. Housing in GGNS ROI
.................................................................................... 2-64 13 Table 2-9. Claiborne County Public Water Supply Systems
............................................. 2-65 14 Table 2-10. Major Commuting Routes Near GGNS 2011 Average Annual Daily 15 Traffic ............................................................................................................. 2-66 16 Table 2-11. Population and Percent Growth in GGNS ROI Counties  from 17 1970-2009 and Projected for 2010

-2050 ....................................................... 2-68 18 Table 2-12. Demographic Profile of the Population in the GGNS ROI in 2010

................... 2-69 19 Table 2-13. 2010 Seasonal Housing in Counties within 50 miles of GGNS
........................ 2-70 20 Table 2-14. Migrant Farm Workers and Temporary Farm Labor in Counties 21 Located within 50 Miles of GGNS
................................................................... 2-72 22 Table 2-15. Major Employers of the GGNS ROI in 2012
.................................................... 2-74 23 Table 2-16. Estimated Income Information for the GGNS ROI in 2010
.............................. 2-75 24 Table 2-17. 2007-2012 Unemployment Rates in the GGNS ROI
...................................... 2-75 25 Table 3-1. Category 1 Issues Related to Refurbishment
.................................................... 3-1 26 Table 3-2. Category 2 Issues Related to Refurbishment
.................................................... 3-2 27 Table 4-1. Land Use Issues
............................................................................................... 4-1 28 Table 4-2. Air Quality Issues
.............................................................................................. 4-2 29 Table 4-3. Surface Water Issues
....................................................................................... 4-3 30 Table 4-4. Groundwater Issues.......................................................................................... 4-3 31 Table 4-5. Aquatic Resource Issues
.................................................................................. 4-6 32 Table 4-6. Terrestrial Resource Issues
.............................................................................. 4-7 33 Table 4-7. Threatened or Endangered Species
................................................................. 4-8 34 Table 4-8. Human Health Issues
..................................................................................... 4-13 35 Table 4-9. Socioeconomics Issues
.................................................................................. 4-19 36 Table 4-10. Summary of Cumulative Impacts on Resource Areas
..................................... 4-43 37 Table 5-1. Issues Related to Postulated Accidents
............................................................ 5-2 38 Table 5-2. GGNS Core Damage Frequency (CDF) for Internal Events
.............................. 5-4 39 Table 5-3. Base Case Mean Population Dose Risk and Offsite Economic Cost 40 Risk for Internal Events ..................................................................................... 5-6 41 Table 5-4. Severe Accident Mitigation Alternatives Cost

-Benefit Analysis for 42 GGNS ............................................................................................................... 5-8 43 Table of Contents xiv Table 5-5. Estimated Cost Ranges for SAMA Applications

.............................................. 5-10 1 Table 6-1. Issues Related to the Uranium Fuel Cycle and Solid Waste 2 Management.
................................................................................................... 6-1 3 Table 6-2. Nuclear Greenhouse Gas Emissions Compared to Coal
.................................. 6-6 4 Table 6-3. Nuclear Greenhouse Gas Emissions Compared to Natural Gas
....................... 6-7 5 Table 6-4. Nuclear Greenhouse Gas Emissions Compared to Renewable Energy 6 Sources ............................................................................................................ 6-8 7 Table 7-1. Issues Related to Decommissioning
................................................................. 7-1 8 Table 8-1. Summary of Alternatives Considered In Depth
................................................. 8-4 9 Table 8-2. Summary of Environmental Impacts of the New Nuclear Alternative 10 Compared to Continued Operation of GGNS
.................................................. 8-12 11 Table 8-3. Summary of Environmental Impacts of the NGCC Alternative 12 Compared to Continued Operation of GGNS
.................................................. 8-21 13 Table 8-4. Summary of Environmental Impacts of the SCPC Alternative 14 Compared to Continued Operation of GGNS
.................................................. 8-32 15 Table 8-5. Summary of Environmental Impacts of the Combination Alternative 16 Compared to Continued Operation of GGNS
.................................................. 8-46 17 Table 8-6. Summary of Environmental Impacts of the No

-action Alternative 18 Compared to Continued Operation of GGNS

.................................................. 8-55 19 Table 8-7. Summary of Environmental Impacts of Proposed Action and 20 Alternatives
..................................................................................................... 8-57 21 Table 10-1. List of Preparers
.............................................................................................

10-1 22 Table A-1. Individuals Who Provided Comments During the Scoping Comment 23 Period .................................................................................................................. 1 24 Table B-1. Summary of Issues and Findings

......................................................................... 1 25 Table C-1. Federal and State Environmental Requirements
............................................... C-1 26 Table C-2. Licenses and Permits
....................................................................................... C-4 27 Table D-1. Consultation Correspondence
.......................................................................... D-1 28 Table E-1. Environmental Review Correspondence
.............................................................. 1 29 Tabl e F-1. Grand Gulf Nuclear Station Core Damage Frequency (CDF) for 30 Internal Events.................................................................................................. F-4 31 Table F-2. Base Case Mean Population Dose Risk and Offsite Economic Cost 32 Risk for Internal Events
..................................................................................... F-5 33 Table F-3. Major GGNS Probabilistic Safety Assessment (PSA) Models
........................... F-7 34 Table F-4. GGNS Fire IPEEE Core Damage Frequency (CDF) Results for 35 Unscreened Compartments
............................................................................ F-13 36 Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for 37 Grand Gulf Nuclear Stati on ............................................................................. F-24 38 Table F-6. Estimated Cost Ranges for SAMA Applications
.............................................. F-36 39 xv EXECUTIVE 

SUMMARY

1 BACKGROUND 2 By letter dated October 28, 2011, Entergy Operations, Inc. (Entergy) submitted an application to 3 the U.S. Nuclear Regulatory Commission (NRC) to issue a renewed operating license for Grand 4 Gulf Nuclear Station, Unit 1 (GGNS), for an additional 20 -year period. 5 Pursuant to Title 10, Part 51.20(b)(2) of the Code of Federal Regulations (10 CFR 51.20(b)(2)), 6 the renewal of a power reactor operating license requires preparation of an environmental 7 impact statement (EIS) or a supplement to an existing EIS. In addition, 10 CFR 51.95(c) states 8 that the NRC shall prepare an EIS, which is a supplement to the Commission's NUREG -1437, 9 Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants. 10 Upon acceptance of Entergy's application, the NRC staff began the environmental review 11 process described in 10 CFR Part 51 by publishing a notice of intent to prepare a supplemental 12 EIS (SEIS) and conduct scoping. In preparation of this SEIS for GGNS, the NRC staff 13 performed the following: 14 conducted public scoping meetings on January 31, 2012, in 15 Port Gibson, Mississippi; 16 conducted a site audit at the plant in March 2012; 17 reviewed Entergy 's environmental report (ER) and compared it to the GEIS; 18 consulted with other agencies; 19 conducted a review of the issues following the guidance set forth in 20 NUREG-1555, "Standard Review Plans for Environmental Reviews for 21 Nuclear Power Plants, Supplement 1: Operating License Renewal"; and 22 considered public comments received during the scoping process. 23 PROPOSED ACTION 24 Entergy initiated the proposed Federal action -issuing a renewed power reactor operating 25 license-by submitting an application for license renewal of GGNS, for which the existing 26 license (NPF-29) for GGNS, will expire on November 1, 2024. The NRC's Federal action is the 27 decision whether or not to renew the license for an additional 20 years. 28 PURPOSE AND NEED FOR ACTION 29 The purpose and need for the proposed action (issuance of a renewed license) is to provide an 30 option that allows for power generation capability beyond the term of the current nuclear power 31 plant operating license to meet future system generating needs. Such needs may be 32 determined by other energy -planning decisionmakers, such as state, utility, and -where 33 authorized, Federal (other than NRC). This definition of purpose and need reflects the NRC's 34 recognition that, unless there are findings in the safety review required by the Atomic Energy 35 Act or findings in the National Environmental Policy Act (NEPA) environmental analysis that 36 would lead the NRC to reject a license renewal application, the NRC does not have a role in the 37 energy planning decisions of whether a particular nuclear power plant should continue to 38 operate. 39 Executive Summary xvi If the renewed license is issued, the appropriate energy -planning decisionmakers, along with 1 Entergy, will ultimately decide if the reactor unit will continue to operate based on factors such 2 as the need for power. If the operating license is not renewed, then the facility must be shut 3 down on or before the expiration date of the current operating license -November 1, 2024. 4 ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL 5 The SEIS evaluates the potential environmental impacts of the proposed action. The 6 environmental impacts from the proposed action are designated as SMALL, MODERATE, or 7 LARGE. As set forth in the GEIS, Category 1 issues are those that meet all of the following 8 criteria: 9 The environmental impacts associated with the issue 10 is determined to apply either to all plants or, for some 11 issues, to plants having a specific type of cooling 12 system or other specified plant or site characteristics. 13 A single significance level (i.e., SMALL, MODERATE, 14 or LARGE) has been assigned to the impacts, except 15 for collective offsite radiological impacts from the fuel 16 cycle and from high -level waste and spent fuel 17 disposal. 18 Mitigation of adverse impacts associated with the 19 issue is considered in the analysis, and it has been 20 determined that additional plant -specific mitigation 21 measures are likely not to be sufficiently beneficial to 22 warrant implementation. 23 For Catego ry 1 issues, no additional site -specific analysis is required in this SEIS unless new 24 and significant information is identified. Chapter 4 of this report presents the process for 25 identifying new and significant information. Site -specific issues (Category

2) are those that do 26 not meet one or more of the criterion for Category 1 issues; therefore, an additional site

-specific 27 review for these non -generic issues is required, and the results are documented in the SEIS. 28 On June 20, 2013, the NRC published a final rule (78 FR 37282) revising its environmental 29 protection regulation, 10 CFR Part 51, "Environmental Protection Regulations for Domestic 30 Licensing and Related Regulatory Functions." The final rule updates the potential 31 environmental impacts associated with the renewal of an operating license for a nuclear power 32 reactor for an additional 20 years. A revised GEIS, which updates the 1996 GEIS, provides the 33 technical basis for the final rule. The revised GEIS specifically supports the revised list of NEPA 34 issues and associated environmental impact findings for license renewal contained in Table B-1 35 in Appendix B to Subpart A of the revised 10 CFR Part 51. The final rule consolidates similar 36 Category 1 and 2 issues, changes some Category 2 issues into Category 1 issues, and 37 consolidates some of those issues with existing Category 1 issues. The final rule also adds new 38 Category 1 and 2 issues. 39 The final rule became effective 30 days after publication in the Federal Register. Compliance 40 by license renewal applicants is not required until 1 year from the date of publication 41 (i.e., license renewal environmental reports submitted later than 1 year after publication must be 42 compliant with the new rule). Nevertheless, under NEPA, the NRC must now consider and 43 analyze, in its license renewal SEISs, the potential significant impacts described by the revised 44 SMALL: Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource. MODERATE: Environmental effects are sufficient to alter noticeably, but not to destabilize, important attributes of the resource. LARGE: Environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource.

Executive Summary xvii rule's new Category 2 issues, and to the extent there is any new and significant information, the 1 potential significant impacts described by the revised rule's new Category 1 issues. 2 The NRC staff has reviewed Entergy's established process for identifying and evaluating the 3 significance of any new and significant information (including the consideration and analysis of 4 new issues associated with the recently approved revision to 10 CFR Part 51) on the 5 environmental impacts of license renewal of GGNS. Neither Entergy nor NRC identified 6 information that is both new and significant related to Category 1 issues that would call into 7 question the conclusions in the GEIS. This conclusion is supported by NRC's review of the 8 applicant's ER, other documentation relevant to the applicant's activities, the public scoping 9 process and substantive comments raised, and the findings from the environmental site audit 10 conducted by NRC staff. Further, the NRC staff did not identify any new issues applicable to 11 GGNS that have a significant environmental impact. The NRC staff, therefore, relies upon the 12 conclusions of the GEIS for all Category 1 issues applicable to GGNS. 13 Table ES-1 summarizes the Category 2 issues applicable to GGNS, if any, as well as the NRC 14 staff's findings related to those issues. If the NRC staff determined that there were no 15 Category 2 issues applicable for a particular resource area, the findings of the GEIS, as 16 documented in Appendix B to Subpart A of 10 CFR Part 51, stand. 17 Table ES-1. NRC Conclusions Relating to Site -Specific Impacts of License Renewal 18 Resource Area Relevant Category 2 Issues Adverse Impacts Land Use None SMALL Air Quality None SMALL Geology and Soils None SMALL Surface Water Resources None SMALL Groundwater Resources Groundwater use conflicts Radionuclides released to groundwater SMALL SMALL Aquatic Resources None SMALL Terrestrial Resources Non-cooling system impacts SMALL Protected Species Threatened or endangered species No effect/ may affect, but is not likely to adversely affect(a) Human Health Issues Electromagnetic fields -acute effects SMALL Socioeconomics Housing Impacts Public services (public utilities) Offsite land use Public services (public transportation) Historic & archaeological resources SMALL Cumulative Impacts Aquatic Resources Terrestrial Resources Protected Species & Habitats All other evaluated resources MODERATE MODERATE May affect, but is not likely to adversely affect(a) SMALL (a): For Federally protected species, the GEIS and the final rule state that, in complying with the Endangered Species Act (ESA), the NRC will report the effects of continued operations and refurbishment in terms of its ESA findings, which varies by species for GGNS. With respect to environmental justice, the NRC staff has determined that there would be no 19 disproportionately high and adverse impacts to these populations from the continued operation 20 of GGNS during the license renewal period. Additionally, the NRC staff has determined that no 21 Executive Summary xviii disproportionately high and adverse human health impacts would be expected in special 1 pathway receptor populations in the region as a result of subsistence consumption of water, 2 local food, fish, and wildlife. 3 SEVERE ACCIDENT MITIGATION ALTERNATIVES 4 Since GGNS had not previously considered alternatives to reduce the likelihood or potential 5 consequences of a variety of highly uncommon, but potentially serious, accidents at GGNS, 6 10 CFR 51.53(c)(3)(ii)(L) requires that Entergy evaluate severe accident mitigation alternative s 7 (SAMAs) in the course of the license renewal review. SAMAs are potential ways to reduce the 8 risk or potential impacts of uncommon, but potentially severe accidents, and they may include 9 changes to plant components, systems, procedures, and training. 10 The NRC staff reviewed the ER's evaluation of potential SAMAs. Based on the staff's review, 11 the NRC staff concluded that none of the potentially cost beneficial SAMAs relate to adequately 12 managing the effects of aging during the period of extended operation. Therefore, they need 13 not be implemented as part of the license renewal, pursuant to 10 CFR Part 54. 14 ALTERNATIVES 15 The NRC staff considered the environmental impacts associated with alternatives to license 16 renewal. These alternatives include other methods of power generation and not renewing the 17 GGNS operating license (the no -action alternative). Replacement power options considered 18 were as follows: 19 new nuclear generation, 20 natural gas -fired combined -cycle generation, 21 supercritical pulverized coal -fired generation, and 22 combination alternative. 23 The NRC staff initially considered a number of additional alternatives for analysis as alternatives 24 to license renewal of GGNS; these were later dismissed due to technical, resource availability, 25 or commercial limitations that currently exist and that the NRC staff believes are likely to 26 continue to exist when the existing GGNS license expire. The no -action alternative by the NRC 27 staff, and the effects it would have, were also considered. Where possible, the NRC staff 28 evaluated potential environmental impacts for these alternatives located both at the GGNS site 29 and at some other unspecified alternate location. Alternatives considered, but dismissed, were 30 as follows: 31 energy conservation and energy efficiency, 32 wind power, 33 solar power, 34 hydroelectric power, 35 wave and ocean energy, 36 geothermal power, 37 municipal solid waste, 38 biomass, 39 oil-fired power, 40 fuel cells, 41 purchased power, and 42 delayed retirement. 43 Executive Summary xix The NRC staff evaluated each alternative using the same impact areas that were used in 1 evaluating impacts from license renewal. 2 RECOMMENDATION 3 The NRC's preliminary recommendation is that the adverse environmental impacts of license 4 renewal for GGNS are not great enough to deny the option of license renewal for 5 energy-planning decisionmakers. This recommendation is based on the followin g: 6 analysis and findings in the GEIS, 7 ER submitted by Entergy, 8 consultation with Federal, State, local, and Tribal government agencies, 9 NRC staff's own independent review, and 10 consideration of public comments received during the scoping process. 11

xxi ABBREVIATIONS AND ACRONYMS 1 °C degree(s) Celsius 2 °F degree(s) Fahrenheit 3 AADT average annual daily traffic 4 AAI American Aquatics, Inc. 5 ac acre(s) 6 ACAA American Coal Ash Association 7 ACC averted cleanup and decontamination costs 8 ACHP Advisory Council on Historic Preservation 9 ADAMS Agencywide Documents Access and Management System 10 AEA Atomic Energy Authority 11 AEC U.S. Atomic Energy Commission 12 ALARA as low as is reasonably achievable 13 ANL Argonne National Laboratory 14 ANS American Nuclear Society 15 AOC averted offsite property damage costs 16 AOE averted occupation exposure 17 AOSC averted onsite costs 18 APE averted public exposure 19 AQCR air quality control region 20 AQRV air quality related values 21 ARI Alternative Resources, Inc. 22 ASME American Society of Mechanical Engineering 23 BACT Best Available Control Technology 24 BEA U.S. Bureau of Economic Analysis 25 BLM Bureau of Land Management 26 BLS U.S. Bureau of Labor Statistics 27 BMPs best management practices 28 BP before present 29 B tu British thermal unit(s) 30 B tu/kWh British thermal units per kilowatt -hour 31 B tu/lb British thermal units per pound 32 BWR boiling water reactor 33 BWROG BWR Owners Group 34 Abbreviations and Acronyms xxii CAA Clean Air Act 1 CAES compressed air energy storage 2 CAPS Circular Area Profiling System 3 CCDPs conditional core damage probabilities 4 CCP coal combustion products 5 CDF core damage frequency 6 CDM Clean Development Mechanism 7 C eq/kWh carbon equivalent per kilowatt -hour 8 CEQ Council on Environmental Quality 9 CET containment event tree 10 CFR Code of Federal Regulations 11 cfs cubic feet per second 12 CH4 methane 13 cm centimeter(s) 14 CNWRA Center for Nuclear Waste Regulatory Analyses 15 CO carbon monoxide 16 CO2 carbon dioxide 17 CO 2e carbon dioxide equivalent 18 COE cost of enhancement 19 COL combined license 20 CP construction permit 21 CS&I Crossroads, Shiloh & Ingleside 22 CWA Clean Water Act 23 CZMA Coastal Zone Management Act 24 dBA decibels adjusted 25 DBA design-basis accident 26 DC direct current 27 DOE U.S. Department of Energy 28 DOT Department of Transportation 29 DSEIS draft Supplemental Environmental Impact Statement 30 DSM demand-side management 31 EA Environmental Assessment 32 EAC Electricity Advisory Committee 33 EDG emergency diesel generator 34 EHV Extra High Voltage 35 Abbreviations and Acronyms xxiii EIA Energy Information Administration 1 EIS environmental impact statement 2 ELF-EMF extremely low frequency -electromagnetic field 3 EMI Entergy Mississippi, Inc 4 EMS environmental management systems 5 Entergy Entergy Operations, Inc. 6 EO Executive Order 7 EPA U.S. Environmental Protection Agency 8 EPCRA Emergency Planning and Community Right -to-Know Act 9 EPRI Electric Power Research Institute 10 EPU extended power uprate 11 ER Environmental Report 12 ESA Endangered Species Act of 1973, as amended 13 ESBWR Economic Simplified Boiling Water Reactor 14 ESP early site permit 15 FEIS final environmental impact statement 16 FEMA U.S. Federal Emergency Management Agency 17 FERC Federal Energy Regulatory Commission 18 FES final environmental statement 19 FIVE Fire-Induced Vulnerability Evaluation 20 FLMs Federal Land Managers 21 FONSI Finding of No Significant Impact 22 FR Federal Register 23 ft foot (feet) 24 ft/s feet per second 25 ft3 cubic feet 26 FWS U.S. Fish and Wildlife Service 27 gal gallon(s) 28 gal/yr gallons per year 29 GE General Electric 30 GEA Geothermal Energy Association 31 GEIS Generic Environmental Impact Statement for License Renewal of 32 Nuclear Power Plants, NUREG-1437 33 GGNS Grand Gulf Nuclear Station 34 GHG greenhouse gas 35 Abbreviations and Acronyms xxiv GI Generic Issue 1 gpd gallons per day 2 gpm gallons per minute 3 GSI Generic Safety Issue 4 GW gigawatt(s) 5 GWh gigawatthour(s) 6 ha hectare(s) 7 HAPs hazardous air pollutan ts 8 H/E high early 9 HFCs hydrofluorocarbons 10 HMR Hydro Meteorological Reports 11 HPCS high-pressure core spray 12 HVAC heating, ventilation, and air conditioning 13 IAEA International Atomic Energy Agency 14 IEEE Institute of Electrical and Electronics Engineers 15 IGCC integrated gasification combined-cycle 16 in. inch(es) 17 INEEL Idaho National Engineering and Environmental Laboratory 18 IPCC Intergovernmental Panel on Climate Change 19 IPE individual plant examination 20 IPEEE individual plant examination of external events 21 ISFSI Independent Spent Fuel Storage Installation 22 kg kilogram(s) 23 km kilometer(s) 24 km 2 square kilometers 25 kV kilovolt(s) 26 kWh kilowatthour(s) 27 lb pound(s) 28 lb/MWh pounds per megawatthour 29 LERF large early release frequency 30 LOCA Loss of Coolant Accident 31 LOSP loss of offsite power 32 LRA license renewal application 33 m meter(s) 34 m/s meters per second 35 Abbreviations and Acronyms xxv m 2 square meters 1 m3 cubic meters 2 m 3/s cubic meters per second 3 m 3/yr cubic meters per year 4 mA milliampere(s) 5 MAAP Modular Accident Analysis Program 6 MACCS2 MELCOR Accident Consequence Code System 2 7 MBTA Migratory Bird Treaty Act of 1918, as amended 8 MCEQ Mississippi Commission on Environmental Quality 9 MCR model change request 10 MDAH Mississippi Department of Archives and History 11 MDEQ Mississippi Department of Environmental Quality 12 MDES Mississippi Department of Employment Security 13 MDH Mississippi Department of Health 14 MDEQ Mississippi Department of Environmental Quality 15 MDOT Mississippi Department of Transportation 16 MDWFP Mississippi Department of Wildlife, Fisheries, and Parks 17 mg/L milligrams per liter 18 mGy milligray 19 mi mile(s) 20 mi 2 square miles 21 MIHL Mississippi Institutions of Higher Learning 22 millirem milliroentgen equivalent man 23 mm millimeter(s) 24 MMB tu/MWh one million Btu per megawatthour 25 MMNS Mississippi Museum of Natural Science 26 MNHP Mississippi Natural Heritage Program 27 MMPA Ma rine Mammal Protection Act 28 MP&L Mississippi Power & Light Company 29 mph miles per hour 30 mrad milliradiation absorbed dose 31 mrem milliroentgen equivalent man 32 MSA Magnuson-Stevens Fishery Conservation and Management Act, 33 as amended through January 12, 2007 34 MSCEQ Mississippi Commission of Environmental Quality 35 Abbreviations and Acronyms xxvi MSL mean sea level 1 mSv millisievert 2 MT metric ton(s) 3 MTHM metric ton of heavy metal 4 MWd/MTU megawatt-days per metric ton of uranium 5 MWe megawatt(s) electrical 6 MWt megawatt(s) thermal 7 N 2 O nitrous oxide 8 NAAQS National Ambient Air Quality Standards 9 NAS National Academy of Sciences 10 NASS National Agricultural Statistics Service 11 NCDC National Climatic Data Center 12 NCES National Center for Education Statistics 13 NCF no containment failure 14 NEA Nuclear Energy Agency 15 NEI Nuclear Energy Institute 16 NEPA National Environmental Policy Act 17 NESC National Electrical Safety Code 18 NETL National Energy Technology Laboratory 19 NGCC natural-gas-fired combined-cycle 20 NHPA National Historic Preservation Act 21 NIEHS National Institute of Environmental Health Sciences 22 NMFS National Marine Fisheries Service 23 NOAA National Oceanic and Atmospheric Administration 24 NO x nitrogen oxide(s) 25 NPDES National Pollution Discharge Elimination System 26 NRC U.S. Nuclear Regulatory Commission 27 NRCS National Resources Conservation Service 28 NREL National Renewable Energy Laboratory 29 NRHP National Register of Historic Places 30 NRR Office of Nuclear Reactor Regulation 31 NS Nuclear Station 32 NUREG NRC technical report designation (Nuclear Regulatory 33 Commission) 34 O 3 ozone 35 Abbreviations and Acronyms xxvii ODCM Offsite Dose Calculation Manual 1 OECD Organization for Economic Co -operation and Development 2 OECR offsite economic cost risk 3 PAH polycyclic aromatic hydrocarbon 4 Pb lead 5 pCi/L picocuries per liter 6 PDR population dose risk 7 PDS plant damage state 8 PFCs perfluorocarbons 9 pH hydrogen-ion concentration 10 PM 10 11 PM2.5 12 PMP probably maximum precipitation 13 PNNL Pacific Northwest National Laboratory 14 POST Parliamentary Office of Science and Technology 15 p pb parts per billion 16 p pm parts per million 17 PRA probabilistic risk assessment 18 PSA probabilistic safety assessment 19 PSD Prevention of Significant Deterioration 20 RAI request for additional information 21 RC release category 22 RCRA Resource Conservation and Recovery Act of 1976 23 REMP radiological environmental monitoring program 24 RES Nuclear Regulatory Research, Office of 25 RLE review level earthquake 26 RM river mile(s) 27 ROI region of influence 28 ROW(s) right(s)-of-way 29 RPC replacement power cost 30 RPSEA Research Partnership to Secure Energy for America 31 RPV reactor pressure vessel 32 RRW risk reduction worth 33 SAAQS State Ambient Air Quality Standards 34 SAMA Severe Accident Mitigation Alternative 35 Abbreviations and Acronyms xxviii SAR safety analysis report 1 SCPC supercritical pulverized coal 2 SDWA Safe Drinking Water Act 3 SEIS supplemental environmental impact statement 4 SERI System Energy Resources, Inc. 5 SF 6 sulfur hexafluoride 6 SHPO State Historic Preservation Office 7 SMA seismic margins assessment 8 SNL Sandia National Laboratory 9 SO 2 sulfur dioxide 10 SO x sulfur oxide(s) 11 SRP Standard Review Plan 12 SSCs systems, structures, and components 13 SSE safe shutdown earthquake 14 SSW standby service water 15 State State of Mississippi 16 Sv sievert(s) 17 TCPA Texas Comptroller of Public Accounts 18 TEEIC Tribal Energy and Environmental Information Center 19 TPWD Texas Parks and Wildlife Department 20 TSS total suspended solids 21 U.S. United States 22 U.S.C. United States Code 23 USACE U.S. Army Corps of Engineers 24 USCB U.S. Census Bureau 25 USDA U.S. Department of Agriculture 26 USFS U.S. Forest Service 27 USFWS U.S. Fish & Wildlife Service 28 USGCRP U.S. Global Change Research Program 29 USGS U.S. Geological Survey 30 USOWC U.S. Offshore Wind Collaborative 31 VOCs volatile organic compounds 32 WCD Waste Confidence Decision Rule 33 1-1 1.0 PURPOSE AND NEED FOR ACTION 1 Under the U.S. Nuclear Regulatory Commission's (NRC's) environmental protection regulations 2 in Title 10 of the Code of Federal Regulations Part 51 (10 CFR Part 51) -which carry out the 3 National Environmental Policy Act (NEPA)-renewal of a nuclear power plant operating license 4 requires the preparation of an environmental impact statement (EIS). 5 The Atomic Energy Act of 1954 originally specified that licenses for commercial power reactors 6 be granted for up to 40 years. The 40 -year licensing period was based on economic and 7 antitrust considerations rather than on technical limitations of the nuclear facility. 8 The decision to seek a license renewal rests entirely with nuclear power facility owners and, 9 typically, is based on the facility's economic viability and the investment necessary to continue 10 to meet NRC safety and environmental requirements. The NRC makes the decision to grant or 11 deny license renewal based on whether the applicant has demonstrated that the environmental 12 and safety requirements in the agency's regulations can be met during the period of extended 13 operation. 14 1.1 Proposed Federal Action 15 Entergy Operations , Inc. (Entergy) initiated the proposed F ederal action by submitting an 16 application for license renewal of Grand Gulf Nuclear Station, Unit 1 (GGNS), for which the 17 existing license (NPF-29) expire s on November 1, 2024. The NRC's Federal action is the 18 decision whether to renew the license for an additional 20 years. 19 1.2 Purpose and Need for the Proposed Federal Action 20 The purpose and need for the proposed action (decision whether to renew the license) is to 21 provide an option that allows for power generation capability beyond the term of a current 22 nuclear power plant operating license to meet future system generating needs, as such needs 23 may be determined by other energy -planning decision -makers. This definition of purpose and 24 need reflects the Commission's recognition that, unless there are findings in the safety review 25 required by the Atomic Energy Act or findings in the NEPA environmental analysis that would 26 lead the NRC to reject a license renewal application, the NRC does not have a role in the 27 energy-planning decisions of State regulators and utility officials as to whether a particular 28 nuclear power plant should continue to operate. 29 If a renewed license is issued, State regulatory agencies and Entergy will ultimately decide 30 whether the plant will continue to operate based on factors such as the need for power or other 31 matters within the State's jurisdiction or the purview of the owners. If a renewed license is 32 denied, then the facility must be shut down on or before the expiration date of the current 33 operating license -November 1, 2024. 34 Purpose and Need for Action 1-2 Figure 1-1. Environmental Review Process 1 1.3 Major Environmental Review Milestones 2 Entergy submitted an Environmental Report (ER) (Entergy 2011a) as part of its License 3 Renewal Application (Entergy 2011b) on November 1, 2011. After reviewing the application and 4 ER for sufficiency, the staff published a Federal Register Notice of Acceptability and Opportunity 5 for Hearing (76 FR 80980) on December 27, 2011. Then, o n December 29, 2011 , the NRC 6 published another notice in the Federal Register (76 FR 81996) on the intent to conduct 7 scoping, thereby beginning the 60-day scoping period. 8 Two public scoping meetings were held on January 31, 2012, in Port Gibson, Mississippi 9 (NRC 2012a). The comments received during the scoping process are presented in 10 NRC staff reviews application Staff conduct s environmental site audit NRC issues draft SEIS Company submits an application to NRC *Scoping Process *Draft SEIS Process NRC issues final SEIS NRC decision on whether to renew license

• Opportunity for Public Involvement

Purpose and Need for Action 1-3 "Environmental Impact Statement, Scoping Process, Summary Report," published in April 2013 1 (NRC 2013 a). The scoping process summary report presents NRC responses to comments 2 that the NRC staff considered to be out -of-scope of the environmental license renewal review. 3 The comments considered within the scope of the environmental license renewal review and the 4 NRC responses are presented in Appendix A of this supplemental environmental impact 5 statement (SEIS). 6 In order to independently verify information provided in the ER, NRC staff conducted a site audit 7 at GGNS in March 2012. During the site audit, NRC staff met with plant personnel, reviewed 8 specific documentation, toured the facility, and met with interested Federal, State, and local 9 agencies. A summary of that site audit is contained in "Summary of Site Audit Related to the 10 Environmental Review of the License Renewal Application for Grand Gulf Nuclear Station, 11 Unit 1," published in May 2012 (NRC 2012b). 12 Upon completion of the scoping period and site audit, NRC staff compiled its findings in a draft 13 SEIS (Figure 1 -1). This document is made available for public comment for 45 days. During 14 this time, NRC staff will host public meetings and collect public comments. Based on the 15 information gathered, the NRC staff will amend the draft SEIS findings as necessary, and 16 publish the final SEIS. 17 The NRC has established a license renewal process that can be completed in a reasonable 18 period of time with clear requirements to assure safe plant operation for up to an additional 19 20 years of plant life. The safety review, which documents its finding in a Safety Evaluation 20 Report, is conducted simultaneously with the environmental review. The findings in both the 21 SEIS and the Safety Evaluation Report are factors in the Commission's decision to either grant 22 or deny the issuance of a renewed license. 23 1.4 Generic Environmental Impact Statement 24 The NRC performed a generic assessment of the environmental impacts associated with 25 license renewal to improve the efficiency of the license renewal process. The Generic 26 Environmental Impact Statement for License Renewal of Nuclear Power Plants, NUREG-1437 27 (GEIS) (NRC 1996, 1999) documented the results of the NRC staff's systematic approach to 28 evaluate the environmental consequences of renewing the licenses of individual nuclear power 29 plants and operating them for an additional 20 years. NRC staff analyzed in detail and resolved 30 those environmental issues that could be resolved generically in the GEIS. 31 The GEIS established 92 separate issues for NRC staff to independently verify. Of these 32 issues, NRC staff determined that 69 are generic to all plants (Category 1) while 21 issues do 33 not lend themselves to generic consideration (Category 2). Two other issues remained 34 uncategorized; environmental justice and chronic effects of electromagnetic fields, and must be 35 evaluated on a site -specific basis. A list of all 92 issues can be found in Appendix B. 36 For each potential environmental issue, the GEIS: 37 (1) describes the activity that affects the environment, 38 (2) identifies the population or resource that is affected, 39 (3) assesses the nature and magnitude of the impact on the affected population or 40 resource, 41 (4) characterizes the significance of the effect for both beneficial and adverse effects, 42 (5) determines whether the results of the analysis apply to all plants, and 43 Purpose and Need for Action 1-4 (6) considers whether additional mitigation measures would be warranted for impacts 1 that would have the same significance level for all plants. 2 The NRC's standard of significance for impacts was established using the Council on 3 Environmental Quality (CEQ) terminology for "significant." The NRC established three levels of 4 significance for potential impacts: SMALL, MODERATE, and LARGE, as defined below. 5 SMALL: Environmental effects are not detectable 6 or are so minor that they will neither destabilize nor 7 noticeably alter any important attribute of the 8 resource. 9 MODERATE: Environmental effects are sufficient 10 to alter noticeably, but not to destabilize, important 11 attributes of the resource. 12 LARGE: Environmental effects are clearly 13 noticeable and are sufficient to destabilize important 14 attributes of the resource. 15 The GEIS includes a determination of whether the analysis of the environmental issue could be 16 applied to all plants and whether additional mitigation measures would be warranted 17 (Figure 1-2). Issues are assigned a Category 1 or a Category 2 designation. As set forth in the 18 GEIS, Category 1 issues are those that meet the following criteria: 19 (1) The environmental impacts associated with the issue have been determined 20 to apply either to all plants or, for some issues, to plants having a specific 21 type of cooling system or other specified plant or site characteristics. 22 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been 23 assigned to the impacts (except for collective offsite radiological impacts from 24 the fuel cycle and from high -level waste and spent fuel disposal). 25 (3) Mitigation of adverse impacts associated with the issue has been considered 26 in the analysis, and it has been determined that additional plant -specific 27 mitigation measures are likely not to be sufficiently beneficial to warrant 28 implementation. 29 For generic issues (Category 1), no additional site -specific analysis is required in this SEIS 30 unless new and significant information is identified. The process for identifying new and 31 significant information is presented in Chapter 4. Site -specific issues (Category

2) are those 32 that do not meet one or more of the criteria of Category 1 issues, and therefore, additional 33 site-specific review for these issues is required. The results of that site-specific review are 34 documented in the SEIS. 35 Significance indicates the importance of likely environmental impacts and is determined by considering two variables:

context and intensity. Context is the geographic, biophysical, and social context in which the effects will occur. Intensity refers to the severity of the impact, in whatever context it occurs . Purpose and Need for Action 1-5 Figure 1-2. Environmental Issues Evaluated During License Renewal 1 The NRC staff initially evaluated 92 issues in the GEIS. Based on the findings of the GEIS, a 2 site-specific analysis is required for 23 of those 92 issues. 3 On June 20, 2013, the NRC published a final rule (78 FR 37282) revising its environmental 4 protection regulation, Title 10 of the Code of Federal Regulations (10 CFR) Part 51, 5 "Environmental Protection Regulations for Domestic Licensing and Related Regulatory 6 Functions." Specifically, the final rule update s the potential environmental impacts associated 7 with the renewal of an operating license for a nuclear power reactor for an additional 20 years. 8 A revised GEIS (NRC 2013b), which updates the 1996 GEIS, provides the technical basis for 9 the final rule. The revised GEIS specifically supports the revised list of NEPA issues and 10 associated environmental impact findings for license renewal contained in Table B-1 in 11 Appendix B to Subpart A of the revised 10 CFR Part 51. The revised GEIS and final rule reflect 12 lessons learned and knowledge gained during previous license renewal environmental reviews. 13 In addition, public comments received on the draft revised GEIS and rule and during previous 14 license renewal environmental reviews were re -examined to validate existing environmental 15 issues and identify new ones. 16 The final rule identifies 78 environmental impact issues, of which 17 will require plant-specific 17 analysis. The final rule consolidates similar Category 1 and 2 issues, changes some 18 Category 2 issues into Category 1 issues, and consolidates some of those issues with existing 19 Category 1 issues. The final rule also adds new Category 1 and 2 issues. The new Category 1 20 Purpose and Need for Action 1-6 New and significant information either: (1) identifies a significant environmental issue not covered in the GEIS, or (2) was not considered in the analysis in the GEIS and leads to an impact finding that is different from the finding presented in the GEIS. issues include geology and soils, exposure of terrestrial organisms to radionuclides, exposure of 1 aquatic organisms to radionuclides, human health impact from chemicals, and physical 2 occupational hazards. Radionuclides released to groundwate r, effects on terrestrial resources 3 (non-cooling system impacts), minority and low -income populations (i.e., environmental justice), 4 and cumulative impacts were added as new Category 2 issues. 5 The final rule became effective 30 days after publication in the Federal Register. Compliance 6 by license renewal applicants is not required until 1 year from the date of publication 7 (i.e., license renewal environmental reports submitted later than 1 year after publication must be 8 compliant with the new rule). Nevertheless, under NEPA, the NRC must now consider and 9 analyze, in its license renewal SEISs, the potential significant impacts described by the final 10 rule's new Category 2 issues and, to the extent there is any new and significant information, the 11 potential significant impacts described by the final rule's new Category 1 issues. 12 1.5 Supplemental Environmental Impact Statement 13 The SEIS presents an analysis that considers the environmental effects of the continued 14 operation of GGNS, alternatives to license renewal, and mitigation measures for minimizing 15 adverse environmental impacts. Chapter 8 contains analysis and comparison of the potential 16 environmental impacts from alternatives while Chapter 9 presents the staff's preliminary 17 recommendation to the Commission on whether or not the environmental impacts of license 18 renewal are so great that preserving the option of license renewal would be unreasonable. The 19 recommendation includes consideration of comments received during the public scoping period. 20 In the preparation of this SEIS for GGNS, the staff: 21 reviewed the information provided in Entergy's ER, 22 consulted with other Federal, State, and local agencies, 23 conducted an independent review of the issues during a site audit, and 24 considered the public comments received during the scoping process. 25 New information can be identified from a 26 number of sources, including the applicant, 27 NRC, other agencies, or public comments. If a 28 new issue is revealed, then it is first analyzed to 29 determine whether it is within the scope of the 30 license renewal evaluation. If it is not 31 addressed in the GEIS then the NRC 32 determines its significance and documents its 33 analysis in the SEIS. 34 1.6 Cooperating Agencies 35 During the scoping process, no Federal, State, or local agencies were identified as cooperating 36 agencies in the preparation of this SEIS. 37 1.7 Consultations 38 The Endangered Species Act of 1973, as amended; the Magnuson-Stevens Fisheries 39 Management Act of 1996, as amended; and the National Historic Preservation Act of 1966 40 require that Federal agencies consult with applicable State and Federal agencies and groups 41 Purpose and Need for Action 1-7 prior to taking action that may affect endangered species, fisheries, or historic and 1 archaeological resources, respectively. Below are the agencies and groups with whom the 2 NRC consulted; Appendix D to this report includes copies of consultation documents. 3 Advisory Council on Historic Preservation 4 National Marine Fisheries Service 5 U.S. Fish and Wildlife Service, Mississippi Field Office 6 U.S. Fish and Wildlife Service, Louisiana Field Office 7 Mississippi Band of Choctaw Indians 8 Jena Band of Choctaw Indians 9 Choctaw Nation of Oklahoma 10 Tunica-Biloxi Tribe of Louisiana 11 1.8 Correspondence 12 During the course of the environmental review, the NRC staff contacted the Federal, State, 13 regional, local, and tribal agencies listed in Section 1.7, as well as the following: 14 Mississippi Department of Archives and History 15 Louisiana Division of Historic Preservation 16 Mississippi Natural Heritage Program 17 Louisiana Natural Heritage Program 18 Appendix E contains a chronological list of all the documents sent and received during the 19 environmental review. 20 A list of persons who received a copy of this SEIS is provided in Chapter

11. 21 1.9 Status of Compliance 22 Entergy is responsible for complying with all NRC regulations and other applicable Federal, 23 State, and local requirements. A description of some of the major Federal statutes can be found 24 in Appendix H of the GEIS. Appendix C to this SEIS includes a list of the permits and licenses 25 issued by Federal, State, and local authorities for activities at GGNS.

26 1.10 References 27 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 28 Protection Regulations for Domestic Licensing and Related Regulator Activities." 29 76 FR 80980. U.S. Nuclear Regulatory Commission, Washington DC, "Notice of Acceptance for 30 Docketing of the Application and Notice of Opportunity for Hearing Regarding Renewal of 31 Facility Operating License No. NPF -29 for an Additional 20 -Year Period, Entergy Operations, 32 Inc., Grand Gulf Nuclear Station." Federal Register 76(248): 80980-80982, December 27, 2011. 33 76 FR 81996. U.S. Nuclear Regulatory Commission, Washington DC, "Entergy Operations, Inc.; 34 Notice of Intent To Prepare an Environmental Impact Statement and Conduct Scoping Process 35 for Grand Gulf Nuclear Station, Unit 1." Federal Register 76(250): 81996 -81998, December 29, 36 2011. 37 78 FR 37282. U.S. Nuclear Regulatory Commission. "Revisions to Environmental Review for 38 Renewal of Nuclear Power Plant Operating Licenses. " Federal Register 78(119): 37282 -37324. 39 June 20, 2013. 40 Atomic Energy Act of 1954. 42 U.S.C. §2011, et seq. 41 Purpose and Need for Action 1-8 Endangered Species Act of 1973, as amended. 16 U.S.C. §1531, et seq. 1 [Entergy] Entergy Operations, Inc. 2011

a. Grand Gulf Nuclear Station, Unit 1, License Renewal 2 Application , Appendix E, Applicant's Environmental Report, Operating License Renewal Stage. 3 Agencywide Documents Access and Management System (ADAMS) Accession 4 No. ML11308A234.

5 [Entergy] Entergy Operations, Inc. 2011b. Grand Gulf Nuclear Station, Unit 1 -License Renewal 6 Application. October 2011. ADAMS Accession No. ML11308A101. 7 Magnuson-Stevens Fishery Conservation and Management Act, as amended by the 8 Sustainable Fisheries Act of 1996. 16 U.S.C. §1855, et seq. 9 National Environmental Policy Act of 1969, as amended. 42 U.S.C. §4321, et seq. 10 National Historic Preservation Act of 1966. 16 U.S.C. §470, et seq. 11 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 12 for License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2. Washington DC. 13 May 1996. ADAMS Accession Nos. ML040690705 and ML040690738. 14 [NRC] U.S. Nuclear Regulatory Commission. 1999. Generic Environmental Impact Statement 15 for License Renewal of Nuclear Plants, Main Report, "Section 6.3 -Transportation, Table 9.1, 16 Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final 17 Report, NUREG -1437, Volume 1, Addendum 1. Washington DC. August 1999. ADAMS 18 Accession No. ML04069 0 720. 19 [NRC] U.S. Nuclear Regulatory Commission. 2012a. "Summary of Public Scoping Meetings 20 Conducted on January 31, 2012, Related to the Review of the Grand Gulf Nuclear Station, 21 Unit 1, License Renewal Application." February 2012. ADAMS Accession No. ML12044A151. 22 [NRC] U.S. Nuclear Regulatory Commission. 2012b. "Summary of Site Audit Related to the 23 Environmental Review of the License Renewal Application for Grand Gulf Nuclear Station, 24 Unit 1." May 21, 2012. ADAMS Accession No. ML12116A060. 25 [NRC] U.S. Nuclear Regulatory Commission. 2012c. Staff Requirements, SECY 0063 - Final 26 Rule: Revisions to Environmental Review for Renewal of Nuclear Power Plant Operating 27 Licenses (10 CFR Part 51; RIN 3150 -AI42). December 6, 2012. ADAMS Accession 28 No. ML12341A134. 29 [NRC] U.S. Nuclear Regulatory Commission. 2013a. "Environmental Impact Statement, Scoping 30 Process, Summary Report," April 2013. ADAMS Accession No. ML12201A623. 31 [NRC] U.S. Nuclear Regulatory Commission. 2013

b. Generic Environmental Impact Statement 32 for License Renewal of Nuclear Plants. Washington, DC: Office of Nuclear Reactor Regulation.

33 NUREG-1437, Revision 1, Volumes 1, 2, and 3. June 2013. ADAMS Accession Nos. 34 ML13106A241, ML13106A242, and ML13106A244. 35 2-1 2.0 AFFECTED ENVIRONMENT 1 Grand Gulf Nuclear Station (GGNS) is located in Claiborne County, Mississippi, on the east 2 bank of the Mississippi River, approximately 25 miles (mi) (39 kilometers (km)) south-southwest 3 of Vicksburg, Mississippi. Figure 2 -1 and Figure 2 -2 present the 50-mi (80-km) and 6-mi 4 (10-km) vicinity maps, respectively. In this supplemental environmental impact statement 5 (SEIS), the "affected environment" is the environment that currently exists at and around GGNS. 6 Because existing conditions are at least partially the result of past construction and operation at 7 the plant, the impacts of these past and ongoing actions, and how they have shaped the 8 environment, are presented here. Section 2.1 of this SEIS describes the facility and its 9 operation, and Section

2.2 discusses

the affected environment. 10 2.1 Facility Description 11 GGNS is a single -unit nuclear power plant that began commercial operation in July 1985. 12 The property boundary shown in Figure 2 -3 encloses approximately 2,100 acres (ac), or 13 850 hectares (ha). Currently, the property is approximately 2,015 ac (816 ha) because of the 14 loss of approximately 85 ac (34 ha) from erosion by the Mississippi River (Entergy 2011a ). The 15 original application submitted in 1972 for GGNS was for a two -unit nuclear power facility. 16 Construction on Unit 2 was halted before completion in 1979. The majority of the Unit 2 power 17 block buildings were completed, along with the outer cylindrical concrete wall of the reactor 18 containment building. The switchyard was designed and constructed for two units 19 (NRC 2006 a). 20 The most conspicuous structures on the GGNS site include the natural draft cooling tower, the 21 turbine building, the Unit 1 reactor containment building, the Unit 2 (cancelled) reactor 22 containment outer cylindrical concrete wall, the auxiliary cooling tower, and various other 23 buildings. 24 2.1.1 Reactor and Containment Systems 25 The GGNS nuclear reactor system is a single -cycle, forced -circulation, General Electric Mark III 26 boiling water reactor (BWR). The reactor core heats water to make steam that is dried by steam 27 separators and dryers located in the upper portion of the reactor vessel. The steam is then 28 directed to the main turbine through the main steam lines where it turns the turbine generator to 29 produce electricity. 30 Fuel for GGNS is made of low-enrichment (less than 5 percent by weight) high -density ceramic 31 uranium dioxide fuel pellets, with a maximum average burnup level of less than 32 62,000 megawatt-days/metric ton of uranium. GGNS operates on an 18 -month refueling cycle 33 and plans to switch to a 24 -month refueling cycle in the future. 34 The functional design basis of the containment, including its penetrations and isolation valves, is 35 to contain, with adequate design margin, the energy released from a design basis 36 loss-of-coolant accident. It also provide s a leak-tight barrier against the uncontrolled release of 37 radioactivity to the environment, even assuming a partial loss of engineered safety features. 38 The reactor and related systems are enclosed in containment and enclosure structures. The 39 containment structure encloses the reactor coolant system, drywell, suppression pool, upper 40 pool, and some of the engineered safety feature systems and supporting systems. The 41 enclosure building and auxiliary building are combined to form a secondary containment which 42 Affected Environment 2-2 Figure 2-1. Location of GGNS, 50 -mi (80-km) Vicinity 1 Source: Entergy 2011a 2 Affected Environment 2-3 Figure 2-2. Location of GGNS, 6 -mi (10-km) Vicinity 1 Source: Entergy 2011a 2 Affected Environment 2-4 Figure 2-3. GGNS, General Site Layout 1 Source: Modified from Entergy 2011a 2 Affected Environment 2-5 maintains a negative pressure in the volume between the containment and enclosure/auxiliary 1 building. These two containment systems and associated engineered safety features are 2 designed and maintained to minimize the release of airborne radioactive materials under 3 accident conditions. 4 2.1.2 Radioactive Waste Management 5 GGNS radioactive waste systems collect, treat, and dispose of radioactive wastes that are 6 byproducts of plant operations. These byproducts are activation products associated with 7 nuclear fission, reactor coolant activation, and non -coolant material activation. 8 Release of liquid and gaseous effluents are controlled to meet the limits specified in Title 9 10, Code of Federal Regulatio ns (CFR) Part 20 and 10 CFR Part 50, Appendix I, through the 10 Radioactive Effluent Controls Program defined in the GGN S technical specifications. Operation 11 procedures for the radioactive waste system s ensure that radioactive wastes are safely 12 processed and discharged from GGNS. The systems are designed and operated to ensure that 13 the quantities of radioactive materials released from GGNS are as low as is reasonably 14 achievable (ALARA) and within the dose standards set forth in 10 CFR Part 20, "Standards for 15 protection against radiation," and Appendix I to 10 CFR Part 50, "Domestic licensing of 16 production and utilization facilities." The GG NS Offsite Dose Calculation Manual (ODCM) 17 contains the methods and parameters used to calculate offsite doses resulting from radioactive 18 effluents. These methods are used to ensure that radioactive material discharges from GGN S 19 meet regulatory dose standards. 20 Radioactive wastes resulting from GGNS plant operations are classified as liquid, gaseous, or 21 solid. Liquid radioactive wastes are generated from liquids received directly from portions of the 22 reactor coolant system or were contaminated by contact with liquids from the reactor coolant 23 system. Gaseous radioactive wastes are generated from gases or airborne particulates vented 24 from reactor and turbine equipment containing radioactive material. Solid radioactive wastes 25 are solids from the reactor coolant system, solids that came into contact with reactor coolant 26 system liquids or gases, or solids used in the steam and power conversion system. 27 Reactor fuel that has exhausted a certain percentage of its fissile uranium content is referred to 28 as spent fuel. Spent fuel assemblies that are removed from the reactor core are replaced with 29 fresh fuel assemblies during routine refueling outages. Spent nuclear fuel from the GGNS 30 reactor is stored on site in a spent fuel pool and an independent spent fuel storage installation 31 (ISFSI) (Entergy 2011 a). 32 2.1.2.1 Radioactive Liquid Waste 33 The GGNS liquid radwaste system collects, processes, recycles, and disposes of potentially 34 radioactive wastes produced during operation of the plant. The liquid effluents from the liquid 35 radwaste system are monitored continuously, and the discharges are terminated if the effluents 36 exceed preset radioactivity levels, which are specified in the GGNS ODCM. The liquid radwaste 37 system is comp rised of a group of subsystems designed to collect and treat different types of 38 liquid waste, designated as the equipment drain processing subsystem (clean radwaste), floor 39 drain processing subsystem (dirty radwaste), chemical waste subsystem, and miscellaneous 40 supporting subsystems. 41 Liquid wastes that accumulate in radwaste drain tanks or in sumps are transferred to collection 42 and sample tanks in the radwaste building. The liquid wastes are processed through filters and 43 demineralizers and returned to the condensate system or released from the plant. 44 Control of discharges from the radwaste system includes a radiation monitor, an effluent flow 45 control valve, and dilution water flow rate monitoring equipment. Radioactive liquid wastes are 46 Affected Environment 2-6 subject to the sampling and analysis program described in the ODCM. This enables GGNS to 1 handle radioactive liquid releases in accordance with applicable regulations and impacts to 2 offsite areas will be consistent with ALARA concepts (Entergy 2011a ). 3 2.1.2.2 Radioactive Gaseous Waste 4 The gaseous radwaste system process es and control s the release of gaseous radioactive 5 effluents to the atmosphere. Gaseous effluents are released from the radwaste building vent, 6 the turbine building vent, the containment vent, the auxiliary vent, and standby gas treatment 7 system. 8 Radioactive gas is continuously removed from the main condenser by the air ejector during 9 plant operation. It is then filtered, cooled, and discharged to the environment. GGNS uses 10 continuous radiation monitors to ensure radioactive gaseous effluent discharges are within 11 specifications in the ODCM (Entergy 2011a). 12 2.1.2.3 Radioactive Solid Waste 13 The solid waste management system collects, processes, and packages solid radioactive 14 wastes for storage and offsite shipment and permanent disposal. GGNS has developed 15 long-term plans that would ensure radwaste generated during the license renewal term would 16 either be stored on site in existing structures or shipped to an offsite licensed facility for 17 processing and disposal. 18 Wet wastes are collected, dewatered, packaged in containers and stored before offsite 19 shipment. 20 Dry wastes usually consist of small tools, air filters, miscellaneous paper, rags, equipment parts 21 that cannot be effectively decontaminated, wood, and solid laboratory waste. Compressible 22 wastes can be shipped off site and compacted to reduce their volume. Noncompressible 23 wastes are packaged in appropriate containers. Because of its low radiation levels , this waste 24 can be stored until enough is accumulated to permit economic transportation off site for final 25 disposal or further processing. 26 GGNS currently transports radioactive waste to licensed processing facilities in Tennessee, 27 such as the Studsvik, Duratek (owned by EnergySolutions), or Race (owned by Studsvik) 28 facilities, where wastes are further processed before they are sent to a facility such as 29 EnergySolutions in Clive, Utah, for disposal. GGNS also may transport material from an offsite 30 processing facility to a disposal site or back to the plant site for reuse or storage. GGNS 31 radioactive waste shipments are packaged in accordance with both NRC and Department of 32 Transportation (DOT) requirements (Entergy 2011a). 33 2.1.2.4 Low-Level Mixed Wastes 34 Currently, no mixed waste s are generated or stored on the GGNS site. If they were, they would 35 be managed and transported to an offsite facility licensed to accept and manage the wastes in 36 accordance with appropriate GGNS and Entergy procedures (Entergy 2011a). 37 2.1.3 Nonradiological Waste Management 38 The Resource Conservation and Recovery Act of 1976 (RCRA) governs nonradioactive 39 hazardous and nonhazardous wastes produced at GGNS. The U.S. Environmental Protection 40 Agency (EPA) is ultimate ly responsib le for implementing RCRA and regulations governing the 41 disposal of solid and hazardous waste are contained in 40 CFR Parts 239-299. Specifically, 42 RCRA Subtitle D regulations for solid (nonhazardous) waste are contained in 43 40 CFR Parts 239-259. RCRA Subtitle C regulations for hazardous waste are contained in 44 Affected Environment 2-7 40 CFR Parts 260-279. RCRA Subtitle C establishes a system for controlling hazardous waste 1 from "cradle to grave ." RCRA Subtitle D encourages states to develop comprehensive plans to 2 manage nonhazardous solid waste and mandates minimum technological standards for 3 municipal solid waste landfills. EPA authorizes states to implement the RCRA hazardous wa ste 4 program through their rulemaking process. 5 EPA granted initial authorization to Mississippi to operate its hazardous waste program on 6 June 13, 1984. The Mississippi Department of Environmental Quality (MDEQ) administers the 7 State's hazardous waste regulations and address es the identification, generation, minimization, 8 transportation, and final treatment, storage, or disposal of hazardous and nonhazardous waste. 9 Mississippi's hazardous waste regulations can be found in MDEQ, Office of Pollution Control, 10 Hazardous Waste Management Regulations, HW -1. Mississippi's solid waste law is contained 11 in Chapter 17, "Solid Wastes Disposal Law of 1974 ," of Title 17, "Local Government; Provisions 12 Common to Counties and Municipalities. " As EPA amends its RCRA regulations, Mississippi 13 has amended its program to maintain consistency with the national standards. 14 2.1.3.1 Nonradioactive Waste Streams 15 GGNS generates nonradioactive waste as part of routine maintenance of equipment, cleaning 16 activities, and plant operations. Nonradioactive waste generated at GGNS include s batteries, 17 fluorescent lamps, scrap metals, used oil, used oil filters, used tires, electronics for 18 reconditioning, and equipment containing mercury. Nonhazardous waste generated at GGNS 19 consists of materials such as blasting media, oil contaminated wastes, wastewater, and 20 wastewater sludges. Hazardous waste generated at GGNS is usually a small percentage of the 21 total waste generated at the plant. Hazardous waste generated at GGNS include s aerosols, oils 22 and solvents, paint, and out-of-date or off -specification chemicals. 23 EPA recognizes the following main types of hazardous waste generators (40 CFR 260.10) 24 based on the quantity of the hazardous waste produced: 25 large quantity generators that generate 2,200 pounds (lb) (1,000 kilograms 26 (kg)) per month or more of hazardous waste, more than 2.2 lb (1 kg) per 27 month of acutely hazardous waste, or more than 220 lb (100 kg) per month of 28 acute spill residue or soil; 29 small quantity generators that generate more than 220 lb (100 kg) but less 30 than 2,200 lb (1,000 kg) of hazardous waste per month; and, 31 conditionally exempt small quantity generators that generate 220 lb (100 kg) 32 or less per month of hazardous waste, 2.2 lb (1 kg) or less per month of 33 acutely hazardous waste, or less than 220 lb (100 kg) per month of acute spill 34 residue or soil. 35 Mississippi has adopted EPA's regulations relating to RCRA Subpart C and Subpart D wastes 36 and MDEQ recognizes GGNS as a small quantity generator of hazardous wastes. The NRC 37 staff reviewed Waste Minimization Certified Reports that GGN S submitted to MDEQ , 38 Environmental Permits Division, for the years 2006 through 2010. These reports document the 39 types and quantities of nonradioactive waste generated at GGNS and verify the status of GGNS 40 as a small quantity generator of hazardous waste. 41 Conditions and limitations for wastewater discharge by GGNS are specified in National Pollution 42 Discharge Elimination System (NPDES) Permit No. MS0029521. Radioactive liquid waste is 43 addressed in Section 2.1.2 of this SEIS. Section

2.2.4 provides

more information about the 44 GGNS NPDES permit and permitted discharges. 45 Affected Environment 2-8 The Emergency Planning and Community Right -to-Know Act (EPCRA) requires applicable 1 facilities to supply information about hazardous and toxic chemicals to local emergency planning 2 authorities and the EPA (42 USC 11001). GGNS is subject to Federal EPCRA reporting 3 requirements. As such, GGNS submits an annual Section 312 (Tier II) report on hazardous 4 substances to the Claiborne County Emergency Planning Committee and to the Mississippi 5 Emergency Management Agency. 6 2.1.3.2 Pollution Prevention and Waste Minimization 7 EPA encourages the use of environmental management systems (EMS) for organizations to 8 assess and manage the environmental impacts associated with their activities, products, and 9 services in an efficient and cost -effective manner. The EPA defines an EMS as "a set of 10 processes and practices that enable an organization to reduce its environmental impacts and 11 increase its operating efficiency." EMSs help organizations fully integrate a wide range of 12 environmental initiatives, establish environmental goals, and create a continuous monitoring 13 process to help meet those goals. The EPA Office of Solid Waste especially advocates the use 14 of EMSs at RCRA -regulated facilities to improve environmental performance, compliance, and 15 pollution prevention (EPA 2010). 16 Related to the use of EMSs, Entergy, the parent company for GGNS, has established a Waste 17 Minimization Plan for its fleet of nuclear power plants. The plan describes the activities plant 18 personnel must take to reduce, to the extent feasible, the hazardous, hazardous/radioactive, 19 and nonhazardous wastes generated, treated, stored , or disposed. The Waste Minimization 20 Plan is used in conjunction with Entergy's fleet procedures and the individual plant's procedures 21 to minimize, to the maximum extent possible, the generation of all types of waste. 22 Pollution-prevention and waste -minimization efforts that GGNS uses are summarized in annual 23 Waste Minimization Certified Reports submitted to MDEQ. Entergy's Waste Minimization 24 procedure (EN -EV-104) lists the practices used to minimize waste generation. The hierarchy for 25 minimizing or managing waste is: 26 source reduction - reduce or eliminate potential waste material, 27 recycle - reuse or reclaim material instead of throwing it in the trash, 28 treatment - neutralize acids or bases, and 29 disposal - last resort when no other action can be taken. 30 2.1.4 Plant Operation and Maintenance 31 Maintenance activities conducted at GGNS include inspection, testing, and surveillance to 32 maintain the current licensing basis of the facility and to ensure compliance with environmental 33 and safety requirements. These maintenance activities include inspection requirements for 34 reactor vessel materials, boiler and pressure vessel inservice inspection and testing, the 35 monitoring program for maintaining structures, and maintenance of water chemistry. 36 Additional programs include those carried out to meet technical specification surveillance 37 requirements, those implemented in response to the NRC generic communications, and various 38 periodic maintenance, testing, and inspection procedures. Certain program activities are carried 39 out during the operation of the unit, while others are carried out during scheduled refueling 40 outages. Nuclear power plants must periodically discontinue the production of electricity for 41 refueling, periodic inservice inspection, and scheduled maintenance. GGNS operates on an 42 18-month refueling cycle. 43 Affected Environment 2-9 2.1.5 Power Transmission System 1 Three 500-kilovolt (kV) transmission lines were constructed to connect GGNS to the regional 2 power grid: the Baxter -Wilson line, the Franklin line, and a short, unnamed tie -in line that 3 connects the Unit 1 turbine building to the GGNS station switchyard. Entergy Mississippi, Inc. 4 (EMI) owns and operates these lines. This section summarizes each line and discusses 5 vegetative maintenance procedures. Figures 2-1 and 2-2 depict the transmission line 6 corridors. 7 The Baxter -Wilson line is a 22 -mi (35-km) single -circuit 500-kV line that extends north from the 8 GGNS switchyard to the Baxter -Wilson Steam Electric Station Extra High Voltage (EHV) 9 switchyard in Claiborne County, Mississippi. Its corridor is 200 f eet (ft) (60 meters (m)) wide 10 and traverses rural, sparsely populated agricultural and forested land. 11 The Franklin line is a 43.6 -mi (70.2-km) single -circuit 500 -kV line that extends southeast from 12 the GGNS switchyard to the Franklin EHV Switching Station in Franklin County, Mississippi. 13 Its corridor is 200 ft (60 m) wide and traverses four major highways, the Bayou Pierre and 14 Homochitto Rivers, and a portion of the Homochitto National Forest. 15 The third transmission line extends 300 ft (90 m) from the Unit 1 turbine building to the GGNS 16 switchyard. 17 EMI inspects each transmission line right-of-way 18 by air or ground at least three times per year to 19 identify encroaching vegetation or other required 20 maintenance. EMI follows an integrated 21 vegetative plan that includes mechanical and 22 manual clearing and herbicide application. The 23 degree and type of clearance varies by line 24 voltage and the type, growth rate, and branching 25 characteristics of trees and vegetation. Large 26 trees generally are trimmed or pruned to allow for 27 adequate line clearance

smaller trees and woody 28 vegetation may be mowed to prepare the area for followup herbicide treatments. In sensitive 29 areas, such as streams, ponds, or other water features, EMI chooses maintenance techniques 30 that minimize erosion. In wetlands and aquatic habitat, EMI personnel selectively apply 31 herbicides that are E PA-approved for aquatic environments. These herbicides are applied on 32 foot with backpack sprayers to minimize impacts. All EMI maintenance crew personnel have a 33 U.S. Department of Agriculture (USDA) state-approved herbicide license.

34 Along the Franklin line, 38.6 ac (15.6 ha) of the transmission line corridor pass through the Bude 35 Range District of the Homochitto National Forest. For this portion of the line, EMI holds a USDA 36 Forest Service Special Use Permit for construction, operation, and maintenance of the line. EMI 37 also uses a low-toxicity herbicide program for this portion of the transmission line corridor to 38 promote open, grassy habitat as part of a partnership established in 2003 with the National Wild 39 Turkey Federation (Entergy 2011a). 40 2.1.6 Cooling and Auxiliary Water Systems 41 A surface water structure to obtain cooling water from the Mississippi River does not exist at 42 GGNS. Instead, water is pumped from Ranney wells located in an aquifer along the Mississippi 43 River. The Ranney well system design and hydrogeology is discussed in greater detail in 44 Section 2.1.7. 45 A transmission line right-of-way (ROW) is a strip of land used to construct, operate, maintain, and repair transmission line facilities. The transmission line is usually centered in the ROW. The width of a ROW depends on the voltage of the line and the height of the structures. ROWs must typically be clear of tall -growing trees and structures that could interfere with a powerline.

Affected Environment 2-10 Entergy's Environmental Report (ER) (Entergy 2011a) provides information on the circulating 1 water system that removes excess heat from the reactor. The circulating water system cools 2 the main condenser. Heat is removed from the circulating water system by cooling towers, 3 which dissipate the heat to the atmosphere. The main cooling tower is a natural draft cooling 4 tower. It does not require the use of fans to operate. It may operate alone or it may operate in 5 tandem with a forced draft auxiliary cooling tower, which use fans. When both tower systems 6 are in service, the maximum temperature of the cooling water delivered to the main condenser 7 by the circulating water system is 32.2

°C (90 °F). 8 Five Ranney wells provide makeup water to replace water lost from the cooling towers by drift, 9 evaporation, and blowdown. During normal operation, as many wells and pumps as required 10 are operated to meet the plant demand. Blowdown (water intentionally removed from the 11 cooling water system to avoid concentration of impurities) is returned to the Mississippi River 12 through a 54-inch (in.) (137-centimeter (cm)) diameter pipeline (Entergy 2011a). 13 The temperature of the water exiting the 54

-in (137-cm) discharge pipeline is monitored 14 throughout the year as required by MDEQ NPDES Permit MS002952

1. GGNS has not violated 15 the thermal conditions of the permit. Therefore, water temperatures in the Mississippi River as 16 a result of this discharge have not exceeded a water temperature change of 2.8 °C (5.0 °F) 17 relative to the upriver temperature, outside a mixing zone not exceeding a maximum width of 18 60 ft (18.5 m) from the river edge and a maximum length of 6,000 ft (1,829 m) downstream from 19 the point of discharge, as measured at a depth of 5 ft (1.5 m). Further, the maximum water 20 temperatures outside the mixing zone have not exceeded 32.2

°C (90 °F), except when ambient 21 river temperatures approach or exceed this value (GGNS 2010a). 22 Should an emergency plant shutdown occur, a standby service water system would supply 23 auxiliary cooling to the reactor. Makeup water is provided automatically by the Ranney wells to 24 the standby service water system basins. However, if the Ranney wells were not operable, t he 25 plant service water basins contain enough water to ensure cooling for the shutdown reactor for 26 30 days (GGNS 2003 a). 27 2.1.7 Facility Water Use and Quality 28 Cooling water for GGNS is supplied from Ranney wells located next to the Mississippi River. 29 A Ranney well is a radial well used to extract water from an aquifer with direct connection to a 30 river or lake. It consists of a vertical caisson constructed into sand or gravel below the surface 31 level of an adjacent river or lake. Screened conduits are extended horizontally from ports in the 32 caisson. The radial arrangement of the screened conduits extending outward from the central 33 vertical caisson forms a large infiltration gallery (Figure 2-4). Groundwater flows into the 34 horizontal screened conduits that make up the infiltration gallery. From there, the water flows to 35 the central caisson, where it is pumped to the surface. One advantage of using a Ranney well 36 to extract water from a river or lake is that less water treatment may be required than if the 37 water is directly extracted from the river or lake.

38 At GGNS, Ranney wells supply water from the Mississippi River by pumping water from the 39 aquifer, which underlies the Mississippi River (NRC 2006 a). Pumping from the aquifer removes 40 suspended sediment from Mississippi River water. With the exception of suspended sediment, 41 the water quality obtained from these wells is nearly identical to that of the Mississippi River. 42 Fresh (potable) water for the plant is obtained from three wells located within the site boundary 43 and from the Crossroads, Shiloh & Ingleside (CS&I) Water Association #1 located 6 mi away 44 from GGNS (Entergy 2011a). 45 The following sections describe water use and relevant quality issues at GGNS. 46 Affected Environment 2-11 2.1.7.1 Surface Water Use 1 Mississippi River water quality is generally hard to very hard, requiring softening to avoid scale 2 formation when heated in a cooling system (NRC 2006). In March 2012, four Ranney well s 3 supplied water from the Mississippi River by pumping water from the Mississippi River Alluvial 4 Aquifer. Most of th is water cool ed the reactor, but some supplied makeup water to the standby 5 service water cooling towers, administration building, and fire protection system. Each of the 6 Ranney wells is permitted by MDEQ to operate at a maximum production rate of 10,000 gallons 7 per minute (gpm) (0.63 cubic meters per second (m 3/s)) (Entergy 2011a). This would produce a 8 total maximum production rate from the Mississippi River of 40,000 gpm (2.5 m 3/s). However, 9 from 2005 through 2010, the four Ranney wells generated a combined annual water production 10 rate that was much less than permitted amounts. This is because infiltration rates have 11 declined over time due to sediment buildup in the screened conduits. Over this time period, the 12 production rate from all four wells averaged approximately 22,396 gpm (1.4 m 3/s). 13 A new Ranney well (well number PSW -6 on Figure 2 -5) was installed and bec ame operational 14 in August 2012. Its purpose is to ensure that adequate plant cooling water is maintained. As 15 with the other Ranney wells, this well is located next to the Mississippi River. The estimated 16 average combined production rate of Mississippi River water is approximately 27,860 gpm 17 (1,758 m 3/s). Of this volume, 7,170 gpm (0.45 m 3/s) of blowdown is estimated to be returned to 18 the Mississippi River through a 54-in. (137-cm) diameter discharge pipeline. An estimated 19 20,690 gpm (1.31 m 3/s) of water is lost to the atmosphere, mainly through evaporation and drift 20 from the cooling towers (Entergy 2011a). 21 Affected Environment 2-12 Figure 2-4. Plan (Map) View and Cross Section View of Ranney Well at GGNS 1 Source: Modified from Entergy 2011a 2 Affected Environment 2-13 Figure 2-5. GGNS Ranney Well Locations 1 Source: Modified from Entergy 2011a 2 Affected Environment 2-14 2.1.7.2 Groundwater Use 1 As discussed in Section 2.1.7.1, the GGNS reactor cooling system relies on induced infiltration 2 from the Mississippi River obtained by a system of Ranney collector wells (Entergy 2012a). 3 The total annual pumping from these four wells amounts to 10,800 -13,100 million gallons (gal) 4 (40.9-49.6 million m 3) per year (Entergy 2006, 2010b, 2011 c). 5 Three wells (North Construction Well and the North and South Drinking Water Wells), located 6 within the site boundary and northeast of the main plant buildings, produce water used for 7 domestic purposes, once -through cooling for plant air conditioners, and for regenerating the 8 water softeners (Figure 2 -6). After it has been used, this water flows to the Mississippi River 9 through a 54-in. (137-cm) diameter pipeline, either after it has been processed by the onsite 10 sewage treatment facility or as other permitted surface water discharges. Total annual pumping 11 from these three wells amounts to 32 -39 million gal/yr (0.12 -0.15 million m 3/yr) 12 (Entergy 2006, 2010b, 2011 c). The average rate of water these wells produce from the 13 groundwater in the Upland Terrace Deposits is estimated to be 67 gpm (0.3 m 3/s). 14 GGNS also obtains potable water from the CS&I Water Association #1. This public water 15 system supplies potable water needs for the GGNS recreational vehicle trailer park, firing range, 16 health physics calibration laboratory, and environmental garden areas. The water association 17 obtains its water from three wells completed in the Catahoula Formation at a location 6 mi 18 (10 km) to the east -northeast of GGNS. The amount of water supplied to GGNS by the water 19 association is estimated to be 286,740 gal/yr (108.5 m 3/yr) (Entergy 2011a). 20 2.2 Surrounding Environment 21 GGNS is located in Claiborne County, Mississippi, on the east bank of the Mississippi River, 22 approximately 25 mi (39 km) south-southwest of Vicksburg, Mississippi. The site is bounded by 23 the Mississippi River on the west. The western half of the site lies in the Mississippi River 24 floodplain . This portion of GGNS has generally level topography, with elevations varying from 25 55 to 75 ft (16.7 to 22.8 m) above mean sea level (MSL) (Figure 2-7). This area also contains 26 Hamilton and Gin Lake

s. These oxbow lakes were once a channel of the Mississippi River.

27 They have an average depth of approximately 8 to 10 ft (2.4 to 3 m). The reactor building and 28 most of the associated facilities are located in the eastern half of the site. This portion of GGNS 29 is separated from the lowland plain by steep bluffs that trend north -south through the middle 30 portion of the site. The topography in the upland area rises from the floodplain as rough, 31 irregular bluffs, with steep slopes and deep -cut stream valleys and drainage courses. 32 The surface topography in the upland area ranges from 80 to 200 ft (24 to 61 m) above MSL. 33 A 6-mile radius from the center of the power block location (Figure 2-2) includes a portion of 34 Claiborne County, Mississippi, on the east side of the Mississippi River and Tensas Parish, 35 Louisiana, on the west side of the Mississippi River. The nearest incorporated community is the 36 City of Port Gibson, which has an estimated population of less than 1,600 people located about 37 6 mi (9 km) southeast of the site. The Grand Gulf Military Park, a Mississippi State park, 38 borders part of the north side of the property. The region surrounding GGNS consists mainly of 39 forest and agricultural lands (Entergy 2011a). 40 Affected Environment 2-15 Figure 2-6. GGNS Upland Complex Aquifer Permitted Wells 1 Source: Modified from Entergy 2011a 2 Affected Environment 2-16 Figure 2-7. Topographic Map of GGNS Facility 1 Source: Modified from GGNS 2003 2 2.2.1 Land Use 3 The GGNS site is comprised of 2,015 ac (815 ha). The western half of the site lies in the 4 Mississippi River floodplain and is mostly undeveloped. The eastern half of the site contains the 5 power block and support facilities (buildings, parking lots, and roads). A 2 ac (1 ha) 6 Affected Environment 2-17 privately-owned residential property is located in the southwest sector of the site and is totally 1 surrounded by the GGNS site property boundary. No other industrial, commercial, institutional, 2 or residential structures are on the site other than a private hunting lodge in the extreme 3 southwest corner. Public access is allowed to parts of the site for recreational purposes 4 (NRC 2006). 5 The immediate area surrounding GGNS is enclosed by a security fence shown in Figure 2-3. 6 Road access to GGNS is through a security gate by a two -lane road connecting to Grand Gulf 7 Road, north of the plant, and from Bald Hill Road on the east and south. The site also can be 8 accessed to the west from a barge slip on the Mississippi River. No active railways traverse the 9 site. Railways constructed for GGNS construction have been abandoned. One 10 county-maintained road runs through the GGNS site. Bald Hill Road cuts through the 11 south-southeast, south, south-southwest, and southwest sectors of the site. Another road 12 (unpaved) traverses the GGNS site property in the north, north -northwest, northwest, 13 west-northwest, and west sectors, providing access to the two lakes on the property. Two 14 transmission lines traverse the eastern edge of the site. 15 The immediate area of GGNS is rural and largely undeveloped or agricultural. Nearby land 16 across the Mississippi River in Louisiana is almost entirely agricultural land. Notable manmade 17 features within a 6 -mi (10-km) radius of GGNS (see Figure 2-2) include several Civil War 18 monuments and historic plantations around the town of Port Gibson. The Port of Claiborne is 19 located 2.2 mi (3.5 km) southwest of GGNS at river mile (RM) 404.8 of the Mississippi. 20 Nearby communities include the small community of Grand Gulf, about 1.6 mi (2.7 km) north, 21 the town of Port Gibson, approximately 6 mi (10 km) southeast; the city of Vicksburg, 25 mi 22 (40 km) north; and the city of Natchez, 37 mi (60 km) southwest. Several other small towns are 23 located in the surrounding area in Mississippi and Louisiana. Alcorn State University 24 (enrollment 3,252, fall 2011) is located 10.5 mi (17 km) southwest of GGNS. The nearest 25 occupied residence is 0.83 mi (1.3 km) east of GGNS. Prominent features of the surrounding 26 area, out to 50 mi (80 km), are shown in Figure 2-1 (Entergy 2011a). 27 2.2.2 Air Quality and Meteorology 28 GGNS is located on the east bank of the Mississippi River in Claiborne County in southwestern 29 Mississippi (NRC 2006a). The site is located approximately 150 mi (240 km) from the coast of 30 the Gulf of Mexico, which has a moderating effect on the climate. During most of the year, the 31 dominant air mass in the region is maritime tropical. As a result, the climate of the region is 32 significantly humid during most of the year, with long, warm summers and short, mild winters. 33 Occasional cold spells are associated with outbreaks of continental polar air but are usually of 34 short duration. In summer, temperatures above 100 F (38 C) are infrequent and extended 35 periods of very hot temperatures in the summers are rare. The location and seasonal intensity 36 of the Bermuda High, which is a semi -permanent area of high pressure, can dominate an entire 37 season in Mississippi (NCDC 2012a). 38 The nearby terrain consists mainly of forest and agricultural lands. The Louisiana side of the 39 Mississippi River is typically a flat alluvial plain, while the Mississippi side is typically upland and 40 rolling, forested hill country. These terrain features do not appreciably influence the local 41 climate around the GGNS site (NRC 2006a). 42 The area around the site is characterized by light winds. Based on 2006 -2011 wind 43 measurements taken at two levels at GGNS, average wind speeds are about 4.3 mph (1.9 m/s) 44 at the lower level (a height of 33 ft (10 m)) and 8.3 mph (3.7 m/s) at the higher level (a height of 45 162 ft [50 m]) (GGNS 2012a, GGNS 2012c), as shown in Figure 2-8. During the same period, 46 highest wind speeds of 22.7 mph (10.1 m/s) and 34 .1 mph (15.2 m/s) were recorded at the 47 Affected Environment 2-18 lower and higher levels, respectively. Seasonal average wind speeds at both levels are highest 1 in winter and about 50 percent higher than the lowest in summer. Although not prominent, 2 prevailing wind directions are from the northeast (about 9.2 percent of the time) at the lower 3 level and from the southeast (about 11.6 percent of the time) at the higher level. At the lower 4 level, winds from the northeast and southeast quadrants are far more frequent than winds from 5 the northwest and southwest quadrants. However, at the higher level, winds from the southeast 6 are far more frequent than winds from the three other quadrants, which are equally distributed. 7 By season, prevailing wind directions at the lower level are south in spring, northeast in summer 8 and fall, and north in winter. In contrast, prevailing wind directions at the higher level swing from 9 southeast to south -southwest throughout the year. The wind patterns at the higher level reflect 10 the regional wind patterns, while those at the lower level seem to be influenced by local 11 topography and nearby vegetation. 12 The long-term (48 years) annual average temperature at Jackson International Airport, which is 13 located about 60 mi (96.5 km) east-northeast of GGNS, was 64 .7 F (18.2 C) (NCDC 2012b). 14 During these years, monthly average temperatures ranged from 45.7 F (7.6 C) in January to 15 81.8 F (27.7 C) in July. From 1971 -2000, the average number of days with maximum 16 temperatures greater than or equal to 90 F (32.2 C) was about 84. In contrast, about 46 days 17 had minimum temperatures at or below freezing, and none of the days had minimum 18 temperatures below 0 F (-17.8 C). During the last 47 -year period, the highest temperature, 19 107 F (41.7 C), was reached in August 2000, and the lowest, 2 F (-16.7 C), in January 1985. 20 Based on 2006 -2011 measurements at GGNS, average temperature with an annual average of 21 64.9 F (18.3 C) and monthly averages ranging from 47.0 F (8.3 C) in January and 80.3 F 22 (26.8 C) in August are similar to those at the Jackson International Airport. For the 2006 -2011 23 period, the lowest and highest temperatures recorded at GGNS were 17.4 F (-8.1 C) and 99.7 24 F (37.6 C), respectively (GGNS 2012a, GGNS 2012c). 25 Mississippi, along with other coastal states along the Gulf of Mexico, is situated in one of the 26 wettest regions in the United States. Based on data from 1971 -2000, the annual average 27 precipitation at Jackson International Airport was about 55.95 in. (142 cm) (NCDC 2012b). 28 Annually, about one third of the days (about 110 days) experienced a measurable precipitation 29 (0.01 in. [0.025 cm] or higher). Precipitation is fairly well -distributed throughout the year, with 30 monthly precipitation ranging from 3.23-5.98 in. (8.20-15.19 cm). In general, monthly 31 precipitation is lower from May through October, and higher from November through April (with 32 the exception of February). At GGNS, the annual average precipitation for 2006 -2011 was 33 about 49.63 in. (126.1 cm) and ranged from 38.43 -58.50 in. (97.6-148.6 cm). For the same 34 period, the annual average precipitation and monthly precipitation patterns at the site are similar 35 to those in Jackson, Mississippi (GGNS 2012a, GGNS 2012c ). Snow in this area starts as early 36 as November and continues as late as April. Most of the snow falls from December through 37 March, with a peak in January that accounts for about 60 percent of snowfalls. The annual 38 average snowfall at the Jackson International Airport is about 0 .9 in. (2.3 cm) (NCDC 2012b). 39 Affected Environment 2-19 Figure 2-8. GGNS Wind at 33 -ft (10-m) and 162 -ft (50-m), 2006-2011 (GGNS 2012) 1 The 30-year (1971 -2000) relative humidity has an annual average of about 75 percent and 2 diurnal variation from 58 percent at 12 p.m. to 91 percent at 6:00 a.m. Hourly average relative 3 humidity ranges from 53 percent at 12 p.m. in April to 95 percent at 6:00 a.m. in August. For 4 each hour, monthly variations in relative humidity are relatively small. When the relative 5 humidity is near 100 percent, small water droplets (fog) form in the atmosphere and degrade 6 visibility. At Jackson, heavy fog, defined as visibility of 1/4 mile (0.4 km) or less, occurs about 7 Affected Environment 2-20 20 days per year based on the last 48 years of data. Heavy fog is more frequent in winter 1 months than in summer months, with the lowest of 0.8 days in June and the highest of about 2 2.9 days in December (NCDC 2012b). 3 Severe weather events, such as floods, hail, high winds and thunderstorm winds, snow and ice 4 storms, tornadoes, and hurricanes have been reported for Claiborne County (NCDC 2012c). 5 Other significant weather can be associated with these events. For example, lightning, hail, and 6 high winds frequently occur with thunderstorms, and tornadoes can occur with both 7 thunderstorms and hurricanes (NRC 2006a). 8 Based on the data for the last 48 -year period, thunderstorms occur about 67.3 days per year at 9 Jackson (NCDC 2012b). Thunderstorms are least frequent in winter (the lowest of 2.3 days in 10 December) and most frequent in summer (the highest of 12.7 days in July). In the warmer 11 season, prevailing southerly winds provide humid, semitropical conditions often conducive to 12 creating afternoon thunderstorms. Thunderstorms sometimes are accompanied by high winds, 13 mostly occurring from March through June. The highest recorded thunderstorm wind speed of 14 about 100 mph (45 m/s) occurred in April 1956 (NCDC 2012c). 15 Since 1999, 13 floods were reported in Claiborne County, 11 of which were classified as flash 16 floods (NCDC 2012c). In Mississippi, the flood season is from November through June 17 (coincident with the period of greatest rainfall), with peaks in March and April, but flooding is 18 also associated with persistent thunderstorms in summer and tropical cyclones in late summer 19 or early fall (NCDC 2012a). 20 Tornadoes occur frequently in Mississippi, many of which are violent. Based on 1991 -2010 21 data, Mississippi is in the higher range among the U.S. states in terms of average number of 22 tornadoes per unit area and average number of strong -violent (on the enhanced Fujita scale of 23 EF3 to EF5) tornadoes per unit area (NCDC 2012d). From 1957 to March 2012, a total of 24 29 tornadoes were reported in Claiborne County, mostly occurring in non -summer months with 25 a peak of 6 tornadoes in November (NCDC 2012c). Magnitudes of tornadoes for 26 pre-2006 years are not available but, since 2006, the worst tornado in Claiborne County was an 27 EF2 reported in March 2012. Historically, a tornado struck the GGNS site shortly after 28 11:00 p.m. on April 17, 1978, when two GGNS units were under construction (NRC 2006b). 29 The damage path at the plant site was approximately 1,500 -1,800 ft (457-549 m) wide, and the 30 highest onsite wind speeds were estimated to be in the 125 -150 mph (56-67 m/s) range. The 31 collapse of construction cranes caused major damage to the power plant facility; high winds 32 also extensively damaged the switchyard installation (NRC 2006a). 33 Tropical cyclones strike the Gulf Coast along the Louisiana and Mississippi coastlines with 34 expected return periods of 7 to 14 years for any hurricane and 20 to 34 years for a major 35 hurricane (Category 3 or higher) passing within 50 nautical miles (57.5 mi or 92.6 km) 36 (Blake et al. 2011). In general, impacts due to high winds from hurricanes include loss of life 37 and property damage but are limited mainly to the coastal areas. Most of these high winds are 38 weakened by passage over land and could cause rain damage to crops and considerable 39 flooding of inland areas (NCDC 2012a). Since 1851, 64 tropical cyclones have passed within 40 100 mi (161 km) of the GGNS site, 14 of which were classified as hurricanes (CSC 2012). 41 Among the 14 hurricanes, the strongest ever recorded were 3 Category 3 hurricanes: 1 not 42 named (1909), Camille (1969), and Elena (1985). 43 2.2.2.1 Air Quality 44 The Air Division of MDEQ is the regulatory agency whose primary responsibility is to ensure that 45 air quality within Mississippi is protective of public health and welfare. MDEQ is charged with 46 controlling, preventing, and abating air pollution to achieve compliance with air emission 47 Affected Environment 2-21 regulations pursuant to the Mississippi Air and Water Pollution Control Act, applicable 1 regulations promulgated by the EPA, and the Federal Clean Air Act (MDEQ 2012a). 2 A facility is defined as a "major" source if it has the potential to emit 100 tons (90.7 metric tons) 3 or more per year of one or more of the criteria pollutants, or 10 tons (9.07 metric tons) or more 4 per year of any of the listed hazardous air pollutants (HAPs), or 25 tons (22.7 metric tons) or 5 more per year of an aggregate total of HAPs. Major sources are subject to Title V of the Clean 6 Air Act (CAA) (42 U.S.C. 7401 et seq.), which standardizes air quality permits and the permitting 7 process across the United States. Permit stipulations include source -specific emission limits, 8 monitoring, operational requirements, recordkeeping, and reporting. A "synthetic minor" (or 9 "conditional major") source has the potential to exceed major source emission thresholds but 10 avoids major source requirements by accepting Federally enforceable permit conditions limiting 11 emissions below major source thresholds. The "small" (or "minor") source has no potential for 12 exceeding major source emission thresholds. 13 GGNS has the following sources of criteria pollutants and HAPs (Entergy 2011a; GGNS 2008): 14 (1) combustion sources: standby emergency diesel generators, fire water pump diesel engines, 15 the Energy Services Center diesel generator, the Operations Support Center diesel generator, 16 diesel start engines, water well diesel engine, outage equipment, and a telecommunications 17 emergency diesel generator; (2) bulk material storage tanks

diesel, gasoline, lube oil, hydraulic 18 oil, and used oil tanks; (3) other sources, such as: natural draft and auxiliary cooling towers, 19 standby service water cooling towers, and sand blasting/painting; and (4) miscellaneous 20 sources, such as: small diesel generators, welding, hand

-held equipment, and laboratory hoods. 21 GGNS is classified as a "synthetic minor" source (air permit number 0420 -00023) (GGNS 2008). 22 Although GGNS may periodically use a portable auxiliary boiler or generator(s) during power 23 outages, nonradioactive combustion-related gaseous effluents result primarily from testing and 24 preventive maintenance of emergency generators and diesel pumps operating on an 25 intermittent basis. To comply with the National Ambient Air Quality Standards (NAAQS) and to 26 ensure that potential air quality impacts are maintained at minimal levels, the MDEQ governs 27 the discharge of regulated pollutants by limiting operational run times and sulfur limits stipulated 28 in the operating permit. GGNS reports operating hours for selected equipment to show 29 compliance with permit limitations, but it has no requirements to report annual emissions 30 inventory data to the MDEQ. Continuous emission sources at the GGNS site include cooling 31 towers, which emit particulate matter as drift. The GGNS air permit does not require reporting 32 of cooling tower operating hours. 33 Air emission sources at GGNS emit criteria pollutants, volatile organic compounds (VOCs), and 34 HAPs into the atmosphere. Maximum allowable emissions from the entire facility, in 35 accordance with operating permit requirements, are presented in Table 2-1, which includes air 36 emissions from all stationary combustion and cooling tower sources at the site (GGNS 2008). 37 Because emission sources are operating well below the maximum operating hours specified in 38 the permit, actual emissions of criteria pollutants, VOCs, and HAPs are typically well below the 39 maximum allowable emissions for a "synthetic minor" source. From 2006-201 1 , there have 40 been no regulatory notices of violation issued to GGNS, based on a review of records 41 associated with the air permit (Entergy 2011a). 42 As shown in Table 2-1, annual emissions for greenhouse gases (GHGs), which include those 43 from stationary and mobile sources, are presented in terms of carbon dioxide equivalent (CO2e). 44 "Carbon dioxide equivalent" adjusts for different global warming potentials for different GHGs . 45 Total annual GHG emissions from GGNS were estimated to be about 5,980 tons CO2e 46 (5,425 metric tons CO2e) in 2011 (EPA 2011; GGNS 2012b), which is well below EPA's 47 mandatory reporting threshold of 25,000 metric tons CO2e per year (74 FR 56264). GGNS 48 Affected Environment 2-22 emits GHGs such as CO 2 , methane (CH 4), and nitrous oxide (N 2O) from combustion sources. 1 Additionally, GGNS uses GHGs such as hydrofluorocarbons (HFCs) in the two plant cooling 2 water chillers as refrigerants and sulfur hexafluoride (SF

6) in three electrical disconnect 3 switches. GGNS does not use perfluorocarbons (PFCs).

4 Table 2-1. Permitted Maximum Allowable Emission Limits for 5 Criteria Air Pollutants and Volatile Organic Compounds (VOCs)(a) 6 and Estimated Annual CO 2e Emission Rate at GGNS 7 Pollutant(b) Emission Limits and CO2e Emission Rate (lb/hr) (tons/yr) CO 225.03 25.17 NO x 850.41 98.18 PM10 42.07 68.73 SO 2 264.13 26.44 VOCs 24.80 12.94 CO2e -(c) 5,980 (5,425)(d) (a) Estimated based on maximum operating hours specified for permitted sources, including stationary combustion sources and cooling towers.

(b) CO = carbon monoxide; CO 2e = carbon dioxide equivalent; NO x = nitrogen oxides; PM 10 = particulate matter with an aerodynamic diameter of  10 m; SO 2 = sulfur dioxide; and VOCs = volatile organic compounds.
(c) A hyphen denotes that the data are not available.
(d) Values in parentheses are in metric tons carbon dioxide equivalent.

Source: EPA (2011); GGNS (2008); GGNS (2012b). Under the CAA, EPA has set NAAQS for pollutants considered harmful to public health and the 8 environment (40 CFR Part 50). NAAQS are established for criteria pollutants

carbon 9 monoxide (CO); lead (Pb); nitrogen oxides (NO x); particulate matter with an aerodynamic 10 diameter of 10 microns or less and 2.5 microns or less (PM 10 and PM2.5, respectively);

11 ozone (O 3); and sulfur dioxide (SO

2) (EPA 2012a). The CAA established two types of NAAQS:

12 primary standards to protect public health, including sensitive populations, such as asthmatics, 13 children, and the elderly; and secondary standards to protect public welfare, including protection 14 against decreased visibility and damage to animals, crops, vegetation, and buildings. Individual 15 states can have their own State Ambient Air Quality Standards (SAAQS), but SAAQS must be 16 at least as stringent as the NAAQS. If a state has no standard corresponding to one of the 17 NAAQS, or the SAAQS is not as stringent as the NAAQS, then the NAAQS apply. Except for 18 odor, Mississippi has adopted the NAAQS (MDEQ 2012b), as presented in Table 2-2. 19 Affected Environment 2-23 Table 2-2. National Ambient Air Quality Standards (NAAQS)(a),(b) 1 Pollutant (c) Averaging Tim e NAAQS Value Type(d) CO 1-hour 35 ppm P 8-hour 9 ppm P Pb Rolling 3-month average 0.15 µg/m 3 P, S NO 2 1-hour 100 ppb P Annual (arithmetic average) 53 ppb P, S O 3 8-hour 0.075 ppm P, S PM10 24-hour 150 µg/m 3 P, S PM2.5 24-hour 35 µg/m 3 P, S Annual (arithmetic average) 15 µg/m 3 P, S SO 2 1-hour 75 ppb P 3-hour 0.5 ppm S (a) Except for odor, the ambient air quality standards for Mississippi are the primary and secondary NAAQS as duly promulgated by EPA. (b) Refer to 40 CFR Part 50 for detailed information on attainment determination and reference method for monitoring.

(c) CO = carbon monoxide; NO 2 = nitrogen dioxide; O 3 = ozone; Pb = lead; PM2.5 = particulate matter with an aerodynamic diameter of 2.5 m; PM 10 = particulate matter with an aerodynamic diameter of  10 m; and SO 2 = sulfur dioxide.
(d) P = primary standards, which set limits to protect public health, including the health of "sensitive" populations such as asthmatics, children, and the elderly; S = secondary standards, which set limits to protect public welfare including protection against decreased visibility, damage to animals, crops, vegetation, and buildings.

Sources: EPA (2012c); MDEQ (2012b). EPA designates areas that meet NAAQS as "attainment areas." Areas that exceed NAAQS are 2 designated as "nonattainment areas." Areas that previously were nonattainment areas but 3 where air quality has improved to meet the NAAQS are redesignated "maintenance areas," 4 subject to an air quality maintenance plan. Claiborne County, Mississippi, where GGNS is 5 located, is part of the Mobile (Alabama) -Pensacola-Panama City (Florida) -Southern Mississippi 6 Interstate Air Quality Control Region (AQCR) (40 CFR 81.68), which includes 3 southwestern 7 counties in Alabama, 10 northwestern panhandle counties in Florida, and 37 southern counties 8 in Mississippi. The area across the Mississippi River from the site is in the Monroe 9 (Louisiana) -El Dorado (Arkansas) Interstate AQCR (40 CFR 81.92). The EPA has designated 10 all of the counties in these AQCRs adjacent to the GGNS site as in compliance with the NAAQS 11 (40 CFR 81.301, 81.304, 81.310, 81.319, and 81.325). Mississippi is in attainment with primary 12 and secondary NAAQS for all criteria pollutants, except De Soto County which is located about 13 200 miles (322 km) north-northeast of GGNS and part of which was recently designated as a 14 marginal nonattainment area for the 2008 8 -hour ozone standard. Outside of Mississippi, the 15 nearest nonattainment areas include the Birmingham area in Alabama for PM2.5 and the 16 Houston-Galveston-Brazoria area in Texas for 8 -hour ozone (O 3), both of which are located 17 about 240 mi (386 km) east-northeast and west -southwest, respectively, of GGNS. The nearest 18 maintenance area is the Baton Rouge area in Louisiana for 8 -hour O 3, which is located about 19 90 mi (145 km) south of GGNS. 20 Affected Environment 2-24 In recent years, three revisions to NAAQS have been announced. Effective January 12, 2009 , 1 EPA revised the Pb standard from a calendar -quarter average of 1.5 3 to a rolling 3-month 2 average of 0.15 3 (73 FR 66964). Effective April 12, 2010, EPA established a new 1 -hour 3 primary NAAQS for NO 2 at 100 ppb (75 FR 6474) and effective August 23, 2010, EPA 4 established a new 1 -hour primary NAAQS for SO 2 at 75 ppb (75 FR 35520). Notwithstandin g 5 these revisions to the NAAQS, the attainment status for Claiborne County will not be affected 6 because concentration levels at nearby monitoring stations are relatively low compared to the 7 NAAQS and generally are trending downward as discussed below. 8 Through operation of a network of air monitoring stations, MDEQ evaluates compliance with 9 NAAQS. The MDEQ monitors all criteria air pollutants, except CO and Pb. Monitoring for CO 10 and Pb was discontinued because the measured concentrations were much lower than the 11 NAAQS limits. Currently, no air monitoring data are available in Claiborne County 12 (MDEQ 2011c), but air monitoring stations exist in nearby Adams County where the city of 13 Natchez is located, and Hinds County where Jackson is located. Eight -hou r O 3 and PM2.5 data 14 collected in these counties indicated a general downward trend for these pollutants from 15 2001-2010. Only Jackson County, which is located in the southeastern corner of the State and 16 abuts the Gulf of Mexico, monitors NO 2 and SO 2 in Mississippi and also exhibits a general 17 downward trend during the same period. As a result, Mississippi meets all NAAQS based on air 18 monitoring data scattered around the State. 19 While the NAAQS place upper limits on the levels of air pollution, Prevention of Significant 20 Deterioration (PSD) regulations (40 CFR 52.21) place limits on the total increase in ambient 21 pollution levels above established baseline levels for SO 2, NO 2, PM 10, and PM2.5, thus 22 preventing "polluting up to the NAAQS." These allowable increments are smallest in Class I 23 areas, such as national parks and wilderness areas, and less limiting in other areas. A major 24 new source or modification of an existing major source located in an attainment or unclassified 25 area must meet stringent control technology requirements. As a matter of policy, EPA 26 recommends that the permitting authority notify the Federal Land Managers (FLMs) when a 27 proposed PSD source will be located within 62 mi (100 km) of a Clas s I area. If the source's 28 emissions are large, EPA recommends that sources beyond 62 mi (100 km) be brought to the 29 attention of the FLMs. The FLMs then become responsible for determin ing whether the 30 source's emissions could have an adverse effect on air quality related values (AQRVs), such as 31 scenic, cultural, biological, and recreational resources. There are no Class I areas in 32 Mississippi and none of the Class I areas in other nearby states are located within the 33 aforementioned 62 -mi (100-km) range. The nearest Class I area is Breton Wilderness Area in 34 Louisiana managed by the U.S. Fish and Wildlife Service (40 CFR 81.412), which is located 35 about 186 mi (300 km) southeast of GGNS. Considering the locations of and intervening terrain 36 features to any nearby Class I areas around GGNS, prevailing wind directions, distances from 37 GGNS, and the minor nature of air emissions from GGNS, there is little likelihood that activities 38 at GGNS would adversely impact air quality and AQRVs in this Class I area. 39 GGNS has a primary and backup tower for monitoring and collecting meteorological data. The 40 primary tower is 162 ft (50 m) high. It has instrumentation at heights of 162 ft (50 m) and 33 ft 41 (10 m). The backup tower is 33 ft (10 m) high. Along with an instrument shack , these towers 42 are located in an open area surrounded by tall vegetation about 0.9 mi (1.4 km) north-northwest 43 of the reactor control building. The backup tower and instrument shack are located about 300 44 and 430 ft (91 and 131 m), respectively, north -northeast of the primary tower. Onsite 45 meteorological monitoring began in March 1972. The original meteorological monitoring system 46 was replaced in December 2000. This current monitoring system will continue to serve for the 47 period of extended operation, with no major changes or upgrades anticipated (GGNS 2010b). 48 Affected Environment 2-25 The primary tower monitors wind speed, wind direction, and ambient temperature along with 1 differential temperature and data used to determine atmospheric stability collected at both 162 ft 2 (50 m) and 33 ft (10 m). Relative humidity data is collected only at 33 ft (10 m), while 3 precipitation data using a tipping bucket rain gauge is collected at the ground level. 4 Meteorological data from the primary tower is supplemented with those from the backup tower . 5 The backup tower monitors wind speed, wind direction, ambient temperature, and atmospheric 6 stability data. GGNS uses data processing procedures for analyzing meteorological data. 7 Observations are averaged to 15 -minute and hourly values and are made available to the 8 GGNS plant computer and then this information is transmitted to the control room. Information 9 from both towers is provided to the reactor control room (GGNS 2010b). 10 The data processing procedures for GGNS meteorological data involve three basic steps: 11 (1) data collection (recorded in digital form); (2) data editing and consolidation; and (3) data 12 analysis. For steps (2) and (3), computer software has been developed to process the collected 13 data. The plant data computer receives data measurements at least every 10 seconds. Data is 14 recorded each time a value varies by a preset amount. Each piece of data is checked to assure 15 it is between the minimum and maximum instrument limits. This quality indication and the time 16 are recorded with each value. An average is calculated every 15 minutes and each hour. The 17 quality of the samples is reflected in the quality of the average. This quality indication and the 18 time the average was calculated are recorded with each value. The meteorological data, for 19 which readings are available every 10 seconds or less, a 15-minute average, and an hourly 20 average, are relayed to the main control room by the plant computer (GGNS 2010b). 21 Based on the NRC's Regulatory Guide 1.23, "Meteorological Monitoring Programs for Nuclear 22 Power Plants," meteorological instruments should be inspected and serviced at a frequency that 23 will ensure data recovery of at least 90 percent annual ly. GGNS has established procedures for 24 the inspection and maintenance of the onsite meteorological system. Routine inspections are 25 made to ensure proper operation of equipment and that no damage to the towers, instrument 26 shack, or any other structure or equipment has occurred. Semi -annual visual inspections of the 27 tower and equipment are made to determine the conditions of sensors, cabinets, wiring, 28 structures, and individual components. Semi -annual checks for proper instrumentation readings 29 are performed. All calibrations at the site are performed in compliance with the 30 recommendations of Regulatory Guide 1.23. Based on the 2006 -2011 onsite meteorological 31 data, the data recovery rates for all meteorological parameters from the meteorological 32 monitoring system at GGNS were over 90 percent. 33 2.2.3 Geologic Environment 34 This section describes the current geologic environment of GGNS and vicinity, including 35 topography, geology, soils, and seismic conditions. 36 2.2.3.1 Topography and Geol ogy 37 GGNS is bounded by the Mississippi River on the west. The western half of the site is called 38 the lowland plain and lies in the floodplain of the Mississippi River. This portion of GGNS has a 39 generally level topography, with elevations that vary from 55 -75 ft (16.7-22.8 m) above MSL 40 (Figure 2-7). This area also contains Hamilton and Gin Lake s. These oxbow lakes were once 41 a channel of the Mississippi River. They have an average depth of approximately 8 -10 ft (2.4-42 3 m). 43 The reactor building and most of the associated facilities are located in the eastern half of the 44 site, which is called the upland area. The upland area is separated from the lowland plain by 45 steep bluffs that trend north -south through the middle portion of the site. The topography in the 46 upland area rises from the floodplain as rough, irregular bluffs, with steep slopes and deep -cut 47 Affected Environment 2-26 stream valleys and drainage courses. The surface topography in the upland area ranges from 1 80-200 ft (24-61 m) above MSL. Most of the facilities are located about 132.5 ft (40.3 m) 2 above MSL. The upland area has two drainage channels that trend east -west. One drainage 3 channel (Stream A) is north of the reactor and site facilities and the other (Stream B) is south of 4 the main plant complex. 5 The lowland plain is underlain by the Mississippi River Alluvium. At the land surface, it consists 6 of a layer of clay and silt that overlies interbedded layers of stream -deposited sand, gravel, silt, 7 and clay. The alluvium generally ranges from 95 -182 ft (29-55 m) thick. On GGNS , t he 8 lowland plain extends from the Mississippi River to the bluffs of the upland area. 9 The upland area is underlain by loess deposits. The loess deposits are made up of about 10 75 ft (23 m) of fine -grained silt deposited by wind and comprise the bluffs that rise above the 11 floodplain of the Mississippi River. The loess deposits are underlain by the Upland Complex , 12 which is comprised of two stream -deposited terraces, the Upland Complex Alluvium and the 13 Upland Complex Old Alluvium. These terrace deposits are thickest near the bluffs (up to 14 150 ft (46 m) thick) and thinnest near the power block area (about 40 ft (12 m) thick) 15 (GZA GeoEnvironmental Inc. 2009). The Upland Complex Alluvium is typically comprised of 16 sands and clayey, silty sands, while the Upland Complex Old Alluvium is comprised of clayey, 17 silty sands with coarse grained sands and gravels. Neither upland complex unit is found west of 18 the bluffs of the upland area, as they have been removed by the erosive activity of the 19 Mississippi River and replaced by Mississippi River Alluvium. 20 The Upland Complex Alluvium, the Upland Complex Old Alluvium, and the Mississippi Alluvium 21 are all underlain by the Catahoula Formation. The Catahoula Formation underlies the entire 22 GGNS property. It consists of lenticular deposits of sand, clayey silt, and sandy -silty clay. The 23 sand layers are predominantly fine -grained and range in thickness from a few inches to more 24 than 100 ft (30 m) thick. 25 At the site, the Catahoula Formation is underlain by the Bucatunna Formation (Entergy 2011a). 26 It is composed of clay and is about 100 -ft (30-m) thick at the site. Underneath the Bucatunna 27 Formation is the Glendon Formation, which is made up of beds of limestone. Figures 2-9 , 28 2-10, and 2-11 contain generalized geologic cross-sections that illustrate the stratigraphy 29 across the site from east to west. 30 2.2.3.2 Soils 31 U.S. Department of Agriculture (USDA 2012) soil unit mapping identifies the area of the site on 32 the Mississippi River alluvial valley (mostly Bowdre soil) as being made up of soils that are 33 somewhat poorly drained, frequently flooded, and in locations where the water table is near the 34 land surface. The soil is comprised of clayey alluvium over loamy alluvium. In areas that 35 underlie surface drainage areas (Adler silt loam), soils are moderately well drained and 36 occasionally flooded. These soils are made up of silt loam. The upland area of the site is 37 largely made up of soils that developed in loess (mostly Memphis and Natchez silt loams). The 38 depth to the water table for these soils generally is in excess of 6 ft (1.8 m). They are well 39 drained and not prone to flooding. Their typical texture is silty loam to silty clay loam. 40 2.2.3.3 Seismic Setting 41 The region is characterized by extremely low rates of earthquake activity. The rate of 42 earthquake activity in the Gulf Coastal Plain is among the lowest in the United States (Entergy 43 2011a). 44 The earliest recorded and strongest earthquake (magnitude 4.6) within Mississippi occurred at 45 Charleston, Mississippi, on December 16, 1931. In the area of maximum intensity, the walls 46 Affected Environment 2-27 and foundation of an agricultural high school cracked and several chimneys were thrown down. 1 The shock was perceptible over a 65,000 square mile area, including the northern two -thirds of 2 Mississippi and adjacent portions of Alabama, Arkansas, and Tennessee. Two earthquakes 3 greater than a magnitude 3.5 occurred within Mississi ppi (USGS 2012a, 2012 b) between 1976 4 and 2003. During that same time period, neighboring Louisiana had one earthquake greater 5 than a magnitude 3.5. 6 Figure 2-9. Location Map for Geologic Cross -Sections A-A' and B-B' 7 Source: Modified from Entergy 2011a 8 Affected Environment 2-28 Figure 2-10. Geologic Cross Section A-A' 1 Source: Modified from Entergy 2011a 2 Affected Environment 2-29 Figure 2-11. Geologic Cross Section B-B' 1 Source: Modified from Entergy 2011a 2 Affected Environment 2-30 Although the number of earthquakes reported within Mississippi's boundaries is small, the State 1 has been affected by numerous shocks located in neighboring states. In 1811 and 1812, a 2 series of earthquakes (maximum magnitude 7.7) occurred, near New Madrid, in southeast 3 Missouri and was felt as far south as the Gulf Coast. This series of earthquakes caused the 4 banks of the Mississippi River to cave in as far south as Vicksburg, more than 300 mi (483 km) 5 from the epicentral region. While earthquakes still occur in the New Madrid area, it is far 6 enough away that only a very small probability exists of experiencing damaging earthquake 7 effects in the area of GGNS (FEMA 2012). 8 The geologic setting and modern tectonic framework suggest that the earthquake hazard for the 9 region will remain low for the foreseeable future. There have been no active faults found within 10 a 5 mi (8 km) radius of the site (Entergy 2011a ). 11 2.2.4 Surface Water Resources 12 With an average discharge of 593,000 cfs (16,792 m 3/s), the Mississippi River is the largest river 13 in the United States. The western boundary of the site begins at the river's eastern bank. At 14 the site, the Mississippi River is about 0.5 mi (0.8 km) wide at low flow and about 1.4 mi 15 (2.3 km) wide during a typical annual high -flow period. The lowland plain between the river and 16 the upland area is subject to nearly annual flooding by the Mississippi River. The plain contains 17 Hamilton and Gin Lake s, which are two shallow oxbow lakes (created in a now abandoned 18 former river channel) and a small borrow pit (created during plant construction). Under 19 non-flooding conditions, watersheds that drain the upland area discharge water into Hamilton or 20 Gin Lake s. Gin Lake discharges water into Hamilton Lake through a culvert. Hamilton Lake 21 discharges into the Mississippi River (Entergy 2011a). 22 The upland area is drained by two watersheds. Watershed A is north of Watershed B. The 23 watersheds are drained by Stream A and Stream B, respectively. The estimated areas of 24 Watershed A and Watershed B are 2.94 mi 2 (7.6 km 2) and 0.68 mi 2 (1.7 km 2), respectively. 25 Water from each watershed flows through sedimentation basins before flowing into either 26 Hamilton or Gin Lakes (Figure 2-12). 27 Surface water discharges that flow to the Mississippi River from the site are permitted by the 28 MDEQ NPDES program. The current permit authorizes discharges at 11 outfalls (locations). 29 Three of the outfalls monitor discharges to surface water outside the site boundary (external 30 outfalls); eight of the outfall locations monitor discharges within the site boundary (internal 31 outfalls). 32 The three external outfalls (Outfalls 001, 013, and 014) monitor all releases to surface water 33 from GGNS. Outfall 001 is a 54 -in. (137-cm) diameter pipe that discharges in the barge slip 34 along the Mississippi River. It receives water from internal outfalls, including cooling tower 35 blowdown, standby service water leakage, the low volume waste basin, liquid radwaste, and 36 storm water. Outfall 013 is the discharge from the northwest end of Sedimentation Basin A to 37 Hamilton Lake; it includes sanitary wastewater effluent from the onsite wastewater treatment 38 plant and storm water. Outfall 014 is at the northwest end of Sedimentation Basin B. This basin 39 receives various effluents at Outfall 007 through a large concrete structure at its southeast end 40 with an approximately 20 -ft (6-m) diameter corrugated metal pipe discharging water from 41 Stream B (designed to convey storm water from the site from a 100 -year storm event). 42 Outfall 007 also receives miscellaneous wastewaters; such as heating, ventilation, and air 43 conditioning (HVAC) blowdown; air conditioner cooling water; oily waste sumps; ionic reject 44 water; and turbine building cooling water blowdown. 45 Affected Environment 2-31 Figure 2-12. GGNS Surface Water Features 1 Source: Modified from Entergy 2011a 2 Permit conditions require flow reporting at all outfalls and value reporting or monthly average 3 and/or maximum of various other parameters. Depending on the outfall, these parameters may 4 include water temperature, free available chlorine, zinc, oil and grease, total suspended solids, 5 Affected Environment 2-32 total residual chlorine, biochemical oxygen demand, and fecal coliform. Iron, arsenic, and 1 copper must be reported at some outfalls, and a range of pH (6.0 -9.0 standard units) is required 2 at several outfalls. Details are provided in GGNS's Certificate of Permit Coverage under 3 Mississippi's Baseline Storm Water General NPDES Permit (MDEQ 2010 a). The permit also 4 specifies a maximum Mississippi River water temperature increase of 5 F (2.8 C) beyond a 5 mixing zone. Thermal monitoring is required during certain low -flow river conditions. 6 The Ranney wells each have their own service water system for motor cooling. Permitted 7 discharge from each is back to the Mississippi River through an underground pipe 8 (MDEQ 2011 b). 9 In March 2011, GGNS had one EPA violation in its effluent monitoring at Outfall 007 for total 10 suspended solids (TSS) (EPA 2012 a). The violation was because of an average TSS of 11 31 mg/L, when the average limit is 30 mg/L. This was not considered a significant 12 noncompliance effluent violation. The ER (Entergy 2011a) lists several other noncompliances 13 from 2006-2010. These included three pH exceedances, a zinc exceedance, a free residual 14 chlorine exceedance, and an unauthorized discharge. 15 As described above, GGNS has an NPDES permit (MDEQ 2011a) to discharge wastewater in 16 accordance with effluent limits, monitoring requirements, and other permit conditions. Under 17 Section 401 of the Clean Water Act (CWA), an entity requiring a Federal permit for any activity 18 that may result in a discharge to navigable waters of the United States must obtain a 401 Water 19 Quality Certification from the state in which the discharge will occur to ensure that the discharge 20 complies with state water quality standards. Mississippi issued a water quality certification for 21 GGNS in 1974. In a letter dated October 17, 2011, MDEQ stated that the water quality 22 certification remains in effect as long as GGNS does not expand its footprint, increase its water 23 discharge, engage in any new activity that would trigger the need for a new certification from the 24 State, and remains in compliance with State and Federal regulations to refrain from violating the 25 State's water quality standards (MDEQ 2011 b). 26 A storm water pollution prevention plan (GGNS 2006) and a permit to discharge storm water 27 (MDEQ 2010 a) are also maintained for the site. The plan documents best management 28 practices (BMPs), potential pollutant sources, and other aspects related to storm water quality. 29 According to GGNS staff at the environmental site audit, no dredging takes place at the 30 Mississippi River barge slip or at the sedimentation basins. 31 2.2.5 Groundwater Resources 32 2.2.5.1 Mississippi River Alluvium 33 The Mississippi River Alluvium forms an aquifer underlying both the river and the lowland plain. 34 The water table in the lowland plain is at most a few feet beneath the ground surface 35 (NRC 2006 a). The Mississippi River Alluvial Aquifer is in close hydraulic connection with the 36 river. Increases or decreases in Mississippi River water levels cause changes in the direction of 37 flow in the Mississippi River Alluvial Aquifer and corresponding increases or decreases in 38 groundwater level. Usually, the alluvium discharges to the river. However, during floods, the 39 river may discharge to the aquifer. 40 This close hydraulic connection between the Mississippi River and the Mississippi River Alluvial 41 Aquifer means that the Mississippi River forms a large, effective hydraulic boundary along the 42 western boundary of the site. As a result, groundwater use, flow, and water quality west of the 43 Mississippi River are unlikely to be influenced by groundwater use, flow, and water quality east 44 of the Mississippi River (the plant side of the river). 45 Affected Environment 2-33 The GGNS cooling system uses Ranney wells to pump water from the Mississippi River Alluvial 1 Aquifer (see Section 2.1.7). Pumping from these wells induces river water to flow through the 2 alluvial aquifer to the wells. The connection between the alluvium and the river means that 3 GGNS is essentially using river water from which river water sediment has been removed 4 (filtered out by the pore spaces of the aquifer) (NRC 2006 a). 5 2.2.5.2 Perched Groundwater and the Upland Complex Aquifer 6 Some perched groundwater occurs in the loess deposits of the upland area (Entergy 2011a). 7 Because of their small area extent, size, and low production rates, the perched groundwater is 8 not considered a groundwater resource. 9 The water table occurs in the sand and gravel deposits of the Upland Complex Aquifer, which 10 underlies the loess deposits. The Upland Complex Alluvium and the Upland Complex Old 11 Alluvium form the Upland Complex Aquifer. West of the bluffs of the upland area, the Upland 12 Complex Aquifer has been removed by the erosive activity of the Mississippi River and replaced 13 by Mississippi River Alluvium. As a result, in the lowland plain, where the two aquifers are in 14 contact, the Upland Complex Aquifer is hydraulically connected to the Mississippi River Alluvial 15 Aquifer. 16 The Upland Complex Aquifer is recharged by local precipitation and the lateral movement of 17 groundwater within the Upland Complex Aquifer. Groundwater flows laterally into the southeast 18 corner of the plant property and moves in a northwest direction. From the west side of Unit 1 19 and Unit 2 power blocks, groundwater in the Upland Complex Aquifer flows west until it reaches 20 the bluffs. At that point, groundwater in the Upland Complex Aquifer flows into the Mississippi 21 River Alluvial Aquifer. From the east side of the power blocks, groundwater in the Upland 22 Complex Aquifer flows towards the northeast, until it exits the site boundary. Downward vertical 23 flow in the Upland Complex Aquifer is prevented by a thick clay layer at the top of the Catahoula 24 Formation. This clay layer has a very low permeability and is approximately 50 ft (15 m). 25 2.2.5.3 Catahoula Aquifer 26 The Catahoula Formation underlies the Mississippi River Alluvial Aquifer in the lowland plain 27 and underlies the Upland Complex Aquifer in the upland area. Sandstone layers, separated by 28 layers of siltstone or clay, transmit water in the Catahoula Formation and make up the 29 Catahoula Aquifer. The top of the Catahoula Formation contains approximately 50 ft (15 m) of 30 clay that forms an effective flow barrier, preventing the downward movement of water from the 31 Upland Complex Aquifer (NRC 2006 a) into the sands of the Catahoula Aquifer. Hydraulic 32 interconnection between the Upland Complex Aquifer and the Catahoula Aquifer has not been 33 identified in pumping well tests, monitor well water levels, or by the collection of drill -hole data. 34 The Catahoula Aquifer is fully saturated and a confined aquifer (water in a well would rise above 35 the top of the Catahoula Aquifer sands). Water in the Catahoula Aquifer is not of local origin. 36 Aquifer recharge occurs north of the site in Warren and Hinds Counties (Entergy 2011a). 37 The substructures (basements) of the plant power blocks penetrate through the loess deposits 38 and the Upland Complex Aquifer and rest on top of the Catahoula Formation. The top of the 39 Catahoula Formation is elevated in the area of the power block, forming a ridge beneath the 40 power block that is oriented northwest -southeast. The elevation of the top of the Catahoula 41 Formation generally decreases in elevation in all directions from the power block area 42 (GZA GeoEnvironmental, Inc. 2009). The thick vertical flow barrier and change in elevation of 43 the top of the Catahoula Formation and the excavation of the power block through the Upland 44 Complex Aquifer is interpreted as causing two directions of lateral groundwater flow in the 45 Upland Complex Aquifer in the power block area. 46 Affected Environment 2-34 At the site, the Catahoula Aquifer is underlain by the Bucatunna Formation (Entergy 2011a). It 1 is composed of clay and is about 100 ft (30 m) thick, forming a barrier to the downward 2 movement of water in the Catahoula Aquifer. Of the three aquifers at the site, the Catahoula 3 Aquifer is the least productive. Not only is it deeper, but the ability of the aquifer to transmit 4 water to a well is much less that the other two aquifers. No wells at the site produce water from 5 the Catahoula Aquifer or from any deeper aquifers. 6 On the lowland plain, the ancient Mississippi River eroded (cut into) the top of the Catahoula 7 Aquifer and then deposited the Mississippi River Alluvial Aquifer on top of that surface 8 (Entergy 2011a). Data from holes drilled on the lowland plain have not detected any hydraulic 9 interconnection between the Catahoula Aquifer and the Mississippi River Alluvial Aquifer. 10 However, it cannot be completely ruled out that some upper sands of the Catahoula Aquifer 11 may be hydraulically connected to the Mississippi River Alluvial Aquifer, either under the river 12 itself or under the lowland areas on either side of the river. This is because it is difficult to 13 determine how deep the Mississippi River has eroded into the top of the Catahoula in the 14 lowland plain or under the river. 15 Transmissivity is a measure of the ability of an aquifer to transmit water. It is more difficult to 16 extract water from aquifers with low transmissivity than from aquifers with high transmissivity. 17 At the site, the transmissivity of the Mississippi River Alluvium ranges from 21,500 to 18 163,500 gpd/ft (267 to 2,031 m 2/day), while the transmissivity of the Catahoula Aquifer sands 19 has an estimated transmissivity of 300 gpd/ft (3.7 m 2/day) (Entergy 2011a). The transmissivity 20 of the Catahoula Aquifer sands is so much less than the Mississippi River Alluvial Aquifer that if 21 an interconnection between the two aquifers exists, wells pumping water from the Mississippi 22 River Alluvial Aquifer would obtain their water as induced infiltration from the Mississippi River 23 rather than from upward discharge of groundwater from the Catahoula Aquifer. Furthermore, 24 should groundwater contamination enter the Mississippi River Alluvial Aquifer, it would be likely 25 to remain in the Mississippi River Alluvial Aquifer or discharge into the Mississippi River. 26 The groundwater quality in Claiborne County is generally good. Onsite groundwater quality is 27 adequate for a variety of uses. Except for less suspended sediment, the induced infiltration 28 from the operation of the GGNS Ranney wells produces water nearly identical to the water 29 quality of the Mississippi River (Entergy 2011a). Onsite Upland Complex Aquifer water quality 30 is suitable for use as potable water. Water from the GGNS Upland Complex Aquifer wells is 31 sampled as required by the Mississippi Department of Health (MDH), pursuant to the Safe 32 Drinking Water Act. County residents obtain their water from the Catahoula Aquifer. 33 Groundwater from the Catahoula Aquifer, although very hard, is suitable for potable uses. 34 Water quality generally decreases for aquifers underlying the Catahoula Formation 35 (NRC 2006 a; Entergy 2011a). 36 EPA designated the Southern Hills Aquifer, which includes the Catahoula Aquifer that underlies 37 GGNS, to be a sole -source aquifer (EPA 2012 c). The designation protects an area's 38 groundwater resource by requiring EPA to review all proposed projects within the designated 39 area that will receive Federal financial assistance. All proposed projects receiving Federal 40 funds are subject to review to ensure they do not endanger the groundwater source . As such, 41 the MDEQ's Wellhead Protection Program is working to identify and manage potential sources 42 of contamination located near public water supply wells. The Port Gibson and CS&I Water 43 Association #1 well fields are the only wellhead protection areas identified within a 6 -mi (10-km) 44 radius of the site (Entergy 2011a; MDEQ 2010 b). 45 2.2.5.4 Groundwater with elevated tritium 46 Groundwater with elevated tritium activities (above background levels) was recently found in 47 backfill material and in the Upland Complex Aquifer near the northeast side of the Unit 2 power 48 Affected Environment 2-35 block. This power block does not contain a nuclear reactor. No other radionuclides have been 1 detected above background levels in the Upland Complex Aquifer. Based on a review of 2 available data, tritium contaminated groundwater has not migrated off site (GGNS 2012 a). 3 Contamination appears to be restricted to the area near the power block. No radionuclides 4 above background levels have been detected in the Catahoula Aquifer or the Mississippi River 5 Alluvial Aquifer (Entergy 2011a). Elevated tritium levels have not been detected in the GGNS 6 potable water supply wells, or in any radiological environmental monitoring program monitoring 7 wells (GGNS 2012 a). 8 With the exception of dewatering well DW-01 and monitor well MW-07, all wells with tritium 9 activities above background levels have levels significantly below the EPA primary drinking 10 water standard for tritium (20,000 pCi/L) (40 CFR 141). Recent tritium values for DW -01 ranged 11 from 8,407 to 21,100 pCi/L and for MW -07 ranged from 7,135 to 17,404 pCi/L. DW -01 12 exceeded the EPA drinking water standard in September 2011. These wells are located close 13 together near the outer wall of the Unit 2 power block (Figure 2-13). These wells are located in 14 backfill material between the power block and the tie -back wall. The backfill material was used 15 to fill the excavation created to build the power blocks. The tie -back wall is a structure built to 16 hold up the sides of the open excavation during construction. After the power blocks were built, 17 this structure was left in place and the excavation was filled in. Outside of the tie -back wall, 18 groundwater near the Unit 2 power block is moving away from the power block toward the 19 northeast (GGNS 2012 a). 20 Elevated tritium values have not been detected in any wells located outside the site. The 21 nearest wells outside GGNS that provide water from the Upland Complex Aquifer are located 22 approximately 1 mi (1.6 km) south-southeast from the Unit 1 power block. One well provides 23 water to two residences; the other well is not being used for human consumption. These wells 24 are located in the opposite direction (i.e., upgradient), from the direction of contamination 25 migration in the Upland Complex Aquifer. CS&I Water Association

#1 provides water to the 26 majority of the rural population in the area. The closest area of concentrated groundwater 27 withdrawal is the Port Gibson municipal water system, which obtains water from the Catahoula 28 Aquifer about 5 mi (8 km) southeast of the site (Entergy 2011a

). Hydraulic interconnection 29 between the Upland Complex Aquifer and the Catahoula Aquifer has not been identified. 30 Elevated tritium levels above background have not been detected in the three onsite Upland 31 Complex Aquifer wells that supply potable water to GGNS. The wells, located near the bluffs 32 between the Mississippi River and the power blocks, are in the opposite direction from any 33 contamination moving northeast from the Unit 2 power block. These are the only drinking water 34 wells that could be affected if groundwater contamination moved westward from the power block 35 towards the Mississippi River Alluvial Aquifer. These wells are sampled annually for tritium and 36 the results are reported to the NRC. 37 In 2007, the nuclear power industry began implementing its "Industry Ground Water Protection 38 Initiative" (NEI 2007). Since 2008, the NRC has been monitoring implementation of this 39 initiative at licensed nuclear reactor sites. The initiative identifies actions to improve utilities' 40 management and response to instances in which the inadvertent release of radioactive 41 substances may result in low but detectible levels of plant -related materials in subsurface soils 42 and water. It also seeks to identify those actions necessary for implementation of a timely and 43 effective groundwater protection program. The areas of contamination were discovered as part 44 of GGNS participation in this initiative. At this time, monitoring wells have been drilled on all 45 sides of the power blocks and GGNS is monitoring them. Monitoring results from these wells 46 are reported annually to the NRC. 47 Affected Environment 2-36 Figure 2-13. Most Recent GGNS Tritium Contaminated Well Data from February 2012* 1 (*Most recent data for MW -07 is August 2011) 2 Source: Modified from GGNS 2012a 3 Affected Environment 2-37 2.2.6 Aquatic Resources 1 GGNS is located adjacent to the Mississippi River, which is part of the largest river basin in 2 North America and the third largest river basin in the world (Brown et al. 2005). GGNS lies 3 within the Lower Mississippi River, which is defined as the portion of the Mississippi River that 4 extends from the confluence with the Ohio River in Illinois to the Gulf of Mexico in Louisiana 5 (Brown et al. 2005). The site occurs within the Gulf Coastal Plain physiographic province. 6 The Lower Mississippi River has relatively high number of species, especially for fish. The high 7 species richness is in part due to the variety of habitats within the Mississippi River, as well as 8 nearby floodplain habitats hydraulically connected to the Mississippi River during flooding 9 events. Other factors that contribute to the high species diversity include the length of the river, 10 the unique habitats that the river's tributaries provide, and the connection with the Gulf of 11 Mexico, which brings marine and anadromous species into the lower reaches of the Mississippi 12 River (Brown et al. 2005). 13 2.2.6.1 Environmental Changes in the Lower Mississippi River 14 Human activities have had a large influence on the relative abundance of many species and 15 their habitat within the Mississippi River. The major activities that altered aquatic resources 16 near GGNS include: (1) efforts to control flooding and increase navigation; (2) chemical 17 contamination from runoff as a result of industrial, urban, and agricultural activities; and 18 (3) introduction of nonnative species (Brown et al. 2005). 19 To allow for ship traffic along the Mississippi River, several projects have changed the relative 20 abundance and types of habitats within the river. Beginning in 1824, the U.S. government has 21 removed snags, such as trees or tree roots, from the river. Snags provide natural habitat for 22 invertebrates that require a firm attachment site. On the other hand, revetments, which are built 23 to prevent erosion and river meandering, have increased availability of hard -surface habitats, 24 but decreased the availability of soft -surface river bank habitats. Revetments such as timber, 25 wooden or wire fences, rocks, and tires cover approximately 50 percent of the banks of the 26 Lower Mississippi River (Baker et al. 1991; Brown et al. 2005). At GGNS, articulated concrete 27 was installed on the river bank downstream of the discharge structure and barge slip to stabilize 28 the river bank (NRC 1981). 29 In addition, the U.S. Army Corps of Engineers (USACE) has artificially created cutoffs that 30 shortened the length of the river by cutting across a point bar or neck of a meander. 31 Baker et al. (1991) estimate that artificially created cutoffs have shortened the length of the 32 Lower Mississippi River by 25 to 30 percent, or approximately 500 km (310 mi). Cutoffs also 33 can increase the river speed and erosion of river banks (Baker et al. 1991). 34 Levees have been built along the Mississippi River for more than 300 years to control flooding. 35 By 1973, 29 km (18 mi) of levees lined the river near New Orleans. By 1844, levees were 36 nearly continuous up to the confluence with the Arkansas River (Baker et al. 1991). As of 2005, 37 nearly 3,000 km (1,864 mi) of levees lined the Lower Mississippi River and an additional 38 1,000 km (621 mi) of levees lined its tributaries (Brown et al. 2005). The levees decrease the 39 frequency of flooding events, during which aquatic biota can move between the Mississippi and 40 floodplain habitats. The movement of aquatic resources from floodplain habitats into the river is 41 one reason that the Lower Mississippi is so rich in species diversity. USACE continues to 42 dredge, install river bank revetments and levees, and regulate upstream reservoirs to minimize 43 the historical movements of the river and create a relatively stable channel. 44 In addition to physical changes, runoff from over 40 percent of the conterminous 48 states 45 drains into the Mississippi River. Land use changes over time have increased the concentration 46 of industrial, chemical, and sediment inputs into the river. For example, forests have been 47 Affected Environment 2-38 cleared to farm cotton, soybeans, rice, and corn near GGNS. Farming practices currently 1 include the use of fertilizers, pesticides, and herbicides, which wash into the Mississippi River, 2 especially after large rain events (Brown et al. 2005). Plowed fields, as compared to forested 3 areas, increase the amount of sediments entering the Mississippi River. 4 From 1963 through 1965, a catastrophic fish kill occurred from Memphis to the Mississippi River 5 mouth as a result of industrial releases of endrin, a pesticide made from a chlorinated 6 hydrocarbon. Mississippi Power & Light Company (MP&L) suggests that the endrin release 7 may have reduced species diversity near GGNS by extirpating some species that were highly 8 sensitive to the chlorinated hydrocarbon pesticide (MP&L 1981). As of 2002, testing has 9 indicated that several of the older "first generation" chlorinated insecticides can be detected in 10 low concentrations in bed sediments, although none of the chemical were detected in the water 11 column. 12 2.2.6.2 Description of the Aquatic Resources Associated With GGNS 13 Aquatic resources in the vicinity of GGNS include the following: 14 the Mississippi River, 15 Hamilton and Gin Lakes, 16 a flooded borrow pit, 17 three small upland ponds, 18 Stream "A" and Stream "B," and 19 ephemeral drainages. 20 In 1972, MP&L conducted aquatic studies on the GGNS site to determine baseline conditions of 21 the aquatic environment before construction. MP&L conducted aquatic ecology surveys from 22 June 1972 to August 1973 and documented 86 fish species, more than 100 plankton taxa, and 23 more than 50 macroinvertebrate taxa (MP&L 1981). System Energy Resources, Inc. (SERI) 24 conducted reconnaissance -level surveys from August 19 to 24, 2002, and October 29 to 25 November 1, 2002, in support of the early site permit (ESP) for GGNS (SERI 2005). These 26 surveys primarily resulted in qualitative data and general observations. In November 2006, 27 Entergy hired a consultant to conduct a mussel survey along the Mississippi River in support of 28 the COL application. Entergy is not aware of any other aquatic studies that have been 29 conducted at GGNS (GGNS 2012 a). 30 SERI (2005) concluded that similar aquatic resources were present in 2002 as in 1972 and 31 1973 at GGNS. SERI (2005) based this finding primarily upon the results of the 2002 32 reconnaissance -level surveys. SERI (2005) also noted that the only major change that coul d 33 have substantial impacts on aquatic biota was the installation of the articulated concrete mats 34 along the river bank in 1979. The staff notes the operation of GGNS and its discharge of 35 effluent into the Mississippi River is another change that has occurred since 1973. 36 The staff notes that the current aquatic resources may vary from that recorded in 1972 and 37 1973. As described above, the relative abundance of human -made habitats in the 38 Mississippi River, such as deep channels and hard substrates, have increased, while 39 meandering portions of the river and soft substrates have decreased. Therefore, species that 40 prefer human -made habitats have likely increased in relative abundance. Similarly, the relative 41 abundance of pollution-sensitive species has likely increased because of the improved water 42 quality in the Mississippi River since the implementation of the CWA and other environmental 43 regulations (Caffey et al. 2002). 44 The staff compared aquatic surveys from 1972 through 1974 with more recent surveys from 45 2006 through 2008. The surveys were recorded on FishNet (2012), which is a collaborative 46 effort by the Mississippi Natural History Museum and other natural history museums and 47 Affected Environment 2-39 biodiversity institutions to compile a database of fish survey data. Aquatic surveys from the 1 Mississippi River near GGNS from 1972 through 1974 captured a total of 215 fish, representing 2 25 different species belonging to 12 families. Aquatic surveys from the Mississippi River near 3 GGNS from 2006 through 2008 captured a total of 205 fish, representing 20 different species 4 belonging to 9 families. Of the 25 species recorded from 1972 through 1974 , 8 species 5 (32 percent) were collected and 17 species (68 percent) were not collected in the more recent 6 surveys. In addition, 12 species were collected from 2006 through 2008 that were not collected 7 during the earlier surveys. Of the 12 families recorded from 1972 through 1974 , 8 families 8 (67 percent) were collected and 4 families (37 percent) were not collected in the more recent 9 surveys. In addition, one family was collected from 2006 through 2008 that was not collected 10 during the earlier surveys. These results suggest that the aquatic resources from 1972 through 11 1974 have changed, although some of the same species and many of the same families likely 12 still inhabit the aquatic environments near GGNS. In addition, some new species have likely 13 been introduced into the Mississippi River near GGNS. The staff also notes that degree of 14 species overlap reported above is likely lower than what occurs in nature given that the studies 15 likely used different capture methods, occurred at different seasons, and sampled in different 16 areas or habitats in the river. 17 Mississippi River 18 The Mississippi River's eastern bank defines the western boundary of the GGNS site. The 19 width of the river ranges from approximately 0.5 mi (0.8 km) at low flow to 1.4 mi (2.3 km) at 20 high flow. The deepest part of the channel is about 16 ft (4.9 m). Three predominate habitat 21 types occur within the Mississippi River near GGNS: backwater habitat, river bank habitat, and 22 the main channel (Entergy 2011a). GGNS-related aquatic surveys within these habitats are 23 described below. 24 Sampling Methods for Preconstruction Studies 25 MP&L (1981) sampled aquatic biota in the Mississippi River from September 1972 through 26 August 1973. MP&L sampled areas within each of the three main habitats between RM 400 27 and RM 410. 28 For fish, MP&L (1981) collected monthly samples for 3 to 15 consecutive days using various 29 mesh sizes of gill, trammel, and hoop nets in backwater and river bank habitats. MP&L set nets 30 for 24 hours, or for as long as conditions permitted. Along the channel, MP&L sampled fish 31 once in September 1972 and monthly from June through September 1973, using an otter trawl 32 and fish-locating echo sounder. MP&L collected larval fish monthly or semi -monthly from 33 January through July 1973. 34 For macroinvertebrates, which are invertebrates that are visible without a microscope, MP&L 35 sampled monthly using a Shipek sediment sampler from September 1972 through August 1973. 36 Starting in January 1973, drifting benthic macroinvertebrate samples were collected near the 37 water surface at two stations in the Mississippi River using a 1 -m (3-ft) diameter plankton net 38 (505-micron mesh). MP&L collected shrimp monthly using 4 x 2 x 1 ft (1.2 x 0.6 x 0.3 m) box 39 traps (MP&L 1981). 40 MP&L sampled plankton monthly to semi -monthly from September 1972 through August 1973. 41 Sample stations were similar to that described for fish. 42 The results of this sampling are discussed in the following sections. 43 Biological Communities in Backwater Habitat 44 Backwater habitat occurs in the slow, relatively shallow waters created by the large bend in the 45 Mississippi River near the site. The substrate is generally loosely consolidated, silty clay 46 Affected Environment 2-40 sediment of low plasticity. MP&L documented an abundant assemblage of fish, 1 macroinvertebrates, and plankton in this habitat. The relatively high number of 2 macroinvertebrates provides food and shelter for spawning fish, eggs, and larvae. 3 Fish. MP&L collected 35 fish species within the backwater habitat. Ten fish species comprised 4 85 percent of the fish captured. The most common species included gizzard shad (Dorosoma 5 cepedianum ), blue catfish (Ictalurus furcatus), river carpsucker (Carpiodes carpio), freshwater 6 drum (Aplodinotus grunniens), and shovelnose sturgeon (Scaphirhynchus platorynchus ). 7 Catch-per-unit-effort (CPUE) was highest in the fall (MP&L 1981). 8 Invertebrates. Benthic invertebrates, which inhabit the bottom of the river, were the most 9 abundant and dense within backwater habitats as compared to river bank and river channel 10 habitats. The most common taxa included tubificid worms, chironomid larvae (dipteran), 11 burrowing mayfly (Hexagenia) larvae, leeches, and bivalves (mussels and clams) 12 (MP&L 1981; NRC 2006 a). The abundance of benthic invertebrates in backwaters increased 13 from September 1972 through June 1973 and then decreased through August. MP&L 14 determined that backwaters provide an important feeding ground for fish based on the dry 15 weight standing stock of benthic macroinvertebrates (MP&L 1981). 16 Biological Communities in River Bank Habitat 17 The river bank provides habitat with moderate to swift currents passing by steep banks. The 18 substrate is generally consolidated, high -plastic clay (SERI 2005). In 1979, the river bank 19 downstream of the discharge structure and barge slip was stabilized with articulated concrete 20 mats (NRC 1981). 21 Juvenile and Adult Fish. MP&L collected 34 fish species within river bank habitat. The most 22 commonly collected fish were gizzard shad, freshwater drum, silver chub (Macrhybopsis 23 storeriana), flathead catfish (Pylodictis olivaris), and blue catfish. Gizzard shad comprised 24 52 percent of the relative abundance of fish. CPUE was highest in late winter, right before larval 25 fish were observed. Therefore, MP&L conjectured that these fish were likely moving toward 26 spawning habitat in late winter (MP&L 1981). 27 Ichthyoplankton. MP&L first observed larval fish in March 1973 and observed seven species 28 during this time. The most abundant early -spawning species included shad, Mississippi 29 silverside (Menidia audens), and mosquitofish (Gambusia affinis) larvae. The density of larval 30 fish increased throughout the spring with peak spawning activity occurring in April and May. 31 MP&L observed lower densities of larvae through July, although spawning activity likely occurs 32 through the fall (MP&L 1981). 33 The spawning periods and number of spawning peaks varied for different species. For 34 example, shad spawning began in early April, peaked in May and June, and extended through 35 July. Drum, on the other hand, spawned during a shorter period of time with two spawning 36 peaks: once in June and again in mid -July. MP&L observed a relatively long spawning period 37 for minnow as larvae were collected throughout the entire sampling period. While MP&L 38 commonly observed adult catfish and suckers, their larvae were not collected near the river 39 bank probably because adults spawn in backwaters where larvae mature until they enter the 40 riverine environment as juveniles (MP&L 1981). 41 Most fish eggs near GGNS are demersal (sinking), adhesive, and small (between 0.02 and 42 0.03 in. (0.5 mm) diameter. As such, eggs spawned in backwaters typically adhere to 43 vegetation or logs and eggs spawned over gravelbars and sandbars typically adhere to the 44 bottom substrate during development. Therefore, MP&L caught relatively few fish eggs in its 45 0.02 in. (0.5 mm)-mesh plankton net. Specifically, MP&L caught 20 fish eggs compared to 46 16,596 larvae (MP&L 1981). 47 Affected Environment 2-41 Invertebrates. MP&L collected benthic invertebrates on stable river banks, but did not observe 1 benthic invertebrates on unstable river banks because these river banks likely eroded before 2 invertebrates could establish in sufficient numbers. Highly erosive clay and sand river banks 3 make for a highly dynamic benthic invertebrate community. In some locations, MP&L observed 4 benthic invertebrates during one sampling period, but not during the following month, because 5 of recently eroded clay river banks. The most common taxa included tubificids, the midges 6 Cryptochironomus and Chaoborus, the mayflies Pentagenia and Tortopus, chironomids, and 7 amphipods (MP&L 1981). 8 MP&L also collected river shrimp (Macrobrachium ohione) in the nearshore habitat along the 9 river bank. River shrimp abundance was highest from August through October and close to 10 zero from November 1972 through April 1973. MP&L attributed the decline in river shrimp to the 11 river temperature dropping below 7.5 C (46 F) in November 1972 and not rising above 20 C 12 (68 F) until April 1973 (MP&L 1981). 13 In November 2006, American Aquatics, Inc. (AAI) conducted a mussel survey in support of 14 Entergy's COL application. The purpose of the survey was to determine whether any mussels 15 occurred along the east Mississippi River bank near RM 406 (Entergy 2008c). Survey methods 16 included visual surveys of dead mussel shells along four shoreline sites and visual underwater 17 surveys for live mussels along six transects. One of the four shoreline sampling sites was in the 18 area of the discharge structure. AAI did not observe any live mussels. AAI found dead mussel 19 shells of two non -native species, zebra mussels (Dresissena polymorpha ) and Asiatic Clam 20 (Corbicula fluminea). River currents likely transported the dead shells from upriver locations. 21 As a result of these surveys, AAI concluded that mussel colonization near GGNS was not likely 22 (Entergy 2008b ). 23 Biological Communities in Main Channel Habitat 24 The most prominent aquatic habitat in the vicinity of GGNS is the main channel. This area 25 provides deep water habitat with strong and turbulent currents. The coarse grained river bottom 26 typically consists of gravelly sand sediments (MP&L 1981; SERI 2005). MP&L documented 27 relatively low productivity within the main channel as few benthic invertebrates inhabited the 28 river bottom and the water column contained less fish compared to other river habitats. 29 However, difficult conditions during sampling techniques, such as rapid currents, irregular bed 30 configurations, and bottom associated debris, also may have contributed to the relatively low 31 numbers of fish captured (MP&L 1981). 32 Fish. Commonly observed species included gizzard shad and drum. During June and July 33 trawls, all captured fish were young -of-the-year. Commonly collected species during trawl 34 sampling in August and September included blue and channel catfish (Ictalurus punctatus), 35 shovelnose sturgeon, and four chub species, most of which were juveniles. Adult fish also were 36 likely present in the main channel, but they may have avoided capture more easily because of 37 faster swim speeds (MP&L 1981). 38 Invertebrates. MP&L collected 36 benthic samples from the bottom of the main channel in 39 September and October 1972, and March, June, July, and August 1973. MP&L did not observe 40 any macroinvertebrates. 41 Overall Biological Community in Mississippi River 42 Fish. MP&L captured a total of 69 fish species (MP&L 1981). A similar study conducted at the 43 same time period captured the same number of species at the River Bend Nuclear Station, 44 232 km (144 mi) downstream from GGNS (MP&L 1981; NRC 2006). Gizzard shad was the 45 most abundant species, and the relative numerical abundance varied from 3 to 76 percent 46 (MP&L 1981). The relative abundances of other dominant species captured were freshwater 47 Affected Environment 2-42 drum (10 percent), blue catfish (8 percent), flathead catfish, and river carpsucker (5 percent) 1 (MP&L 1981). 2 Plankton. MP&L (1981) characterized plankton in the Mississippi River as either zooplankton 3 or phytoplankton. Zooplankton are small animals that float, drift, or weakly swim in the water 4 column of any body of water, whereas phytoplankton are plants. Zooplankton density ranged 5 over two orders of magnitude during the study period. MP&L identified 46 taxa and dominant 6 zooplankton that included a stalked protozoan (Carchesium sp.), various cladocerans, and a 7 colonial rotifer. Carchesium sp. can be an indicator of pollution, especially where sewage is not 8 treated properly. MP&L identified a total of 49 phytoplankton genera and the most dominant 9 were centric diatoms (MP&L 1981). 10 Hamilton and Gin Lakes 11 Hamilton and Gin Lakes are remnants of a former Mississippi River channel after the river 12 moved west. The lakes are relatively shallow, approximately 2 to 3 m (8 to 10 ft deep 13 (Energy 2011a). SERI (2005) examined aerial photography from 2001 and estimated the 14 surface area of Hamilton Lake to be 26 ha (64 ac) and Gin Lake to be 22 ha (55 ac). The lakes 15 have decreased in size since 1973. 16 Water enters and leaves Hamilton and Gin Lakes when the Mississippi River floods. Hamilton 17 Lake also receives water from Streams "A" and "B," which transport storm water from GGNS. 18 Gin Lake is connected to Hamilton Lake through a culvert beneath the Heavy Haul Road 19 (MP&L 1981; SERI 2005). 20 MP&L characterized the oxbow lakes as similar to backwater habitat in physical characteristics. 21 The lakes are relatively shallow with no current and the bottom habitat is loosely consolidated, 22 highly plastic clay sediments. Relatively productive biotic assemblages inhabit the lakes 23 (MP&L 1981). 24 Biological Communities in Hamilton and Gin Lakes 25 Fish. MP&L sampled for fish in Hamilton and Gin Lakes bimonthly from June 1972 through 26 August 1973 using electrofishing gear or gill and trammel nets (MP&L 1981). MP&L set nets for 27 24 hours, or for as long as conditions permitted. 28 Although both lakes have similar habitats, MP&L collected 46 fish species in Hamilton Lake and 29 36 species from Gin Lake. The greater number of species in Hamilton Lake likely is due to the 30 more frequent connection with the Mississippi River (MP&L 1981). For example, eight of the 31 species observed in Hamilton Lake, but not in Gin Lake, were species that typically inhabit the 32 Mississippi River. 33 Despite the difference in species diversity, the most common species in both lakes were the 34 same: Eighty percent of the fish were gizzard shad, bluegill (Lepomis macrochirus), threadfin 35 shad (Dorosoma petenense), or largemouth bass (Micropterus salmoides). In both lakes, 36 gizzard shad was the most common species within open -water habitats, whereas bluegill was 37 the most common species within shoreline -covered habitats. 38 Fish communities within oxbow lakes are relatively dynamic. When the Mississippi River floods, 39 aquatic biota can enter and leave the lakes. For example, in April and May 1973, the 40 Mississippi River flooded to Hamilton Lake and the silvery minnow (a river species) comprised 41 17 and 2 percent of the lake, respectively. In June, after the flood subsided, MP&L did not 42 observe silvery minnow in the lakes. Therefore, MP&L's one -year study provides a basic 43 characterization of the lakes that may vary considerably both on a short-term and long -term 44 basis. 45 Affected Environment 2-43 Invertebrates. MP&L sampled benthic invertebrates in Hamilton and Gin Lakes using a Ponar 1 bottom grab starting in October 1972 through August 1973. Benthic macroinvertebrates in 2 Hamilton and Gin Lakes resembled the macroinvertebrate community MP&L observed in 3 backwater habitats of the Mississippi River. Grab samples during the fall and winter indicated 4 that the most common taxa included larvae of the phantom midge Chaoborus and various 5 genera of chironomid midges (e.g., Coelotanypus , Procladius, Cryptochironomus, Pentaneura 6 and Tanypus). During the spring, common taxa included tubificid worms and bivalves 7 (MP&L 1981). MP&L also observed several species not included in grab samples, such as 8 large unionid mussels (Carunculinus , Anodonta, and Lampsilus), large snails (Campeloma and 9 Viviparus), whirligig beetles (Gyrinus), water striders (Notonectidae), crayfish (Procambarus), 10 and the grass shrimp Palaemonetes kadiakensis. 11 Benthic invertebrate density in Hamilton Lake was relatively stable, whereas MP&L observed 12 several peaks of benthic invertebrate density in Gin Lake (MP&L 1981). 13 Plankton. During the 1972 and 1973 studies, MP&L observed that the frequency and duration 14 of Mississippi River flooding, which allowed the plankton to enter or leave the lakes, had a 15 strong influence on the plankton composition and abundance. When the lakes were not 16 flooded, plankton developed into distinct populations that differed from the river communities. 17 However, during flood events, the plankton community more closely resembled plankton 18 communities within the Mississippi River (MP&L 1981). 19 Flooded B orrow Pit 20 MP&L created a borrow pit north of the barge slip in the 1970s to obtain fill for use in GGNS 21 construction. Water enters and leaves the borrow pit when the Mississippi River floods. The 22 depth of the pit is not known. SERI (2005) examined aerial photography from 2001 and 23 estimated the surface area to be 6.5 ha (16 ac) in size. The pit does not appear to be 24 hydrologically connected to the lakes, except when the Mississippi River floods and the flood 25 water flows between the lakes and burrow pit. The bottom habitat within the burrow pit is likely 26 similar to that of the oxbow lakes (SERI 2005). 27 Three Small Upland Ponds 28 Three small upland ponds exist on the GGNS site. Each pond is approximately 0.25 -0.50 ac 29 (0.1-0.2 ha). MP&L (1981) concluded that previous land owners stocked the ponds with bluegill 30 and channel catfish. 31 Biological Communities in Upland Ponds 32 MP&L sampled the upland ponds using electrofishing and mark -recapture methods 33 (MP&L 1981). The most common species include bluegill and mosquitofish. One pond also 34 contained a few channel catfish. 35 Streams A and B 36 Streams A and B are perennial streams that run through the GGNS site. Stream A flows west 37 from the GGNS sanitary waste water treatment facility. Stream A receives continual flow from 38 facility storm water and processed dischar ge from the waste water treatment facility 39 (NRC 2006 a). Stream B flows west from the cooling towers on the south side of Heavy Haul 40 Road. Flow in Stream B is intermittent, consisting mostly of storm runoff, and runs into Hamilton 41 Lake. MP&L constructed sedimentation basins on both Stream A and B, referred to as 42 Outfall 13 and 14, respectively (MP&L 1981; SERI 2005). 43 Affected Environment 2-44 Biological Communities in Stream A and B 1 MP&L sampled Stream A twice between 1972 and 1973 (MP&L 1981). MP&L observed a total 2 of 21 fish species, including bluntnose minnow, green sunfish (Lepomis cyanellus), longear 3 sunfish (Lepomis megalotis), silvery minnow (Hybognathus nuchalis, a river species), and 4 blackspotted top minnow (Fundulus olivaceus). Aquatic biota likely entered the stream during 5 spring floods (SERI 2005). For example, several species, such as largemouth bass, river shiner 6 (Notropus blennius), and warmouth (Lepomis gulosus), also inhabit Hamilton and Gin Lakes 7 and the Mississippi River (MP&L 1981). In addition to the small number of fish, MP&L observed 8 unidentified bivalves and snails in Stream A. As a result of the preconstruction studies, 9 SERI (2005) concluded that Stream A is relatively unproductive. For example, species diversity 10 in Stream A was lower than similar streams near Vicksburg, Mississippi (MP&L 1981). 11 NRC is not aware of any aquatic surveys in Stream B. Stream A and B likely provide similar 12 habitat for aquatic resources (SERI 2005), and therefore contain similar species. However, the 13 aquatic community within Stream B may be smaller than the community in Stream A due to the 14 intermittent flow of water. In addition, the species in Stream B would need to be able to survive 15 in a wide-range of environmenta l conditions due to the intermittent flow of water. 16 Ephemeral Drainages 17 SERI (2005) calculated 24,140 linear ft (7.4 km) of ephemeral drainage channels throughout the 18 GGNS site. These ephemeral drainage channels occur on the upland bluffs primarily on the 19 eastern portion of the GGNS site. Several drainages support small wetlands (SERI 2005). 20 Commercially and Recreationally Important Fish 21 Limited commercial fishing occurs in the area. Most commercial fishing occurs on the 22 Mississippi River near GGNS and on the Big Black and Bayou Pierre Rivers (NRC 2006 a). 23 Predominate harvest species include bigmouth (Ictiobus cyprinellus) and smallmouth buffalo 24 (Ictiobus bubalus) (SERI 2005). 25 In 1973, MP&L estimated that there may have been 10 -15 full-time and 30 -40 part-time 26 commercial fishermen operating between Grand Gulf and Natchez. Commonly collected 27 species from a creel study in January through February 1973 included bigmouth and 28 smallmouth buffalo (MP&L 1981). 29 Recreational fishing occurs on the Mississippi River and Hamilton and Gin Lakes (SERI 2005; 30 NRC 2006a). Recreational fisherman generally fish from boats and the bank as well as use 31 trotlines in the lakes. The most common fish caught include catfish, bluegill, and bass 32 (MP&L 1981; SERI 2005). 33 Nuisance Speci es 34 The ERs associated with the Operating Permit (MP&L 1981), ESP (SERI 2005), COL 35 (Entergy 2008c), and LRA (Entergy 2011a) did not identify aquatic nuisance species in the 36 waters associated with GGNS. As described above, in November 2006, AAI observed dead 37 mussel shells of two exotic species, zebra mussels (Dresissena polymorpha ) and Asiatic Clam 38 (Corbicula fluminea), while conducting mussel surveys in support of the COL application 39 (Entergy 2008 c). River currents likely transported the dead shells from an unknown upriver 40 location. Zebra mussels also have been observed 35 river miles upriver of GGNS, near 41 Vicksburg and throughout the Lower Mississippi River (Benson 2011). The Asiatic clam has 42 been observed in the Big Black River north of GGNS and throughout the Lower Mississippi 43 River (USGS 2012 c). 44 Affected Environment 2-45 Aquatic Resources Associated with Transmission Line Rights -of-Way 1 Transmission line rights -of-way for GGNS cross waterways in Claiborne County. The 2 Baxter-Wilson right -of-way crosses the Big Black River approximately 12 km (7.5 mi) to the 3 northeast of the GGNS site. In addition, the Baxter -Wilson substation in Warren County is less 4 than 0.75 km (0.47 mi) from the shores of the Mississippi River. The Franklin right -of-way 5 crosses the Bayou Pierre approximately 5.5 km (3.4 mi) to the south of GGNS (NRC 2006 a). 6 The Franklin right -of-way also crosses the Homochitto River (Entergy 2011a). 7 Neither the ER for the ESP (SERI 2005), the ER for the COL (Entergy 2008 c), nor the ER for 8 license renewal (Entergy 2011a) provide a description of the aquatic resources along the 9 transmission lines. NRC (2006 a) determined that information on aquatic resources was not 10 available from the transmission and distribution system owner and operator, EMI. 11 2.2.7 Terrestrial Resources 12 2.2.7.1 GGNS Ecoregion 13 GGNS lies where the Mississippi Valley Alluvial Plain and Mississippi Valley Loess Plain meet. 14 The Mississippi Valley Alluvial Plain ecoregion consists of a broad, flat alluvial plain. River 15 terraces, swales, and levees provide the main elements of relief. Soils are typically 16 finer-textured and poorly drained compared to the upland soils of the adjacent Mississippi Valley 17 Loess Plains ecoregion. The Mississippi Valley Loess Plains consist of a thin strip of land that 18 extends from western Kentucky southward to Louisiana. It is about 750 km (470 mi) long, 19 110 k m (70 mi) wide, and covers about 43,775 km 2 (16,901 mi

2) of land (USGS 2011). This 20 ecoregion consists of irregular plains with a thick layer of highly erodible loess deposits, 21 oak-hickory and oak

-hickory-pine forests, and streams with low gradients and silty substrates. 22 2.2.7.2 Summary of Past GGNS Site Surveys and Reports 23 In 1972 , MP&L conducted vegetation and wildlife studies on the GGNS site to determine 24 baseline conditions of the terrestrial environment before construction. As part of these studies, 25 MP&L mapped overstory and understory vegetation and conducted wildlife surveys to determine 26 the occurrence and relative abundance of mammals, birds, reptiles, and amphibians on the site. 27 The U.S. Atomic Energy Commission (NRC's predecessor agency) summarized the results of 28 these studies and described the terrestrial environment in its Final Environmental Statement 29 Related to Construction of Grand Gulf Nuclear Station, Units 1 and 2 (FES) (AEC 1973). 30 In 2003, SERI submitted an application to the NRC for an ESP on the GGNS site. As part of its 31 ESP application, SERI prepared an ER (SERI 2005). In its preparation of the ESP ER, SERI 32 conducted qualitative reconnaissance site visits to compare the ecological conditions with those 33 described in the 1973 FES. The ESP ER identified little change in undeveloped portions of the 34 site; the report largely summarized the findings in AEC's 1973 FES. The NRC developed an 35 environmental impact statement (EIS) (NRC 2006 a) during its review of the ESP application, 36 which it published in 2006. 37 In 2008, Entergy submitted an application for a combined license (COL) to the NRC for the 38 proposed Grand Gulf, Unit 3. Entergy requested that the NRC suspend its review of this 39 application in January 2009 until further notice. Nevertheless, the application contained an ER 40 (Entergy 2008 c) that include d an assessment of the terrestrial environment. Entergy conducted 41 several new surveys during the preparation of its ER for the COL specific to protected species. 42 Section 2.2.8 discusses these surveys in more detail. In 2011, Entergy submitted an application 43 for license renewal to the NRC. The associated ER (Entergy 2011a) also described the 44 terrestrial environment. Entergy did not conduct any new surveys for the license renewal 45 application. Entergy does not conduct any ongoing terrestrial monitoring on the site beyond that 46 Affected Environment 2-46 associated with the site's radiological environmental monitoring program (REMP) 1 (Entergy 2011a). Section 4.8 of this SEIS describes the REMP. 2 Since multiple, previously published reports describe the GGNS site in detail, the following 3 section provides a brief overview of the site habitats and wildlife. Refer to the reports 4 referenced above for a more detailed description of the GGNS site. 5 Affected Environment 2-47 Figure 2-14. GGNS Property Habitat Types (Source: Entergy 2011a) 1 2.2.7.3 GGNS Site 2 The GGNS site lies along the east bank of the Mississippi River. North -south bluffs run parallel 3 to the river and divide seasonally inundated bottomlands from upland habitat atop the bluffs. 4 Affected Environment 2-48 Roughly half of the site consists of upland habitats and half the site consists of bottomland 1 habitats. Two small lakes -Hamilton and Gin Lakes -lie within the bottomlands. During 2 construction, about 270 ac (109 ha) of upland habitat was cleared for GGNS buildings and 3 related infrastructure. Upland areas are more diverse than bottomland areas because they do 4 not experience prolonged periods of river inundation as do the bottomland habitats 5 (Entergy 2011a). The South Woods, which lies to the south and west of the cooling tower, is an 6 especially diverse area because of its complex topography of narrow ridges with steep slopes, 7 ravines, and bluffs. Figure 2-14 shows the GGNS property by habitat type. This figure outlines 8 the historical property boundary, which encompasses 2,100 ac (850 ha), although the actual 9 property size today is 2,015 ac (815 ha) because of erosional loss from the Mississippi River. 10 Table 2-3 summarizes the GGNS site habitats. Since the only terrestrial site surveys were 11 conducted before construction, the table primarily relies on information from these surveys as 12 they were presented in the AEC's 1973 FES. However, the table includes updated or more 13 specific habitat information, as available in the ESP ER (SERI 2005), the COL ER 14 (Entergy 2008 c), and the license renewal ER (Entergy 2011a). Two primary habitat changes 15 between preconstruction and present day are in the bottomland scrub -shrub wetlands (east of 16 Gin Lake) and the upland open fields and clearings, in which Entergy has planted American 17 sycamore (Platanus occidentali) and loblolly pine (Pinus taeda), respectively. 18 Table 2-3. Dominant Vegetation by Habitat Type 19 Bottomland Hardwood Forest Community types: bottomland deciduous forest Area: 985 ac (398 ha)(a) Dominant vegetation: Overstory box elder (Acer negundo) pecan (Carya illinoiensis) sugarberry (Celtis laevigata) swamp privet (Forestiera acuminate) green ash (Fraxinus pennsylvanica) black willow (Salix nigra) Understory aster (Aster spp.) buckvine [or ambervine] (Ampelopsis arborea) false nettle (Boehmeria cylindrica) trumpet creeper (Campsis radicans) sugarberry (Celtis laevigata) ladies'-eardrops (Fuchsia megellanica) dewberry (Rubus spp.) Johnson grass (Sorghum halepense) poison ivy (Toxicodendron radicans ) Bottomland Emergent Wetlands Community types: palustrine, emergent seasonally flooded Area: 30 ac (12 ha) Dominant vegetation: redtop panicgrass (Panicum rigidulum ) sedges (Carex spp.) Bottomland Scrub -Shrub Wetlands (east of Gin Lake) Community types: palustrine, seasonally flooded Area: 70 ac (28 ha) Dominant vegetation: American sycamore (Platanus occidentali ) Affected Environment 2-49 Bottomland Scrub -Shrub Wetlands (north, northwest, and south of Gin Lake) Community types: palustrine, seasonally flooded Area: 10 ac (4 ha) Dominant vegetation: black willow (Salix nigra) swamp privet (Forestiera acuminate) common button bush (Cephalanthus occidentalis ) Upland Loessial Bluff Hardwood Forest Community types: oak forests American elm forests oak-sweetgum forests Area: 400 ac (162 ha) Dominant vegetation: Overstory bitternut hickory (Carya cordiformis) pecan (C. illinoiensis) sweetgum (Liquidambar styraciflua) cherrybark oak (Quercus pagoda) southern red oak (Q. falcata) Texas oak (Q. texana) water oak (Q. nigra) American elm (Ulmus americana) Understory aster (Aste r spp.) switchcane (Arundinaria gigantean) sedges (Carex spp.) Japanese honeysuckle (Lonicera japonica) poison ivy (Toxicodendron radicans) oaks (Quercus spp.) greenbriers (Similax spp.) winged elm (Ulmus alata) grasses Upland Open Fields and Clearings Community types: upland early successional field Area: 155 ac (63 ha) Dominant vegetation: loblolly pine (Pinus taeda) goldenrod (family Asteraceae) sida (Sida spp.) goatweed (Ageratum conyzoides) mare's-tail (Hippuris spp.) common ragweed (Ambrosia artemisiifolia) dog fennel (Anthemis spp.) (a) Habitat acreage in each of the references varies because of the loss of riparian habitat along the Mississippi River to erosion over time. This table uses those areas that appear in the most recent reference, the license renewal ER (Entergy 2011a). However, the FES (AEC 1973) is the only reference that specifies acreage for the bottomland hardwood forest area. Therefore, for this habitat type, the staff used the acreage estimate from the FES. Sources: AEC 1973; Entergy 2008c; Entergy 2011a; SERI 2005 The 1972 pre -operational wildlife surveys documented 96 species of birds on the site out of an 1 estimated 141 species likely to occur in the area (AEC 1973). Additionally, the AEC (1973) 2 notes that 45 mammalian species, 67 reptiles, and 25 amphibians are likely to occupy the 3 GGNS site. Tables D -1 through D -5 in the AEC's 1973 FES list these species. Table 2 -4 4 below lists the most common or abundant species on the site. Common or abundant birds and 5 mammals are those identified in the ESP EIS (NRC 2006 a). The ESP EIS, however, does not 6 Affected Environment 2-50 include information on reptiles or amphibians. Thus, reptile and amphibian species listed in 1 Table 2-4 are those identified as being abundant in the license renewal ER (Entergy 2011a) or 2 in the FES (AEC 1973). 3 Table 2-4. Most Common or Abundant Wildlife Documented on GGNS 4 Birds(a) Passerines and Near Passerines Acadian flycatcher S (Empidonax virescens) mourning dove Y (Zenaida macroura ) American robin W (Turdus migratorius) northern cardinal Y (Cardinalis cardinalis ) belted kingfisher Y (Ceryle alcyon ) northern rough -winged swallow S (Stelgidopteryx serripennis) blue jay Y (Cyanocitta cristata ) orchard oriole S (Icterus spurius) field sparrow W (Spizella pusilla) red-winged blackbird Y (Agelaius phoeniceus ) lark sparrow W (Chondestes grammacus) ruby-crowned kinglet W (Regulus calendula) Herons, Egrets, and Storks American coot W (Fulica americana ) tricolored heron S (Egretta tricolor ) cattle egret S (Bubulcus ibis ) white ibis S (Eudocimus albus ) great blue heron Y (Ardea Herodias ) wood stork S (Mycteria americana ) great egret S (Ardea alba ) yellow-billed cuckoo S (Coccyzus americanus ) Waterfowl and Grebes pied-billed grebe W (Podilymbus podiceps) northern pintail S (Anas acuta) mallard S (Anas platyrhynchos) wood duck Y (Aix sponsa ) Birds of Prey black vulture Y (Coragyps atratus) American kestrel M (Falco sparverius ) turkey vulture Y (Cathartes aura ) Mississippi kite S (Ictinia mississippiensis ) broad-winged hawk S (Buteo lineatus ) great horned owl Y (Bubo virginianus ) red-tailed hawk Y (Buteo jamaicensis ) northern harrier M (Circus cyaneus ) red-shouldered hawk Y (Buteo lineatus ) eastern screech owl Y (Otus asio) sharp-shinned hawk M (Accipiter striatus ) Affected Environment 2-51 Mammals beaver (Castor canadensis ) least shrew (Cryptotis parva ) bobcat (Lynx rufus ) marsh rice rat (Oryzomys palustris ) cotton mouse (Peromyscus gossypinus ) nine-banded armadillo (Dasypus novemcinctus ) eastern chipmunk (Tamias striatus ) opossum (Didelphis marsupialis ) eastern cottontail (Sylvilagus floridanus ) raccoon (Procyon lotor ) eastern fox squirrel (Sciurus niger ) shorttail shrew (Blarina brevicauda ) eastern gray squirrel (Sciurus carolinensis ) striped skunk (Mephitis mephitis ) fulvous harvest mouse (Reithrodontomys fulvescens ) swamp rabbit (Sylvilagus aquaticus ) golden mouse (Ochrotomys nuttalli ) white-footed mouse (Peromyscus leucopus ) gray fox (Urocyon cinereoargenteus ) whitetail deer (Odocoileus virginianus ) hispid cotton rat (Sigmodon hispidus ) woodland vole (Microtus pinetorum ) house mouse (Mus musculus ) Reptiles(b) American alligator AQ, TR (Alligator mississippiensis ) ground skink TR (Lygosoma laterale ) American toad TR (Bufo americanus ) red-eared turtle AQ (Pseudemys scripta ) black racer TR (Coluber constrictor ) southern black racer TR (Coluber constrictor priapus ) broad-banded water snake AQ, TR (Natrix sipedon ) southern copperhead TR (Agkistrodon contortrix contortrix ) diamond-backed water snake AQ, TR (Natrix rhombifera ) spade foot toad LB (Scaphiopus holbrookii ) eastern hognose TR (Heterodon platyrhinos ) speckled kingsnake TR (Lampropeltis getulus ) Fowler's toad TR (Bufo woodhousel fowleri ) stinkpot AQ (Sternotherus odoratus ) gray rat snake TR (Elaphe obsolete ) three-toed box turtle TR (Terrapene carolina triunguis ) green anole TR (Anolis carolinensis carolinensis ) western cottonmouth AQ, TR (Agkistrodon piscivorus leucostoma ) Affected Environment 2-52 Amphibians(b) amphiuma salamander BL (Amphiuma spp.) lesser siren BL (Siren intermedia ) bronze frog AQ, TR (Rana clamitans ) mole salamander LB (Ambystoma talpoideum ) bullfrog AQ, TR (Rana catesbeiana ) slimy salamander LB (Plethodon glutinosus ) (a)Codes following bird names signify seasonal use of the GGNS site; S = summer; M = migratory stopover; W = fall and winter; Y = year -round. (b)Codes following amphibian names signify habitat use; AQ = aquatic habitat; BL = bottomlands; LB = loessial bluffs; TR = terrestrial habitat (general). Sources: AEC 1973; Entergy 2011a; NRC 2006 a 2.2.7.4 Transmission Line Corridors 1 Section 2.1.5 of this SEIS describes the three transmission lines (two full-length lines and one 2 short tie that terminates on the site) associated with GGNS construction. The majority of the 3 land (77.7 percent) that the transmission lines traverse is undeveloped. About 15 percent of the 4 transmission line corridors is agricultural lands. Table 2-5 provides the land use by acreage 5 and percent along the transmission line corridors. 6 Table 2-5. Transmission Line Corridor Land Use by Area 7 Land Use Acres (Hectares) Percent Agricultural 246 (100) 14.7 Developed (Residential) 28 (11) 1.6 Developed (Non -residential) 3 (1) 0.2 Undeveloped 1,296 (525) 77.7 Water or Wetlands 96 (39) 5.8 Source: Entergy 2011a; NRC 2006a The Baxter -Wilson line runs through hardwood forest, loessial bluffs, hardwood -forested Big 8 Black River bottomland, farmland, and sparsely populated rural areas. The Franklin line runs 9 through loessial bluff hardwood forest and fields, pine and hardwood forest, and farmland 10 (Entergy 2011a). The Franklin line also runs through Homochitto National Forest to the 11 southeast of the GGNS site. Homochitto National Forest is an 189,000 ac (76,500 ha) National 12 Forest that spans seven Mississippi counties. 13 2.2.8 Protected Species and Habitats 14 The U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS) 15 jointly administer the Endangered Species Act (ESA) of 1973, as amended. The FWS manages 16 the protection of and recovery effort for listed terrestrial and freshwater species, while the NMFS 17 manages the protection of and recovery effort for listed marine and anadromous species. 18 Within Mississippi, the Mississippi Department of Wildlife, Fisheries, and Parks (MDWFP) lists 19 species as State endangered under the Mississippi Nongame and Endangered Species 20 Conservation Act of 1974 (MNHP 20 11). 21 The NMFS has not designated any essential fish habitat under the Magnuson -Stevens Fishery 22 Conservation and Management Act, as amended, within affected waterbodies within the vicinity 23 Affected Environment 2-53 of GGNS (NMFS 2012 a); therefore, this section does not discuss species with essential fish 1 habitat. 2 This section also discusses those species protected under the Bald and Golden Eagl e 3 Protection Act of 1940, as amended, and the Migratory Bird Treaty Act of 1918, as amended. 4 The FWS and NMFS have not designated any critical habitat under the ESA within the action 5 area, nor has either agency proposed the listing or designation of any new species or critical 6 habitat within the action area. 7 2.2.8.1 Action Area 8 For purposes of its protected species and habitat discussion and analysis, the NRC considers 9 the action area, as defined by the ESA regulations at 50 CFR 402.02, to include the lands and 10 waterbodies described below. The following sections only consider terrestrial and aquatic 11 species that occur or have the potential to occur within this action area. 12 Terrestrial, wetland, and riparian habitat on the GGNS site and surrounding area within a 13 2-mi (10-km) radius. The 2,015-ac (815-ha) GGNS site lies within Claiborne County, 14 Mississippi. The site includes hardwood forest, open fields and clearings, and several areas of 15 emergent wetlands and riparian habitat bordering the Mississippi River. Section 2.2.7 describes 16 the site terrestrial ecology. 17 Mississippi River 6 river miles (10 river kilometers) upstream and downstream of GGNS 18 and site aquatic features. This area includes the extent of the maximum thermal plume from 19 GGNS discharge into the Mississippi River. The action area also includes the aquatic features 20 at GGNS, including Hamilton and Gin Lakes, the borrow pit, streams "A" and "B ," three small 21 upland ponds, and ephemeral drainages. Section 2.2.6 describes the site aquatic ecology. 22 Transmission line corridors and 1 -mi (1.6-km) buffer on either side of the lines. The 23 transmission lines associated with GGNS travel through Claiborne, Franklin, Jefferson, and 24 Warren Counties. The transmission line corridors traverse pine and hardwood forest, loessial 25 bluffs, farmland, and sparsely populated rural areas and cross several rivers, including the 26 Mississippi, Bayou Pierre, and Big Black Rivers. One of the lines (the Franklin line) also runs 27 through Homochitto National Forest to the southeast of the GGNS site. 28 2.2.8.2 Overview of Protected Aquatic and Terrestrial Species 29 Sections 2.2.6 and 2.2.7 summarize past aquatic and terrestrial surveys that have been 30 conducted on the GGNS site. MP&L captured pallid sturgeon (Scaphirhynchus albus), chestnut 31 lamprey (Ichthyomyzon castaneus), black buffalo (Ictiobus niger), blue sucker (Cycleptus 32 elongates), and paddlefish (Polyodon spathula) during the 1972 through 1973 preconstruction 33 surveys (AEC 1973). However, neither the preconstruction surveys, the recent reconnaissance 34 surveys associated with the ESP application, nor the surveys associated with the COL 35 application identified any other Federally or State-listed species on the GGNS site. Several of 36 these Federally listed species (see Table 2-6) have the potential to occur in the action area. 37 Table 2-6 identifies Federally and State-listed species that occur in Claiborne County, in which 38 GGNS is located, or within one of the four counties through which the transmission line corridors 39 traverse. The NRC compiled this table from FWS's online search by county (F WS 2012 b); the 40 Mississippi Natural Heritage Program's online database (MNHP 201 1); and correspondence 41 from the FWS (2012 c, 2012 d), MDWFP (2012), and NMFS (2012 b). The MNHP online 42 database lists about 30 additional State-listed animal species and about 30 additional plant 43 species that do not appear in Table 2 -6; however, the MDWFP (2012) did not identify any of 44 these additional species as occurring within 2 mi (3.2 km) of the GGNS site or transmission line 45 corridors. Therefore, this section does not include these species in its discussion. 46 Affected Environment 2-54 In response to the NRC's request for endangered and threatened species that could be affected 1 by the proposed license renewal, NMFS (2012 b) stated that no species under its jurisdiction 2 occur within the action area, but that gulf sturgeon (Acipenser oxyrinchus desotoi) are known to 3 occur in the Mississippi River and have been collected upstream of the project site in the region 4 of Vicksburg, Mississippi. NMFS (2012 b) suggested that the NRC contact the FWS Panama 5 City Office about the gulf sturgeon. In response to the NRC's inquiry, the FWS Panama City 6 Office stated that it defer s to the letters written by the Louisiana FWS Office (FWS 2012 c) and 7 Mississippi FWS Office (FWS 2012 d) regarding Section 7 consultation. FWS (2012c, 2012d) 8 did not identify any concerns related to the proposed project on gulf sturgeon. Furthermore, 9 FWS, which has jurisdiction over the gulf sturgeon in the Mississippi River, did not identify the 10 species as occurring within the action area or within Claiborne, Franklin, Jefferson, or Warren 11 Counties (FWS 2012b, 2012c, 2012 d). Therefore, the NRC will not consider this species in any 12 further detail in this SEIS. 13 Affected Environment 2-55 Table 2-6. Federally and State -Listed Species 1 County(ies) of Occurrence(c) Scientific Name Common Name Federal Status(a) State Status(a) State Rank(b) Claiborne Franklin Jefferson Warren Amphibians Plethodon websteri Webster's salamander

- - S3 x  x  Birds         Eudocimus albus white ibis
- - S2B, S3N x x x x Haliaeetus leucocephalus bald eagle
- E S1B, S2N x x x x Mycteria americana wood stork E E S2N x x x x Picoides borealis red-cockaded woodpecker E E S1  x x  Sterna antillarum least tern (interior pop.) E E S3B x  x x Fish         Crystallaria asprella crystal darter 
- E S1 x x   Cycleptus elongatus blue sucker
- - S3 x    Etheostoma rubrum bayou darter T T S1 x    Ichthyomyzon castaneus chestnut lamprey
- - S3 x    Ictiobus niger black buffalo
- - S3 x   x Macrhybopsis meeki sicklefin chub
- - SA    x Polyodon spathula paddlefish
- - S3 x   x Scaphirhynchus albus pallid sturgeon E E S1 x  x x Mammals         Ursus americanus luteolus Louisiana black bear T E S1 x x x x Ursus americanus American black bear T(SA) E S1 x x x x Mussels         Potamilus capax fat pocketbook E E S1 x  x x Quadrula cylindrica ssp. cylindrica rabbitsfoot PT - - x   x (a) E = endangered; T = threatened; T(SA) - threatened due to similarity of appearance to another listed species; PT = proposed threatened.
(b) S1 = critically imperiled in MS because of extreme rarity; S2 = imperiled in MS because of rarity; S3 = rare or uncommon in MS; SA = accidental or casual in MS (i.e., infrequent and far outside usual range); B = applies to breeding populations; N = applies to migratory or non

-breeding populations.

(c) GGNS is located in Claiborne County, Mississippi. The transmission lines associated with GGNS traverse Claiborne, Franklin, Jefferson, and Warren Counties.

Sources: FWS 2012b, 2012c, 2012d; Mann et al. 2011; MDWFP 2012

Affected Environment 2-56 2.2.8.3 Species and Habitats Protected Under the Endangered Species Act 1 Wood Stork (U. S. Breeding Population) 2 The U.S. Fish and Wildlife Service (FWS) listed the U.S. breeding population of wood stork 3 (Mycteria americana) as endangered in 1984 (49 FR 7332). The wood stork is a large, white 4 wading bird with black flight and tail feathers. Its head is not feathered, and both the head and 5 bill are grey to brownish -grey in color. Wood storks' historic breeding range extends from South 6 Carolina to Florida, west to Texas, and throughout most of South America. Today, the species 7 breeds in South Carolina, Florida, and Georgia, though it still migrates west and south. Within 8 Mississippi, the wood stork occurs along the western edge of the State along the Mississippi 9 River in late summer and fall near freshwater wetlands, ponds, bayheads, oxbow lakes, a nd 10 ditches (MMNS 2001). 11 The AEC's 1973 FES notes that pre -construction surveys recorded the wood stork as occurring 12 in the summer on or near Hamilton and Gin Lakes. The license renewal ER (Entergy 2011a) 13 does not provide any updated information on the species' occurrence but notes that the wood 14 stork is a possible non -breeding transient to the GGNS site and surrounding area. Thus, the 15 staff assumes that the wood stork occurs in the action area. However, individuals in Mississippi 16 represent migrants from Mexican breeding colonies (49 FR 7332), and thus, would not be part 17 of the U.S. breeding population. Therefore, the NRC will not analyze this species in any further 18 detail in this SEIS. 19 The FWS has not designated critical habitat for this species. 20 Red-cockaded Woodpecker 21 I n 1970, under the Endangered Species Preservation Act of 1966, the predecessor regulation to 22 the Endangered Species Act (ESA) (35 FR 16047), the FWS listed the red -cockaded 23 woodpecker (Picoides borealis) as endangered wherever found. The red -cockaded 24 woodpecker is a medium -sized woodpecker that is distinguishable by barred black and whit e 25 horizontal stripes on its back and black cap and nape encircling white cheek patches. Males 26 have a small red streak along the back portion of their heads. 27 Red-cockaded woodpeckers live in family groups with one breeding pair and several 28 non-breeding birds that help raise young (FWS 2003). Males more often are helpers, but 29 females also may take on the helper role. If a breeder dies, a helper can replace the breeder. 30 Helpers also may increase fledgling success and reduce the workload of breeders, which 31 increases breeder survivorship (Khan and Walters 2002). Therefore, the effective population 32 size depends more on the number of breeding groups instead of the number of young 33 successfully raised in a given year. This cooperative breeding system makes the red -cockaded 34 woodpecker resistant to many environmental and demographic changes, but highly sensitive to 35 habitat spatial characteristics (FWS 2003). 36 Red-cockaded woodpeckers inhabit open pine woodlands and savannahs with large old pines 37 that serve as cavity trees for nesting and roosting. The species uses mature pine stands with 38 open canopies, little to no midstory, and native bunchgrass and forbs for foraging. Cavity tree 39 availability is often the limiting factor for growth in most populations (FWS 2003). 40 The red-cockaded woodpecker does not occur in Claiborne County; therefore, it does not occur 41 on the GGNS site. The Homochitto National Forest, which spans seven Mississippi counties, 42 including Franklin and Jefferson Counties, contains a secondary core population of the species 43 (FWS 2003). As of 2000, this national forest contained 51 active breeding clusters (FWS 2003). 44 The recovery plan sets forth a goal of 254 active breeding clusters for this population. The 45 Franklin transmission line (discussed in Section 2.1.5) travels through the northern section of 46 Affected Environment 2-57 Homochitto National Forest in Jefferson and Franklin Counties before its termination point at the 1 Franklin EHV Switching Station in Franklin County. Thus, the species is likely to occur within 2 the action area in the vicinity of the Franklin transmission line corridor within the Homochitto 3 National Forest. 4 The FWS has not designated critical habitat for this species. 5 Least Tern (Interior Population) 6 The FWS listed the interior population of the least tern (Sterna antillarum) as endangered in 7 1985 (50 CFR 21784). The least tern is an 8- to 9-in. bird that has a white body, gray back and 8 wings, a black crown on its head, orange legs, and a yellow bill. 9 Least terns arrive in the United States from early April to early June and spend 3 to 5 months in 10 breeding grounds (TPWD 2012). The species inhabits barren to sparsely vegetated sandbars 11 along the Missouri, Mississippi, Ohio, Red, and Rio Grande Rivers; sand and gravel pits; an d 12 lake and reservoir shorelines (Sidle and Harrison 1990). Least terns nest in small colonies in 13 such areas, and females create nests by scraping shallow holes in sandy areas or exposed 14 flats. Females lay two to three eggs over a period of several days in late May. Chicks hatch 15 within 20 to 22 days and are capable of flight within 3 weeks. Because least terns nest on 16 sandbars and shorelines, annual nesting success in a given location varies greatly due to water 17 level fluctuations. Least terns generally stay close to their breeding colony and limit their activity 18 to that portion of the river near the colony. The species is territorial and individuals communally 19 will defend the colony against invaders. Least terns are opportunistic feeders and prey on a 20 variety of small fish, crustaceans, and insects. Least terns migrate south to fall and winter 21 habitats beginning in late August.

(TPWD 2012) 22 Since 1986, biologists from the U.S. Army Corps of Engineers and Dyersburg State Community 23 College have conducted least tern surveys along the Mississippi River from Cape Girardeau, 24 Missouri, to Baton Rouge, Louisiana. The least tern occurs along this entire stretch of the 25 Mississippi River. During the most recent survey conducted in July 2011, Jones (2011) 26 recorded a total of 12,247 least terns and 45 nesting colonies. Two nesting colonies occur 27 within the action area:  the Yukatan Dikes (RM 410; 4 RM upriver of GGNS) colony and the 28 Bondurant Towhead Dikes (RM 393; 13 RM downriver of GGNS) colony. The Baxter

-Wilson 29 transmission line lies 0.46 mi (0.74 km) from the Mississippi River at its closest point, and the 30 nearest least tern colonies are at least 2 mi (3.2 km) away from the transmission line corridor; 31 thus, these colonies are outside the action area. 32 The FWS has not designated critical habitat for this species. 33 Bayou Darter 34 The FWS listed the bayou darter (Etheostoma rubrum) as threatened in 1975 (40 FR 17590). 35 Bayou darter are small fish; adults range from 1.0-1.8 in. (2.5 -4.6 cm) in length. These fish are 36 the smallest representative of the subgenus Nothonotus. Bayou darters are endemic to the 37 Bayou Pierre and also occur in the lower reaches of its tributaries, including White Oak Creek, 38 Foster Creek, and Turkey Creek. Bayou darter habitat includes meandering stream with stable 39 gravel riffles or sandstone exposures (FWS 2012d). Such habitat is often found downstream of 40 a headcutting area. In these areas, the stream becomes shallow (less than 6 -in. (15-mm) 41 depth), the flow is moderate to swift, and riffles become numerous. Primary prey includes 42 midges, blackflies, water mites, caddisflies, and mayflies (FWS 2012d). Bayou darter spawn 43 when water temperatures rise to between 72 and 84 F (22 and 29 C), which generally occurs 44 from April to early June (FWS 2012d). Past and current threats to the Bayou darter include 45 human-induced habitat alteration, such as floodplain or channel modification, petroleum 46 exploration and transportation, and farming and forestry (FWS 2012d). 47 Affected Environment 2-58 At GGNS, MP&L did not observe bayou darter during preconstruction studies from 1972 through 1 1973 (Entergy 2011a). However, bayou darter is endemic to Bayou Pierre, which flows within 2 2 mi (3.2 km) of the GGNS site and is crossed by the Franklin transmission line. Therefore, the 3 bayou darter is likely to occur within the action area. 4 The FWS has not designated critical habitat for this species. 5 Pallid Sturgeon 6 In 1990, the FWS listed the pallid sturgeon (Scaphirhynchus albus) as endangered wherever 7 found (55 FR 36641). Pallid sturgeon have a long, uniformly grayish-white body and a flattened, 8 shovel-shaped snout. Pallid sturgeon inhabit the Mississippi and Missouri Rivers from Montana 9 to Louisiana. Within the Mississippi River, primary habitat includes the main channel, especially 10 near the river bottom. Primary prey include fish and aquatic insects (FWS 2007 a). Although 11 information on reproduction is limited, pallid sturgeon likely spawn between June and August 12 (FWS 2007a). Larval fish drift downstream from the hatching site (Kynard et al. 2002). Eleven 13 to 17 days after hatching, larvae settle from the lower portion of the water column (FWS 2007a). 14 Current threats include commercial and recreational harvest because of misidentification by 15 fishermen, habitat modification (e.g., channelization of the Mississippi River), and curtailment of 16 the species' habitat range due to the operation of dams along the Missouri River (FWS 2009). 17 During the 1972 -1973 preconstruction studies , a specimen was collected offshore of the future 18 GGNS site (Entergy 201 1a). Spawning habitat may exist within 10 mi (16 km) of the site. 19 In 2001, FWS, the Mississippi Museum of Natural Science, and the Lower Mississippi River 20 Conservation Committee conducted trawl surveys for pallid sturgeon approximately 21 38 mi (61 km) upstream of GGNS (Hartfield et al. 2001 in SERI 2005). The team observed nine 22 adult pallid sturgeon and seven intermediates (sub -adults) within a variety of channel habitats 23 that included moderate to strong currents, sand or gravel substrates, 20 -40 ft (6.1 -12.2 m) 24 depths, and usually some type of habitat structure. From 2000 -2005, USACE sampled the 25 lower Mississippi River from river miles (RMs)145 to 954. USACE collected 162 pallid sturgeon 26 from more than 130 locations (FWS 2005). FWS (2012c) stated that pallid sturgeon may occur 27 within 50 mi (80 km) of GGNS. Similarly , MDFWP (2012) stated that pallid sturgeon may occur 28 within 2 mi (3.2 km) of GGNS. Therefore, the pallid sturgeon may occur within the action area. 29 The FWS has not designated critical habitat for this species. 30 Louisiana and American Black Bears 31 The Louisiana black bear (Ursus americanus luteolus) is one of 16 recognized subspecies of 32 American black bear (U. americanus). I n 1992, the FWS published a final rule listing the 33 Louisiana black bear as threatened (57 FR 588). This final rule also listed the American black 34 bear as threatened because of its similarity in appearance to the Louisiana black bear. The 35 American black bear is listed as threatened within all Louisiana counties and those Mississippi 36 and Texas counties within the historic range of the Louisiana black bear. 37 The Louisiana black bear is distinguished from the American black bear by its longer and 38 narrower skull and larger molar teeth. The species has a brown muzzle and generally uniformly 39 black fur, although its fur can range from shades of brown to red. Adult males weigh between 40 200 and 400 lbs (90 to 180 kg), and females weigh between 120 and 200 lbs (55 to 90 kg) 41 (FWS undated a). 42 The Louisiana black bear is an opportunistic omnivore whose diet varies with food availability 43 and season. From 2002 through 2004, Benson and Chamberlain (2006) studied the diets of two 44 subpopulations in the Tensas River Basin, which lies west of the GGNS site and runs parallel to 45 the Mississippi River. The study identified corn; pokeberry (Phytolacca americana), muscadine 46 Affected Environment 2-59 (Vitis rotundifolia), and other shrubs or vine fruit; and invertebrates as the primary sources of 1 food in spring. In the fall, acorns made up a significant portion of the Louisiana black bear's 2 diet. In the winter, the species relied on acorns, grasses, sedges, and invertebrates. Louisiana 3 black bears also consume small mammals and carrion opportunistically. In areas where bears 4 are in close proximity to agricultural fields, they often consume large amounts of wheat, oats, 5 and other cereal grains (Benson 2005). 6 Louisiana black bears prefer bottomland hardwood forest habitat with relatively inaccessible 7 terrain, thick understory vegetation, and abundant hard (acorns and nuts) and soft (leaf buds, 8 berries, drupes) mast (74 FR 10350). Studies indicate that individual home ranges of Louisiana 9 black bears are rather large and habitat use varies widely by gender, season, food availability, 10 and reproductive status. In a movement ecology study, Marchinton (1995) found that males 11 have a mean home range of about 52 km 2 (20 mi 2), while females have a mean home range of 12 about 13 km 2 (5 mi 2), and that ranges for both sexes were largest in fall. The Louisiana Black 13 Bear Recovery Plan (FWS 1995) indicates that in the Tensas River Basin, males and females 14 may have a home range of up to 162 km 2 (63 mi 2) and 73 km 2 (28 mi 2), respectively. The 15 smaller mean range of females could correlate with reproduction. Females may restrict their 16 ranges while rearing cubs because of the limited mobility of young in the first few months of life 17 (Lindzey and Meslow 1977). Availability of covered corridors between fragmented forest 18 habitats also affects individual ranges. 19 Females breed at three to four years of age and give birth to one to three cubs in late January to 20 early February while hibernating. Females and their cubs emerge from dens in late March to 21 late May, and females continue to care for cubs until their second summer. Thus, females 22 reproduce at most every other year. 23 Historically, the species occurred across North America as far north as Alaska and south to 24 Mexico. The species now occurs in two core populations within the Tensas and Atchafalaya 25 River Basins in Louisiana and in small, scattered populations in Mississippi. Continued habitat 26 fragmentation from transportation development, agricultural activities, and urban sprawl as well 27 as human-induced mortality from poaching and vehicle strikes threaten the continued existence 28 of the Louisiana black bear (74 FR 10350). 29 The FES for construction of GGNS (AEC 1973) did not identify either the Louisiana or American 30 black bears as likely to occur on the GGNS site. However, the Final ER for operation of GGNS 31 (MP&L 1981) indicates that black bears (subspecies unidentified) were observed on the GGNS 32 site four times in 1977, and several bear tracks and other signs of inhabitance were observed in 33 the bottomlands south of the GGNS property line. MP&L (1981) did not indicate that these 34 observations were part of any formal surveys; they appear to have been causal sightings 35 recorded by construction or site staff. 36 Entergy commissioned a field survey for suitable Louisiana black bear habitat on GGNS in 37 December 2006 (Wenstrom 2007a). The survey identified 30 trees that met the FWS's criteria 38 of candidate trees for black bear den habitat. The trees included water oak (Quercus nigra), 39 chinquapin oak (Quercus muehlembergii), and other oaks, pecans (Carya spp.), and elms 40 (Ulmus spp.) of 36 in. (91 cm) diameter at breast height or larger. Only one tree had a cavity, 41 which was open and exposed. None of the trees had enclosed cavities, claw marks, or other 42 evidence of black bear use. The survey also identified one potential ground den about 400 ft 43 (121 m) north of the heavy haul road and 3,800 ft (1,200 m) east of the Mississippi River. The 44 survey noted numerous foraging areas containing blackberry (Rubus trivialis) thickets or shallow 45 water in bottomlands scattered throughout the GGNS site. Wenstrom (2007a) concluded that 46 the site contains suitable habitat for black bear foraging and denning, but the survey did not 47 reveal any evidence of current use by bears. 48 Affected Environment 2-60 Based on historic occurrence and recent habitat surveys of the GGNS site, the NRC assumes 1 that the Louisiana and American black bears occur in the action area. 2 Designated critical habitat for the Louisiana black bear is discussed below. The FWS has not 3 designated critical habitat for the American black bear. 4 Louisiana Black Bear Critical Habitat 5 The FWS published a final rule to designate Louisiana black bear critical habitat in 2009 6 (74 FR 10350). The FWS did not designate any land within Mississippi as critical habitat; the 7 closest critical habitat lies along the Tensas River Basin about 16 mi (26 km) west of the GGNS 8 site at its closest point (Entergy 2011a; NRC 2006 a). The FWS has designated a total of 9 628,505 ac (254,347 ha) of habitat as critical within this basin, of which about a third is owned 10 by the Federal or State government (74 FR 10350). However, because no critical habitat 11 occurs within the action area, the NRC will not analyze designated Louisiana black bear habitat 12 in any further detail in this SEIS. 13 Fat Pocketbook Mussel 14 In 1976, the FWS listed the fat pocketbook mussel (Potamilus capax) as endangered wherever 15 found (41 FR 24062). Fat pocketbook mussels are large freshwater mussels that grow up to 16 130 mm (5.1 in) in length (FWS 2012e). The shells are shiny and tan or light brown without 17 rays. Fat pocketbook mussels inhabit sand, mud, and silt substrates (FWS 2007b). Similar to 18 other freshwater mussels, fat pocketbook mussels filter feed by siphoning phytoplankton, 19 zooplankton, detritus, and diatoms from the water. 20 During the reproductive cycle, males release sperm into the water column that are sucked in by 21 females through their siphons during feeding and respiration. Fertilized eggs develop into 22 larvae (glochidia) within the gills of females. After releasing the mussel glochidia into the water, 23 the glochidia must attach to the appropriate species of fish, which they parasitize until they 24 develop into juvenile mussels (FWS 2012e). 25 Historically, fat pocketbook mussels inhabited a significant portion of the Mississippi River, from 26 the confluence of the Minnesota and St. Croix rivers, in Minnesota, downstream to the White 27 River system in Arkansas (FWS 2007b). While most historical records are from the upper 28 Mississippi River, FWS (2007b) was not aware of any records of occurrence within the upper 29 Mississippi River within the past two decades. Within the Lower Mississippi River, these 30 mussels currently inhabit some secondary channels and side channels along a 300 -mi (480-km) 31 stretch of the Mississippi River that includes the GGNS area (FWS 2007b). In 2003, Mississippi 32 Museum of Natural Science biologists collected 16 dead shells and 1 live fat pocketbook in the 33 Ben Lomond Dike Field near Vicksburg in the Mississippi River channel (FWS 2004). These 34 mussels also occur downstream of GGNS in St. Catherine Creek Wildlife Refuge on the 35 Mississippi River near Natchez (FWS 2006). 36 At GGNS, MP&L did not observe fat pocketbook mussels during preconstruction studies fro m 37 1972-1973 (Entergy 2011a). In November 2006, AAI conducted a mussel survey in support of 38 Entergy's COL application. The purpose of the survey was to determine whether any mussels 39 occurred along the east Mississippi River bank near RM 406, which is near the discharge 40 structure (Entergy 2008 b). Survey methods included visual surveys of dead mussel shells 41 along four shoreline sites and visual underwater surveys for live mussels along six transects. 42 AAI did not observe any dead or live fat pocketbook mussels. As a result of these surveys, AAI 43 concluded that mussel colonization near GGNS was not likely (Entergy 2008 b). 44 In correspondence with the NRC, FWS Louisiana Ecological Services Office stated that the fat 45 pocketbook occurs within 50 mi (80 km) of GGNS (FWS 2012 c). However, MDWFP (2012) did 46 Affected Environment 2-61 not identify the fat pocketbook as occurring within 2 mi (3.2 km) of GGNS. Given that MP&L 1 and AAI did not observe any dead or live fat pocketbook mussels at GGNS and MDFWP (2012) 2 did not identify fat pocketbook mussels within 2 mi (3.2 km) of GGNS, the NRC staff concludes 3 that this species is not likely to occur within the action area. The FWS has not designated 4 critical habitat for this species. 5 Rabbitsfoot Mussel 6 The FWS issued a proposed rule to list the rabbitsfoot mussel (Quadrula cylindrica ssp. 7 cylindrica) as threatened under the ESA in October 2012 (77 FR 63439). The ESA allows the 8 FWS one year from the publication of its proposed rule to make a final determination as to 9 whether to list the rabbitsfoot mussel as threatened. 10 Rabbitsfoot mussels are freshwater, medium to large -sized mussels that grow to about 11 6 in. (15 cm) in length (FWS 2010). Rabbitsfoot mussels filter feed by siphoning phytoplankton, 12 zooplankton, detritus, and diatoms from the water. Similar to fat pocketbook and other 13 freshwater mussels, male rabbitsfoot mussels release sperm into the water column that are 14 sucked in by females and develop into glochidia (FWS 2010). 15 At GGNS, MP&L did not observe rabbitsfoot mussels during preconstruction studies from 16 1972-1973 (Entergy 201 1a). As described above, in November 2006, AAI conducted a mussel 17 survey in support of Entergy's COL application (Entergy 2008 b). AAI did not observe any dead 18 or live rabbitsfoot mussels. As a result of these surveys, AAI concluded that mussel 19 colonization near GGNS was not likely (Entergy 2008 b). 20 In correspondence with natural resource agencies, FWS Louisiana Ecological Services Office, 21 FWS Mississippi Field Office, and MDWFP did not include rabbitsfoot mussel as a species that 22 occurs within the action area (FWS 2012 d, 2012 c; MDWFP 2012). Therefore, the NRC staff 23 concludes that this species is not likely to occur within the action area. 24 Rabbitsfoot Mussel Proposed Critical Habitat 25 The FWS proposed critical habitat for the rabbitsfoot mussel with its October 2012 Federal 26 Register notice issuing a proposed rule to list the species as threatened under the ESA 27 (77 FR 63439). The rule proposes critical habitat within 10 states in the midwest and 28 southeastern U.S. Within Mississippi, proposed critical habitat occurs within Hinds, Sunflower, 29 Tishomingo, and Warren Counties. The only county applicable to the proposed GGNS license 30 renewal action area is Warren County, in which one proposed critical habitat unit occurs: RF17 31 (Big Black River). RF17 includes 43.3 river kilometers (26.9 river miles) of the Big Black River 32 from the Porter Creek confluence west of Lynchburg, Hinds County, Mississippi, downstream to 33 Mississippi Highway 27 west of Newman, Warren County, Mississippi (77 FR 63439). 34 Within the action area, the Baxter -Franklin transmission line corridor traverses the Big Black 35 River in Claiborne County. However, the corridor does not traverse this river within Warren 36 County where the proposed critical habitat unit RF17 is located. The portion of the 37 Baxter-Franklin transmission line in Warren County is a 2.2 -mi (3.5-km) stretch in the western 38 portion of the county. RF17 occurs in the eastern portion of the county. Thus, the NRC will not 39 analyze proposed rabbitsfoot mussel critical habitat in any further detail in this SEIS. 40 2.2.8.4 Species Protected by the State of Mississippi 41 Aquatic Species 42 Crystal Darter The State of Mississippi considers crystal darters (Crystallaria asprella) 43 endangered . These fish are elongated, cigar -shaped fish that grow to a maximum length of 44 approximately 150 mm (6 in.). The body is light -olive with dark lateral bands and dark blotches 45 along each side (MDWFP 2001). Crystal darters inhabit larger creeks and rivers with sand and 46 Affected Environment 2-62 gravel bottoms and a depth of 60 cm (2 ft) or more. These fish prefer moderate to strong 1 currents. The historical range of crystal darters included Wisconsin east to Ohio and south to 2 Oklahoma, Louisiana and Florida, although they currently are absent from all of Ohio, Indiana, 3 and Illinois (MDWFP 2001). Crystal darters inhabit the Bayou Pierre River and tributaries, 4 which flow as close as 2 mi (3.2 km) east of GGNS (MDWFP 2001; Entergy 2011a). The FES 5 for construction of GGNS (AEC 1973) and the ESP EIS (NRC 2006 a) did not identify crystal 6 darter as occurring on the GGNS site. 7 Crystal darters may occur in suitable habitat along the transmission line corridors. For example, 8 crystal darters inhabit the Bayou Pierre, which is crossed by the Franklin transmission line. 9 However, no GGNS-related aquatic surveys have been conducted along the transmission lines. 10 Species of Special Concern In the State of Mississippi, a species of special concern includes 11 "any species that is uncommon in Mississippi, or has unique or highly specific habitat 12 requirements or scientific value and therefore requires careful monitoring of its status" 13 (MDWFP 2011). In its correspondence with the NRC, the MDWFP (2012) identified five fish 14 species considered species of special concern by the State of Mississippi: blue sucker 15 (Cycleptus elongates), chestnut lamprey (Ichthyomyzon castaneus), black buffalo 16 (Ictiobus niger), sicklefin chub (Macrhybopsis meeki), and paddlefish (Polyodon spathula). 17 These species inhabit portions of the Mississippi River (NatureServe 2010). MP&L observed 18 paddlefish, black buffalo, blue sucker, and chestnut lamprey during preconstruction surveys in 19 1972 and 1973 (AEC 1973). The FES for construction of GGNS (AEC 1973) and the ESP EIS 20 (NRC 2006 a) did not identify sicklefin chub as occurring on the GGNS site. 21 Chestnut lamprey, blue sucker, black buffalo sicklefin chub, and paddlefish may occur in 22 suitable habitat along the transmission line corridors. For example, crystal darter, chestnut 23 lamprey, blue sucker, and chestnut lamprey inhabit the Bayou Pierre, which is crossed by the 24 Franklin transmission line. However, no GGNS-related aquatic surveys have been conducted 25 along the transmission lines. 26 Terrestrial Species 27 In its correspondence with the NRC, the MDWFP (2012) identified two State -listed species that 28 may occur in the action area: Webster's salamander (Plethodon websteri) and the white ibis 29 (Eudocimus albus). Webster's salamander is a small salamander with several color morphs 30 that occurs in mesophytic forest bordering rocky streams. It generally seeks shelter under logs, 31 bark, or leaf litter on the forest floor or on rocky stream beds. The white ibis is a large white bird 32 that nests in large groups in coastal marshes along the Atlantic and Gulf coasts. The FES for 33 construction of GGNS (AEC 1973) and the ESP EIS (NRC 2006 a) identify the white ibis as 34 occurring on the GGNS site. The species is also likely to occur in suitable habitat along the 35 transmission line corridors. Because the MDWFP (2012) did not identify any impacts of the 36 proposed license renewal that would affect these species, neither the Webster's salamander nor 37 the white ibis will be considered in further detail in this SEIS. 38 2.2.8.5 Species Protected Under the Bald and Golden Eagle Protection Act 39 The Bald and Golden Eagle Protection Act prohibits anyone from taking bald eagles 40 (Haliaeetus leucocephalus) or golden eagles (Aquila chrysaetos), including their nests or eggs, 41 without an FWS -issued permit. The term "take" in the Act is defined as to "pursue, shoot, shoot 42 at, poison, wound, kill, capture, trap, collect, molest, or disturb" (50 CFR 22.3). "Disturb" means 43 to take action that (1) causes injury to an eagle, (2) decreases its productivity by interfering with 44 breeding, feeding, or sheltering behavior, or (3) results in nest abandonment (50 CFR 22.3). 45 Bald eagles live and nest along the Mississippi River, but no studies are available on nesting 46 or population status in the action area. However, Entergy commissioned a one -day 47 Affected Environment 2-63 reconnaissance field survey to identify bald eagle nests along the Mississippi River in the 1 vicinity of GGNS in December 2006 (Wenstrom 2007b). The survey did not identify any bald 2 eagle nests or any eagles scavenging or perched in the survey area that would indicate bald 3 eagles may nest along this portion of the river (Wenstrom 2007b). 4 2.2.8.6 Species Protected Under the Migratory Bird Treaty Act 5 The FWS administers the Migratory Bird Treaty Act (MBTA), which prohibits anyone from taking 6 native migratory birds or their eggs, feathers, or nests. The MBTA definition of a "take" differs 7 from that of the ESA and is defined as "to pursue, hunt, shoot, wound, kill, trap, capture, or 8 collect, or any attempt to carry out these activities" (50 CFR 10.12). Unlike a take under the 9 ESA, a take under the MBTA does not include habitat alteration or destruction. The MBTA 10 protects a total of 1,007 migratory bird species (75 FR 9282). Of these 1,007, the FWS allows 11 for the legal hunting of 58 species as game birds (FWS undated b). Within Mississippi, the 12 MDWFP manages migratory bird hunting seasons and associated licenses for turkeys, 13 waterfowl, quail, and doves. The Federally and State -listed bird species that appear in 14 Table 2-6 are protected under the MBTA. Table 2 -4 lists other bird species that commonly 15 occur on or near the GGNS site, all of which are protected by the MBTA. Additionally, all U.S. 16 native bird species that belong to the families, groups, or species listed at 10 CFR 10.13 are 17 protected under the MBTA. 18 Entergy holds a depredation permit from the FWS that authorizes Entergy to take 200 cliff 19 swallows (Petrochelidon spp.), 200 cliff swallow nests (including eggs), 200 barn swallows 20 (Hirundo rustica), and 200 barn swallow nests (including eggs) per year to mitigate the 21 safety-related concern that the birds pose when nesting on certain plant structures 22 (FWS 2012 a). The permit directs Entergy to favor the use of hazing, harassment, or other 23 non-lethal techniques over lethal techniques. From 2006 through 2010, Entergy took 13 cliff 24 swallows and 7 eggs in 2006 and 4 barn swallows in 2009 (Entergy 2007, 2008a, 2009, 2010a, 25 2011b). 26 2.2.9 Socioeconomics 27 This section describes current socioeconomic factors that have the potential to be directly o r 28 indirectly affected by changes in operations at GGNS. GGNS, and the communities that 29 support it, can be described as a dynamic socioeconomic system. The communities supply the 30 people, goods, and services required to operate the nuclear power plant. Power plant 31 operations, in turn, supply wages and benefits for people and dollar expenditures for goods and 32 services. The measure of a community's ability to support GGNS operations depends on its 33 ability to respond to changing environmental, social, economic, and demographic conditions. 34 The socioeconomics region of influence (ROI) is defined by the areas where GGNS employees 35 and their families reside, spend their income, and use their benefits, thus affecting the economic 36 conditions of the region. GGNS employs a permanent workforce of approximately 37 690 employees (Entergy 2011a). Approximately 81 percent live in Claiborne, Hinds, Jefferson, 38 and Warren counties (see Table 2-7). Most of the remaining 19 percent of the workforce are 39 spread among 13 counties in Mississippi, with numbers ranging from one to 31 employees per 40 county. Given the residential locations of GGNS employees, the most significant effects of plant 41 operations are likely to occur in Claiborne, Hinds, Jefferson, and Warren counties; therefore , 42 these four counties are the GGNS ROI. The focus of the socioeconomic impact analysis in this 43 document is, therefore, on the impacts of continued GGNS operation on these four counties. 44 Affected Environment 2-64 Table 2-7. 2009 GGNS Employee Residence by County 1 County Number of Employees Percentage of Total Mississippi Warren 240 35 Claiborne 142 21 Hinds 94 14 Jefferson 82 12 Copiah 31 4 Adams 30 4 Lincoln 23 3 Other 37 5 Other states 11 2 Total 690 100 Source: Entergy 2011a Refueling outages at the GGNS typically have occurred at 18 -month intervals. During refueling 2 outages, site employment increases by as many as 700 -900 temporary workers for 3 approximately 25 -30 days (Entergy 2011a). Outage workers are drawn from all regions of the 4 country; however, the majority would be expected to come from Mississippi, Louisiana, and 5 other southeastern states. The following sections describe the housing, public services, offsite 6 land use, visual aesthetics and noise, population demography, and the economy in the ROI 7 surrounding GGNS. 8 2.2.9.1 Housing 9 The socioeconomic ROI is dominated by Hinds County, which is part of the Jackson 10 metropolitan area. The size of the Jackson area weighs heavily on the housing statistics, as the 11 rural counties of Claiborne and Jefferson are considerably different than the ROI averages 12 would indicate. Table 2-8 lists the total number of occupied and vacant housing units, vacancy 13 rates, and median home value in the four -county ROI. According to the 2010 Census, there 14 were approximately 133,096 housing units in the socioeconomic region, of which approximately 15 113,607 were occupied. The median values of owner -occupied housing units in the ROI range 16 from $53,500 in Claiborne County to $105,000 in Hinds County. The vacancy rate also ranged 17 considerably, from 11.5 percent in Warren County to 23.8 percent in Jefferson County 18 (USCB 2012). 19 Table 2-8. Housing in GGNS ROI 20 2006-20 10 , 5-year Estimate Claiborne Hinds Jefferson Warren ROI Total 4,255 103,351 3,717 21,773 133,096 Occupied housing units 3,308 88,201 2,831 19,267 113,607 Vacant units 947 15,150 886 2,506 19,489 Vacancy rate (percent) 22.3 14.7 23.8 11.5 14.6 Median value (dollars) 53,500 105,000 67,000 99,700 101,400 Source: USCB 2012

Affected Environment 2-65 2.2.9.2 Public Services 1 This section presents information on public services that include water supply, education, and 2 transportation. 3 Water Supply 4 Information about municipal water suppliers in close proximity to GGNS and maximum design 5 yields, reported annual peak usage, and population served are presented in Table 2 -9. The 6 source of potable water at GGNS is Entergy's private water system accessing groundwater. 7 Table 2-9. Claiborne County Public Water Supply Systems 8 Water System Capacity (GPM) Usage (GPM) Population Served Alcorn State University 1,136 646 3,824 CS&I Water Association #1 288 185 1,100 Hermanville Water Association 552 160 1,230 Pattison Water Association -West 982 389 2,994 Reedtown Water Association 243 35 504 Romola Water Association 556 155 650 Town of Port Gibson 850 587 4,308 Entergy Operations Inc. (private) 1,335 223 1,000 Sources: Entergy 2011a; EPA 2012e Beyond the water systems near GGNS, larger systems supply water to Vicksburg, Clinton, and 9 Jackson, Mississippi. These systems use groundwater wells with the exception of the City of 10 Jackson, which relies on Lake Jackson to provide water to a population of approximately 11 176,000 (EPA 2012e). 12 Education 13 The Claiborne County School District has one elementary school, one middle school, and one 14 high school. During the 2009 -2010 school year, enrollment was 1,723 students (NCES 2012a). 15 Hinds County has four public school districts and 42 elementary schools, 17 middle schools, 16 11 high schools, and 16 alternative or special needs schools. The enrollment in 2009 was over 17 42,200 students (NCES 2012a). 18 The Jefferson County School District has two elementary schools, one middle school, one high 19 school, and two alternative or vocational schools. The enrollment during the 2009 -2010 school 20 year was 1,465 students (NCES 2012a). 21 The Vicksburg -Warren School District serves all of Warren County and includes eight 22 elementary schools, four middle schools, two high schools, and two alternative or vocational 23 schools. During the 2009 -2010 school year, enrollment was 8,871 students (NCES 2012a). 24 Transportation 25 The area surrounding GGNS is largely rural. Highway access to Claiborne County and GGNS 26 from population centers is via US -61, a principal arterial paralleling the Mississippi River along 27 much of its course. Interstate 20 is a four -lane divided highway that runs east and west, 28 Affected Environment 2-66 connecting Dallas, TX with Jackson, MS, and passes through 1 Vicksburg-about 25 mi north of GGNS. US -84 is also a four -lane divided highway that lies 2 about 30 mi south of GGNS, and runs east -west, connecting Interstate 49 in Louisiana with 3 Interstate 55 in central Mississippi. The Natchez Trace Parkway, administered by the National 4 Park Service, preserves a transportation route of Civil War historical significance and provides 5 tourist access to Jefferson and Claiborne counties as it traverses a route between Natchez and 6 Clinton. 7 Table 2-10 lists commuting routes to GGNS and average annual daily traffic (AADT) volume 8 values. The AADT values represent traffic volume during the average 24 -hour period 9 during 2011. 10 Table 2-10. Major Commuting Routes Near GGNS 2011 Average Annual Daily Traffic 11 Roadway and Location Average Annual Daily Traffic Grand Gulf R oad at GGNS main gate 1,600 Old Mill R oad between Grand Gulf R oad and Bald Hill R oad 860 Grand Gulf R oad between Lake Claiborne R oad and Old Mill R oad 980 Grand Gulf R oad between US Hwy 61 and Lake Claiborne R oad 1,200 US Hwy 61 between Shiloh R oad and Willow R oad 7,500 US Hwy 61 between Natchez Trace Pkwy and McComb Avenue 6,600 Source: MDOT 2012 2.2.9.3 Offsite Land Use 12 Land use in the GGNS ROI primarily consists of agricultural lands, with small urban areas and 13 undeveloped forested land. 14 Claiborne County occupies approximately 487 mi 2 (1,247 square kilometers (km 2)) 15 (USCB 2012). Agricultural and forested lands make up the majority of the land used, with urban 16 lands making up about 4 percent of the total county land area (USDA NASS 2012). The 17 principal agriculture land use is pasture and hay crops and livestock products, with the market 18 value of crops (mostly cotton and soybeans) being about double that of livestock, poultry, and 19 their products. The number of farms in Claiborne County decreased about 12 percent from 20 2002-2007. Farmland acreage in the county decreased 7 percent during the same period, and 21 the average size of a farm increased 6 percent to 360 ac (146 ha) (USDA NASS 2009). 22 Hinds County occupies approximately 869 mi 2 (2,251 km 2) (USCB 2012). Hinds County is 23 home to part of Jackson, the State capital and largest city in Mississippi, along with Clinton, a 24 principal suburb of Jackson. Nearly 14 percent of the county is urbanized (USDA NASS 2012). 25 The majority of the county land area is either forested (40 percent) or agricultural land 26 (30 percent). The principal crop is livestock forage (i.e., hay and grass silage), followed by 27 cotton and nursery and greenhouse products. Livestock (mostly cattle and calves) is about 28 23 percent the market value for all agriculture products. The number of farms in Hinds County 29 decreased from 2002 -2007 by 14 percent. Farmland acreage in the county decreased 30 seven percent during the same period, and the average size of a farm increased 9 percent to 31 24 ac (98 ha) (USDA NASS 2009). 32 Jefferson County covers approximately 519 mi 2 (1,344 km 2) (USCB 2012). Jefferson County is 33 mainly rural, with just 4 percent of the county urbanized (USDA NASS 2012). Undeveloped 34 forest, grassland, and wetlands make up over 87 percent of the county's land area. The 35 Affected Environment 2-67 principal crop is livestock forage (i.e., hay and grass silage), followed by cotton and nursery and 1 greenhouse products. Livestock (mostly poultry and cattle) is about 70 percent the market 2 value for all agriculture products. The number of farms in Jefferson County increased from 3 2002-2007 by 13 percent. Farmland acreage in the county also increased 10 percent during 4 the same period, and the average size of a farm increased 2 percent to 282 ac (114 ha) 5 (USDA NASS 2009). 6 Warren County occupies approximately 587 mi 2 (1,520 km 2) (USCB 2012). Nearly 7 seven percent of the county is urbanized (USDA NASS 2012), with Vicksburg being the 8 principal city. The majority of the county land area is either forested (about 40 percent) or 9 wetlands (about 30 percent). The principal crops are soybeans and cotton, making up over 10 85 percent of the value of all agricultural products. The number of farms in Warren County 11 remained stable over the 2002 -2007 period, as has farmland acreage. The average size of a 12 farm is 403 ac (163 ha) (USDA NASS 2009). 13 2.2.9.4 Visual Aesthetics and Noise 14 GGNS is situated on a relatively flat bluff above the shore of the Mississippi River. Predominant 15 features include the containment structure, turbine building, auxiliary building, control building, 16 diesel generator building, standby service water cooling towers and basins, enclosure building, 17 radwaste building, independent spent fuel storage installation (ISFSI), auxiliary cooling tower, 18 and the natural draft cooling tower (Entergy 2011a). 19 There is often a visible plume of condensation rising up from the cooling towers. Its height and 20 visibility depend on weather conditions such as temperature, humidity, and wind speed. It is 21 typically several hundred feet tall and can be seen from several miles away. Because of the 22 open and flat terrain on the Louisiana side of the Mississippi River, the plume and the cooling 23 tower are clearly seen from US -65 in Louisiana for many miles in all directions. The rolling and 24 forested terrain of Claiborne County provides significant visual screening in the immediate 25 vicinity of GGNS. 26 Noise from nuclear plant operations can be detected off site. There are no local noise 27 ordinances that limit allowable sound levels at GGNS. The staff determined background noise 28 levels at GGNS are expected to range from 45 to 55 dBA at the nearest site boundary 29 (NRC 2006a). Noise levels may sometimes exceed the 55 -decibel adjusted level that the EPA 30 uses as a threshold level to protect against excess noise during outdoor activities. However, 31 according to the EPA this threshold does "not constitute a standard, specification, or regulation," 32 but was intended to give a basis for state and local governments establishing noise standards 33 (EPA 1974). 34 2.2.9.5 Demography 35 According to the 2010 Census, an estimated 23,406 people live within 20 mi (32 km) of GGNS, 36 which equates to a population density of 19 persons per mi 2 (Entergy 2011a). This translates to 37 a Category 1, "most sparse" population density using the GEIS measure of sparseness (less 38 than 40 persons per mi 2 and no community with 25,000 or more persons within 20 mi). An 39 estimated 329,043 people live within 50 mi (80 km) of GGNS with a population density of 40 42 persons per mi 2 (Entergy 2011a). Since Jackson is located beyond 50 mi from GGNS, this 41 translates to a Category 1 density, using the GEIS measure of proximity (no cities with 42 100,000 or more persons and less than 50 persons per mi 2 within 50 mi). Therefore, GGNS is 43 located in a low population area based on the GEIS sparseness and proximity matrix. 44 Table 2-11 shows population projections and growth rates from 1970 -2050 in the four -county 45 GGNS ROI. The net population growth rate in the ROI has been negative over the last two 46 decades. Based on State forecasts, rural counties are expected to continue to decline in 47 Affected Environment 2-68 population through 2025, while more developed urban counties are expected to continue 1 modest growth through 2025 (MIHL 2012). Beyond 2025, the staff applied the 50 -year trend in 2 population, observed between 1970 and 2020 projections, to approximate long -term trends. 3 Table 2-11. Population and Percent Growth in GGNS ROI Counties 4 from 1970-2009 and Projected for 2010 -2050 5 Year Claiborne Hinds Jefferson Warren Popu- lation Percent growth(a) Popu- lation Percent growth(a) Popu- lation Percent growth(a) Popu- lation Percent growth(a) 1970 10,086 - 214,973 - 9,295 - 44,981 - 1980 12,279 21.7% 250,998 16.8% 9,181 -1.2% 51,627 14.8% 1990 11,370 -7.4% 254,441 1.4% 8,653 -5.8% 47,880 -7.3% 2000 11,831 4.1% 250,800 -1.4% 9,740 12.6% 49,644 3.7% 2010 9,604 -18.8% 245,285 -2.2% 7,726 -20.7% 48,773 -1.8% 2020 8,700 -9.4% 250,264 2.0% 7,074 -8.4% 48,030 -1.5% 2030 8,676 -0.3% 251,086 0.3% 7,040 -0.5% 48,095 0.1% 2040 8,652 -0.3% 251,910 0.3% 7,006 -0.5% 48,160 0.1% 2050 8,628 -0.3% 252,737 0.3% 6,973 -0.5% 48,225 0.1% - = No data available.

(a) Percent growth rate is calculated over the previous decade.

Sources: Population data for 1970 through estimated population data for 2009 (USCB 2012); population projections for 2020 by Mississippi Institutions of Higher Learning (MIHL2012); 2030 -2050 calculated. Demographic Profile 6 According to the 2010 Census, minority populations were estimated to have increased by over 7 17,100 persons and comprised 69.4 percent of the ROI population (see Table 2 -12). Most of 8 this increase was due to an estimated influx of African Americans to urban centers such as 9 Jackson and Vicksburg, while minority populations in rural counties declined over the same 10 period. 11 Affected Environment 2-69 Table 2-12. Demographic Profile of the Population in the GGNS ROI in 2010 1 Claiborne Hinds Jefferson Warren ROI Total Population 9,604 245,285 7,726 48,773 311,388 Race (percent of total population, Not -Hispanic or Latino) White 14.1 28.0 13.7 49.5 30.6 Black or African American 84.0 68.8 85.4 46.8 66.3 American Indian and Alaska Native 0.1 0.1 0.2 0.2 0.2 Asian 0.4 0.8 0.0 0.8 0.7 Native Hawaiian Other Pacific Islander 0.0 0.0 0.0 0.0 0.0 Some other race 0.1 0.1 0.0 0.0 0.1 Two or more races 0.5 0.7 0.3 0.7 0.7 Ethnicity Hispanic or Latino 74 3,630 28 896 4,628 Percent of total population 0.8 1.5 0.4 1.8 1.5 Minority population (including Hispanic or Latino ethnicity) Total minority population 8,251 176,676 6,670 24,630 216,227 Percent minority 85.9 72.0 86.3 50.5 69.4 Source: USCB 2012. Transient Population 2 Within 50 mi (80 km) of GGNS, colleges and recreational opportunities attract daily and 3 seasonal visitors who create demand for temporary housing and services. In 2010, there were 4 approximately 21,859 students attending colleges and universities within 50 mi (80 km) of 5 GGNS (NCES 2012b). 6 Based on the 2010 Census, approximately 10,471 seasonal housing units are located within 7 50 mi of GGNS. Of those, 1,536 are located in the GGNS four-county ROI. Table-13 supplies 8 information on seasonal housing for the counties located all or partly within 50 mi of GGNS. 9 Affected Environment 2-70 Table 2-13. 2010 Seasonal Housing in Counties within 50 miles of GGNS 1 County(a) Housing Units Vacant Housing Units: for Seasonal, Recreational, or Occasional Use Percent Mississippi Adams 14,771 649 4.4 Amite 6,638 553 8.3 Claiborne 4,255 388 9.1 Copiah 12,056 323 2.7 Franklin 4,170 482 11.6 Hinds 103,351 458 0.4 Issaquena 712 46 0.4 Jefferson 3,717 350 6.5 Lincoln 15,101 411 9.4 Madison 37,349 375 2.7 Rankin 55,200 544 1.0 Sharkey 2,065 167 1.0 Simpson 11,837 94 8.1 Warren 21,773 340 0.8 Wilkinson 5,085 928 1.6 Yazoo 10,094 374 18.2 County Subtotal 308,174 6,482 2.1 Louisiana Caldwell 5,014 622 12.4 Catahoula 4,987 779 15.6 Concordia 9,369 931 9.9 East Carroll 2,813 65 2.3 Franklin 8,987 295 3.3 Madison 4,827 235 4.9 Richland 8,557 442 5.2 Tensas 3,357 620 18.5 County Subtotal 47,911 3,989 8.3 Total 356,085 10,471 2.9 (a) Counties within 50 mi (80 km) of GGNS with at least one block group located within the 50 -mi (80-km) radius. Source: USCB 2012. Migrant Farm Workers 2 Migrant farm workers are individuals whose employment requires travel to harvest agricultural 3 crops. These workers may or may not have a permanent residence. Some migrant workers 4 follow the harvesting of crops, particularly fruit, throughout rural areas of the United States. 5 Others may be permanent residents near GGNS and travel from farm to farm harvesting crops. 6 Affected Environment 2-71 Migrant workers may be members of minority or low -income populations. Because they travel 1 and can spend a significant amount of time in an area without being actual residents, migrant 2 workers may be unavailable for counting by census takers. If uncounted, these workers would 3 be "underrepresented" in U.S. Census Bureau (USCB) minority and low -income population 4 counts. 5 Information on migrant farm and temporary labor was collected in the 2007 Census of 6 Agriculture. Table 2-14 supplies information on migrant farm workers and temporary farm labor 7 (less than 150 days) within 50 mi of GGNS. According to the 2007 Census of Agriculture, 8 approximately 6,440 farm workers were hired to work for less than 150 days and were 9 employed on 1,419 farms within 50 mi of GGNS. The county with the largest number of 10 temporary farm workers (1,152) on 185 farms was Franklin County, Louisiana 11 (USDA NASS 2009). 12 Affected Environment 2-72 Table 2-14. Migrant Farm Workers and Temporary Farm Labor in Counties Located 1 within 50 Miles of GGNS 2 County(a) Number of Farms with Hired Farm Labor Number of Farms Hiring Workers for Less than 150 days Number of Farm Workers Working for Less than 150 days Number of Farms Reporting Migrant Farm Labor Mississippi Adams 30 24 (b) 3 Amite 91 72 339 7 Claiborne 49 47 176 3 Copiah 108 86 438 2 Franklin 22 20 64 2 Hinds 142 108 344 9 Issaquena 28 15 76 3 Jefferson 56 38 143 0 Lincoln 125 100 401 6 Madison 134 95 280 9 Rankin 138 108 364 5 Sharkey 38 7 171 4 Simpson 114 95 300 5 Warren 50 40 157 2 Wilkinson 49 38 155 0 Yazoo 121 77 508 7 Subtotal 1,295 970 3,916 67 Louisiana Caldwell 65 58 139 4 Catahoula 61 36 218 4 Concordia 61 33 198 1 East Carroll 75 25 178 2 Franklin 250 185 1152 6 Madison 67 28 156 4 Richland 112 74 250 13 Tensas 59 10 233 5 Subtotal 750 449 2,524 39 Total 2,045 1,419 6,440 106 (a) Counties within 50 miles of GGNS with at least one block group located within the 50 -mi radius. (b) Data not disclosed by USDA. Source: 2007 Census of Agriculture -County Data (USDA NASS 2009). In the 2002 Census of Agriculture, farm operators were asked for the first time whether or not 3 they hired migrant workers -defined as a farm worker whose employment required travel -to 4 do work that prevented the migrant worker from returning to their permanent place of residence 5 the same day. A total of 106 farms, in the 50 -mi radius of GGNS, reported hiring migrant 6 Affected Environment 2-73 workers in the 2007 Census of Agriculture. Richland County, Louisiana, reports the most farms 1 with migrant farm labor (13 farms) (USDA NASS 2009). 2 2.2.9.6 Economy 3 This section contains a discussion of the economy, including employment and income, 4 unemployment, and taxes. 5 Employment and Income 6 From 2000 to 2012, the civilian labor force in the GGNS ROI declined by about 5 percent to just 7 over 147,000. The number of employed persons declined by about 7 percent over the same 8 period, to about 135,000. Consequently, the number of unemployed people in the ROI has 9 increased over 36 percent in the same period, to over 12,200, or about 8.3 percent of the 10 current workforce (BLS 2012). 11 In 2010, state and local government made up the largest sector of the economy in terms of 12 employment (19.6 percent), followed by health care and social assistance (13.9 percent), retail 13 trade (8.2 percent), administrative services (6.4 percent) and accommodations and food 14 services (6.2 percent) (BEA 2012). A list of selected major employers in the ROI is given in 15 Table 2-15. As shown in the table, GGNS is the 22nd largest employer in the ROI and the 16 second largest in Claiborne County. 17 Affected Environment 2-74 Table 2-15. Major Employers of the GGNS ROI in 2012 1 Employer Number of Employees County State of Mississippi 31,556 Hinds University Medical Center 8,000 Hinds U.S. Government 5,500 Hinds Jackson Public Schools 4,814 Hinds Baptist Health Systems 2,875 Hinds St. Dominic Health Services 2,600 Hinds City of Jackson 2,323 Hinds Jackson State University 1,667 Hinds USACE Engineer Research & Development Center 1,600 Warren River Region Health Systems 1,500 Warren AT&T Mississippi 1,300 Hinds Vicksburg-Warren School District 1,300 Warren Central MS Medical Center 1,200 Hinds USACE, Division/District 1,100 Warren Trustmark National Bank 1,075 Hinds Delphi Mississippi 1,075 Hinds Ameristar Casino 900 Warren Saks Incorporated 800 Hinds Entergy Mississippi 765 Hinds Alcorn State University 750 Claiborne LeTourneau Technologies 750 Warren Grand Gulf Nuclear Station 691 Claiborne Tyson Foods 680 Warren Eaton Aerospace 625 Hinds DiamondJacks Casino Hotel 588 Warren City of Vicksburg 586 Warren Walmart Supercenter 550 Warren Jefferson Co School District 100 Jefferson Southern Lumber Co., Inc. 80 Claiborne MMC Materials, Inc. 32 Claiborne Source: Port Gibson Chamber (2012), Warren Co. Port Commission (2012), Hinds Co. Economic Development Authority (2008). Smaller Jefferson and Claiborne County employers are shown to be representative. Estimated income information for the GGNS ROI is presented in Table 2 -16. According to the 2 USCB's 2006 -2010 American Community Survey 5 -Year Estimates, people living in Claiborne 3 and Jefferson Counties had median household and per capita incomes below the State 4 average, while Hinds and Warren counties had median incomes higher than the State average. 5 The same trend is evident for families and individuals living below the official poverty level. The 6 relative lack of economic development in Claiborne and Jefferson counties contributes to higher 7 Affected Environment 2-75 than average poverty and lower than average median incomes compared to the more 1 economically developed counties of Hinds and Warren. The State of Mississippi, as a whole, is 2 positioned between the economically developed and the economically undeveloped county 3 groupings of the GGNS ROI for both median income and living below poverty level. 4 Table 2-16. Estimated Income Information for the GGNS ROI in 2010 5 Claiborne Hinds Jefferson Warren Mississippi Median household income (dollars)(a) 24,150 39,215 24,304 40,404 37,881 Per capita income (dollars)(a) 12,571 20,676 12,534 22,079 19,977 Individuals living below the poverty level (percent) 35.0 22.5 39.0 21.4 16.7 Families living below the poverty level (percent) 27.6 17.7 29.3 16.5 21.2 (a) In 2010 inflation adjusted dollars. Source: USCB 2012. Unemployment 6 Unemployment rates in the GGNS ROI have mirrored State and national trends from 2007 to 7 2012. Table 2 -17 illustrates the not -seasonally -adjusted unemployment rates for the GGNS 8 ROI counties compared to State and national rates. 9 The effects of the recent economic recession on employment are visible in all counties. 10 Claiborne and Jefferson Counties have had consistently higher unemployment rates than their 11 urban neighboring counties through this period. 12 Table 2-17. 2007-2012 Unemployment Rates in the GGNS ROI 13 ROI Counties 2007 2008 2009 2010 2011 2012 Claiborne 9.8 9.1 14.3 12.8 14.3 11.8 Hinds 5.4 5.0 7.1 8.9 8.8 7.6 Jefferson 11.2 10.7 14.7 14.4 14.5 13.0 Warren 6.0 5.3 8.7 10.5 11.3 9.3 Mississippi 5.9 5.5 8.3 9.9 10.0 8.3 United States 4.3 4.8 8.6 9.5 8.7 7.7 Source: MDES (2012); for consistency all values not seasonally adjusted. Taxes 14 Mississippi Code Title 27 addresses taxation of nuclear generating plants and the distribution of 15 tax revenues from nuclear plants. This code states that any nuclear generating plant located in 16 the State, which is owned or operated by a public utility, is exempt from county, municipal, and 17 district ad valorem taxes. In lieu of the payment of county, municipal, and district ad valorem 18 taxes, the nuclear power plant pays the Mississippi State Tax Commission a sum based on the 19 assessed value of the nuclear generating plant. 20 GGNS is taxed by the State for a sum equal to 2 percent of the assessed value but not less 21 than $20 million annually, $7.8 million of which is provided to Claiborne County. Of this amount, 22 $3 million is contingent upon Claiborne County upholding its commitment to the GGNS offsite 23 Affected Environment 2-76 emergency plan. The $7.8 million provided by the State represents roughly 83 percent of all 1 Claiborne County revenues. 2 The Mississippi State Tax Commission transfers $160,000 annually to the city of Port Gibson, 3 provided the city maintains its commitment to the GGNS offsite emergency plan. Ten percent of 4 the remainder of the payments are transferred from the Mississippi Tax Commission to the 5 General Fund of the State. The balance of the tax revenue from the GGNS site is transferred to 6 the counties and municipalities in the State of Mississippi where electric service is provided. 7 The tax revenues are distributed in proportion to the amount of electric energy consumed by the 8 retail customers in each county, with no county receiving an excess of 20 percent of the funds. 9 This distribution, based on energy consumed, also includes Claiborne County. 10 (Mississippi Code Title 27) 11 2.2.10 Historic and Archaeological Resources 12 This section discusses the cultural background and known historic and archaeological 13 resources in and around GGNS. 14 2.2.10.1 Cultural Background 15 The area in and around GGNS has a high potential for significant prehistoric and historic 16 resources. Human occupation in the Mississippi Valley area is generally characterized based 17 on the following chronological sequence (Peacock 2005): 18 Paleoindian Period (14,000+ to 9,000 years before present (BP)) 19 Archaic Period (9,000 to 3,000 BP) 20 Woodland Period (3,000 to 1,000 BP) 21 Mississippian Period (1,000 to 300 BP) 22 Protohistoric/Historic Period (300 BP to present) 23 Paleoindian Period (14,000 to 9,000 BP) 24 The Paleoindian Period is generally characterized by highly mobile bands of hunters and 25 gatherers. Little information is known about Paleoindian methods of subsistence, but it is 26 assumed that they would have hunted now -extinct megafauna (e.g., mammoth, ground sloth, 27 and saber-tooth tiger), in addition to hunting smaller game and gathering wild plants. No 28 Paleoindian sites are currently known in the GGNS vicinity; however, Paleoindian sites in the 29 Southeastern U.S. generally consist of isolated projectile points or other tools such as flaked 30 stone end scrapers or bone tools (Peacock 2005). 31 Archaic Period (9,000 to 3,000 BP) 32 The Archaic Period is generally distinguished from the preceding Paleoindian Period by 33 changes in the environment, technology, and population. The warmer and dryer part of the 34 Early Archaic Period facilitated groups' ability to exploit more diverse resources, and 35 consequently their tool kit also became more diversified. Technological changes are evidenced 36 by the manufacture of notched projectile points, which were smaller than Paleoindian points, 37 likely reflecting a reliance on smaller game (Neusius and Gross 2007). Groups became 38 sedentary as the climate became wetter and warmer as the Archaic Period progressed, and 39 ceremonialism (e.g., mounds, effigies) is evident in the archaeological record during this time. 40 Archaic sites have been documented on GGNS property (Entergy 2011a; MDAH 2012). 41 Affected Environment 2-77 Woodland Period (3,000 to 1,000 BP) 1 The Woodland Period is often divided into early, middle, and late periods. One of the most 2 notable aspects in the archaeological record of the Woodland Period is widespread pottery use; 3 the period is sometimes referred to as the Early Ceramic Period. Groups living permanently in 4 one place dominated the settlement pattern during the Woodland Period, an aspect that may 5 have facilitated the widespread development of pottery (Peacock 2005). Mounds were 6 frequently built in the Middle Woodland Period, but this practice dissipated by the end of the 7 period. Sites dating to the Late Woodland Period are the most common sites found in 8 Mississippi. These sites are found in various types of landforms; valleys, hills, deltas, and 9 prairies (Peacock 2005). Another important development during the latter portion of the 10 Woodland Period is the bow -and-arrow, which is evidenced by smaller projectile points and 11 likely involved significant changes in the way warfare and hunting were conducted (Lee 2010). 12 The GGNS property contains an example of a Middle Woodland mound. The Grand Gulf 13 Mound Site (22Cb522) is located on a loess bluff 220 ft above sea level, overlooking the 14 Mississippi River. Clarence Moore identified the mound in 1911. Members of Harvard's 15 Peabody Museum visited the site in the 1940s, and it was excavated in 1973 by the Mississippi 16 Department of Archives and History (MDAH) (Brookes 1976). Unfortunately, two -thirds of the 17 mound was bulldozed before its excavation and the portion that was not destroyed was 18 vandalized by looters. Human remains (mandible with teeth, several ribs, and a humerus) were 19 found in the dirt from the bulldozed section of the mound (Stone 1972). Artifacts found during 20 excavation of the mound include copper pieces (of non -local origin), ceramics, and a platform 21 pipe (found by a collector) (Brookes 1976). These artifacts suggest that those living at the 22 Grand Gulf Mound Site likely participated in an extensive trading network, the Hopewell 23 Interaction Sphere, with groups throughout the Eastern Woodlands. Potentially significant 24 deposits in the vicinity of the mound are still possible. 25 Two other mounds were documented at GGNS. They were located close to each other and 26 likely were farther back on the bluff than the Grand Gulf Mound Site; however, they have since 27 been destroyed (Brookes 1976). Additionally, Brookes (1976) noted that the area just north of 28 the Grand Gulf Mound Site had many surface finds and suggested that the area may have been 29 an Archaic Site or Woodland work area. Woodland sites also have been documented on the 30 western side of the Mississippi River across from the town of Grand Gulf located just north of 31 GGNS (Brookes 1976). 32 Mississippian Period (1,000 to 300 BP) 33 The Mississippian Period is arguably the most intensely studied period in the American 34 Southeast. With sites as far north as Wisconsin and extending to the Gulf Coast, Mississippian 35 peoples maintained a vast cultural and trading network. In the vicinity of GGNS, the 36 Mississippian Period was preceded by an Emergent Mississippian Period, referred to as the 37 Coles Creek Culture, beginning around A.D. 700 and lasting until about A.D. 1200 (Roe and 38 Schilling 2010). This period is characterized by changes in settlement patterns, mortuary 39 practices, and ceramic technology and decoration, as well as distinctive ceremonial centers 40 (Roe and Schilling 2010). Subsistence during the Emergent Mississippian Period in this area 41 continued to rely on hunting and gathering, with small amounts of maize and domesticated 42 crops beginning to appear (Roe and Schilling 2010). Around A.D. 1200, the Mississippian 43 Culture took hold in the region and is expressed locally as the Plaquemine Culture. The type 44 site of the culture is the Medora Site in West Baton Rouge Parish, Louisiana (Rees 2010). 45 Characterized by ceremonial mound centers, shell -tempered pottery, ceramic and stone 46 smoking pipes, stone axes, game stones and small stemmed projectile points, it is commonly 47 Affected Environment 2-78 accepted that the Mississippian Period saw more social stratification than previous periods, and 1 these high -status individuals likely lived on top of the platform mounds constructed (Rees 2010). 2 In other parts of the Southeast, the Mississippian Period is seen to decline around A.D. 1500, 3 but in the Lower Mississippi Valley the Mississippian Period appears to have continued into th e 4 Protohistoric Period, with historically known groups such as the Natchez and Chitimacha 5 persisting in the Mississippian culture until contact with Europeans changed their way of life. 6 Protohistoric/Historic Period (300 BP to Present) 7 Hernando de Soto undertook the earliest European expedition into the Southeast United States 8 that passed by the GGNS study area. While he did not stop near GGNS, the impact of this 9 expedition was felt by Native American tribes throughout the Southeast United States, which 10 were decimated by the diseases that the Europeans brought. Until fall 1543, de Soto and his 11 expedition attacked and enslaved the Native populations throughout the Southeast United 12 States, often exhausting Native food supplies (Neusius and Gross 2007). 13 An early historic reference to Grand Gulf comes from French explorer René Robert Cavelier, 14 Sieur de La Salle's 1862 voyage down the Mississippi River to find water passages into Spanish 15 territory. He traveled passed the GGNS vicinity and his subsequent maps referred to the locale 16 as "Grand Gouffre ," designating a large whirlpool (Wright 1982). The whirlpool was formed by 17 the Black River entering the Mississippi River, and the eddy was made more treacherous with a 18 large rock outcropping known as "Point of Rock," which is located within the Grand Gulf Military 19 Monument Park near GGNS. 20 Significant political and social reorganization took place among most of the Southeastern tribes 21 after European contact. Many of the historically known tribes were formed from refugee 22 populations or around the remnants of once great chiefdoms (Saunt 2004); however, in the 23 vicinity of GGNS little is known about the period between the end of the Mississippian Period 24 and European settlement. It has been suggested that early historic period groups moved 25 frequently based on the location of Europeans on the landscape (Kidder 2004). There are no 26 historical records of the tribal affiliation of groups in the GGNS vicinity; however, the Natchez 27 had significant settlements south of the property and the Taensa were located on the other side 28 of the Mississippi River in Louisiana. 29 An established European presence in the region came in 1699, when the French formed a 30 colony at Biloxi Bay near D'Iberville, Mississippi, about 170 mi southeast of GGNS. At this time, 31 the Mississippi River was one of the most important transportation and trade routes in the 32 country, and Europeans set up temporary camps along the river to float their cargo downriver to 33 the commercial center of New Orleans. The location of Grand Gulf on the Mississippi River, 34 along with the construction of a railroad connecting Grand Gulf and Port Gibson in 1830, 35 provided the opportunity for Grand Gulf's citizens to flourish as cotton shippers (Wright 1982). 36 Unfortunately, the prosperity would not last, when, after several floods, a tornado hit the town in 37 1853 and the town was unable to recover. 38 During the Civil War, Union General William Sherman's "total war" campaign decimated several 39 parts of the State of Mississippi. Union forces destroyed homes, factories, and infrastructure as 40 they battled throughout the State. After the fall of New Orleans in April 1862, Grand Gulf began 41 to play an increasingly important role in the Confederate defense of Vicksburg. Leading up to 42 the eventual 1863 Union victory at Vicksburg, Confederate installations at Grand Gulf 43 successfully defended Vicksburg and surrounding towns against several Union maneuvers 44 (Wright 1982). However, in April 1863, Union forces made the largest amphibious landing in 45 American History (before World War II) at Grand Gulf. The outnumbered Confederates held 46 onto their positions for 18 hours before abandoning the fortifications and retreating to Bayou 47 Affected Environment 2-79 Pierre. The Union forces moved into the town and used Grand Gulf as a base until early June. 1 This was by far the largest battle fought at Grand Gulf, but a n additional skirmish occurred 2 between a Union patrol and Confederate partisans on July 16, 1864, and a Union boat was 3 destroyed by Confederate forces in December 1864 (Wright 1982). The 1863 Union capture of 4 Vicksburg is viewed as one of the critical turning points in the war that helped to ensure a Union 5 victory (Smith 2010). 6 At the end of the war, a main feature of Reconstruction was the introduction of the sharecropper 7 system to the area surrounding GGNS. In this system, land owners rent ed parcels of their land 8 to those who farm ed it in exchange for a percentage of the crop. Many newly freed slaves 9 participated in this system and potential sharecropper sites were documented at GGNS during a 10 survey in 2006 (22Cb824 and 22Cb827). Most of the African -American sharecroppers began 11 resettling at the end of the 19 th century in nearby towns, and the area around GGNS remained 12 rural farmland until GGNS acquired it in the 1970s (Entergy 2011a). GGNS began commercial 13 operations in July 1985, as the first and only nuclear power plant in Mississippi. 14 2.2.10.2 Historic and Archaeological Resources 15 Before the construction of the approximately 2,0 15-ac (816-ha) GGNS site, the area was used 16 as farmland. The Mississippi River bounds the property on the west, with other land owners to 17 the north, south, and east. Both historic and prehistoric resources have been documented on 18 the GGNS property; however, any extant cultural resources are most likely subsurface remains 19 and would not be discovered unless land -disturbing operation s took place. 20 The GGNS property has been subject to several archaeological surveys and consultations with 21 the Mississippi State Historic Preservation Office. In June 1972 , Mississippi Power & Light 22 Company (MP&L), a precursor of Entergy, contracted the MDAH to perform archaeological, 23 architectural, and historical surveys of the property and transmission routes in Claiborne 24 County. Eight sites were recorded as a result of this survey, only one of which (the Grand Gulf 25 Mound) was considered potentially eligible for inclusion in the National Register of Historic 26 Places (NRHP). 27 The architectural survey of Claiborne County identified one additional resource, the Callendar 28 house. This was a mid -19 th century Greek Revival style house, located on the eastern portion 29 of the GGNS property. The house was in poor condition during the 1970s and is no longer 30 extant. The 164 acres of land GGNS donated to the Grand Gulf Military Monument Park 31 contained vestiges of the town of Grand Gulf that has been preserved with the protection the 32 park provides (Entergy 2011a). 33 Two transmission lines , which leave GGNS property, were constructed to connect GGNS to the 34 regional power grid: the Baxter -Wilson line and the Franklin line. Neither of these transmission 35 lines are documented as having been formally surveyed before construction. Other surveys 36 conducted in the vicinity of the transmission lines have identified at least seven cultural resource 37 sites that are present either in the path of the Baxter -Wilson and Franklin transmission lines or 38 in very close proximity to them. One of the sites along the Baxter -Wilson right -of-way is the 39 Loosa Yokena site (22Wr691), which is a Middle- to Late-Archaic stone and gem working 40 workshop and occupation site that is listed on the NRHP. The Yokena Mound Group 41 (Site 22Wr500/544) consists of three pyramid mounds damaged by a railroad cut, an d 42 Site 22Wr530 is a small occupational area on the Mississippi River floodplain. The current 43 eligibility status of these two sites is undetermined and would require further investigation to 44 assess their eligibility. Site 22Li558 is a Woodland site very near to the Franklin right -of-way 45 with lithics (stone tools and other chipped stone artifacts) and ceramics that requires further 46 testing before an NRHP eligibility determination can be made. Site 22Cb642 is also a 47 Affected Environment 2-80 Woodland period site with undetermined eligibility status. Sites 22Je581 and 22Je584 are not 1 eligible for listing in the NRHP (MDAH 2012). 2 The Archaeological Research Laboratory of the University of Tennessee conducted a Phase I 3 survey of areas of potential construction for a proposed new reactor at GGNS. The survey 4 identified two previously recorded sites (22Cb524 and 22Cb528), as well as nine newly 5 discovered sites (22Cb820, 22Cb821, 22Cb822, 22Cb823, 22Cb824, 22Cb825, 22Cb826, 6 22Cb827, and 22Cb828). Site 22Cb528 is an Archaic Period village consisting of ceramics and 7 lithics at various stages of production. It was determined that the site should be avoided or 8 tested further to determine eligibility (Entergy 2011a; MDAH 2012). A portion of the Grand Gulf 9 to Port Gibson railroad passes through the site boundary and was inspected by NRC staff on 10 April 13, 2004. It was determined that because the only extant remnants of the railroad are the 11 bed and berm , this section of the railroad does not retain enough integrity to warrant 12 preservation (Stapp 2004). 13 Overall, 17 archaeological sites have been documented on GGNS property; only one (22Cb528) 14 is considered potentially eligible for listing in the NRHP. Fifteen of these sites are prehistoric, 15 and two of them have both prehistoric and historic components. Even though the Grand Gulf 16 Mound (22Cb522) has been excavated, mound sites were typically part of larger village sites, 17 and it is possible that significant subsurface deposits exist in the vicinity of the mound complex. 18 Within 10 mi of GGNS, 219 archaeological sites have been documented, 9 of which are listed 19 on the NRHP, 2 are eligible, 40 are potentially eligible, 138 are of unknown potential, and 30 are 20 not eligible. Claiborne County maintains 38 properties in the NRHP; the closest listed properties 21 to GGNS are the Grand Gulf Military Park and historic sites in the town of Port Gibson 22 (Entergy 2011a; MDAH 2012). 23 2.3 Related Federal and State Activities 24 The staff reviewed the possibility that activities of other Federal agencies might affect the 25 renewal of the operating license for GGNS. Any such activity could result in cumulative 26 environmental impacts and the possible need for a Federal agency to become a cooperating 27 agency in the preparation of NRC's SEIS for GGNS. 28 There are no Federal projects that would make it necessary for another Federal agency to 29 become a cooperating agency in the preparation of this document. There are no known 30 American Indian lands within 50 mi (80 km) of GGNS. Federally owned facilities within 50 mi 31 (80 km) of GGNS are listed below: 32 Tensas River National Wildlife Refuge 33 Bayou Cocodrie National Wildlife Refuge 34 Poverty Point National Monument 35 Natchez Trace Parkway and National Scenic Trail 36 Vicksburg National Military Park 37 Natchez National Historical Park 38 Homochitto National Forest 39 Saint Catherine Creek National Wildlife Refuge 40 Delta National Forest 41 The NRC is required, under Section 102(2)(c) of the National Environmental Policy Act, to 42 consult with and obtain the comments of any Federal agency that has jurisdiction by law or 43 special expertise with respect to any environmental impact involved. For example, during the 44 course of preparing this DSEIS, the NRC consulted with the FWS and the NMFS. Federal 45 agency consultation correspondence is presented in Appendix D. 46 Affected Environment 2-81 2.4 References 1 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for 2 protection against radiation." 3 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic licensing of 4 production and utilization facilities." 5 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 6 protection regulations for domestic licensing and related regulatory functions." 7 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for 8 renewal of operating licenses for nuclear power plants." 9 10 CFR Part 61. Code of Federal Regulations, Title 10, Energy, Part 61, "Licensing 10 requirements for land disposal of radioactive waste." 11 10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, "Packaging and 12 transportation of radioactive material." 13 40 CFR Part 50. Code of Federal Regulations, Title 40, Protection of Environment, Part 50, 14 "National primary and secondary ambient air quality standards." 15 40 CFR Part 52. Code of Federal Regulations, Title 40, Protection of Environment, Part 52, 16 "Approval and promulgation of implementation plans." 17 40 CFR Part 81. Code of Federal Regulations, Title 40, Protection of Environment, Part 81, 18 "Designation of areas for air quality planning purposes." 19 40 CFR Part 141. Code of Federal Regulations, Title 40, Protection of Environment, Part 141, 20 "National primary drinking water regulations." 21 40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 22 "Environmental radiation protection standards for nuclear power operations." 23 50 CFR Part 10. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 10, "General 24 provisions." 25 50 CFR Part 22. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 22, "Eagle 26 permits." 27 35 FR 16047. U.S. Fish and Wildlife Service. "Conservation of endangered species and other 28 fish or wildlife; Appendix D -United States list of endangered native fish and wildlife." Federal 29 Register 35(199):16047 -16048. October 13, 1970. 30 49 FR 7332. U.S. Fish and Wildlife Service. "Endangered and threatened wildlife and plants; 31 U.S. breeding population of the wood stork determined to be endangered." Federal Register 32 49(40):7332 -7335. February 28, 1984. Available at 33 <http://ecos.fws.gov/docs/federal_register/fr800.pdf > (accessed 11 June 2012). 34 50 FR 21784. U.S. Fish and Wildlife Service. "Endangered and threatened wildlife and plants; 35 interior population of the least tern determined to be endangered." Federal Register 36 50(102):21784 -21792. May 28, 1985. Available at 37 <http://ecos.fws.gov/docs/federal_register/fr957.pdf > (accessed 12 June 2012). 38 57 FR 588. U.S. Fish and Wildlife Service. "Endangered and threatened wildlife and plants; 39 threatened status for the Louisiana black bear and related rules." Federal Register 40 57(4):588-595. January 7, 1992. Available at 41 <http://ecos.fws.gov/docs/federal_register/fr2000.pdf > (accessed 11 June 2012). 42 Affected Environment 2-82 73 FR 66964. U.S. Environmental Protection Agency. "National ambient air quality standards for 1 lead; final rule." Federal Register 73(219):66964 -67062. November 12, 2008. 2 74 FR 10350. U.S. Fish and Wildlife Service." Endangered and threatened wildlife and plants; 3 designation of critical habitat for the Louisiana black bear (Ursus americanus luteolus): final 4 rule." Federal Register 74(45):10350 -10409. March 10, 2009. Available at 5 <http://www.gpo.gov/fdsys/pkg/FR -2009-03-10/pdf/E9-4536.pdf#page=1 > (accessed 6 11 June 2012). 7 74 FR 56264. U.S. Environmental Protection Agency. "Mandatory reporting of greenhouse 8 gases; final rule." Federal Register 74(209):56260 -56519. October 30, 2009. 9 75 FR 6474. U.S. Environmental Protection Agency. "Primary national ambient air quality 10 standards for nitrogen dioxide; final rule." Federal Register 75(26):6474 -6537. February 9, 2010. 11 75 FR 9282. U.S. Fish and Wildlife Service. "General provisions; revised list of migratory birds." 12 Federal Register 75(39):9282 -9314. March 1, 2010. 13 75 FR 35520. U.S. Environmental Protection Agency. "Primary national ambient air quality 14 standard for sulfur dioxide; final rule." Federal Register 75(119):35520 -35603. June 22, 2010. 15 77 FR 63439. U.S. Fish and Wildlife Service. Endangered and threatened wildlife and plants; 16 Proposed endangered status for the Neosho mucket, threatened status for the rabbitsfoot, and 17 designation of critical habitat for both species; proposed rule." Federal Register 18 77 (200): 63439-63536. October 16, 2012. 19 [AEC] U.S. Atomic Energy Commission. 1973. Final Environmental Statement Related to the 20 Construction of Grand Gulf Nuclear Station, Units 1 and 2. Washington, DC: AEC. August 1973. 21 393 p. Agencywide Documents Access and Management System (ADAMS) No. ML021370576. 22 Baker, J.A., K.J. Killgore, and R.L. Kasul. 1991. Aquatic habitats and fish communities 23 in the lower Mississippi River. Rev. Aquatic. Sci. 3: 313 -356. 24 [BEA] U.S. Bureau of Economic Analysis. 2012. Total full -time and part -time employment by 25 industry (Series CA25, CA25N). Available at 26 http://www.bea.gov/iTable/iTable.cfm?ReqID=70&step=1&isuri=1&acrdn=5# (accessed 27 May 2012). 28 Benson JF. 2005. "Ecology and Conservation of Louisiana Black Bears in the Tensas River 29 Basin and Reintroduced Populations." M.S. thesis. Louisiana State University, Baton Rouge, 30 LA. May 2005. 126 p. Available at <http://etd.lsu.edu/docs/available/etd -04112005-125206/ 31 unrestricted/Benson_thesis.pdf > (accessed 11 June 2012). 32 Benson JF, Chamberlain MJ. 2006. Food habitats of Louisiana black bears (Ursus americanus 33 luteolus) in two subpopulations of the Tensas River Basin. The American Midland Naturalist, 34 156(1):118 -127. 35 Benson, A. J. 2011. Zebra mussel sightings distribution. Available at: 36 http://nas.er.usgs.gov/taxgroup/mollusks/zebramussel/zebramusseldistribution.aspx (accessed 37 20 June 2012). 38 Blake ES, Landsea CW, Gibney EJ. 2011. The Deadliest, Costliest, and Most Intense United 39 States Tropical Cyclones from 1851 to 2010 (and Other Frequently Requested Hurricane 40 Facts). NOAA Technical Memorandum NWS NHC -6. August. Available at 41 http://www.nhc.noaa.gov/pdf/nws -nhc-6.pdf (accessed 21 June 2012). 42 [BLS] U.S. Bureau of Labor Statistics. 2012. Local Area Unemployment Statistics. Available at 43 http://www.bls.gov/data/

(accessed June 2012).

44 Affected Environment 2-83 Brookes SO. 1976. The Grand Gulf Mound Salvage Excavation of an Early Marksville Burial 1 Mound in Claiborne County, Mississippi. Mississippi Department of Archives and History , 2 Jackson, Mississippi. 3 Brown A.V., Brown K.B., Jackson D.C. & Pierson W.K. 2005. The lower Mississippi River and its 4 tributaries. In A.C. Benke & C.E. Cushing eds. Rivers of North America. New York, Academic 5 Press. 6 Caffey, R. H. , P. Coreil, and D. Demcheck. 2002. Mississippi River Water Quality: Implications 7 for Coastal Restoration, Interpretive Topic Series on Coastal Wetland Restoration in Louisiana , 8 Coastal Wetland Planning, Protection, and Restoration Act (eds.), National Sea Grant Library 9 No. LSU-G 002. 10 [CSC] Coastal Services Center. 2012. Historical Hurricane Tracks. National Oceanic and 11 Atmospheric Administration (NOAA). Available at <http://www.csc.noaa.gov/hurricanes/ > 12 (accessed 21 June 2012). 13 Clean Air Act of 1963, as amended. 42 U.S.C. §7401 et seq. 14 Endangered Species Act of 1973, as amended. 16 U.S.C. §1531 et seq. 15 [Entergy] Entergy Operations, Inc. 200

4. Telephone call to M. Snow (Entergy Services, Inc.) 16 from J. Becker (P NNL), "Occurrences of Habitats and Species of Concern along Transmission 17 Corridors,"

December 2, 2004. Available at http://www.nrc.gov/reading -rm/adams.html, 18 Accessi on No. ML050350147. 19 [Entergy] Entergy Operations, Inc. 2006. Letter from W.R. Brian, General Manager, Plant 20 Operations, to J. Warner, Mississippi Department of Environmental Quality, regarding Grand 21 Gulf Nuclear Station Water Use Program, August 17, 2006. ADAMS N o. ML12157A178. 22 [Entergy] Entergy Nuclear Operations, Inc. 2007. Depredation Annual Report for 2006. 23 January 31, 2007. ADAMS No. ML12157A495. 24 [Entergy] Entergy Nuclear Operations, Inc. 2008a. Depredation Annual Report for 2007. 25 January 31, 2008. ADAMS No. ML12157A442. 26 [Entergy] Entergy Nuclear Operations, Inc. 2008b. Grand Gulf Nuclear Station, Unit 3 Combined 27 Operating License Application Responses to Environmental Site Audit Follow -up Items. 28 August 27, 2008. ADAMS No. ML082470608. 29 [Entergy] Entergy Operations, Inc. 2008c. Grand Gulf Nuclear Station, Unit 3, Combined 30 License Application. Part 3, Environmental Report. February 2008. ADAMS No. ML080640404. 31 [Entergy] Entergy Nuclear Operations, Inc. 2009. Depredation Annual Report for 2008. 32 January 31, 2009. ADAMS No. ML12157A443. 33 [Entergy] Entergy Nuclear Operations, Inc. 2010

a. Depredation Annual Report for 2009.

34 January 31, 2010. ADAMS N o. ML12157A445. 35 [Entergy] Entergy Operations, Inc. 2010

b. Letter from C.K. Shepphard, GGNS Site 36 Environmental Lead, to J.L. Crawford, Mississippi Department of Environmental Quality, 37 regarding Grand Gulf Nuclear Station Water Use Program. July 28, 2010. ADAMS 38 No. ML12157A178.

39 [Entergy] Entergy Operations, Inc. 2011

a. Grand Gulf Nuclear Station, Unit 1, License Renewal 40 Application. Appendix E, Applicant's Environmental Report.

Port Gibson, MS: Entergy. 41 October 2011. 425 p. ADAMS No. ML11308A234 42 Affected Environment 2-84 [Entergy] Entergy Nuclear Operations, Inc. 2011

b. Depredation Annual Report for 2010. 1 January 31, 2011. ADAMS No.

ML12157A446. 2 [Entergy] Entergy Operations, Inc. 2011

c. Letter from C.K. Shepphard, GGNS Site 3 Environmental Lead, to J.L. Crawford, Mississippi Department of Environmental Quality, 4 regarding Grand Gulf Nuclear Station 2010 Water Use Program Survey. June 7, 2011 ADAMS 5 No. ML12157A178.

6 [Entergy] Entergy Operations, Inc. 2012

a. Entergy Nuclear Grand Gulf Nuclear Station License 7 Renewal Environmental Audit - Hydrology Patton

- Attachment A labeled Radial Collector Well 8 Data. ADAMS No. ML12157A175. 9 [Entergy] Entergy Operations, Inc. 2012

b. Entergy Nuclear Grand Gulf Nuclear Station License 10 Renewal Environmental Audit - Hydrology Patton

- Attachment D labeled Well Permits. 11 ADAMS No. ML12157A177. 12 [EPA] U.S. Environmental Protection Agency. 1974. Information on Levels of Environmental 13 Noise Requisite to Protect Health and Welfare with an Adequate Margin of Safety. 14 Washington, D.C., Report 550/9 004.. Available at 15 <http://www.nonoise.org.library/levels74/levels74.htm > (accessed June 2012). 16 [EPA] U.S. Environmental Protection Agency. 2010. Waste Environmental Management 17 Systems. Available at <http://www.epa.gov/osw/inforesources/ems/index.htm > (accessed 18 June 2012). 19 [EPA] U.S. Environmental Protection Agency. 2011. Emission Factors for Greenhouse Gas 20 Inventories, last modified November 7, 2011. Available at <http://www.epa.gov/climateleaders/ 21 documents/emission -factors.pdf> (accessed 18 December 2012). 22 [EPA] U.S. Environmental Protection Agency. 2012

a. Enforcement & Compliance History Online 23 (ECHO), Detailed Facility Report.

Available at <http://www.epa -echo.gov/cgi -bin/ 24 get1cReport.cgi?tool=echo&IDNumber=MS0029521 > (accessed 22 March 2012). 25 [EPA] U.S. Environmental Protection Agency. 2012b. National Ambient Air Quality Standards 26 (NAAQS), Updated on May 1, 2012. Available at <http://www.epa.gov/air/criteria.html> 27 (accessed 16 May 2012). 28 [EPA] U.S. Environmental Protection Agency. 2012c. Sole Source Aquifers in the Southeast , 29 Available at <http://www.epa.gov/region4/water/groundwater/r4ssa.html > (accessed 30 14 May 2012). 31 [EPA] U.S. Environmental Protection Agency. 2012d. The Green Book Nonattainment Areas for 32 Criteria Pollutants. Available at <http://www.epa.gov/oaqps001/greenbk/ > (accessed 33 23 March 2012). 34 [EPA] U.S. Environmental Protection Agency. 2012e. USEPA Envirofacts, Safe Drinking Water 35 Information System, List of Water Systems in SDWIS, Claiborne County, Mississippi. Available 36 at <http://oaspub.epa.gov/enviro/sdw_query_v2 > (accessed 14 May 2012). 37 [FEMA] U.S. Federal Emergency Management Agency. 2012. Earthquake Hazard Maps. 38 available at <http://www.fema.gov/hazard/earthquake/hazards.shtm > (accessed 21 June 2012). 39 FishNet. 2012. FishNet2, Search FishNet. Available at <http://www.fishnet2.net > (accessed 40 6 June 2012). 41 [FWS] U.S. Fish and Wildlife Service. 1995. "Louisiana Black Bear (Ursus americanus luteolus) 42 Recovery Plan." Atlanta, GA: FWS Southeast Region. 59 p. Available a t <http://www.fws.gov/ 43 ecos/ajax/docs/recovery_plan/950927.pdf > (accessed 11 June 2012). 44 Affected Environment 2-85 [FWS] U.S. Fish and Wildlife Service. 2003. "Recovery Plan for the Red -cockaded Woodpecker 1 (Picoides borealis)." Second Revision. January 27, 2003. Atlanta, GA: FWS Southeast Region. 2 316 p. Available at <http://ecos.fws.gov/docs/recovery_plan/030320_2.pdf > (accessed 3 11 June 2012). 4 [FWS]. U.S. Fish and Wildlife Service. 2004. Letter dated April 14, 2004 from C. James, FWS, 5 Assistant Field Supervisor, Jackson, Mississippi Field Office, to M. Masnik, NRC, "Adding the 6 Fat Pocketbook Mussel (Potamilus capax) to the List of Endangered and Threatened Species." 7 ML041310449. 8 [FWS] U.S. Fish and Wildlife Service. 2005. 5 -Year Review: Summary and Evaluation of Pallid 9 Sturgeon (Scaphirhynchus albus). Endangered Species Bulletins and Technical Reports 10 (USFWS). Paper 33. Available at

<http://digitalcommons.unl.edu/endangeredspeciesbull/33

> 11 (accessed 11 June 2012). 12 [FWS]. U.S. Fish and Wildlife Service. 2006. St. Catherine Creek National Wildlife Refuge 13 Comprehensive Conservation Plan. Atlanta, Georgia. August, 2006. 14 [FWS] U.S. Fish and Wildlife Service. 2007

a. Pallid Sturgeon (Scaphirhynchus albus) 5-Year 15 Review Summary and Evaluation.

Available at 16 http://ecos.fws.gov/docs/five_year_review/doc1059.pdf (accessed 20 June 2012). 17 [FWS] U.S. Fish and Wildlife Service. 2007

b. Fat Pocketbook (Potamilus capax) 5-Year Review 18 Summary and Evaluation.

Available at 19 <http://www.fws.gov/southeast/5yearReviews/5yearreviews/fatpocketbookmussel.pdf> 20 (accessed 20 June 2012). 21 [FWS] U.S. Fish and Wildlife Service. 2009. U.S. Fish and Wildlife Service Spotlight Species 22 Action Plan, Pallid Sturgeon. Available at http://ecos.fws.gov/docs/action_plans/doc3026.pdf. 23 (accessed 20 June 2012). 24 [FWS] U.S. Fish and Wildlife Service. 2010. Species Assessment and Listing Priority 25 Assignment Form. Rabbitsfoot (Quadrula cylindrica cylindrical). Available at 26 <http://ecos.fws.gov/docs/candidate/assessments/2010/r4/F03X_I01.pdf>. 27 (accessed 20 June 2012). 28 [FWS] U.S. Fish and Wildlife Service. 2012

a. Federal Fish and Wildlife Permit for Depredation 29 No. MB798276

-0. February 4, 2012. ADAMS No. ML12157A492. 30 [FWS] U.S. Fish and Wildlife Service. 2012

b. "Find Endangered Species" Database for 31 Claiborne, Franklin, Jefferson, and Warren Counties. Available at 32 <http://www.fws.gov/endangered/> (accessed 12 June 2012).

33 [FWS] U.S. Fish and Wildlife Service. 2012

c. Letter from J.D. Weller, Louisiana Field Office 34 Supervisor, FWS, to D. Wrona, RPB2 Branch Chief, NRC. Reply to request for concurrence with 35 list of protected species and habitats for Grand Gulf license renewal review. February 29, 2012. 36 ADAMS No. ML12082A141.

37 [FWS] U.S. Fish and Wildlife Service. 2012

d. Letter from S. Ricks, Mississippi Field Office 38 Supervisor, FWS, to D. Drucker, Project Manager, NRC. Reply to request for concurrence with 39 list of protected species and habitats for Grand Gulf license renewal review. February 3, 2012. 40 ADAMS No. ML12047A113.

41 [FWS] U.S. Fish and Wildlife Service. 2012e. Fat Pocketbook (Potamilus capax). Available at 42 http://ecos.fws.gov/docs/life_histories/F00T.html (accessed 20 June 2012). 43 [FWS] U.S. Fish and Wildlife Service. Undated a. "Louisiana Black Bear." Available at 44 <http://www.fws.gov/southeast/pubs/LA_blackbear -fs.pdf> (accessed 11 June 2012). 45 Affected Environment 2-86 [FWS] U.S. Fish and Wildlife Service. Undated b. "Birds Protected by the Migratory Bird Treaty 1 Act: Game Birds and Hunted Species." Available at

<http://www.fws.gov/

2 migratorybirds/RegulationsPolicies/mbta/gmebrd.html > (accessed 30 August 2012). 3 [GGNS] Grand Gulf Nuclear Station. 2003

a. Lesson Plan Number GLP*GPST*P4100, General 4 Plant Systems Training, Standby Service Water (SSW) P41. May 2. ADAMS 5 No. ML12157A185.

6 [GGNS] Grand Gulf Nuclear Station. 2003

b. Grand Gulf Early Site Permit Application, 7 Revision 2, Part 3 - Environmental Report. Section 2.0, Site Characteristics, Figure 2.1

-1 8 through Figure 2.2-8. ADAMS No. ML052790325. 9 [GGNS] Grand Gulf Nuclear Station. 2006. Storm Water Pollution Prevention Plan. Revision

13. 10 July. ADAMS No. ML12157A249.

11 [GGNS] Grand Gulf Nuclear Station. 2007. (Water Withdrawal Mod), Groundwater Withdrawal 12 Permit Modification Grand Gulf Nuclear Station, Port Gibson, MS. ADAMS No. ML12157A250. 13 [GGNS] Grand Gulf Nuclear Station. 2008. Grand Gulf Nuclear Station (GGNS), Facility 14 No. 0420-00023, Renewal of Existing Synthetic Minor Operating Permit No. 0420 -00023, 15 Correspondence GEXO -2008/00086. November 25, 2008. ADAMS No. ML12157A448. 16 [GGNS] Grand Gulf Nuclear Station. 2010

a. License Amendment Request, Extended Power 17 Uprate. Attachment 4. ADAMS No. ML102660405.

18 [GGNS] Grand Gulf Nuclear Station. 2010

b. Grand Gulf Nuclear Unit 1 Updated Final Safety 19 Analysis Report. April 5, 2010. 20 [GGNS] Grand Gulf Nuclear Station. 2012

a. Response to Request for Additional Information 21 (RAI) Dated April 23, 2012 Grand Gulf Nuclear Station, Unit 1.

ADAMS No. ML12157A173. 22 [GGNS] Grand Gulf Nuclear Station. 2012

b. Response to Request for Additional Information 23 (RAI) Dated May 8, 2012 Grand Gulf Nuclear Station, Unit 1.

ADAMS No. ML12158A445. 24 [GGNS] Grand Gulf Nuclear Station. 2012

c. GGNS 2006

-2011 Meteorological Data. RAI 25 response dated May 23, 2012. ADAMS Nos. ML12157A218, ML12157A219, ML12157A220, 26 ML12157A221, ML12157A224, and ML12157A225. 27 GZA GeoEnvironmental, Inc. 2009. GPI Data Review Grand Gulf Nuclear Station Port Gibson, 28 Mississippi. ADAMS No. ML102350525. 29 Hinds County Economic Development Authority (2008). Largest Employers -Hinds County 30 Economic Development Authority. Available at 31 http://www.selecthinds.com/largestemployers.asp x (accessed May 2012). 32 Jones KH. 2011. Population survey of the interior least tern on the Mississippi River from Cape 33 Girardeau, Missouri, to Baton Rouge, Louisiana. July, August 2011. Dyersburg, TN: Dyersburg 34 State Community College. 130 p. Available at <http://www.mvm.usace.army.mil/river/ 35 Environmental/FINAL_Srvy_Rprt_2011.pdf > (accessed 12 June 2012). 36 Khan MZ, Walters JR. 2002. Effects of helpers on breeder survival in the red -cockaded 37 woodpecker (Picoides borealis). Behavioral Ecology and Sociobiology 51:336 -344. 38 Kidder TR. 2004. "Prehistory of the Lower Mississippi Valley After 800 B.C." In Handbook of 39 North American Indians: Southeast, edited by Raymond D. Fogelson. Washington, DC: 40 Smithsonian Institution. 41 Affected Environment 2-87 Kynard B, Henyey E, Horgan M. 2002. Ontogenetic behavior, migration, and social behavior of 1 pallid sturgeon, Scaphirhynchus albus, and shovelnose sturgeon, S. platorynchus, with notes on 2 the adaptive significance of body color. Environmental Biology of Fishes, Volume 63:389-403. 3 Lee AL. 2010. "Troyville and the Baytown Period." In Archaeology of Louisiana, edited by 4 Mark A. Rees. Louisiana State University Press. Baton Rouge, Louisiana. 5 Lindzey FG, Meslow EC. 1977. Home range and habitat use by black bears in southwestern 6 Washington. Journal of Wildlife Management 41:413 -425. 7 Mann DL, Mann TM, Thomas ML, Jourdan MB, Foss KL. 2011. The distribution of Webster's 8 salamander, Plethodon websteri, in Mississippi in relation to local geology. 96th ESA Annual 9 Meeting, August 7 -12, 2011. Available at <http://eco.confex.com/eco/ 10 2011/webprogram/Paper31670.html > (accessed 7 March 2012). 11 Marchinton FB. 1995. Movement ecology of black bears in a fragmented bottomland hardwood 12 habitat in Louisiana. M.S. thesis, University of Tennessee, Knoxville, TN.

p. 107. 13 Mississippi Code of 1972, as amended. Title 27: Taxation and Finance. Available at 14 http://www.mscode.com/free/statutes/27/index.htm (accessed June 2012). 15 [MDAH] Mississippi Department of Archives and History. 2012. Site file search conducted by 16 K. Wescott, Argonne National Laboratory, and E. Larson, Nuclear Regulatory Commission, at 17 the MDAH, Jackson, Mississippi on March 29 and 30. 18 [MDEQ] Mississippi Department of Environmental Quality. 2007. Correspondence from 19 J. Crawford, Groundwater Withdrawal, to R. Shaw, Entergy Operations, Grand Gulf Nuclear 20 Station. October 8, 2007. ADAMS No. ML12157A255.

21 [MDEQ] Mississippi Department of Environmental Quality. 2009. Records of Public -Supply 22 Wells in Mississippi. ADAMS No. ML12157A256. 23 [MDEQ] Mississippi Department of Environmental Quality. 2010 a. Certificate of Permit 24 Coverage under Mississippi's Baseline Storm Water General NPDES Permit. Coverage Number 25 MSR000883. December 1, 2010. ADAMS N o. ML12157A180. 26 [MDEQ] Mississippi Department of Environmental Quality. 2010

b. Well Head Protection Areas. 27 ADAMS No. ML12157A412.

28 [MDEQ] Mississippi Department of Environmental Quality. 2011a. Permit to discharge 29 wastewater in accordance with National Pollutant Discharge Elimination System, permit 30 no. MS0029521. ADAMS No. ML12157A413. 31 [MDEQ] Mississippi Department of Environmental Quality. 2011 b. (401 WQC Letter), Mississippi 32 Department of Environmental Quality, Re: Grand Gulf Nuclear Station License Renewal. 33 ADAMS No. ML11350A190. 34 [MDEQ] Mississippi Department of Environmental Quality. 2011

c. 2010 Air Quality Data 35 Summary. Available at

<http://www.deq.state.ms.us/ 36 mdeq.nsf/pdf/Air_2010AirQualityDataSummary/$File/2010%20Air%20Quality%20Data%20 37 Summary.pdf?OpenElement > (accessed 25 June 2012). 38 [MDEQ] Mississippi Department of Environmental Quality. 2012a. Home - Air Division. 39 Available at <http://www.deq.state.ms.us/mdeq.nsf/page/air_homepage?

(accessed 40 24 May 2012). 41 [MDEQ] Mississippi Department of Environmental Quality. 2012b. Mississippi Commission on 42 Environmental Quality Regulation APC-S-4: Ambient Air Quality Standards , Last Amended 43 Affected Environment 2-88 June 27, 2002. Available at 

<http://www.deq.state.ms.us/ 1 mdeq.nsf/page/Air_AirQualityPlanningandEmissionStandards? > (accessed 23 March 2012). 2 [MDES] Mississippi Department of Employment Security. 2012. Labor Market Data for 3 April 2012. Available at http://mdes.ms.gov/Home/docs/LMI/ 4 Publications/Labor%20Market%20Data/labormarketdata.pdf (accessed May 2012). 5 [MDOT] Mississippi Department of Transportation. 2012. MDOT Traffic Counts Web application. 6 Available at 7 http://sp.gomdot.com/Intermodal%20Planning/planning/Maps/Pages/Traffic -Volume-Maps.aspx 8 (accessed May 2012). 9 [MDWFP] Mississippi Department of Wildlife, Fisheries, and Parks. 2001. "Endangered Species 10 of Mississippi." Crystal Darter. Available at 11 http://www.mdwfp.com/media/127063/endangered_species_packet.pdf (accessed Apr 201 3). 12 [MDWFP] Mississippi Department of Wildlife, Fisheries, and Parks. 2011. Available at 13 http://museum.mdwfp.com/downloads/science/listed_ms_species_status_rank_definition.pdf 14 (accessed May 2012). 15 [MDWFP] Mississippi Department of Wildlife, Fisheries, and Parks. 2012. Letter from 16 A. Sanderson, Ecologist, Mississippi Natural Heritage Program, MDWFP, to D. Wrona, RPB2 17 Branch Chief, NRC.

Subject:

Reply to request for protected species and habitat information for 18 Grand Gulf license renewal review. February 13, 2012. ADAMS No. ML12055A312. 19 [MIHL] Mississippi Institutions of Higher Learning. 2012. Mississippi Population Projections 20 2015, 2020, 2025. Available at http://www.ihl.state.ms.us/urc/downloads 21 /PopulationProjections.pdf (accessed May 2012). 22 [MMNS] Mississippi Museum of Natural Science. 2001. "Endangered Species of Mississippi." 23 97 p. Available at <http://museum.mdwfp.com/downloads/ 24 science/endangered_species_packet.pdf > (accessed 6 March 2012). 25 [MNHP] Mississippi Natural Heritage Program. 201 1. "Listed Species of Mississippi." Available 26 at <http://www.mdwfp.com/media/127066/endangered_species_list.pdf

> 27 (accessed 11 June 2012). 28 [MP&L] Mississippi Power & Light Company. 1981. Grand Gulf Nuclear Station, Units 1 and 2, 29 Final Environmental Report. December 1981. ADAMS No.

ML12157A492. 30 National Environmental Policy Act of 1969, as amended. 42 U.S.C. §4321 et seq. 31 National Historic Preservation Act of 1966. 16 U.S.C. §470 et seq. 32 NatureServe. 2012. NatureServe Explorer: An online encyclopedia of life [web application]. 33 NatureServe, Arlington, Virginia. Available at http://www.natureserve.org/explorer. (accessed 34 June 25, 2012). 35 [NCDC] National Climatic Data Center. 1990. 1989 Local Climatological Data Annual Summary 36 with Comparative Data, Jackson, Mississippi. National Oceanic and Atmospheric 37 Administration, National Environmental Satellite, Data, and Information Service. Available at 38 <http://www7.ncdc.noaa.gov/IPS/lcd/lcd.html > (accessed 22 June 2012). 39 [NCDC] National Climatic Data Center. 2012a. Climates of the States (CLIM60): Climate of 40 Mississippi. National Oceanic and Atmospheric Administration, Satellite and Information 41 Service. Available at <http://cdo.ncdc.noaa.gov/cgi -bin/climatenormals/climatenormals.pl > 42 (accessed 23 March 2012). 43 Affected Environment 2-89 [NCDC] National Climatic Data Center. 2012b. 2011 Local Climatological Data Annual Summary 1 with Comparative Data, Jackson, Mississippi (KJAN). National Oceanic and Atmospheric 2 Administration, Satellite and Information Service. Available at <http://www7.ncdc.noaa.gov/ 3 IPS/lcd/lcd.html > (accessed 19 June 2012). 4 [NCDC] National Climatic Data Center. 2012c. Storm Events Database. National Oceanic and 5 Atmospheric Administration. Available at

<http://www.ncdc.noaa.gov/stormevents/

> (accessed 6 21 June 2012). 7 [NCDC] National Climatic Data Center. 2012d. U.S. Tornado Climatology. National Oceanic and 8 Atmospheric Administration, Satellite and Information Service. Available at 9 <http://www.ncdc.noaa.gov/oa/climate/severeweather/tornadoes.html > (accessed 10 21 June 2012). 11 [NCES] U.S. Department of Education, National Center for Education Statistics. 2012a. U.S. 12 Department of Education, National Center for Education Statistics, Common Core of Data 13 (CCD), "Public Elementary/Secondary School Universe Survey ," 2010-11 School Y ear." 14 Available at http://nces.ed.gov/ccd/districtsearch/

(accessed April 2012). 15 [NCES] U.S. Department of Education, National Center for Education Statistics. 2012b. College 16 Navigator Web Application. Available at http://nces.ed.gov/collegenavigator/default.aspx 17 (accessed May 2012). 18 [NEI] Nuclear Energy Institute. 2007. Industry Ground Water Protection Initiative - Final 19 Guidance Document. Washington, DC: Nuclear Energy Institute. NEI 07

-07 (Final). 20 August 2007. ADAMS No. ML091170588. 21 Neusius SW, Gross GT. 2007. Seeking Our Past: An Introduction to North American 22 Archaeology. New York, NY: Oxford University Press. 23 [NMFS] National Marine Fisheries Service. 2012

a. Essential Fish Habitat Mapper v2.0.

24 Available at http://sharpfin.nmfs.noaa.gov/website/EFH_Mapper/map.aspx (Accessed on 25 Ju ne 13, 2012). 26 [NMFS] National Marine Fisheries Service. 2012

b. Letter from D. Bernhart, Southeast Assistant 27 Regional Administrator for Protected Resources, to D. Wrona, RPB2 Branch Chief, NRC.

28

Subject:

Reply to request for list of species at Grand Gulf Nuclear Station, Unit 1. 29 March 1, 2012. ADAMS Accession No. ML12065A167. 30 [NRC] U.S. Nuclear Regulatory Commission. 19

81. Final Environmental Statement Related to 31 the Operation of Grand Gulf Nuclear Station, Units 1 and 2, Docket Nos. 50

-416 and 50 -417. 32 NUREG-0777. September 1981 . ADAMS Legacy Library No. 8110220161. 33 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 34 for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG -1437. May 1996. 35 ADAMS Nos. ML040690705 and ML040690738. 36 [NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3 -Transportation, Table 9.1, 37 Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic 38 Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: 39 NRC. NUREG -1437, Volume 1, Addendum 1. August 1999. ADAMS N o. ML04069720. 40 [NRC] U.S. Nuclear Regulatory Commission. 2006

a. Environmental Impact Statement for an 41 Early Site Permit (ESP) at the Grand Gulf ESP Site , Final Report. NUREG-1817. April 2006.

42 876 p. ADAMS No. ML060900037. 43 [NRC] U.S. Nuclear Regulatory Commission. 2006b. Safety Evaluation Report for an Early Site 44 Permit (ESP) at the Grand Gulf Site. NUREG-1840. April 2006. 45 Affected Environment 2-90 [NRC] U.S. Nuclear Regulatory Commission. 2007. Regulatory Guide 1.23, "Meteorological 1 Monitoring Programs for Nuclear Power Plant," Rev.1. March 2007. Available at 2 <http://pbadupws.nrc.gov/docs/ML0703/ML070350028.pdf > (accessed 5 July 2012). 3 Peacock E. 2005. Mississippi Archaeology: Q & A. Jackson, MI: University Press of Mississippi. 4 Port Gibson Chamber of Commerce. 2012. Port Gibson on the Mississippi.com: Employers. 5 Available at http://port gibsononthemississippi.com/Employers.html (accessed May 2012). 6 Rees MA. 2010. "Plaquemine and Mississippian." In Archaeology of Louisiana, edited by 7 Mark A. Rees. Baton Rouge, LA: Louisiana State University Press. 8 Roe LM, Schilling TM. 2010. "Coles Creek." In Archaeology of Louisiana, edited by 9 Mark A. Rees. Baton Rouge, LA: Louisiana State University Press. 10 Saunt C. 2004. "History until 1776." In Handbook of North American Indians: Southeast, edited 11 by Raymond D. Fogelson. Washington, DC: Smithsonian Institution. 12 [SERI] System Energy Resources, Inc. 2005. Grand Gulf Site Early Site Permit Application. 13 Revision 2 . Available at <http://www.nrc.gov/reading -rm/adams.html >. ADAMS No. 14 ML052780449. 15 Sidle JG, Harrison WF. 1990. Interior population of the least tern (Sterna antillarum) recovery 16 plan. Bloomington, MN: U.S. Fish and Wildlife Service, Midwest Region. 95 p. Available at 17 <http://ecos.fws.gov/docs/recovery_plan/900919a.pdf> (accessed 11 April 2013). 18 Smith TB. 2010. Mississippi in the Civil War. Jackson, MI: University Press of Mississippi. 19 Stapp DC. 2004. "Historic and Cultural Resources Contribution to Grand Gulf Trip 20 Report 4-13-04 to 4-15-04." ADAMS No. ML050350472. 21 Stone JH. 1972. "Grand Gulf Mound Statement of Significance and National Register of Historic 22 Places Nomination Form." U.S. Department of the Interior, National Park Service. Available at 23 the Mississippi SHPO. 24 [TPWD] Texas Parks and Wildlife Department. 2012. "Interior Least Tern (Sterna antillarum 25 athalassos)." Available at <http://www.tpwd.state.tx.us/huntwild/wild/species/leasttern/ > 26 (accessed 14 June 2012). 27 [USCB] U.S. Census Bureau (USCB), 2012. "American FactFinder, Census 2000 and 2006 -28 2010, 5-Year Estimate, American Community Survey, State and County QuickFacts on 29 Claiborne, Hinds, Jefferson, and Warren Counties," 2010, Available URLs: 30 http://factfinder.census.gov and http://quickfacts.census.gov (accessed May 2012). 31 [USDA] U.S. Department of Agriculture. 2012. Custom Soil Resource Report for Claiborne 32 County, Mississippi. National Resources Conservation Service, Available at 33 <http://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx > (accessed 3 April 2012). 34 [USDA NASS] U.S. Department of Agriculture. National Agricultural Statistics Service. 2009. 35 "2007 Census of Agriculture," Volume 1 Chapter 2, "County Level Data for Mississippi and 36 Louisiana," Table 1: "County Summary Highlights: 2007" and Table 7: "Hired Farm Labor -37 Workers and Payroll: 2007 ." Released February 4, 2009, and updated December 2009. 38 Available at http://www.agcensus.usda.gov/Publications/2007/ 39 Full_Report/Volume_1,_Chapter_2_County_Level/Mississippi/index.asp

40 http://www.agcensus.usda.gov/Publications/2007/Full_Report/Volume_1,_Chapter_2_County_L 41 evel/Louisiana/index.asp (accessed April 2012).

42 Affected Environment 2-91 [USDA NASS] U.S. Department of Agriculture. National Agricultural Statistics Service. 2012. 1 CropScape W eb Application of the 2011 Crop Data Layer Spatial Dataset. Available at 2 http://nassgeodata.gmu.edu/CropScape/

(accessed June 2012).

3 [USGS] U.S. Geological Survey. 2011. "Mississippi Valley Loess Plains." Updated 19 May 2011. 4 Available at <http://landcovertrends.usgs.gov/east/eco74Report.html> (accessed 5 2 March 2012). 6 [USGS] U.S. Geological Survey. 2012

a. Earthquake Hazards Program, Mississippi Earthquake 7 History. Available at

<www.earthquake.usgs.gov/earthquakes/states/mississippi/history.php > 8 (accessed 20 June 2012). 9 [USGS] U.S. Geological Survey. 2012 b. Earthquake Hazards Program, Top Earthquake States. 10 Available at

<www.earthquake.usgs.gov/earthquakes/states/top_states.php

> (accessed 11 21 June 2012). 12 [USGS] U.S. Geological Survey. 2012

c. Nonindigenous Aquatic Species Database. Gainesville, 13 Florida.(accessed 20 June 2012).

14 Warren County Port Commission. 2012. Vicksburg -Warren County Port Commission and EDF: 15 Top 10 Employers. Available at www.vicksburgedf.org/top10industry.htm (accessed May 2012). 16 Wenstrom, B. 2007a. Black Bear Habitat Survey, Grand Gulf Nuclear Station. Conducted 17 December 13-14, 2006. p. 7. ADAMS No. ML12157A493. 18 Wenstrom, B. 2007b. Memo from B. Wenstrom to GGNS COL Application File. January 2, 2007. 19 p. 7. ADAMS No. ML12157A493. 20 Wright, W.C. 1982. The Confederate Magazine at Fort Wade Grand Gulf, Mississippi: 21 Excavations, 1980 -1981. Mississippi Department of Archives and History and Grand Gulf 22 Military Monument. Archaeological Report No. 8. 23

3-1 3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT 1 Facility owners or operators may need to undertake or, for economic or safety reasons, may 2 choose to perform refurbishment activities in anticipation of license renewal or during the license 3 renewal term. The major refurbishment class of activities characterized in the Generic 4 Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants (NRC 1996) is 5 intended to encompass actions that typically take place only once in the life of a nuclear plant, if 6 at all. Examples of these activities include, but are not limited to, replacement of boiling water 7 reactor recirculation piping and pressurized water reactor steam generators. These actions may 8 have an impact on the environment beyond those that occur during normal operations and that 9 require evaluation, depending on the type of action and the plant -specific design. Table 3-1 10 lists the environmental issues associated with refurbishment that the U.S. Nuclear Regulatory 11 Commission (NRC) staff (the staff) determined to be Category 1 issues in the GEIS. 12 Table 3-1. Category 1 Issues Related to Refurbishment 13 Issue GEIS section(s) Surface water quality, hydrology, and use (for all plants) Impacts of refurbishment on surface water quality 3.4.1 Impacts of refurbishment on surface water use 3.4.1 Aquatic ecology (for all plants) Refurbishment

3.5 Groundwater

use and quality Impacts of refurbishment on groundwater use and quality 3.4.2 Land use Onsite land use 3.2 Human health Radiation exposures to the public during refurbishment

3.8.1 Occupational

radiation exposures during refurbishment

3.8.2 Socioeconomics

Public services: public safety, social services, and tourism and recreation 3.7.4; 3.7.4.3; 3.7.4.4; 3.7.4.6 Aesthetic impacts (refurbishment)

3.7.8 Table

source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51 Table 3-2 lists environmental issues related to refurbishment that the NRC staff determined to 14 be plant-specific or inconclusive in the GEIS. These issues are Category 2 issues. The 15 definitions of Category 1 and 2 issues can be found in Section 1.4. 16 Environmental Impacts of Refurbishment 3-2 Table 3-2. Category 2 Issues Related to Refurbishment 1 Issue GEIS section(s) 10 CFR 51.53 (c)(3)(ii) Subparagraph Terrestrial resources Refurbishment impacts 3.6 E Threatened or endangered species (for all plants) Threatened or endangered species 3.9 E Air quality Air quality during refurbishment (nonattainment and maintenance areas) 3.3 F Socioeconomics Housing impacts 3.7.2 I Public services: public utilities 3.7.4.5 I Public services: education (refurbishment) 3.7.4.1 I Offsite land use (refurbishment) 3.7.5 I Public services, transportation 3.7.4.2 J Historic and archaeological resources 3.7.7 K Environmental justice Environmental justice(a) Not addressed Not addressed (a) Guidance related to environmental justice was not in place at the time the U.S. Nuclear Regulatory Commission (NRC) prepared the GEIS and the associated revision to 10 CFR Part 51. If an applicant plans to undertake refurbishment activities for license renewal, the applicant's environmental report (ER) and the staff's environmental impact statement must address environmental justice. Table source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51 Table B.2 of the GEIS identifies systems, structures, and components (SSCs) that are subject to 2 aging and might require refurbishment to support continued operation during the license 3 renewal period of a nuclear facility. In preparation for its license renewal application, Entergy 4 Operations, Inc. (Entergy) performed an evaluation of these SSCs pursuant to Section 54.21 of 5 Title 10 of the Code of Federal Regulation (10 CFR 54.21) in order to identify the need to 6 undertake any major refurbishment activities that would be necessary to support the continued 7 operation of Grand Gulf Nuclear Station (GGNS) during the proposed 20 -year period of 8 extended operation. 9 In its SSC evaluation, Entergy did not identify the need to undertake any major refurbishment or 10 replacement actions associated with license renewal to support the continued operation of 11 GGNS beyond the end of the existing operating license (Entergy 2011). Therefore, the staff will 12 not assess refurbishment activities in this SEIS. 13 3.1 References 14 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy , Part 51, "Environmental 15 protection regulations for domestic licensing and related regulatory functions." 16 Environmental Impacts of Refurbishment 3-3 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for 1 renewal of operating licenses for nuclear power plants." 2 [Entergy] Entergy Operations, Inc. 2011. Grand Gulf Nuclear Station, Unit 1, License Renewal 3 Application. Port Gibson, MS: Entergy. Appendix E, Applicant's Environmental Report. 4 October 2011. 425 p. Agencywide Documents Access and Management System (ADAMS) 5 Accession No. ML11308A234. 6 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 7 for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG -1437. May 1996. 8 ADAMS Accession Nos. ML040690705 and ML040690 738. 9 [NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3 - Transportation, Table 9.1, 10 Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic 11 Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: 12 NRC. NUREG -1437, Volume 1, Addendum 1. August 1999. ADAMS Accession 13 No. ML04069720. 14

4-1 4.0 ENVIRONMENTAL IMPACTS OF OPERATION 1 This chapter addresses potential environmental impacts related to the license renewal term of 2 Grand Gulf Nuclear Station (GGNS). These impacts are grouped and presented according to 3 resource. Generic issues (Category

1) rely on the analysis presented in the Generic 4 Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants 5 (NRC 1996, 1999a, 2013a

), unless otherwise noted. Most site-specific issues (Category

2) 6 have been analyzed for GGNS and assigned a significance level of SMALL, MODERATE, or 7 LARGE. For Protected Species and Habitats and Historic and Archaeological Resources the 8 impact significance determination language is specific to the authorizing legislation (e.g., 9 Endangered Species Act, National Historic Preservation Act).

Also, environmental justice and 10 chronic effects of electromagnetic fields were considered. Some issues are not applicable to 11 GGNS because of site characteristics or plant features. Section 1.4 of this supplemental 12 environmental impact statement (SEIS) provides an explanation of the criteria for Category 1 13 and Category 2 issues, as well as the definitions of SMALL, MODERATE, and LARGE. As also 14 described in Section 1.4, the U.S. Nuclear Regulatory Commission (NRC) has published a final 15 rule (78 FR 37282, June 20, 2013) revising its environmental protection regulation, Title 10 of 16 the Code of Federal Regulations (10 CFR) Part 51, "Environmental Protection Regulations for 17 Domestic Licensing and Related Regulatory Functions." The final rule consolidates similar 18 Category 1 and 2 issues, changes some issues from Category 2 to Category 1 issues, and 19 consolidates some of those issues with existing Category 1 issues. The final rule also adds new 20 Category 1 and 2 issues. 21 The NRC staff also considers new and significant information on environmental issues related to 22 operation during the renewal term. New and significant information is information that identifies 23 a significant environmental issue not covered in the GEIS and codified in Table B -1 of 24 Appendix B to Subpart A of 10 CFR Part 51 or information that was not considered in the 25 analyses summarized in the GEIS and that leads to an impact finding that is different from the 26 finding presented in the GEIS and codified in 10 CFR Part 51. Section 4.11 of this SEIS 27 describes the process used to identify and evaluate new and significant information. 28 4.1 Land Use 29 Table 4-1 identifies the two land use issues applicable to GGNS during the renewal term. 30 Section 2.2.1 of this SEIS describes the land use conditions near GGNS. 31 Table 4-1. Land Use Issues 32 Issue GE IS section Category Onsite land use 4.5.3 1 Power line right-of-way (ROW) 4.5.3 1 Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 The NRC staff did not find any new and significant information during the review of the 33 applicant's Environmental Report (ER) (Entergy 201 1a), the site audit, the scoping process, or 34 the evaluation of other available information. Therefore, the staff concludes that there are no 35 impacts related to these issues beyond those discussed in the GEIS. Consistent with the GEIS, 36 the staff concludes that the impacts are SMALL. 37 Environmental Impacts of Operation 4-2 4.2 Air Quality 1 Table 4-2 identifies the air quality issue applicable to GGNS during the renewal term. Section 2 2.2.2 of this SEIS describes the meteorology and air quality in the vicinity of GGNS. 3 Table 4-2. Air Quality Issues 4 Issue GEIS Section Category Air quality effects of transmission lines 4.5.2 1 Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 The NRC staff did not find any new and significant information during the review of the 5 applicant's ER (Entergy 201 1a), the site audit, the scoping process, or the evaluation of other 6 available information. Therefore, the staff concludes that there are no impacts related to this 7 issue beyond those discussed in the GEIS. Consistent with the GEIS, the staff concludes that 8 the impacts are SMALL. 9 4.3 Geologic Environment 10 4.3.1 Geology and Soils 11 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmenta l 12 protection regulation, 10 CFR Part 51, "Environmental protection regulations for domestic 13 licensing and related regulatory functions." With respect to the geologic environment of a plant 14 site, the final rule amend s Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 , by adding a 15 new Category 1 issue, "Geology and soils." This new issue has an impact level of SMALL. This 16 new Category 1 issue considers geology and soils from the perspective of those resource 17 conditions or attributes that can be affected by continued operations during the renewal term. 18 An understanding of geologic and soil conditions has been well established at all nuclear power 19 plants and associated transmission lines during the current licensing term, and these conditions 20 are expected to remain unchanged during the 20 -year license renewal term for each plant. The 21 impact of these conditions on plant operations and the impact of continued power plant 22 operations and refurbishment activities on geology and soils are SMALL for all nuclear power 23 plants and not expected to change appreciably during the license renewal term. Operating 24 experience shows that any impacts to geologic and soil strata would be limited to soil 25 disturbance from construction activities associated with routine infrastructure renovation and 26 maintenance projects during continued plant operations. Implementing best management 27 practices would reduce soil erosion and subsequent impacts on surface water quality. 28 Information in plant -specific SEISs prepared to date and reference documents has not identified 29 these impacts as being significant. 30 Section 2.2.3 of this SEIS describes the local and regional geologic environment relevant to 31 GGNS. The NRC staff did not identify any new and significant information with regard to th is 32 Category 1 (generic) issue based on review of the ER (Entergy 2011a), the public scoping 33 process, or as a result of the environmental site audit. As discussed in Chapter 3 of this SEIS 34 and as identified in the ER (Entergy 2011a), Entergy has no plans to conduct refurbishment or 35 replacement actions associated with license renewal to support the continued operation of 36 GGNS. Further, Entergy anticipates no new construction or other ground -disturbing activities or 37 changes in operations and that operation and maintenance activities would be confined to 38 previously disturbed areas or existing ROWs. Based on this information, it is expected that any 39 incremental impacts on geology and soils during the license renewal term would be SMALL. 40 Environmental Impacts of Operation 4-3 4.4 Surface Water Resources 1 Table 4-3 identifies the surface water issues applicable to GGNS during the renewal term. 2 Section 2.2.4 of this SEIS describes surface water at GGNS. 3 Table 4-3. Surface Water Issues 4 Issue GEIS Section Category Impact of refurbishment on surface water quality 3.4.1 1 Impacts of refurbishment on surface water use 3.4.1 1 Altered salinity gradients 4.2.1.2.1 1 Temperature effects on sediment transport capacity 4.2.1.2.3 1 Scouring caused by discharged cooling water 4.2.1.2.3 1 Eutrophication 4.2.1.2.3 1 Discharge of chlorine or other biocides 4.2.1.2.4 1 Discharge of sanitary wastes and minor chemical spills 4.2.1.2.4 1 Discharge of other metals in wastewater 4.2.1.2.4 1 Table source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51 The NRC staff did not find any new and significant information during the review of the 5 applicant's ER (Entergy 201 1a), the site audit, the scoping process, or the evaluation of other 6 available information. Therefore, the staff concludes that there are no impacts related to these 7 issues beyond those discussed in the GEIS. For these issues, the GEIS concludes that the 8 impacts are SMALL. 9 4.5 Groundwater Resources 10 Table 4-4 identifies the issues related to groundwater that are applicable to GGNS during the 11 renewal term. Section 2.2.5 of this SEIS describes groundwater at GGNS. 12 Table 4-4. Groundwater Issues 13 Issue GEIS Section Category Groundwater use conflicts (potable and service water; plants that use <100 gpm) 4.8.1.1 1 Groundwater use conflicts (Ranney wells) 4.8.1.4 2 Groundwater quality degradation (Ranney wells) 4.8.2.2 1 Radionuclides released to groundwater 4.5.1.2(a) 2 Table source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51; (a) NRC 2013a 4.5.1 Generic Groundwater Issues 14 The NRC staff did not identify any new and significant information associated with the 15 Category 1 groundwater issues during the review of the applicant's ER (Entergy 201 1a), the site 16 audit, the scoping process, or the evaluation of other available information. Therefore, the staff 17 concludes that there are no impacts related to these issues beyond those discussed in the 18 GEIS. Consistent with the GEIS, the staff concludes that the impacts are SMALL. 19 Environmental Impacts of Operation 4-4 4.5.2 Groundwater Use Conflicts (Ranney Wells) 1 For nuclear power plants using Ranney wells or pumping more than 100 gpm (0.006 m 3/s) of 2 groundwater (total on site), the potential impact on groundwater is considered a Category 2 3 issue, therefore requiring a plant -specific assessment. The requirement for this assessment is 4 specified by 10 CFR 51.53(c)(3)(ii)(C). This groundwater aspect was classified as a site-5 specific (Category

2) issue because groundwater levels might be lowered beyond the site 6 boundary. The staff previously concluded in the GEIS that "[t]he impact of cooling water intake 7 on groundwater at the Grand Gulf plant (the only plant employing Ranney wells) does not 8 conflict with other groundwater uses in the area" (NRC 1996). In evaluating the potential 9 impacts resulting from groundwater use conflicts associated with license renewal, the NRC staff 10 uses as its baseline the existing groundwater resource conditions described in Sections 2.1.7 11 and 2.2.5 of this SEIS. These baseline conditions encompass the existing hydrogeologic 12 framework and conditions (including aquifers) potentially affected by continued operations as 13 well as the nature and magnitude of groundwater withdrawals for cooling and other purposes 14 (as compared to relevant appropriation and permitting standards). The baseline also considers 15 other downgradient or in

-aquifer uses and users of groundwater. 16 Future activities at the GGNS site are not expected to lower groundwater levels beyond the 17 plant boundary. The original evaluation of groundwater withdrawal impacts in the GGNS final 18 environmental statemen t (FES) was for an estimated 42,636 gpm (2.69 m 3/s) for makeup 19 cooling water needs. This evaluation was for two nuclear reactors (NRC 1973). However, only 20 one reactor was constructed. Groundwater withdrawals during the license renewal term are 21 expected to be approximately 27,860 gpm (1.76 m 3/s), which is about 65 percent of the 22 withdrawal rate previously evaluated and found to be acceptable (Entergy 2011 a). Groundwater 23 level changes are not detected far from the Ranney well s (Entergy 2011 a) because water from 24 the Mississippi River continuously flows into the Mississippi River Alluvial Aquifer, which 25 supplies the Ranney wells, and the aquifer is a thick water table aquifer. Consistent with the 26 GEIS, the staff concludes that the impact for this issue is SMALL. 27 4.5.3 Radionuclides Released to Groundwater 28 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 29 protection regulation, 10 CFR Part 51. With respect to groundwater quality, the final rule 30 amend s Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new 31 Category 2 issue, "Radionuclides released to groundwater," with an impact level range of 32 SMALL to MODERATE, to evaluate the potential impact of discharges of radionuclides from 33 plant systems into groundwater. This new Category 2 issue has been added to evaluate the 34 potential impact to groundwater quality from the discharge of radionuclides from plant systems, 35 piping, and tanks. This issue was added because, within the past several years, there have 36 been events at nuclear power reactor sites that involved unknown, uncontrolled, and 37 unmonitored releases of radioactive liquids into the groundwater. In evaluating the potential 38 impacts on groundwater quality associated with license renewal, the NRC staff uses as its 39 baseline the existing groundwater conditions described in Section 2.2.5 of this SEIS. These 40 baseline conditions encompass the existing quality of groundwater potentially affected by 41 continued operations (as compared to relevant state or EPA primary drinking water standards) 42 as well as the current and potential onsite and offsite uses and users of groundwater for drinking 43 and other purposes. The baseline also considers other downgradient or in -aquifer uses and 44 users of groundwater. 45 Section 2.2.5.4 of this SEIS contains a description of tritium contamination on the northeast side 46 of the Unit 2 power block. The groundwater contamination appears to be restricted to the 47 Environmental Impacts of Operation 4-5 backfill material and the Upland Complex Aquifer near the power block. This power block does 1 not contain a nuclear reactor. No other radionuclides have been detected above background 2 levels in the Upland Complex Aquifer. Tritium -contaminated groundwater has not migrated off 3 site. No radionuclide concentrations above background levels have been detected in the 4 Catahoula Aquifer or the Mississippi River Alluvial Aquifer or in any other areas in the Upland 5 Complex Aquifer. 6 GGNS is actively involved in defining the extent of contamination and determining its cause 7 (Entergy 2011 a). Should the contamination continue unchecked, it is very unlikely to move 8 downward into the Catahoula Aquifer because of the thick clay bed on top of the aquifer. 9 Rather, the areas of contamination should move laterally with the direction of groundwater flow 10 (northeast) within the Upland Complex Aquifer. 11 At this time, it is unknown if the plume will continue in that direction or if it will eventually flow 12 into the Mississippi River Alluvial Aquifer and from there to the Mississippi River. In any case, 13 dispersion, radioactive decay, and dilution would decrease the tritium activity concentration in 14 the plume. 15 In 2007, the nuclear power industry began implementing its "Industry Ground Water Protection 16 Initiative" (NEI 2007). Since 2008, the staff has been monitoring implementation of this initiative 17 at licensed nuclear reactor sites. The initiative identifies actions to improve utilities' 18 management and response to instances in which the inadvertent release of radioactive 19 substances may result in low but detectible levels of plant -related materials in subsurface soils 20 and water. It also seeks to identify those actions necessary for implementation of a timely and 21 effective groundwater protection program. The area s of contamination were discovered as part 22 of GGNS participation in this initiative. At this time, monitoring wells have been drilled on all 23 sides of the power blocks and GGNS is monitoring them. Monitoring results from these wells 24 are reported annually to the NRC. 25 The NRC staff's analysis of groundwater monitoring results and the site's hydrogeologic regime 26 indicates there is no immediate threat to groundwater resources. Water use in the area should 27 not be affected even if tritium -contaminated groundwater were ever to move off site. Therefore, 28 the NRC staff concludes that inadvertent releases of tritium have not substantially impaired site 29 groundwater quality or affected groundwater use. With continued NRC attention and GGNS 30 action, the NRC staff further concludes that groundwater quality impacts would remain SMALL 31 during the license renewal term. 32 4.6 Aquatic Resources 33 Sections 2.1.6 and 2.2.6 of this SEIS describe the GGNS cooling system and aquatic 34 environment, respectively. Table 4 -5 identifies the Category 1 issues related to aquatic 35 resources that are applicable to GGNS during the renewal term. There are no Category 2 36 issues that apply to aquatic resources at GGNS. The staff did not find any new and significant 37 information during the review of the applicant's ER (Entergy 201 1a), the site audit, the scoping 38 process, or the evaluation of other available information; therefore, the staff concludes that there 39 are no impacts related to aquatic resource issues beyond those discussed in the GEIS. For 40 these issues, the GEIS concludes that the impacts are SMALL. 41 Environmental Impacts of Operation 4-6 Table 4-5. Aquatic Resource Issues 1 Issues GEIS Section Category For All Plants Accumulation of contaminants in sediments or biota 4.1.1.2.4 1 Entrainment of phytoplankton & zooplankton 4.2.2.1.1 1 Cold shock 4.2.2.1.5 1 Thermal plume barrier to migrating fish 4.2.2.1.6 1 Distribution of aquatic organisms 4.2.2.1.6 1 Premature emergence of aquatic insects 4.2.2.1.7 1 Gas supersaturation (gas bubble disease) 4.2.2.1.8 1 Low dissolved oxygen in the discharge 4.2.2.1.9 1 Losses from predation, parasitism, and disease among organisms exposed to sublethal stresses 4.2.2.1.10 1 Stimulation of nuisance organisms 4.2.2.1.11 1 Exposure of aquatic organisms to radionuclides 4.6.1.2(a) 1 For Plants with Cooling Tower -Based Heat Dissipation Systems Entrainment of fish and shellfish in early life stages 4.3.3 1 Impingement of fish and shellfish 4.3.3 1 Heat shock 4.3.3 1 Table source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51; (a) NRC 2013a 4.6.1 Exposure of Aquatic Organisms to Radionuclides 2 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 3 protection regulation, 10 CFR Part 51. With respect to the aquatic organisms, the revision 4 amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new Category 1 5 issue, "Exposure of aquatic organisms to radionuclides," among other changes. This new 6 Category 1 issue considers the impacts to aquatic organisms from exposure to radioactive 7 effluents discharged from a nuclear power plant during the license renewal term. An 8 understanding of the radiological conditions in the aquatic environment from the discharge of 9 radioactive effluents within NRC regulations has been well established at nuclear power plants 10 during their current licensing term. Based on this information, the NRC concluded that the 11 doses to aquatic organisms are expected to be well below exposure guidelines developed to 12 protect these organisms and assigned an impact level of SMALL. 13 The NRC staff has not identified any new and significant information related to the exposure of 14 aquatic organisms to radionuclides during its independent review of the applicant's ER, the site 15 audit, and the scoping process. Section 2.1.2 of this SEIS describes the applicant's radioactive 16 waste management program to control radioactive effluent discharges to ensure that they 17 comply with NRC regulations in 10 CFR Part 20. Section 4.9.2 of this SEIS contains the NRC 18 staff's evaluation of GGNS's radioactive effluent and radiological environmental monitoring 19 programs. GGNS's radioactive effluent and radiological environmental monitoring programs 20 provide further support for the conclusion that the impacts to aquatic organisms from 21 radionuclides are SMALL. The NRC staff concludes that there would be no impacts to aquatic 22 organisms from radionuclides beyond those impacts contained in the GEIS (NRC 2013a) and 23 therefore, the impacts to aquatic organisms from radionuclides are SMALL. 24 4.7 Terrestrial Resources 25 The Category 1 (generic) and Category 2 (site -specific) terrestrial resources issues applicable t o 26 GGNS are discussed in the following sections and listed in Table 4-6. Terrestrial resources 27 issues that apply to GGNS are described in Sections 2.2.7 and 2.2.8. 28 Environmental Impacts of Operation 4-7 Table 4-6. Terrestrial Resource Issues 1 Issue GEIS Section Category Cooling tower impacts on crops and ornamental vegetation 4.3.4 1 Cooling tower impacts on native plants 4.3.5.1 1 Bird collisions with cooling towers 4.3.5.2 1 Power line right -of-way management (cutting, herbicide application) 4.5.6.1 1 Bird collisions with power lines 4.5.6.1 1 Impacts of electromagnetic fields on flora and fauna (plants, agricultural crops, honeybees, wildlife, livestock) 4.5.6.3 1 Floodplains and wetland on power line right -of-way 4.5.7 1 Exposure of terrestrial organisms to radionuclides 4.6.1.1(a) 1 Effects on terrestrial resources (non -cooling system impacts) 4.6.1.1(a) 2 Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51; (a) NRC 2013a 4.7.1 Generic Terrestrial Resource Issues 2 For the Category 1 terrestrial resources issues listed in Table 4 -6, the NRC staff did not identify 3 any new and significant information during the review of the ER (Entergy 2011a), the NRC 4 staff's site audit, the scoping process, or the evaluation of other available information. 5 Therefore, there are no impacts related to these issues beyond those discussed in the GEIS. 6 For these issues, the GEIS concludes that the impacts are SMALL. 7 4.7.2 Exposure of Terrestrial Organisms to Radionuclides 8 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 9 protection regulation, 10 CFR Part 51. With respect to the terrestrial organisms, the revision 10 amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new Category 1 11 issue, "Exposure of terrestrial organisms to radionuclides," among other changes. This new 12 issue has an impact level of SMALL. This new Category 1 issue considers the impacts to 13 terrestrial organisms from exposure to radioactive effluents discharged from a nuclear power 14 plant during the license renewal term. An understanding of the radiological conditions in the 15 terrestrial environment from the discharge of radioactive effluents within NRC regulations has 16 been well established at nuclear power plants during the ir current licensing term. Based on this 17 information, the NRC concluded that the doses to terrestrial organisms are expected to be well 18 below exposure guidelines developed to protect these organisms and assigned an impact level 19 of SMALL. 20 The NRC staff has not identified any new and significant information related to the exposure of 21 terrestrial organisms to radionuclides during its independent review of the applicant's ER, the 22 site audit, and the scoping process. Section 2.1.2 of this SEIS describes the applicant's 23 radioactive waste management program to control radioactive effluent discharges to ensure that 24 they comply with NRC regulations in 10 CFR Part 20. Section 4.9.2 of this SEIS contains t he 25 NRC staff's evaluation of GGNS's radioactive effluent and radiological environmental monitoring 26 programs. GGNS's radioactive effluent and radiological environmental monitoring programs 27 provide further support for the conclusion that the impacts from radioactive effluents are SMAL L. 28 Environmental Impacts of Operation 4-8 Therefore, the NRC staff concludes that there would be no impact to terrestrial organisms from 1 radionuclides beyond those impacts contained in the GEIS (NRC 2013a). For this issue, the 2 GEIS concl udes that the impacts are SMALL. 3 4.7.3 Effects on Terrestrial Resources (Non -cooling System Impacts) 4 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 5 protection regulation, 10 CFR Part 51. With respect to the terrestrial organisms, the revision 6 amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by expanding the Category 2 7 issue, "Refurbishment impacts," among others, to include normal operations, refurbishment, and 8 other supporting activities during the license renewal term. This issue remains a Category 2 9 issue with an impact level range of SMALL to LARGE; however, the GEIS (NRC 2013a) 10 renames this issue "Effects on terrestrial resources (non-cooling system impacts)." 11 The geographic scope for the assessment of this issue is the GGNS site and area near the site, 12 and the baseline is the condition of the terrestrial resources under the no -action alternative. 13 Section 2.2.7 describes the terrestrial resources on and in the vicinity of the GGNS site, and 14 Section 2.2.8 describes protected species and habitats. During construction of GGNS, 15 approximately 14 percent of the plant site (270 ac [109 ha]) was cleared for buildings, parking 16 lots, roads, and other infrastructure. The remaining terrestrial and associated wetland habitats 17 have not changed significantly since construction , except for reforestation activities performed 18 by Entergy (see Section 2.2.7). As discussed in Chapter 3 of this SEIS and according to the 19 applicant's ER (Entergy 2011a), Entergy has no plans to conduct refurbishment or replacement 20 actions associated with license renewal to support the continued operation of GGNS. Further, 21 Entergy (2011a) anticipates no new construction or other ground-disturbing activities, changes 22 in operations, or changes in existing land use conditions due to license renewal. Entergy 23 (2011a) reports that operation and maintenance activities would be confined to previously 24 disturbed areas or existing ROWs. As a result, Entergy (2011a) anticipates no new impacts on 25 the terrestrial environment on the GGNS site or along the in-scope transmission line corridors 26 during the license renewal term. Based on the staff's independent review, the staff concludes 27 that operation and maintenance activities that Entergy might undertake during the renewal term, 28 such as maintenance and repair of plant infrastructure (e.g., roadways, piping installations, 29 onsite transmission lines, fencing and other security infrastructure), would likely be confined to 30 previously -disturbed areas of the GGNS site. Therefore, the staff expects non -cooling system 31 impacts on terrestrial resources during the license renewal term to be SMALL. 32 4.8 Protected Species and Habitats 33 Section 2.2.8 of this SEIS describes the action area, as defined by the Endangered Species Act 34 of 1973, as amended (ESA), regulations at 50 CFR 402.02, and describes the protected species 35 and habitats within the action area associated with the GGNS license renewal. 36 Table 4-7 identifies the one Category 2 issue related to protected species and habitats that is 37 applicable to GGNS. 38 Table 4-7. Threatened or Endangered Species 39 Issue GEIS Section Category Threatened or endangered species 4.1 2 Table source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51 Environmental Impacts of Operation 4-9 4.8.1 Correspondence with Federal and State Agencies 1 As part of its National Environmental Policy Act (NEPA) and ESA reviews, the NRC staff 2 contacted the Louisiana and Mississippi Field Offices of the U.S. Fish and Wildlife Service 3 (FWS), the National Marine Fisheries Service (NMFS), the Louisiana Department of Wildlife and 4 Fisheries (LDWF) and the Mississippi Department of Wildlife, Fisheries, and Parks (MDWFP) to 5 gather information on protected species and habitats that may occur in the action area. 6 The NRC staff sent letters to the Louisiana and Mississippi FWS Field Offices and the NMFS on 7 January 19, 2012 (NRC 2012a, 2012b, 2012c), requesting concurrence with the NRC's list of 8 Federally protected species in the vicinity of GGNS. The Mississippi FWS Field Office replied in 9 a letter dated February 3, 2012 (FWS 2012a). In that letter, the FWS did not address the list of 10 Federally protected species, but it stated that no Federally listed species or their habitats are 11 likely to be affected from the proposed GGNS license renewal and that no further consultation 12 under the ESA would be necessary with that office. The Louisiana FWS Field Office concurred 13 with the NRC's list of Federally protected species in the vicinity of GGNS in a letter dated 14 February 29, 2012 (FWS 2012b). The NMFS replied to the NRC on March 1, 2012, as 15 described in Section 2.2.8 (NMFS 2012). 16 The NRC sent a letter to the MDWFP on January 20, 2012 (NRC 2012d), requesting information 17 on both Federally and State -listed species. The MDWFP replied in a letter dated 18 February 13, 2012 (MDWFP 2012), that provided the NRC with a list of species that occur within 19 2 mi (3.2 km) of the GGNS site and transmission line corridors. 20 The NRC (2012e) sent a letter to the LDWF on February 6, 2012, requesting information on 21 both Federally and State -listed species. The LDWF (2012) replied in a letter dated 22 February 16, 2012, that stated, "After careful review of our database, no impacts to rare, 23 threatened or endangered species or critical habitats are anticipated from the proposed project." 24 Pursuant to the ESA, the NRC intends to submit this draft SEIS to the FWS with a request for 25 concurrence on the NRC's effect determinations for Federally listed species and designated 26 critical habitat. The results of this consultation will be documented in the final SEIS. 27 4.8.2 Species and Habitats Protected Under the Endangered Species Act 28 4.8.2.1 Wood Stork 29 Section 2.2.8 concludes that the wood stork (Mycteria americana) occurs in the action area, but 30 that the individuals within Mississippi do not represent members of the endanger ed 31 U.S. breeding populations. Thus, the staff concludes that the proposed GGNS license renewal 32 would have no effect on the wood stork. 33 4.8.2.2 Red-cockaded Woodpecker 34 Section 2.2.8 concludes that the red -cockaded woodpecker occurs in the action area along the 35 portion of the Franklin transmission line corridor that travels through the Homochitto National 36 Forest and the corresponding 1 -mi (0.6-km) buffer. 37 Because the red -cockaded woodpecker does not occur on the GGNS site, ongoing operations 38 and maintenance activities associated with the proposed license renewal would have no effect 39 on the species. 40 In 2003, the U.S. Forest Service (USFS) completed an environmental assessment that 41 considered the environmental effects of managing utility corridors with practices intended to 42 enhance wildlife habitat within the Homochitto National Forest (USFS 2003). The environmental 43 assessment included a biological evaluation of the effects of transmission line maintenance on 44 Environmental Impacts of Operation 4-10 the red-cockaded woodpecker. The biological evaluation concluded that herbicide application 1 and other activities associated with transmission line maintenance would have no direct or 2 indirect effects on the species (USFS 2003). Since EMI's transmission line maintenance 3 procedures have not changed since 2003, the NRC adopts the USFS's conclusion of "no effect." 4 Additionally, in correspondence with the NRC, the FWS (2012a) indicated that no Federally 5 listed species would be affected by the proposed license renewal. 6 The staff concludes that the proposed license renewal would have no effect on the 7 red-cockaded woodpecker. 8 4.8.2.3 Least Tern (Interior Population) 9 Section 2.2.8 concludes that the least tern occurs within the action area along the Mississippi 10 River upstream and downstream of the GGNS site. The proposed GGNS license renewal 11 would not include new construction, refurbishment, ground-disturbing activities, or changes to 12 existing land use conditions that would affect any of the natural habitats on the site or any offsite 13 areas. Additionally, in its correspondence with the NRC, the FWS (2012 b) indicated that no 14 Federally listed species would be affected by the proposed license renewal. 15 The staff concludes that the proposed action would have no effect on the least tern. 16 4.8.2.4 Bayou Darter 17 Section 2.2.8 concludes that bayou darters occur in the action area along the portion of the 18 Franklin transmission line corridor that crosses Bayou Pierre. Although highly unlikely, 19 transmission line and vegetation maintenance requiring in -stream work could adversely affect 20 bayou darters directly or indirectly. Potential indirect effects could include a temporary decline 21 in habitat quality from increased sedimentation and turbidity during maintenance activities. 22 Entergy Mississippi, Inc. (EMI), takes a number of precautions to avoid impacts to bayou darters 23 and their habitat when performing maintenance in or near water bodies. As described in 24 Section 2.1.5, EMI chooses maintenance techniques that minimize impacts in streams and 25 other water features. In wetlands and aquatic habitats, EMI personnel selectively apply 26 Environmental Prote ction Agency (EPA) approved herbicides for wetlands and aquatic area 27 applications. Personnel spray areas on foot with backpack sprayers to minimize impacts. All 28 EMI maintenance crew personnel hold U.S. Department of Agriculture (USDA) State-approved 29 herbicide licenses. Therefore, the continued operation and maintenance of the Franklin 30 transmission line would have discountable or insignificant effects on bayou darters. 31 Bayou darters do not occur on the GGNS site because the species is endemic to the Bayou 32 Pierre, which does not flow through GGNS, as described in Section 2.2.8. Because bayou 33 darters do not occur on the GGNS site, ongoing operations and maintenance activities 34 associated with the proposed license renewal would have no effect on the species. 35 In correspondence with the NRC, the FWS Mississippi Field Office concluded that neither bayou 36 darters nor their habitat would likely be affected from the proposed GGNS operating license 37 renewal (FWS 2012 a). Similarly, MDFWP (2012) stated that the proposed project likely poses 38 no threat to listed species or their habitat if best management practices are properly 39 implemented. Based on FWS (2012a), MDWFP (2012), and the NRC staff's assessment that 40 the continued operation and maintenance of the Franklin transmission line would have 41 discountable or insignificant effects on bayou darters, the NRC staff concludes that the 42 proposed GGNS license renewal may affect, but is not likely to adversely affect bayou darters. 43 4.8.2.5 Pallid Sturgeon 44 Section 2.2.8 concludes that pallid sturgeon could occur in the action area in the Mississippi 45 River. Increased water temperature and other conditions near GGNS's discharge could affect 46 Environmental Impacts of Operation 4-11 pallid sturgeon. Direct effects to pallid sturgeon from heat shock would be highly unlikely 1 because the thermal plume does not create a barrier across the Mississippi River; therefore, the 2 fish could avoid the warmer temperature water (NRC 1972). Indirect effects could include a 3 decrease in habitat quality from thermal discharge in the Mississippi River. GGNS's NPDES 4 permit limits the flow, temperature, and other conditions of GGNS's discharge into the 5 Mississippi River. Therefore, the continued discharge from GGNS would have discountable or 6 insignificant effects on pallid sturgeon. 7 In correspondence with the NRC, the FWS Mississippi Field Office concluded that neither pallid 8 sturgeon nor their habitat would likely be affected from the proposed GGNS operating license 9 renewal (FWS 2012 a). Similarly, MDFWP (2012) stated that the proposed project likely poses 10 no threat to listed species or their habitat if best management practices are implemented 11 properly. Based on FWS (2012a), MDWFP (2012), and the staff's assessment that the 12 continued discharge from GGNS would have discountable or insignificant effects on pallid 13 sturgeon, the NRC staff concludes that the proposed GGNS license renewal may affect, but is 14 not likely to adversely affect the pallid sturgeon. 15 4.8.2.6 Louisiana and American Black Bears 16 Section 2.2.8 concludes that the Louisiana (Ursus americanus luteolus) and American 17 (U. americanus) black bears occur in the action area in bottomland hardwood forest habitat or 18 other suitable habitat. Black bears would be expected to avoid areas of human activity and 19 would be unlikely to occur on the developed portion of the GGNS site. Within the GGNS site, 20 the proposed license renewal would include maintenance and operation activities within 21 developed or previously disturbed areas and would not involve new construction, refurbishment , 22 ground-disturbing activities, or changes to existing land use conditions in either natural or 23 developed areas. The continued operation of GGNS during the license renewal term would 24 preserve the existing natural habitats on the site. The large tracts of bottomland and upland 25 hardwood forests on the site are relatively remote, restricted from public access, and provide 26 contiguous habitat with offsite areas of hardwood forest. Therefore, continued operation of the 27 GGNS site could result in beneficial effects to the species. 28 The continued operation and maintenance of the Baxter -Wilson and Franklin transmission lines 29 would have discountable or insignificant effects on black bears. Within the transmission line 30 corridors, black bears could take in herbicides that have been sprayed on berries or shrubs. 31 Noise from machinery and human activity could temporarily alter the behavior of black bears 32 during transmission line maintenance activities. However, none of these effects would be 33 measurable or detectable or reach the scale in which a take would occur. Transmission line 34 maintenance could require removal of mature trees if they pose a threat to the transmission 35 lines; however, black bears are unlikely to den at the edge of forest habitat, so tree removal 36 should not affect denning habitat. 37 Based on the staff's assessment that the continued operation and maintenance of the 38 Baxter-Wilson and Franklin transmission lines would have discountable or insignificant effects 39 on bears, the NRC staff concludes that the proposed GGNS license renewal may affect, but is 40 not likely to adversely affect the Louisiana and American black bears. 41 4.8.2.7 Louisiana Black Bear Critical Habitat 42 Secti on 2.2.8 concludes that no designated Louisiana black bear critical habitat occurs within 43 the action area, but notes that the closest designated critical habitat lies about 16 mi (26 km) 44 west of the GGNS site at its closest point. Because no designated critical habitat lies within the 45 action area, the staff conclude s that the proposed GGNS license renewal would have no effect 46 on designated Louisiana black bear critical habitat. 47 Environmental Impacts of Operation 4-12 4.8.2.8 Fat Pocketbook Mussel 1 Section 2.2.8 concluded that fat pocketbook mussels are not likely to occur within the action 2 area. In correspondence with the NRC, the FWS Mississippi Field Office concluded that neither 3 fat pocketbook mussels nor their habitat would likely be affected from the proposed license 4 renewal (FWS 2012 a). Similarly, MDFWP (2012) stated that the proposed project likely poses 5 no threat to listed species or their habitat if best management practices are implemented 6 properly. Therefore, the staff concludes that the proposed GGNS license renewal would have 7 no effect on fat pocketbook mussels. 8 4.8.2.9 Rabbitsfoot Mussel 9 Section 2.2.8 concluded that rabbitsfoot mussels are not likely to occur within the action area. 10 In correspondence with natural resource agencies, FWS Mississippi Field Office, FWS 11 Louisiana Field Office, and MDW FP did not include rabbitsfoot mussel as a species that would 12 be affected by the proposed license renewal (FWS 2012 a, 2012 b; MDFWP 2012). Therefore, 13 the staff concludes that the proposed GGNS license renewal would have no effect on 14 rabbitsfoot mussels. 15 4.8.2.10 Rabbitsfoot Mussel Proposed Critical Habitat 16 Section 2.2.8 concludes that no proposed rabbitsfoot mussel critical habitat occurs within the 17 action area. Thus, the staff conclude s that the proposed GGNS license renewal would have no 18 effect on proposed rabbitsfoot mussel critical habitat. 19 4.8.3 Species Protected by the State of Mississippi 20 4.8.3.1 Aquatic Species 21 Section 2.2.8 concluded that the chestnut lamprey, black buffalo, paddlefish, blue sucker, and 22 sicklefin chub inhabit portions of the Mississippi River (NatureServe 2010). Section 2.2.8 also 23 concluded that crystal darter, chestnut lamprey, blue sucker, black buffalo sicklefin chub, and 24 paddlefish may occur in suitable habitat along the transmission line corridors, such as the 25 transmission line crossings along the Mississippi, Big Black, and Bayou Pierre rivers. No 26 GGNS-related aquatic surveys have been conducted along the transmission lines. 27 In the Mississippi River, increased water temperature and other conditions near GGNS's 28 discharge could affect State-protected fish. As described above, GGNS's NPDES permit limits 29 the flow, temperature, and other conditions of GGNS's discharge into the Mississippi River. In 30 addition, the thermal plume would not extend the width of the Mississippi River; therefore, fish 31 could swim away to avoid the plume (NRC 1972). 32 The continued operation and maintenance of the transmission lines would have discountable or 33 insignificant effects on State-protected fish. Although highly unlikely, line and vegetation 34 maintenance requiring in -stream work could adversely affect fish directly and indirectly. 35 Potential adverse effects include a temporary decline in habitat quality from increased 36 sedimentation and turbidity during maintenance activities. As described in Section 2.1.5, EMI 37 takes a number of precautions to avoid impacts to State-protected fish and their habitat when 38 performing transmission line maintenance in or near water bodies. As described in Section 39 2.1.5, EMI chooses maintenance techniques that minimize erosion in streams and other water 40 features. In wetlands and aquatic habitats, EMI personnel selectively apply EPA -approved 41 herbicides on foot with backpack sprayers to minimize impacts. All EMI maintenance crew 42 personnel hold USDA state -approved herbicide licenses. 43 Environmental Impacts of Operation 4-13 In correspondence with the NRC, MDWFP (2012) did not identify any impacts of the proposed 1 license renewal that would affect State-protected species, assuming that best management 2 practices are implemented properly 3 4.8.3.2 Terrestrial Species 4 Section 2.2.8 discusses two species protected under the Mississippi Nongame and Endangered 5 Species Conservation Act of 1974: Webster's salamander (Plethodon websteri) and the white 6 ibis (Eudocimus albus). In its correspondence with the NRC, the MDWFP (2012) concluded 7 that "the proposed project likely poses no threat to listed species or their habitats." 8 4.8.4 Species Protected Under the Bald and Golden Eagle Protection Act 9 Though bald eagles occur throughout the action area, no known nests are in close proximity to 10 the GGNS site or along the transmission line corridors that could be disturbed by operations or 11 maintenance activities associated with the proposed license renewal. Since the proposed 12 license renewal does not involve construction or land disturbances, the proposed license 13 renewal would not affect any bald eagle habitat. 14 4.8.5 Species Protected Under the Migratory Bird Treaty Act 15 Section 2.2.7 discusses a variety of migratory birds that inhabit the GGNS site and surrounding 16 region. Section

2.2.8 describes

Entergy's depredation permit for cliff swallows 17 (Petrochelidon spp.) and barn swallows (Hirundo rustica). In the past 5 years of available 18 depredation reports, Entergy has taken a small number of birds to ensure the safety and 19 integrity of plant structures. This small number of takes would not be expected to destabilize or 20 noticeably alter either species' populations. Also, the FWS reviews Entergy's depredation 21 reports and renews the depredation permit annually to ensure that impacts to migratory birds 22 are minimal. The proposed license renewal does not involve construction or other land 23 disturbances that might adversely affect migratory birds. 24 4.9 Human Health 25 Table 4-8 lists the issues related to human health that are applicable to GGNS. 26 Table 4-8. Human Health Issues 27 Issue GEIS Section Category Microbiological organisms (occupational health) 4.3.6 1 Noise 4.3.7 1 Radiation exposures to public (license renewal term) 4.6.2 1 Occupational radiation exposures (license renewal term) 4.6.3 1 Electromagnetic fields -acute effects (electric shock) 4.5.4.1 2 Electromagnetic fields -chronic effects 4.5.4.2 Uncategorized Human health impact from chemicals 4.9.1.1.2 (a) 1 Physical occupational hazards 4.9.1.1.5 (a) 1 Table source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51; (a) NRC 2013 a 4.9.1 Generic Human Health Issues 28 Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B -1, applicable to GGNS in 29 regard to human health are listed in Table 4 -9. Entergy stated in its ER (Entergy 2011a) that it 30 Environmental Impacts of Operation 4-14 was not aware of any new and significant human health issues associated with the renewal of 1 the GGNS operating license. The NRC staff did not identify any new and significant information 2 during its independent review of the applicant's ER, the staff's site audit, the scoping process, or 3 the evaluation of other available information. Therefore, there are no impacts related to 4 Category 1 human health issues beyond those discussed in the GEIS . For these issues, the 5 GEIS concluded that the impacts are SMALL, and additional site -specific mitigation measures 6 are not likely to be sufficiently beneficial to warrant implementation. These impacts are 7 expected to remain SMALL through the license renewal term. 8 4.9.1.1 New Category 1 Human Health issues 9 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 10 protection regulation, 10 CFR Part 51. With respect to the human health, the revision amend s 11 Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding two new Category 1 issues, 12 "Human health impact from chemicals" and "Physical occupational hazards." The first issue 13 considers the impacts from chemicals to plant workers and members of the public. The second 14 issue only considers the non -radiological occupational hazards of working at a nuclear power 15 plant. An understanding of these non -radiological hazards to nuclear power plant workers and 16 members of the public have been well established at nuclear power plants during those plants' 17 current licensing terms. The impacts from chemical hazards are expected to be minimized 18 through the licensee's use of good industrial hygiene practices as required by permits and 19 Federal and State regulations. Also, the impacts from physical hazards to plant workers will be 20 of small significance if workers adhere to safety standards and use protective equipment as 21 required by Federal and State regulations. The impacts to human health for each of these new 22 issues from continued plant operations are SMALL. 23 The NRC staff has not identified any new and significant information related to these non -24 radiological issues during its independent review of the applicant's ER, the site audit, and the 25 scoping process. Therefore, the NRC staff concludes that there would be no impact to human 26 health from chemicals or physical hazards beyond those impacts described in the GEIS 27 (NRC 2013a) and, therefore, the impacts are SMALL. 28 4.9.2 Radiological Impacts of Normal Operations 29 Entergy stated in its ER that it was not aware of any new and significant radiological impacts 30 related to human health issues associated with the renewal of the GGNS operating license. 31 The NRC staff has not identified any new and significant information radiological impacts related 32 to human health issues during its independent review of the applicant's ER, the site audit, the 33 scoping process, or its evaluation of other available information. Therefore, the NRC staff 34 concludes that there would be no impact from radiation exposures to the public or to workers 35 during the renewal term beyond those discussed in the GEIS. 36 The findings in the GEIS are as follows: 37 Radiation exposures to public (license renewal term) -Based on information 38 in the GEIS, the NRC found that radiation doses to the public will continue at 39 current levels associated with normal operations. 40 Occupational exposures (license renewal term) -Based on information in the 41 GEIS, the NRC found that project ed maximum occupational doses during the 42 license renewal term are within the range of doses experienced during 43 normal operations and normal maintenance outages, and would be well 44 below regulatory limits. 45 There are no Category 2 issues related to radiological impacts of routine operations. 46 Environmental Impacts of Operation 4-15 The information presented below is a discussion of selected radiological programs conducted at 1 GGNS. 2 4.9.2.1 GGNS Radiological Environmental Monitoring Program 3 GGNS conducts a radiological environmental monitoring program (REMP) to assess the 4 radiological impact, if any, to its employees, the public, and the environment from operations. 5 The REMP measures aquatic, terrestrial, and atmospheric radioactivity, as well as ambient 6 radiation. 7 The REMP also measures background radiation (i.e., cosmic sources, global fallout, and 8 naturally occurring radioactive material, including radon). The REMP supplements the 9 radioactive effluent monitoring program, discussed later in this section, by verifying that any 10 measurable concentrations of radioactive materials and levels of radiation in the environment 11 are not higher than those calculated using the radioactive effluent release measurements and 12 transport model

s. 13 An annual radiological environmental operating report is issued, which contains a discussion of 14 the results of the monitoring program performed for the previous year. The REMP collects 15 samples of environmental media to measure the radioactivity levels that may be present. The 16 media samples are representative of the radiation exposure pathways that may have an impact 17 on the public.

18 The GGNS radiological environmental monitoring program consists of four categories based on 19 exposure pathways to the public. These categories are: airborne, waterborne, ingestion, and 20 direct radiation. The airborne samples taken around GGNS are airborne particulate and 21 airborne iodine. The waterborne pathway samples are taken from surface water and 22 groundwater sources. Sediment samples also are included in this pathway. The ingestion 23 pathway samples include fish and broadleaf vegetation. GGNS will also sample milk for this 24 pathway if it is available commercially within 8 km (5 mi) of the site. For 201 2, there was no 25 commercial milk available to sample. The direct radiation pathway measures direct exposure 26 from environmental radiation doses using thermoluminescent dosimeters. 27 In addition to the REMP, GGNS has an onsite groundwater protection program designed to 28 monitor the onsite environment for detection of leaks from plant systems and pipes containing 29 radioactive liquid (Entergy 2011 a). Additional information on the groundwater protection 30 program is contained later in this section and in the groundwater quality section in Chapter 2 of 31 this document. 32 The NRC staff reviewed the GGNS annual radiological environmental operating reports for 2008 33 through 201 2 for significant impacts to the environment or unusual trends in the data 34 (Entergy 2009a, 2010a, 2011 b, 2012a, 2013a ). Five year s provides a data set that covers a 35 broad range of activities that occur at a nuclear power plant, including refueling outages, 36 non-refueling outage years, routine operation, and years where there may be significant 37 maintenance activities. Based on the staff's review, no adverse trends (i.e., steadily increasing 38 build-up of radioactivity levels) were observed and the data showed no measurable impact to 39 the environment from operations at GGNS. 40 4.9.2.2 Ground Water Protection Program 41 In 2007, the Nuclear Energy Institute (NEI) established a standard for monitoring and reporting 42 radioactive isotopes in groundwat er: NEI 07-07, "Industry Ground Water Protection Initiative - 43 Final Guidance Document" (NEI 2007). GGNS implemented the recommendations of this 44 industry standard after initial sampling efforts in 2007. Results of Entergy's groundwate r 45 Environmental Impacts of Operation 4-16 protection program are contained in the annual radioactive effluent release report submitted 1 annually to the NRC . 2 Information on the GGNS groundwater protection program is located in Sections 2.2.5 and 4. 5.3 3 in this SEIS. 4 4.9.2.3 GGNS Radioactive Effluent Release Program 5 All nuclear plants were licensed with the expectation that they would release radioactive 6 material to both the air and water during normal operation. However, NRC regulations require 7 that radioactive gaseous and liquid releases from nuclear power plants must meet radiation 8 dose-based limits specified in 10 CFR Part 20, and the as low as is reasonably achievable 9 (ALARA) criteria in Appendix I to 10 CFR Part 50. Regulatory limits are placed on the radiation 10 dose that members of the public can receive from radioactive effluents that a nuclear power 11 plant releases. In addition, 10 CFR 50.36(a) requires nuclear power plants to submit an annual 12 report to the NRC that lists the types and quantities of radioactive effluents released into the 13 environment. 14 The NRC staff reviewed the annual radioactive effluent release reports for 2008 through 2012 15 (Entergy 2009b, 2010b, 2011c, 2012b, 2013b ). The review focused on the calculated doses to 16 a member of the public from radioactive effluents released from GGNS. The doses were 17 compared to the radiation protection standards in 10 CFR 20.1301 and the ALARA dose design 18 objectives in Appendix I to 10 CFR Part 50 and EPA's 40 CFR Part 190. 19 Dose estimates for members of the public are calculated based on radioactive gaseous and 20 liquid effluent release data and atmospheric and aquatic transport models. The 2012 annual 21 radioactive effluent release report (Entergy 2013b) contains a detailed presentation of the 22 radioactive discharges and the resultant calculated doses. The following summarizes the 23 calculated dose to a member of the public located outside the GGNS site boundary from 24 radioactive gaseous and liquid effluents released during 2012: 25 The total-body dose to an offsite member of the public from GGNS 26 radioactive liquid effluents was 3.02x10-01 mrem (3.02x10-03 mSv), which is 27 well below the 3 mrem (0.03 mSv) dose criterion in Appendix I to 28 10 CFR Part 50. 29 The organ (liver) dose to an offsite member of the public from GGNS 30 radioactive liquid effluents was 5.64x10-01 mrem (5.64x10-03 mSv), which is 31 well below the 10 mrem (0.10 mSv) dose criterion in Appendix I to 32 10 CFR Part 50. 33 The air dose at the site boundary from gamma radiation in gaseous effluents 34 from GGNS was 4.23x10-01 mrad (4.23x10-03 mGy), which is well below the 35 10 mrad (0.1 mGy) dose criterion in Appendix I to 10 CFR Part 50. 36 The air dose at the site boundary from beta radiation in gaseous effluents 37 from GGNS was 2.16x10-01 mrad (2.16x10-03 mGy), which is well below the 38 20 mrad (0.2 mGy) dose criterion in Appendix I to 10 CFR Part 50. 39 The dose to an organ (bone) from radioactive iodine, radioactive particulates, 40 and carbon -14 from GGNS was 7.06 mrem (7.06x10-02 mSv), which is below 41 the 15 mrem (0.15 mSv) dose criterion in Appendix I to 10 CFR Part 50. 42 4.9.2.4 Summary 43 The NRC staff's review of the GGNS radioactive effluent control program showed that radiation 44 doses to members of the public for the years 2008 -2012 comply with Federal radiation 45 Environmental Impacts of Operation 4-17 protection standards contained in Appendix I to 10 CFR Part 50, 10 CFR Part 20, and 1 40 CFR Part 190. 2 The applicant has no plans to conduct refurbishment activities during the license renewal term; 3 however, routine plant refueling and maintenance activities currently performed will continue 4 during the license renewal term. Based on the past performance of the radioactive waste 5 system to maintain the dose from radioactive effluents to be ALARA, similar performance is 6 expected during the license renewal term. Continued compliance with regulatory requirements 7 is expected during the license renewal term; therefore, the staff concludes that the impacts from 8 radioactive effluents would be SMALL. 9 4.9.3 Electromagnetic Fields-Acute Effects 10 Based on the GEIS, the NRC found that electric shock resulting from direct access to energized 11 conductors or from induced charges in metallic structures has not been a problem at most 12 operating nuclear power plants and generally is not expected to be a problem during the license 13 renewal term. However, site -specific review is required to determine the significance of the 14 electric shock potential along portions of the transmission lines within the scope of this 15 document. 16 In the GEIS (NRC 1996), the NRC found that without a review of the conformance of each 17 nuclear plant transmission line with National Electrical Safety Code (NESC) criteria, it was not 18 possible to determine the significance of the electric shock potential (IEEE 2002). Evaluation of 19 individual plant transmission lines is necessary because electric shock safety was not 20 addressed in the licensing process for some plants. For other plants, land use in the vicinity o f 21 transmission lines may have changed, or power distribution companies may have upgraded line 22 voltage. The NRC uses the NESC criteria as its baseline to assess the potential human health 23 impact of the induced current from an applicant's transmission lines. As discussed in the GEIS, 24 the issue of electric shock is of small significance for transmission lines that are operated in 25 adherence with the NESC criteria. To comply with 10 CFR 51.53(c)(3)(ii)(H), Entergy provided 26 an assessment of the impact of the proposed action on the potential shock hazard from the 27 transmission lines. 28 GGNS electrical output is delivered to the Baxter -Wilson Steam Electric Station Extra High 29 Voltage (EHV) switchyard and the Franklin EHV Switching Station through two 500 -kilovolt (kV) 30 transmission lines. The Baxter -Wilson transmission line is a 22 -mi (35-km) single-circuit line 31 that spans from the 500 -kV switchyard located at GGNS to the Baxter -Wilson Steam Electric 32 Station EHV switchyard. The Franklin transmission line is a 43.6 -mi (70.2-km) single-circuit line 33 that spans from the 500 -kV switchyard located at GGNS to the Franklin EHV Switching Station. 34 There is also a 500 -kV line that spans approximately 300 ft (90 m) from the GGNS Turbine 35 Building to the 500-kV switchyard located on site. Entergy Mississippi, Inc. (EMI) owns and 36 operates the transmission lines constructed to connect GGNS to the electric grid. 37 Entergy completed an acute shock analysis for the transmission lines using the software 38 "EMF-10 Electric Field Induction" developed by the Electric Power Research Institute (EPRI). 39 The input parameters included the design features of the Franklin and Baxter -Wilson 40 transmission lines and a large tractor -trailer was assumed to be the maximum vehicle size 41 under the lines. The minimum clearance on the Franklin line above any of the travel ways 42 mentioned was 35.4 ft (10.8 m). The minimum clearance above any of the travel ways 43 mentioned on the Baxter -Wilson line was 44.5 ft (13.6 m). The maximum induced current 44 calculated for those power lines was 2.03 mA on the Franklin transmission line. The minimum 45 clearance at any point on the 500 -kV line that spans approximately 300 ft (90 m) from the 46 GGNS Turbine Building to the 500 -kV switchyard located on site was 70 ft (21.3 m). Since that 47 Environmental Impacts of Operation 4-18 clearance is almost twice the clearance used in the acute shock analyses for the Baxter -Wilson 1 and Franklin transmission lines, this span would not induce a current greater than the 2 NESC 5 mA criterion. Therefore, the lines meet the NESC 5 mA criterion (Entergy 2011 a). 3 The GGNS transmission line corridor crosses over mostly rural agricultural and forest land, with 4 the exception of the Franklin transmission line, which crosses over portions of highways and 5 rivers in the area. EMI inspects all transmission lines 230-kV and above at least three times 6 each year. Any problems or hazards related to vegetation are recorded in an electronic 7 database and assigned to crews for mitigation. Also, transmission lines 230 -kV and above are 8 presently scheduled to receive herbicide every 2 years to maintain proper clearances from 9 conductors. EMI also uses aerial patrols to inspect their transmission lines and works with 10 internal and external customers to investigate and resolve potential problems, such as building 11 or roadway construction projects and pipeline installation or maintenance. EMI's current 12 maintenance practices associated with maintaining transmission line clearances will continue 13 during the license renewal term (Entergy 2011 a). 14 The NRC staff reviewed the information Entergy provided to document the results of its acute 15 shock evaluation of its transmission lines. The staff notes that Entergy used appropriate 16 assumptions in its calculations: identification of the transmission lines covered by 17 10 CFR 51.53(c)(3)(ii)(H), the use of the maximum vehicle size to be located below the 18 transmission lines, and software developed by EPRI-the nationally recognized expert in this 19 area. Based on this information, the NRC staff concludes that the potential impacts from 20 electric shock during the renewal period would be SMALL. 21 4.9.4 Electromagnetic Fields -Chronic Effects 22 In the GEIS, the effects of chronic exposure to 60 -Hz electromagnetic fields from power lines 23 were not designated as Category 1 or 2, and will not be until a scientific consensus is reached 24 on the health implications of these fields. 25 The potential effects of chronic exposure from these fields continue to be studied and are not 26 known at this time. The National Institute of Environmental Health Sciences (NIEHS) directs 27 related research through the U.S. Department of Energy (DOE). 28 The report by NIEHS (NIEHS 1999) contains the following conclusion: 29 The NIEHS concludes that ELF -EMF (extremely low frequency -electromagnetic 30 field) exposure cannot be recognized as entirely safe because of weak scientific 31 evidence that exposure may pose a leukemia hazard. In our opinion, this finding 32 is insufficient to warrant aggressive regulatory concern. However, because 33 virtually everyone in the United States uses electricity and therefore is routinely 34 exposed to ELF -EMF, passive regulatory action is warranted such as continued 35 emphasis on educating both the public and the regulated community on means 36 aimed at reducing exposures. The NIEHS does not believe that other cancers or 37 non-cancer health outcomes provide sufficient evidence of a risk to currently 38 warrant concern. 39 This statement is not sufficient to cause the NRC staff to change its position with respect to the 40 chronic effects of electromagnetic fields. The NRC staff considers the GEIS finding of 41 "UNCERTAIN" still appropriate and will continue to follow developments on this issue. 42 4.10 Socioeconomics 43 The socioeconomic issues applicable to GGNS are shown in Table 4 -9. Section 2.2.9 of this SEIS 44 describes the socioeconomic conditions near GGNS. 45 Environmental Impacts of Operation 4-19 Table 4-9. Socioeconomics Issues 1 Issues GEIS Section Category Housing impacts 4.7.1 2 Public services: public safety, social services, tourism & recreation 4.7.3, 4.7.3.3, 4.7.3.4, 4.7.3.6 1 Public services: public utilities 4.7.3.5 2 Public services: education (license renewal) 4.7.3.1 1 Offsite land use (license renewal term) 4.7.4 2 Public Services: transportation 4.7.3.2 2 Historic & archaeological resources 4.7.7 2 Aesthetic impacts (license renewal term) 4.7.6 1 Aesthetic impacts of transmission lines (license renewal term) 4.5.8 1 Environmental justice: minority and low -income populations 4.10.1(a) 2 Table source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51; (a)NRC 201 3a 4.10.1 Generic Socioeconomic Issues 2 The applicant's ER, scoping comments, and other available data records on GGNS, were 3 reviewed and evaluated for new and significant information. The review included a data 4 gathering site visit to GGNS. No new and significant information was identified during this 5 review that would change the conclusions presented in the GEIS. Therefore, for these 6 Category 1 issues, impacts during the renewal term are not expected to exceed those 7 discussed in the GEIS. For GGNS, the staff incorporates the GEIS conclusions by reference. 8 Impacts for Category 2 issues and the uncategorized issue (environmental justice) are 9 discussed in Sections 4.10.2 through 4. 10.7. In evaluating the potential socioeconomic impacts 10 resulting from license renewal, the NRC uses as its baseline the existing socioeconomic 11 conditions described in Section 2.2.9 of this SEIS. These baseline socioeconomic conditions 12 include existing housing, transportation, offsite land use, demographic, public services, and 13 economic conditions affected by ongoing operations at the nuclear power plant. 14 4.10.2 Housing 15 Appendix C of the GEIS presents a population characterization method based on two factors, 16 sparseness and proximity (GEIS, Section C.1.4). Sparseness measures population density 17 within 20 miles (32 kilometers) of the site, and proximity measures population density and city 18 size within 50 miles (80 kilometers). Each factor has categories of density and size 19 (GEIS, Table C.1). A matrix is used to rank the population category as low, medium, or high 20 (GEIS, Figure C.1). 21 According to the 2010 Census, an estimated 23,406 people lived within 20 mi (32 km) of GGNS, 22 which equates to a population density of 19 persons per mi 2 (Entergy 2011a). This translates to 23 a Category 1, "most sparse" population density using the GEIS measure of sparseness (less 24 than 40 persons per mi 2 and no community with 25,000 or more persons within 20 mi). An 25 estimated 329,043 people live within 50 mi (80 km) of GGNS with a population density of 26 42 persons per mi 2 (Entergy 2011a). This translates to a Category 1 density, using the GEIS 27 measure of proximity (no cities with 100,000 or more persons and less than 50 persons per mi 2 28 Environmental Impacts of Operation 4-20 within 50 mi). Therefore, GGNS is located in a low population area based on the GEIS 1 sparseness and proximity matrix. 2 Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, states that impacts on housing availability 3 may be SMALL, MODERATE, or LARGE. MODERATE or LARGE housing impacts of the 4 workforce associated with refurbishment may be associated with plants located in sparsely 5 populated areas or in areas with growth control measures that limit housing development. 6 Since Entergy has no planned refurbishment activities at GGNS and Claiborne, Hinds, 7 Jefferson, and Warren counties are not subject to growth-control measures that would limit 8 housing development; any changes in employment at GGNS would have little noticeable effect 9 on housing availability in these counties. Since Entergy has no plans to add non -outage 10 employees during the license renewal period, employment levels at GGNS would remain 11 relatively constant with no additional demand for permanent housing during the license renewal 12 term. Based on this information, there would be no impact on housing during the license 13 renewal term beyond what already has been experienced. Therefore, the NRC staff concludes 14 that the impacts would be SMALL. 15 4.10.3 Public Services -Public Utilities 16 Impacts on public utility services (e.g., water, sewer) are considered SMALL if the public utility 17 has the ability to respond to changes in demand and would have no need to add or modify 18 facilities. Impacts are considered MODERATE if service capabilities are overtaxed during 19 periods of peak demand. Impacts are considered LARGE if additional system capacity is 20 needed to meet ongoing demand. 21 Analysis of impacts on the public water systems considered both plant demand and 22 plant-related population growth. Section 2.1.7 describes the permitted withdrawal rate and 23 actual use of water for reactor cooling at GGNS. 24 Since Entergy has no plans to add non -outage employees during the license renewal period, 25 employment levels at GGNS would remain relatively unchanged with no additional demand for 26 public water services. Public water systems in the region are adequate to meet the demands of 27 residential and industrial customers in the area. Therefore, there would be no impact to public 28 water services during the license renewal term beyond what is already being experienced. 29 Therefore, the NRC staff concludes that the impacts would be SMALL. 30 4.10.4 Public Services -Transportation 31 Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 states the following: 32 Transportation impacts (level of service) of highway traffic generated...during the 33 term of the renewed license are generally expected to be of SMALL significance. 34 However, the increase in traffic associated with additional workers and the local 35 road and traffic control conditions may lead to impacts of MODERATE or LARGE 36 significance at some sites. 37 The regulation in 10 CFR 51.53(c)(3)(ii)(J) requires all applicants to assess the impacts of 38 highway traffic generated by the proposed project on the level of service of local highways 39 during the term of the renewed license. Since Entergy has no plans to add non -outage 40 employees during the license renewal period, traffic volume and levels of service on roadways 41 in the vicinity of GGNS would not change. Therefore, there would be no transportation impacts 42 during the license renewal term beyond what is already being experienced. Therefore, the N RC 43 staff concludes that the impacts would be SMALL. 44 Environmental Impacts of Operation 4-21 4.10.5 Offsite Land Use 1 Offsite land use during the license renewal term is a Category 2 issue (10 CFR Part 51, Subpart 2 A, Appendix B, Table B -1). Table B -1 notes that; "significant changes in land use may be 3 associated with population and tax revenue changes resulting from license renewal." Section 4 4.7.4 of the GEIS defines the magnitude of land -use changes as a result of plant operation 5 during the license renewal term as SMALL when there will be little new development and 6 minimal changes to an area's land use pattern, as MODERATE when there will be considerable 7 new development and some changes to the land use pattern, and LARGE when there will be 8 large-scale new development and major changes in the land use pattern. 9 Tax revenue can affect land use because it enables local jurisdictions to provide the public 10 services (e.g., transportation and utilities) necessary to support development. Section 4.7.4.1 of 11 the GEIS states that the assessment of tax -driven land use impacts during the license renewal 12 term should consider the size of the plant's tax payments relative to the community's total 13 revenues, the nature of the community's existing land use pattern, and the extent to which the 14 community already has public services in place to support and guide development. If the plant's 15 tax payments are projected to be small relative to the community's total revenue, tax driven land 16 use changes during the plant's license renewal term would be SMALL, especially where the 17 community has pre -established patterns of development and has provided public services to 18 support and guide development. Section 4.7.2.1 of the GEIS states that if tax payments by the 19 plant owner are less than 10 percent of the taxing jurisdiction's revenue, the significance level 20 would be SMALL. If tax payments are 10 to 20 percent of the community's total revenue, new 21 tax-driven land use changes would be MODERATE. If tax payments are greater than 22 20 percent of the community's total revenue, new tax -driven land use changes would be 23 LARGE. This would be especially true where the community has no pre -established pattern of 24 development or has not provided adequate public services to support and guide development. 25 As discussed in Sections 4.10.2, 4.10.3, and 4.10.4, it is not expected that there would be any 26 change in the staffing levels at GGNS or increased demand for additional housing, public 27 services related to public utilities, and transportation during the license renewal period. 28 Therefore, the NRC staff concludes that the impacts would be SMALL. 29 4.10.5.1 Population -Related Impacts 30 Since Entergy has no plans to add non -outage employees during the license renewal period, 31 there would be no plant operations -driven population increase in the vicinity of GGNS. 32 Therefore, there would be no population -related offsite land use impacts during the license 33 renewal term beyond what has already been experienced. Therefore, the NRC staff concludes 34 that the impacts would be SMALL. 35 4.10.5.2 Tax Revenue -Related Impacts 36 As discussed in Chapter 2, Entergy pays property taxes for GGNS to the State of Mississippi. 37 Part of these taxes are distributed to counties near GGNS. Since Entergy started making 38 property tax payments, local county populations have been in decline and land use conditions 39 have generally remained unchanged. Therefore, tax revenue from GGNS as a proportion of 40 total tax revenue in the ROI has had little or no effect on land use conditions within these 41 counties. Since employment levels would remain relatively unchanged with no increase in the 42 assessed value of GGNS, annual property tax payments also would be expected to remain 43 relatively unchanged throughout the license renewal period. Based on this information, there 44 would be no tax -revenue-related offsite land use impacts during the license renewal term 45 beyond those already being experienced. Therefore, the NRC staff concludes that the impacts 46 would be SMALL. 47 Environmental Impacts of Operation 4-22 4.10.6 Historic and Archaeological Resources 1 The National Historic Preservation Act (NHPA) requires Federal agencies to consider the effects 2 of their undertakings on historic properties. Historic properties are defined as resources eligible 3 for listing on the National Register of Historic Places (NRHP). The criteria for eligibility are listed 4 in 36 CFR 60.4 and include association with significant events in history; association with the 5 lives of persons significant in the past; embodiment of distinctive characteristics of type, period, 6 or construction; and sites or places that have yielded or are likely to yield important information. 7 The historic preservation review process (Section 106 of the National Historic Preservation Act 8 of 1966, as amended [NHPA]) is outlined in regulations issued by the Advisory Council on 9 Historic Preservation (ACHP) in 36 CFR Part 800. In accordance with 36 CFR 800.8(c), the 10 NRC has elected to use the NEPA process to comply with the obligations found under 11 Section 106 of the NHPA. 12 In accordance with 36 CFR 800.8(c), the NRC initiated Section 106 consultation with the ACHP 13 and the Mississippi and Louisiana State Historic Preservation Office s (SHPOs) in January 2012, 14 by notifying them of the agency's intent to review a request from Entergy to renew the GGNS 15 operating license (NRC 2012 f, 2012 g, 2012h). On February 28, 2012, the Mississippi SHPO 16 responded to the NRC's letter stating its opinion that the proposed license renewal will have no 17 adverse effect on historic properties (MDAH 2012 a). No comments were received from the 18 ACHP or the Louisiana SHPO as a result of these consultation letters. 19 The NRC also initiated consultation on the proposed GGNS license renewal with four Federally 20 recognized tribes: the Jena Band of Choctaw Indians, the Mississippi Band of Choctaw Indians , 21 the Choctaw Nation of Oklahoma, and the Tunica -Biloxi Tribe of Louisi ana (NRC 2012 i). In 22 letters to the tribes, the NRC supplied information about the proposed action (license renewal) 23 and the definition of the area of potential effect, and stated that the NHPA review would be 24 integrated with the NEPA process, according to 35 CFR 800.8. The NRC invited the Tribes to 25 participate in the identification of potentially affected historic properties near GGNS and the 26 scoping process. The Choctaw Nation of Oklahoma, Jena Band of Choctaw Indians, and the 27 Mississippi Band of Choctaw Indians responded. The Tribes did not raise any concerns through 28 scoping comments and requested updates throughout the review process (see Appendix D). 29 The staff reviewed information on historic and archaeological resources provided in the 30 applicant's ER. It also conducted a review at the Mississippi Department of Archives and 31 History (MDAH) and identified 17 previously recorded archaeological resources on GGNS 32 property; surveys conducted in 1972 and 2006 of the archaeological, architectural, and historic 33 resources on and around GGNS property; and multiple surveys that intersected the 34 transmission lines (MDAH 2012 b). One site identified in these surveys, 22Cb528, is located on 35 GGNS property and is considered potentially eligible for listing in the NRHP. Site 22Cb528 is 36 an Archaic Period village consisting of ceramics and lithics at various stages of production, and 37 it has been determined that the site should be avoided or tested further to determine eligibility 38 (Entergy 2011 a; MDAH 2012 b). Along the transmission lines, seven sites were identified as 39 being within or very near to the transmission line rights -of-way; one is listed in the NRHP; four 40 others would require further evaluation to determine eligibility status and are considered 41 potentially eligible until a determination is made; and the remaining two are ineligible. 42 Background research also identified nine NRHP -listed resources within a 10 -mi (16km) radius of 43 the facility; however, none are located within the boundaries of the GGNS property. 44 As noted in Section 2.2.10.1, the area near where the Grand Gulf Mound was located has high 45 potential for subsurface archaeological deposits. Additionally, areas on the property could have 46 historic resources related to the Grand Gulf town site or the Civil War battles that took place on 47 and near the GGNS property. Because the GGNS property has been surveyed for historic and 48 Environmental Impacts of Operation 4-23 archaeological resources, it is likely that the undiscovered resources would be subsurface 1 deposits. 2 Entergy currently has no planned changes or ground -disturbing activities associated with 3 license renewal at GGNS. However, given the high potential for the discovery of additional 4 historic and archaeological resources at GGNS, Entergy has formal guidelines in its 5 Environmental Reviews and Evaluations Nuclear Management Manual (EN-EV-115) for 6 protecting archaeological resources. The procedure advises Entergy staff on consulting with 7 the appropriate SHPO, and the NRC, as applicable, before ground -disturbing activities take 8 place at GGNS. An additional procedure (EN -EV-121) requires work to be stopped if evidence 9 of a historical or archaeological artifact is found during ground disturbance. The vegetation 10 management plan for transmission lines, however, does not specifically mention vegetation 11 maintenance near cultural resources (AM-ERS-FAC-001). Entergy could minimize any possible 12 effects to cultural resources found within transmission line corridors by adding procedures for 13 maintenance near cultural resources. GGNS also is governed by Mississippi State burial law, 14 which requires a work stoppage if human remains are unexpectedly uncovered. 15 Based on the review of Mississippi SHPO files for the region, published literature, and 16 information Entergy and consulting parties provided, the staff concludes that the potential 17 impact from license renewal of GGNS on historic or archaeological resources is SMALL, and 18 there would be no adverse effect on historic properties as specified in 36 CFR 800.4(d)(1). 19 Entergy could further reduce any potential effect to historic and archaeological resources at the 20 GGNS site by referencing its formal guidelines for protecting historic and archaeological 21 resources in its vegetation management plan. 22 4.10.7 Environmental Justice 23 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 24 protection regulation, 10 CFR Part 51. With respect to environmental justice concerns, the 25 revision amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new 26 Category 2 issue, "Minority and low-income populations," to evaluate the impacts of continued 27 operations and any refurbishment activities during the license renewal term on minority 28 populations and low-income populations living in the vicinity of the plant. Environmental justice 29 was listed in Table B-1 as a concern but was not evaluated in the 1996 GEIS and therefore, is 30 addressed in each SEIS. 31 Under Executive Order (EO) 12898 (59 FR 7629, February 16, 1994 ), Federal agencies are 32 responsible for identifying and addressing, as appropriate, disproportionately high and adverse 33 human health and environmental impacts on minority and low -income populations. In 2004, the 34 Commission issued a Policy Statement on the Treatment of Environmental Justice Matters in 35 NRC Regulatory and Licensing Actions (69 FR 52040, August 24, 2004 ), which states, "The 36 Commission is committed to the general goals set forth in EO 12898, and strives to meet those 37 goals as part of its NEPA review process." 38 The Council of Environmental Quality (CEQ) provides the following information in Environmental 39 Justice: Guidance Under the National Environmental Policy Act (CEQ 1997): 40 Disproportionately High and Adverse Human Health Effects. Adverse health 41 effects are measured in risks and rates that could result in latent cancer fatalities, 42 as well as other fatal or nonfatal adverse impacts on human health. Adverse 43 health effects may include bodily impairment, infirmity, illness, or death. 44 Disproportionately high and adverse human health effects occur when the risk or 45 rate of exposure to an environmental hazard for a minority or low -income 46 population is significant (as employed by NEPA) and appreciably exceeds the 47 Environmental Impacts of Operation 4-24 risk or exposure rate for the general population or for another appropriate 1 comparison group. 2 Disproportionately High and Adverse Environmental Effects. A 3 disproportionately high environmental impact that is significant (as defined by 4 NEPA) refers to an impact or risk of an impact on the natural or physical 5 environment in a low -income or minority community that appreciably exceeds the 6 environmental impact on the larger community. Such effects may include 7 ecological, cultural, human health, economic, or social impacts. An adverse 8 environmental impact is an impact that is determined to be both harmful and 9 significant (as employed by NEPA). In assessing cultural and aesthetic 10 environmental impacts, impacts that uniquely affect geographically dislocated or 11 dispersed minority or low -income populations or American Indian tribes are 12 considered. 13 The environmental justice analysis assesses the potential for disproportionately high and 14 adverse human health or environmental effects on minority populations and low -income 15 populations that could result from the operation of GGNS during the renewal term. In assessing 16 the impacts, the following definitions of minority individuals and populations and low -income 17 population were used (CEQ 1997): 18 Minority individuals. Individuals who identify themselves as members of the 19 following population groups: Hispanic or Latino, American Indian or Alaska Native, 20 Asian, Black or African American, Native Hawaiian or Other Pacific Islander, or two or 21 more races, meaning individuals who identified themselves on a Census form as 22 being a member of two or more races (e.g., Hispanic and Asian). 23 Minority populations. Minority populations are identified when (1) the minority 24 population of an affected area exceeds 50 percent or (2) the minority population 25 percentage of the affected area is meaningfully greater than the minority population 26 percentage in the general population or other appropriate unit of geographic analysis. 27 Low-income population. Low-income populations in an affected area are identified 28 with the annual statistical poverty thresholds from the Census Bureau's Current 29 Population Reports, Series P60, on Income and Poverty. 30 4.10.7.1 Minority Population 31 According to 2010 Census data, 53.2 percent of the population residing within a 50 -mi (80-km) 32 radius of GGNS identified themselves as minority individuals. The largest minority group was 33 Black or African American (51.3 percent), followed by Hispanic or Latino (of any race) 34 (2.0 percent) (CAPS 2012). 35 According to 2010 Census data, minority populations in the socioeconomic region of influence 36 (ROI) (Claiborne, Hinds, Jefferson, and Warren Counties) comprised 69.4 percent of the total 37 four-county population (see Table 2-12). Figure 4-1 shows minority population block groups, 38 using 2010 Census data for race and ethnicity, within a 50 -mi (80-km) radius of GGNS. 39 Census block groups were considered minority population block groups if the percentage of the 40 minority population within any block group exceeded 53.2 percent (the percent of the minority 41 population within the 50 -mi [80-km] radius of GGNS). A minority population exists if the 42 percentage of the minority population within the block group is meaningfully greater than the 43 minority population percentage in the 50 -mi (80-km) radius. Approximately 144 of the 294 44 census block groups located within the 50 -mi (80-km) radius of GGNS were determined to have 45 meaningfully greater minority populations. 46 Environmental Impacts of Operation 4-25 Minority population block groups are concentrated on the east side of the Mississippi River and 1 include the c ensus block group containing GGNS. According to the 2010 Census, 2 approximately 85.4 percent of the Port Gibson population identified themselves as minority. 3 4.10.7.2 Low-Income Population 4 According to 2010 American Community Survey Census data, an average of 16.3 percent of 5 families and 21.1 percent of individuals residing in the 24 counties within a 50 -mi (80-km) radius 6 of GGNS were identified as living below the Federal poverty threshold in 2010. The 7 2010 Federal poverty threshold was $22,314 for a family of four (USCB 2012). 8 According to the 2010 Census, 16.7 percent of families and 21.2 percent of individuals in 9 Mississippi were living below the Federal poverty threshold in 2010, and the median household 10 income for Mississippi was $37,881 (USCB 2012). Claiborne and Jefferson Counties had lower 11 median household incomes and higher percentages of families and individuals living in poverty 12 compared to State averages. Hinds and Warren Counties had higher median incomes when 13 compared to the State average. Claiborne County had a median household income average of 14 $24,150 and 35.0 percent of individuals and 27.6 percent of families living below the poverty 15 level. Hinds County had a median household income average of $39,215 and 22.5 percent of 16 individuals and 17.7 percent of families living below the poverty level. Jefferson County had a 17 median household income of $24,304 and 39.0 percent of individuals and 29.3 percent of 18 families living below the poverty level. Warren County had a median household income 19 average of $40,404 and 21.4 percent of individuals and 16.5 percent of families living below the 20 poverty level (USCB 2012). 21 Figure 4-2 shows low-income census block groups within a 50 -mi (80-km) radius of GGNS. 22 Census block groups were considered low -income population block groups if the percentage of 23 individuals living below the Federal poverty threshold within any block group exceeded the 24 percent of the individuals living below the Federal poverty threshold within the 50 -mi (80-km) 25 radius of GGNS. Approximately 120 of the 294 census block groups located within the 50 -mi 26 (80-km) radius of GGNS were determined to have meaningfully greater low -income populations. 27 Environmental Impacts of Operation 4-26 Figure 4-1. 2010 Census Minority Block Groups Within a 50 -mi Radius of GGNS 1 Source: USCB 2012 2 Environmental Impacts of Operation 4-27 Figure 4-2. 2010 Census Low -Income Block Groups Within a 50 -mi Radius of GGNS 1 Source: USCB 2012 2 Environmental Impacts of Operation 4-28 Low-income block groups are distributed across the 50 -mi (80-km) radius area around GGNS , 1 with no particular concentrations. The nearest low -income population to GGNS is located in 2 Port Gibson, Mississippi, and several other low -income block groups are in close proximity to 3 GGNS. 4 4.10.7.3 Analysis of Impacts 5 The NRC addresses environmental justice matters for license renewal through (1) identifying 6 the location of minority and low -income populations that the continued operation of the nuclear 7 power plant may affect during the license renewal term, and (2) determining whether there 8 would be any potential human health or environmental effects to these populations and special 9 pathway receptors, and (3) determining if any of the effects may be disproportionately high and 10 adverse. 11 Figures 4-1 and 4-2 identify the location of minority and low -income block group populations 12 residing within a 50 -mi (80-km) radius of GGNS. This area of impact is consistent with the 13 impact analysis for public and occupational health and safety, which also focuses on 14 populations within a 50 -mi (80-km) radius of the plant. Chapter 4 presents the assessment of 15 environmental and human health impacts for each resource area. The analyses of impacts for 16 all environmental resource areas indicated that the impact from license renewal would b e 17 SMALL. 18 Potential impacts to minority and low -income populations (including migrant workers or Native 19 Americans) mostly would consist of socioeconomic and radiological effects; however, radiation 20 doses from continued operations during the license renewal term are expected to continue at 21 current levels and would remain within regulatory limits. Chapter 5 of this SEIS discusses the 22 environmental impacts from postulated accidents that might occur during the license renewal 23 term, which include both design -basis and severe accidents. In both cases, the staff has 24 generically determined that impacts associated with design -basis accidents are SMALL 25 because nuclear plants are designed and operated to successfully withstand such accidents, 26 and the probability weighted impact risks associated with severe accidents also were SMALL. 27 Therefore, based on this information and the analysis of human health and environmental 28 impacts presented in Chapters 4 and 5 of this SEIS, there would be no disproportionately high 29 and adverse impacts to minority and low -income populations from the continued operation of 30 GGNS during the license renewal ter

m. 31 4.10.7.4 Subsistence Consumption of Fish and Wildlife 32 As part of addressing environmental justice concerns associated with license renewal, the staff 33 also assessed the potential radiological risk to special population groups (such as migrant 34 workers or Native Americans) from exposure to radioactive material received through their 35 unique consumption and interaction with the environment. These include subsistence 36 consumption of fish, native vegetation, surface waters, sediments, and local produce; 37 absorption of contaminants in sediments through the skin; and inhalation of airborne radioactive 38 material released from the plant during routine operation. This analysis is presented below.

39 The special pathway receptors analysis is an important part of the environmental justice 40 analysis because consumption patterns may reflect the traditional or cultural practices of 41 minority and low-income populations in the area, such as migrant workers or Native Americans. 42 Section 4-4 of Executive Order 12898 (1994) directs Federal agencies, whenever practical and 43 appropriate, to collect and analyze information on the consumption patterns of populations that 44 rely principally on fish and/or wildlife for subsistence and to communicate the risks of these 45 consumption patterns to the public. In this SEIS, the NRC considered whether there were any 46 Environmental Impacts of Operation 4-29 means for minority or low -income populations to be disproportionately affected by examining 1 impacts to African American, American Indian, Hispanics, migrant workers, and other traditional 2 lifestyle special pathway receptors. The assessment of special pathways took into account the 3 levels of radiological and nonradiological contaminants in native vegetation, crops, soils and 4 sediments, groundwater, surface water, fish, and game animals on or near GGNS. 5 The following is a summary discussion of the staff's evaluation from Section 4.9.2 of the 6 radiological environmental monitoring programs that assess the potential impacts for 7 subsistence consumption of fish and wildlife near the GGNS site. 8 Entergy has an ongoing comprehensive REMP to assess the impact of GGNS operations on the 9 environment. To assess the impact of nuclear power plant operations, samples are collected 10 annually from the environment and analyzed for radioactivity. A plant effect would be indicated 11 if the radioactive material detected in a sample was significantly larger than background levels. 12 Two types of samples are collected. The first type, control samples, are collected from areas 13 beyond the measurable influence of the nuclear power plant or any other nuclear facility. These 14 samples are used as reference data to determine normal background levels of radiation in the 15 environment. These samples are then compared with the second type of samples, indicator 16 samples, collected near the nuclear power plant. Indicator samples are collected from areas 17 where any contribution from the nuclear power plant will be at its highest concentration. These 18 samples are then used to evaluate the contribution of nuclear power plant operations to 19 radiation or radioactivity levels in the environment. An effect would be indicated if the 20 radioactivity levels detected in an indicator sample were significantly larger than the control 21 sample or background levels. 22 Samples of environmental media are collected from the aquatic and terrestrial pathways in the 23 vicinity of GGNS. The aquatic pathways include groundwater, surface water, drinking water, 24 fish, and shoreline sediment. The terrestrial pathways include airborne particulates and food 25 products (i.e., broad leaf vegetation). During 2011, analyses performed on samples of 26 environmental media at GGNS showed no significant or measurable radiological impact above 27 background levels from site operations (Entergy 2012 a). 28 Based on the radiological environmental monitoring data from GGNS, the staff finds that no 29 disproportionately high and adverse human health impacts would be expected in special 30 pathway receptor populations in the region as a result of subsistence consumption of water, 31 local food, fish, and wildlife. 32 4.11 Evaluation of New and Potentially Significant Information 33 The staff has not identified new and significant information on environmental issues related to 34 operation during the renewal term. The staff also determined that information provided during 35 the public comment period did not identify any new issue that requires site -specific assessment. 36 The staff reviewed the discussion of environmental impacts associated with operation during the 37 renewal term in the GElS and has conducted its own independent review, including a public 38 involvement process (e.g., public meetings) to identify issues with new and significant 39 information. 40 New and significant information is information that identifies a significant environmental issue 41 not covered in the GEIS and codified in Table B -1 of 10 CFR Part 51, Subpart A, Appendix B, 42 or information that was not considered in the analyses summarized in the GEIS and that leads 43 to an impact finding that is different from the finding presented in the GEIS and codified in 44 10 CFR Part 51. 45 Environmental Impacts of Operation 4-30 In accordance with 10 CFR 51.53(c), the ER that the applicant submit s must provide an analysis 1 of the Category 2 issues in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B. Additionally, 2 it must discuss actions to mitigate any adverse impacts associated with the proposed action and 3 environmental impacts of alternatives to the proposed action. In accordance with 4 10 CFR 51.53(c)(3), the ER does not need to contain an analysis of any Category 1 issue 5 unless there is new and significant information on a specific issue. 6 The NRC also has a process for identifying new and significant information. That process is 7 described in NUREG -1555, Supplement 1, Standard Review Plans for Environmental Reviews 8 for Nuclear Power Plants, Supplement 1: Operating License Renewal (NRC 1999b, 2013b). 9 The search for new information includes: 10 review of an applicant's ER and the process for discovering and evaluating 11 the significance of new information, 12 review of public comments, 13 review of environmental quality standards and regulations, 14 coordination with Federal, State, and local environmental protection and 15 resource agencies, and 16 review of the technical literature. 17 New information that the staff discovered is evaluated for significance using the criteria set forth 18 in the GEIS. For Category 1 issues in which new and significant information is identified, 19 reconsideration of the conclusions for those issues is limited in scope to assessment of the 20 relevant new and significant information; the scope of the assessment does not include other 21 facets of an issue that the new information does not affect. 22 4.12 Cumulative Impacts 23 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 24 protection regulation, 10 CFR Part 51. With respect to cumulative impacts , t he revision amends 25 Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new Category 2 issue, 26 "Cumulative impacts," to evaluate the potential cumulative impacts of license renewal. 27 The staff considered potential cumulative impacts in the environmental analysis of continued 28 operation of GGNS during the renewed license term. Cumulative impacts may result when the 29 environmental effects associated with the proposed action are overlaid or added to temporary or 30 permanent effects associated with other past, present, and reasonably foreseeable actions. 31 Cumulative impacts can result from individually minor, but collectively significant, actions taking 32 place over a period of time. It is possible that an impact that may be SMALL by itself could 33 result in a MODERATE or LARGE cumulative impact when considered in combination with the 34 impacts of other actions on the affected resource. Likewise, if a resource is regionally declining 35 or imperiled, even a SMALL individual impact could be important if it contributes to or 36 accelerates the overall resource decline. 37 For the purposes of this cumulative analysis, past actions are those before the receipt of the 38 license renewal application. Present actions are those related to the resources at the time of 39 current operation of the power plant, and future actions are those that are reasonably 40 foreseeable through the end of plant operation including the period of extended operation. 41 Therefore, the analysis consider s potential impacts through the end of the current license terms 42 as well as the 20 -year license renewal term. The geographic area over which past, present, 43 Environmental Impacts of Operation 4-31 and reasonably foreseeable actions would occur is dependent on the type of action considered 1 and is described below for each resource area. 2 To evaluate cumulative impacts, the incremental impacts of the proposed action, as described 3 in Section s 4.1-4.10, are combined with other past, present, and reasonably foreseeable future 4 actions regardless of what agency (Federal or non -Federal) or person undertakes such actions. 5 The staff used the information provided in the ER, responses to requests for additional 6 information; information from other Federal, State, and local agencies; scoping comments, and 7 information gathered during the audit at the GGNS site to identify other past, present, and 8 reasonably foreseeable actions. 9 To be considered in the cumulative analysis, the staff determined if the project would occur 10 within the noted geographic areas of interest and within the period of extended operation, if it 11 was reasonably foreseeable, and if there would be potential overlapping effect with the 12 proposed project. For past actions, consideration within the cumulative impacts assessment i s 13 resource and project specific. In general, the effects of past actions are included in the 14 description of the affected environment in Chapter 2, which serves as the baseline for the 15 cumulative impacts analysis. However, past actions that continue to have an overlapping effect 16 on a resource potentially affected by the proposed action are considered in the cumulative 17 analysis. Other actions and projects that were noted during this review and considered in the 18 cumulative impact analysis are described below: 19 modification and management of the Mississippi River basin 20 construction of fossil -fuel power plant(s) to meet regional electricity demands 21 climate change 22 increased agricultural activities 23 maintenance of transmission line crossings through the Homochitto National Forest 24 continued operation of independent spent fuel storage installation (ISFSI) at GGNS 25 Additionally, NRC prepared an FEIS in 2006 in response to an application for an early site 26 permit (ESP) for the construction and operation of a new nuclear power plant at GGNS 27 (NRC 2006). On April 5, 2007, the NRC issued an ESP for the GGNS site. In 2008, Entergy 28 submitted an application for a combined license for a new boiling -water reactor at GGNS , 29 designated as Unit 3. However, in January 2009, Entergy informed the NRC that it was 30 considering alternate reactor design technologies and requested the NRC suspend its review 31 effort until further notice. Accordingly, the construction of Unit 3 at GGNS is considered a 32 reasonably foreseeable future action and is included in the cumulative impacts assessment 33 (NRC 2006). 34 4.12.1 Air Quality 35 This section addresses the direct and indirect effects of license renewal on air quality when 36 added to the aggregate effects of other past, present, and reasonably foreseeable future 37 actions. In evaluating the potential impacts on air quality associated with license renewal, the 38 NRC staff uses as its baseline the existing air quality conditions described in Section 2.2.2 .1 of 39 this SEIS. These baseline conditions encompass the existing air quality conditions (EPA's 40 National Ambient Air Quality Standard (NAAQS) county designations) potentially affected by air 41 emissions from continued operations. As described in Section 2.2.2.1, the Mobile (Alabama) -42 Pensacola-Panama City (Florida) -Southern Mississippi Interstate Air Quality Control Region 43 (AQCR) (40 CFR 81.68), which encompasses GGNS, is designated as an attainment area for 44 all criteria pollutants except for part of De Soto County, Mississippi, which is designated as a 45 marginal nonattainment area for the 2008 8 -hour ozone standard and is located about 200 miles 46 (322 km) north-northeast of GGNS. Other nearby nonattainment areas include the Birmingham 47 Environmental Impacts of Operation 4-32 area in Alabama for PM2.5 and the Houston -Galveston-Brazoria area in Texas for 8 -hour ozone , 1 located about 240 mi (386 km) east-northeast and west -southwest of GGNS, respectively. T he 2 nearest maintenance area for 8 -hour ozone is located about 90 mi (145 km) south of GGNS. 3 Currently, GGNS is operating under a "synthetic minor" permit, which covers site-wide 4 combustion emission sources, such as diesel generators, fire water pump engines, and cooling 5 towers (GGNS 2008 a). GGNS operations are in compliance with its air permit and Entergy has 6 no plans for refurbishments or other license renewal -related construction activities that would 7 affect permitted operations for the license renewal term (Entergy 2011 a). Annual emissions of 8 criteria pollutants, volatile organic compounds (VOCs), and hazardous air pollutants (HAPs) at 9 GGNS vary from year to year but are well below the plant's permitted "synthetic minor" 10 emissions limits (see Table 2-1), based on actual operating hours reported to MDEQ. 11 Considering the distances to the nearest nonattainment and maintenance areas around GGNS, 12 prevailing wind directions, and the minor nature of air emissions from GGNS, emissions from 13 GGNS operations are not anticipated to affect current attainment or maintenance area status. 14 Accordingly, air emissions from continued operation of the plant and associated effects on 15 ambient air quality would not be expected to change during the license renewal term. 16 As discussed in Section 2.2.2.1, operations at GGNS release greenhouse gas (GHG) emissions 17 as follows: carbon dioxide (CO 2), methane (CH 4), and nitrous oxide (N 2O) from fuel combustion; 18 hydrofluorocarbons (HFCs) in the two plant cooling water chillers; and sulfur hexafluoride (SF

6) 19 in three electric disconnect switches. Perfluorocarbons (PFCs) currently are not used at GGNS.

20 Combustion-related GHG emissions (such as CO 2, CH 4, and N 2O) at GGNS are minor. The 21 permitted combustion sources are designed for efficiency and operated intermittent ly throughout 22 the year (i.e., often only for testing and preventive maintenance). Other combustion-related 23 GHG emission sources at GGNS include commuter, visitor, support, and delivery vehicle traffic 24 within, to, and from the plant. In addition, small amounts of HFCs and SF 6 are released into the 25 atmosphere during normal operations or at various stages of the equipment's life cycle. Total 26 annual GHG emissions from the GGNS site were estimated to be about 5,980 tons CO2e 27 (5,425metric tons CO2e) in 2011 (GGNS 2012a; EPA 2011b), which is well below the EPA's 28 mandatory reporting threshold of 25,000 metric tons CO 2e per year (74 FR 56264). 29 To estimate the amount of GHG releases potentially avoided by continued GGNS operation, its 30 electricity generation can be compared to an equivalent amount of electricity generation in 31 fossil-fuel power plant(s). For 2009, the composite CO2e emission factor (representing an 32 average of all operating fossil -fuel power plants) is approximately 1,107 lb/MWh for the 33 Mississippi Valley subregion (EPA 2012a). GGNS generates approximately 11,500 GWh per 34 year, at 1,475 MWe and a capacity factor of 89 percent based on a 2007 -2009 average 35 (Entergy 2011 a). Thus, GGNS 's generating capacity avoids the release of approximatel y 36 6.4 million tons (5.8 million metric tons) of CO2e. This is approximately 2

3.5 percent

of the 37 27.0 million tons (24.5 million metric tons) CO2e emitted by fossil fuel electricity generation in 38 Mississippi in 2009 (EPA 2012a). This also equals about 0.08 percent of total U.S. GHG 39 emissions of 7 ,520 million tons (6 , 822 million metric tons) CO2e, in 2010 (EPA 2012b). 40 The Intergovernmental Panel on Climate Change (IPCC 2011) also estimated GHG emission 41 factors during the life cycle of nuclear power plants along with other renewable and conventional 42 power generation technologies. Estimated median GHG emission factors of 16 g CO2e/kWh for 43 nuclear energy are comparable to those for renewable energy (ranging from 4 g CO2e/kWh for 44 hydropower to 46 g CO2e/kWh for photovoltaic solar energy) but far lower than those for fossil 45 fuel energy (ranging from 469 g CO 2e/kWh for natural gas to 1 , 001 g CO 2e/kWh for coal). 46 Entergy did not report any foreseeable projects that could contribute to cumulative impacts to air 47 quality (Entergy 2011 a). If a project with the potential to affect air quality did occur, permitting 48 Environmental Impacts of Operation 4-33 and licensing requirements would limit its impact. The review of the GGNS Unit 3 combined 1 license (COL) application is currently on hold. However, if the facility were to be built in the 2 future, impacts on air quality that may result from construction will be temporary. The impacts of 3 construction on air quality would be from ground -clearing, grading and excavation activities that 4 raise dust, emissions from construction equipment, and emissions resulting from construction 5 workforce transportation. The impacts of operation on air quality would be from releases to the 6 environment of heat and moisture from the cooling towers, emissions from operation of auxiliary 7 equipment, and emissions from the workforce. The operation of Unit 3 would have air 8 emissions similar to those of the existing GGNS plant. NRC (2006) concluded that the impacts 9 of construction and operation of a proposed unit would be SMALL. 10 As discussed in Section 2.2.2, patterns of ambient temperature and precipitation at Jackson 11 International Airport generally are increasing slowly based on data from 1960 to 2011 12 (NCDC 1990, 2012). Recent research on climate change effects in the United States done by 13 the U.S. Global Change Research Program (USGCRP), a Federal Advisory Committee 14 (USGCRP 2009), was considered in preparation of this document. In the near term (2010 -2029 15 projected average change), which includes the first 5 years of the period of extended operation, 16 the temperatures around GGNS are projected to rise an additional 2-3 °F (1.1-1.7 °C), 17 compared to the recent past (1961 -1979). In 2040 -2059, which includes the last 5 years of the 18 period of extended operation, the temperatures around GGNS are projected to rise an additional 19 3-4 °F (1.7-2.2 °C) compared to the recent past. Over the past 50 years, average precipitation 20 around GGNS has increased about 5 -10 percent. Future changes in total precipitation are 21 more difficult to project than those in temperatures, but models generally predict that in the 22 Southeast region of the United States, encompassing GGNS, precipitation rates will decrease in 23 winter, spring, and summer relative to current precipitation rates (USGCRP 2009). During the 24 past 50 years, more severe weather, such as tornadoes and severe thunderstorms, ha s been 25 reported. This increase is widely believed to be due to improvements in monitoring 26 technologies such as Doppler radars combined with changes in population and increasi ng 27 public awareness. Considering these factors, there is no clear trend in the frequency or 28 strength of tornadoes since the 1950s in the United States as a whole. The power and 29 frequency of Atlantic hurricanes has increased in recent decades, and the intensity of these 30 storms is likely to increase in this century. However, an increase in the frequency of hurricanes 31 making landfall has not been observed in recent decades; therefore, there may not necessarily 32 be an increase in the number of these storms that make landfall in the future (USGCRP 2009). 33 Changes in hurricanes are difficult to project because many countervailing forces are involved. 34 Given that there is no planned site refurbishment associated with the GGNS license renewal 35 and, therefore, no additional air emissions beyond those noted in Section 2.2.2.1 from continued 36 operations of GGNS, the incremental impacts to cumulative air quality impacts near GGNS 37 would be SMALL. Although not identified, other reasonably foreseeable projects could result in 38 cumulative impacts to air quality. However, permitting and licensing requirements and various 39 mitigation measures likely would limit air quality impacts such that air quality continues to meet 40 applicable air quality standards. 41 Based on the above discussion, the staff concludes that combined with the emissions from 42 other past, present, and reasonably foreseeable future actions, cumulative impacts on ambient 43 air quality and global climate change from operations at GGNS would be SMALL. 44 4.12.2 Water Resources 45 This section addresses the direct and indirect effects of license renewal on water resources 46 when added to the aggregate effects of other past, present, and reasonably foreseeable future 47 actions. The geographic area considered in the cumulative aquatic resources analysis includes 48 Environmental Impacts of Operation 4-34 the vicinity of GGNS, including the Mississippi River basin near GGNS. As described in 1 Sections 4.4 and 4.5, the incremental impacts on water resources from continued operation of 2 GGNS during the license renewal term would be SMALL. 3 4.12.2.1 Cumulative Impacts on Surface Water Resources 4 The review of the GGNS Unit 3 COL application is currently on hold. However, this facility, if 5 built in the future, has the potential to influence surface water use and availability within the 6 geographic area. NRC (2006) determined that the normal makeup flow rate of the new nuclear 7 facility would be approximately 3,175 L/s (50,320 gpm), and the maximum expected makeup 8 flow would be 5,400 L/s (85,000 gpm). In addition, approximately 25 percent of this water would 9 be returned to the Mississippi River as blowdown. NRC (2006) concluded that a new nuclear 10 unit would withdraw only a small amount of water relative to the total river flow (about 0.2 11 percent) at even the lowest minimum river discharge conditions recorded for the area . Climate 12 patterns and increased water demands upstream of GGNS , also may increase the number of 13 water users and rate of withdrawal from the Mississippi River (Caffey et al. 2002). Continued 14 regulation of the flow by the U.S. Army Corps of Engineers is expected to preserve the course 15 and flow of the Mississippi River. Building and operating a new nuclear unit and other activities 16 beyond GGNS would not be expected to noticeably alter water resources within the Mississippi 17 River because the Mississippi River is an abundant source of surface water. 18 Similar to surface water use and availability, the proposed new nuclear unit at GGNS has 19 potential to influence surface water quality within the geographic area considered because the 20 proposed new unit would discharge into the Mississippi River. However, the flow of water in the 21 Mississippi River is so large that a new reactor is unlikely to change the river's basic water 22 quality. As discussed in Section 4.12 .3.2, historically the Mississippi River has experienced 23 decreased water quality from other land-use activities such as agriculture, industrial 24 development, and urban sprawl. However, with the implementation of the Clean Water Act, the 25 water quality of the past few decades has progressively improved. In addition, the proposed 26 new units and other water discharges in the area would obtain and comply with its NPDES 27 permit, which would define the limits of certain chemical and thermal properties of the 28 discharge. 29 Therefore, the staff concludes that the cumulative impact on the site's surface water use and 30 quality are SMALL. 31 4.12.2.2 Cumulative Impacts on Groundwater Resources 32 Activities that could potentially impact groundwater use in the area of interest include public 33 water supply companies, the construction and operating of the proposed new nuclear reactor , 34 and continued operations of GGNS. Most groundwater users outside of the GGNS site obtain 35 their water from public water supply companies that get their water from deep aquifers 36 (Catahoula Aquifer and deeper aquifer). The public water supply companies distribute the water 37 to customers via buried pipes and this operation is expected to continue for the reasonably 38 foreseeable future. The existing unit and the new nuclear unit proposed in the COL application 39 (review currently on hold) at GGNS have the potential to influence groundwater use within the 40 geographic area considered . However, it is expected the future reactor would not consume 41 groundwater from the deep underlying aquifers (GGNS 2008a) used by the public water supply 42 companies, similar to the existing unit at GGNS. Instead, makeup water and potable water for 43 the new reactor would be drawn from groundwater near surface aquifers that either have a 44 direct or indirect hydraulic connection to the Mississippi River. These aquifers near GGNS are 45 not connected to the deep aquifers. In addition, abundant water supplies exist from the deeper 46 aquifer accessed by the water supply companies to supply the needs of other future land -use 47 activities in the area. 48 Environmental Impacts of Operation 4-35 Activities that could potentially impact groundwater quality in the area of interest include the 1 construction and operation of the proposed new nuclear reactor, continued operations of GGNS, 2 and other land use actions that could result in contaminants reaching groundwater. However, 3 the groundwater quality of aquifers used as a source of public water is not likely to be noticeably 4 altered by present and future activities at GGNS or in the region. This is due to the large 5 thickness of low permeability geologic deposits that overly (i.e. protect) these aquifers from 6 surface contaminants. In addition, as discussed in Section 2.2.5, the EPA has identified the 7 Catahoula Aquifer as a sole source aquifer and will work to protect the deep groundwater 8 resources from contamination from projects that receive federal financial assistance. As such, 9 the MDEQ's Wellhead Protection Program will manage potential present and future sources of 10 contamination that are located near public water supply wells that obtain water from the 11 Catahoula Aquifer. No activities have been identified at or near GGNS that could impact the 12 quality of the Catahoula and deeper aquifers. These regulatory programs are expected to 13 continue to protect groundwater quality from future land -use activities. 14 Therefore, the staff concludes that the cumulative impact on the site's ground water use and 15 quality are SMALL. 16 4.12.3 Aquatic Resources 17 This section addresses the direct and indirect effects of license renewal on aquatic resources , 18 including protected aquatic species, when added to the aggregate effects of other past, present, 19 and reasonably foreseeable future actions. The cumulative impact is the total effect on the 20 aquatic resources of all actions taken, no matter who has taken the actions. The geographic 21 area considered in the cumulative aquatic resources analysis includes the vicinity of GGNS, 22 including the Mississippi River basin near GGNS and on site aquatic features such as Hamilton 23 and Gin Lakes, the borrow pit, three small ponds, streams "A" and "B," and ephemeral 24 drainages. Consistent with other agencies use of the term "baseline" and CEQ's NEPA 25 guidance, the term "baseline" pertains to the condition of the resource without the action, i.e., 26 under the no -action alternative. Under the no action alternative, the plant would shut down and 27 the resource would conceptually return to its condition without the plant (which is not necessarily 28 the same as the condition before the plant was constructed). The baseline, or benchmark, for 29 assessing cumulative impacts on aquatic resources takes into account the pre -operational 30 environment as recommended by the EPA (1999) for its review of NEPA documents: 31 Designating existing environmental conditions as a benchmark may focus the 32 environmental impact assessment too narrowly, overlooking cumulative impacts 33 of past and present actions or limiting assessment to the proposed action and 34 future actions. For example, if the current environmental condition were to serve 35 as the condition for assessing the impacts of relicensing a dam, the analysis 36 would only identify the marginal environmental changes between the continued 37 operation of the dam and the existing degraded state of the environment. In this 38 hypothetical case, the affected environment has been seriously degraded for 39 more than 50 years with accompanying declines in flows, reductions in fish 40 stocks, habitat loss, and disruption of hydrologic functions. If the assessment 41 took into account the full extent of continued impacts, the significance of the 42 continued operation would more accurately express the state of the environment 43 and thereby better predict the consequences of relicensing the dam. 44 Sections 2.2.6 and 2.2.8 present an overview of the conditions of the Mississippi River basin 45 near GGNS and the history and factors that led to its current condition. Since the 1700s, efforts 46 to control flooding and increase navigation along the Mississippi River have changed th e 47 relative abundance of various habitats within the river. In addition, levees have decreased the 48 connectivity of aquatic life within floodplain habitats and the Mississippi River because of the 49 Environmental Impacts of Operation 4-36 decrease in flooding events when biota can move in between floodplain habitats and the river. 1 In addition to physical changes to aquatic habitat, runoff has led to habitat degradation and 2 decreased water quality. Land use changes within the Mississippi River basin have introduced 3 new industrial and chemical inputs into the river (Brown et al. 2005). The introduction of 4 non-native species also has threatened many protected, native species near GGNS. As 5 described in Section 2.2.6.2, the staff compared aquatic surveys from 1972 through 1974 with 6 surveys from 2006 through 2008 (FishNet 2012). Of the 25 species recorded in the earlier 7 surveys, 8 species (32 percent) were collected and 17 species (68 percent) were not collected 8 in the later surveys (FishNet 2012). These results indicate that many species that once 9 inhabitated the Mississippi River may no longer exist near GGNS. 10 Many natural and human activities can influence the current and future aquatic life in the area 11 surrounding GGNS. Potential biological stressors include continued potential thermal stress 12 from GGNS as described in Section 4.8.2.5; modifications to the Mississippi River; runoff from 13 industrial, agricultural, and urban areas; other water users and dischargers; and, climate 14 change, as described in Section 4.12.3.4. 15 4.12.3.1 Modifications to the Mississippi River 16 The relative abundance of hard substrate, deep channel, and river bank habitat has been 17 largely influenced by human activities to decrease flooding events and increase navigability. 18 The U.S. Army Corps of Engineers (USACE) and Mississippi River Commission continue to 19 oversee a comprehensive river management program that includes: 20 levees for containing flood flows; 21 floodways for the passage of excess flows past critical reaches of the 22 Mississippi River; 23 channel improvement and stabilization to provide an efficient and reliable 24 navigation channel, increase the flood -carrying capacity of the river, and 25 protect the levee system; and, 26 tributary basin improvements for major drainage basins to include dams and 27 reservoirs, pumping plants, auxiliary channels and pumping stations 28 (MRC 2012). 29 Implementing this management program will continue to affect the relative availability of aquatic 30 habitats, resulting in, for example, a decrease in the amount of soft sediment river bank habitat 31 and an increase in the amount of hard substrates (e.g., riprap or other materials used to line the 32 river bank). Consequently, invertebrates that depend on a hard surface for attachment, and can 33 colonize human -made materials, such as tires, concrete, or riprap used to line river banks, likely 34 will continue to increase in relative abundance as compared to species that require soft 35 sediments along the river bank. 36 The Mississippi River Commission also implements various programs to support the 37 sustainability of aquatic life within the Mississippi River. For example, the Davis Pond and 38 Caernarvon freshwater diversion structures divert more than 18,00 0 ft 3/s (510 m 3/s) of fresh 39 water to coastal marshlands. The input of freshwater helps to preserve the marsh habitat and 40 reduce coastal land loss (MRC 2012). In addition, the Mississippi River Commission conducted 41 research and determined that using grooved articulated concrete mattresses to line river banks 42 can help support benthic invertebrate and fish populations. For example, using grooved 43 articulated concrete mattresses increases larval insect production, which is an important source 44 of prey for many fish (MRC 2012). 45 Environmental Impacts of Operation 4-37 4.12.3.2 Runoff from Industrial, Agricultural, and Urban Areas 1 Nearly 40 percent of the land within the contiguous United States drains into the Mississippi 2 River. Land use changes and industrial activities within this area have had a substantial impact 3 on aquatic habitat and water quality within the Mississippi River. For example, historically, the 4 Mississippi River has experienced decreased water quality as a result of industrial discharges, 5 agricultural runoff, municipal sewage discharges, surface runoff from mining activity, and 6 surface runoff from municipalities. However, over the past few decades, water quality within the 7 Mississippi River has improved because of the implementation of the Clean Water Act and other 8 environmental regulations (Caffey et al. 2002). For example, most of the older, first -generation 9 chlorinated insecticides have been banned since the late 1970s. Similarly, the addition and 10 upgrading of numerous municipal sewage treatment facilities, rural septic systems, and animal 11 waste management systems ha ve helped to significantly decrease the concentration of median 12 fecal coliform bacteria in the Mississippi River (Caffey et al. 2002). Despite the trend of 13 improving water quality within the Mississippi River, trace levels of some contaminants and 14 increased nutrients from agricultural lands remain a source of concern for aquatic life (Caffey et 15 al. 2002; Rabalais et al. 2009). 16 4.12.3.3 Other Water Users and Discharges 17 Several other currently existing and proposed facilities withdraw water from the Mississippi 18 River. For example, Entergy previously proposed to build a new nuclear reactor at the GGNS 19 site, which would withdraw water from the Mississippi River as a source of cooling water 20 (NRC 2006). In addition, climate patterns and increased water demands upstream of GGNS 21 also may increase the number of water users and rate of withdrawal from the Mississippi River 22 (Caffey et al. 2002). Aquatic life, especially threatened and endangered species, rely on 23 sufficient flow within streams and rivers to survive. Also, fish and other aquatic life could be 24 impinged and entrained within the new nuclear unit and other facility water intake systems. 25 Entergy proposed to use a clos ed-cycle cooling system, which would minimize impingement 26 and entrainment (NRC 2006). In addition, as described in Section 4.1 2.3.1, continued 27 regulation of the flow by the U.S. Army Corps of Engineers is expected to preserve the course 28 and flow of the Mississippi River. Building and operating a new nuclear unit and other activities 29 beyond GGNS would not be expected to noticeably alter aquatic resources within the 30 Mississippi River. 31 A new reactor at GGNS and other water users along the Mississippi River also would discharge 32 cooling water and other effluents into the Mississippi River. NRC (2006) considered the impacts 33 to aquatic resources from discharge of heated effluent (e.g., water temperature, dissolved 34 oxygen, thermal stratification, impact to fauna), cold shock, and chemical treatment of the 35 cooling water and determined that the effluent would not noticeably alter aquatic resources. 36 Additionally, Entergy and other water dischargers would be required to comply with NPDES 37 permits that must be renewed every 5 years, allowing MDEQ to ensure the permit limits provide 38 the appropriate level of environmental protection. 39 4.12.3.4 Climate change 40 Climate change could noticeably alter aquatic resources near GGNS. In the southeastern 41 United States, precipitation during the fall has increased 30 percent from 1901 to 2007 and the 42 overall amount of heavy downpours also has increased (USGCRP 2009). Heavy downpours 43 can increase the rate of runoff and pollutants reaching the Mississippi River because the 44 heavier precipitation, and the pollutants washed away in the runoff, have less time to be 45 absorbed in the soil before reaching the river and other surface waterbodies. Climate change 46 models predict continued increases in heavy downpours in the southeastern United States. 47 Environmental Impacts of Operation 4-38 Climate models also predict increasing temperatures in the southeast, especially during spring 1 and summer (USGCRP 2009). Increased temperatures and nutrients in runoff could lead to a 2 decline in oxygen within small streams, lakes, and shallow aquatic habitats. During periods of 3 low oxygen, many fish and other aquatic life may not be able to survive. Increased 4 temperatures also may increase the frequency of shellfish -borne illness, alter the distribution of 5 native fish, increase the local loss of threatened and endangered species, and increase the 6 displacement of native species by non -native species (USGCRP 2009). 7 Since the 1970s, there has been an increase in the amount of moderate to severe drought, 8 especially during spring and summer. Climate models predict a continued increase in the 9 amount and severity of droughts, which can lead to water use conflicts (USGCRP 2009). 10 Regulatory programs will be required to ensure sufficient water and flow is available within 11 surface waterbodies to provide habitat for aquatic life, especially threatened and endangered 12 species. 13 4.12.3.5 Conclusion 14 The direct and indirect impacts to aquatic resources from historical Mississippi River 15 modifications and pollutants and sediments introduced into the river have had a substantial 16 effect on aquatic life and their habitat. The incremental impacts from GGNS are SMALL for 17 aquatic resources because GGNS operation would have minimal impacts on aquatic life due to 18 use of a closed-cycle cooling system and Ranney wells. The cumulative stress from the 19 activities described above, spread across the geographic area of interest depends on many 20 factors that the NRC staff cannot quantify. This stress may noticeably alter some aquatic 21 resources. For example, climate change may increase the temperature of the Mississippi River 22 and rate of runoff into the river. This may noticeably alter the habitat for species most sensitive 23 to nutrient loading, high levels of contaminants, and higher temperatures. In addition, a 24 comparison of fish surveys from 1972 through 1974 and from 2006 through 2008 suggests that 25 some species no longer inhabitate the Mississippi River near GGNS (FishNet 2012). Therefore, 26 the staff concludes that the cumulative impacts from the proposed license renewal and other 27 past, present, and reasonably foreseeable projects would be MODERATE. 28 4.12.4 Terrestrial Resources 29 This section addresses past, present, and future actions that could result in cumulative impacts 30 on the terrestrial species and habitats described in Section 2.2.7, including protected terrestrial 31 species. For purposes of this analysis, the geographic area considered in the evaluation 32 includes the GGNS site and the in -scope transmission line corridors. As explained for aquatic 33 resources, the baseline for this assessment is the condition of the resource without the action, 34 i.e., under the no -action alternative. 35 4.12.4.1 Historic Conditions 36 Section 2.2.7 discusses the ecoregions in which the GGNS site lies -the Mississippi Valley 37 Alluvial Plain and Mississippi Valley Loess Plain. This region consists of irregular plains with a 38 thick layer of highly erodible loess deposits, oak -hickory and oak -hickory-pine forests, and 39 streams with low gradients and silty substrates. When GGNS was built, forests and agriculture 40 were the dominant land types. Between 1973 and 2000, agricultural lands decreased by 41 6.8 percent, while developed land increased by 4.0 percent (USGS 2001). Forested land 42 remained relatively constant and accounted for 43 to 44 percent of land cover over the time 43 period (USGS 2001). 44 On the immediate site, Mississippi Power & Light Company cleared about 270 ac (109 ha) of 45 upland habitat for GGNS buildings and related infrastructure. The terrestrial habitats on the 46 Environmental Impacts of Operation 4-39 undeveloped portions of the site have not changed significantly since GGNS's construction 1 (Entergy 2011 a). The two primary habitat changes between preconstruction and present day 2 are in the bottomland scrub -shrub wetlands (east of Gin Lake) and the upland open fields and 3 clearings, in which Entergy has planted American sycamore (Platanus occidentali) and loblolly 4 pine (Pinus taeda), respectively. 5 4.12.4.2 GGNS Unit 3 6 The review of the GGNS Unit 3 COL application is currently on hold. However, if the facility 7 were to be built in the future, Entergy (2011a) anticipates that onsite land disturbance would be 8 primarily limited to previously disturbed areas of the site. GGNS Unit 3 may require the 9 construction of new transmission lines. The impacts from such construction would vary 10 depending on the types of habitat the lines would cross and whether such transmission lines are 11 routed along existing transmission line corridor

s. Terrestrial resource impacts resulting from 12 operation of G GNS Unit 3 would be similar to impacts of operation of GGNS and would be 13 SMALL. 14 4.12.4.3 Agricultural Runoff 15 Within Claiborne County, 531 ac (126,073 ha) of land were used for cultivation of major crops 16 as of 2006 (NRC 2006). The 2000 National Water Quality Inventory reported that agricultural 17 nonpoint source pollution accounted for the second largest source of impairments to wetlands 18 (EPA 2012 a). Fertilizers and pesticides can affect wetlands and bottomlands in a variety of 19 ways. Because wetlands and bottomlands are often at lower elevation than surrounding land, 20 these habitats receive much of the runoff first, and that runoff persists because it is unable to 21 drain to lower ground. This can result in bioaccumulation of pollutants and changes to species 22 composition and abundance. Species that rely on wetlands, such as birds and amphibians, are 23 more sensitive to these environmental stressors than other animal groups.

24 4.12.4.4 National Forests 25 The Franklin transmission line crosses through the Homochitto National Forest to the southeast 26 of the GGNS site. This national forest will continue to provide valuable habitat to native wildlife 27 and migratory birds during the proposed license renewal period. As habitat fragmentation 28 resulting from various types of development increases, these areas will become ecologically 29 more important because they will provide large areas of natural habitat. 30 4.12.4.5 Climate Change 31 Since 1970, the average annual temperature in the southeastern United States has risen by 32 about 2 °F (1.1 °C) and the number of freezing days has declined by 4 to 7 days per year 33 (USGCRP 2009). Over the next several decades, the U.S. Global Change Research Program 34 (USGCRP 2009) estimates that the average temperatures in the region will rise by an additional 35 4.5 °F (2.5 °C). The Gulf Coast states, including Mississippi, will have less rainfall in winter and 36 spring, and higher temperatures will increase the frequency, duration, and intensity of drought. 37 Hurricane intensity also will likely increase (USGCRP 2009). Changes in the climate will shift 38 many wildlife population ranges and alter migratory patterns. Such changes could favor 39 non-native invasive species and promote population increases of insect pests and plant 40 pathogens. Climate change will likely alter the severity or frequency of precipitation, flooding, 41 and fire. Climate change may also exacerbate the effects of existing stresses in the natural 42 environment, such as those caused by habitat fragmentation, invasive species, nitrogen 43 deposition and runoff from agriculture, and air emissions. 44 Environmental Impacts of Operation 4-40 4.12.4.6 Conclusion 1 Section 4.7 of this SEIS concludes that the impact from the proposed license renewal would not 2 noticeably alter the terrestrial environment, and, thus, would be SMALL. However, as 3 environmental stressors such as agricultural runoff and climate change continue over the 4 proposed license renewal term, certain attributes of the terrestrial environment (such as species 5 diversity and distribution) are likely to noticeably change. The staff does not expect these 6 impacts to destabilize any important attributes of the terrestrial environment because such 7 impacts will cause gradual change, which should allow the terrestrial environment to 8 appropriately adapt. The staff concludes that the cumulative impacts of the proposed license 9 renewal of GGNS plus other past, present, and reasonably foreseeable future projects or 10 actions would result in MODERATE impacts to terrestrial resources. 11 4.12.5 Human Health 12 The NRC and EPA have developed radiological dose limits for protection of the public and 13 workers to address the cumulative impact of acute and long -term exposure to radiation and 14 radioactive material. These dose limits are codified in 10 CFR Part 20 and 40 CFR Part 190. 15 For the purpose of this analysis, the area within a 50 -mi (80-km) radius of GGNS was included. 16 The radiological environmental monitoring program Entergy conducted in the vicinity of the 17 GGNS site measures radiation and radioactive materials from all sources (i.e., hospitals and 18 other licensed users of radioactive material); therefore, the monitoring program measures 19 cumulative radiological impacts. There currently are no other nuclear power reactors or 20 uranium fuel cycle facilities within the 50-mi (80-km) radius of the GGNS site. 21 Radioactive effluent and environmental monitoring data for the 5 -year period from 200 8 to 2012 22 were reviewed as part of the cumulative impacts assessment. In Section 4.9.1 of this SEIS, the 23 staff concluded that impacts of radiation exposure to the public and workers (occupational) from 24 operation of GGNS during the renewal term are SMALL. The NRC and the State of Mississippi 25 would regulate any future actions in the vicinity of the GGNS site that could contribute to 26 cumulative radiological impacts. 27 Entergy constructed an independent spent fuel storage installation (ISFSI) on the GGNS site in 28 2000 for the storage of its spent fuel. The installation and monitoring of this facility is governed 29 by NRC requirements in 10 CFR Part 72, "Licensing Requirements for the Independent Storage 30 of Spent Nuclear Fuel, High -Level Radioactive Waste, and Reactor -Related Greater Than 31 Class C Waste." Radiation from this facility, as well as from the operation of GGNS, is required 32 to be within the radiation dose limits in 10 CFR Part 20, 40 CFR Part 190, and 10 CFR Part 72. 33 The NRC carries out periodic inspections of the ISFSI to verify its compliance with its licensing 34 and regulatory requirements. 35 In September 2010, Entergy applied to the NRC for an extended power uprate (EPU). In 36 July 2012, the NRC issued an amendment approving the power increase (NRC 2012j). The 37 staff considered the environmental impacts of the EPU in this evaluation. 38 As discussed in Section 4.12, review of the application for the proposed new nuclear reactor 39 designated as GGNS Unit 3 is on hold. However, GGNS Unit 3 is considered in the cumulative 40 impacts section since it is a reasonable and foreseeable future action. 41 The cumulative radiological impacts from GGNS Unit 1, the ISFSI, and the proposed GGNS 42 Unit 3, would be required to meet the radiation dose limits in 10 CFR Part 20 and 43 40 CFR Part 190. For these reasons, the staff concludes that cumulative radiological impacts 44 would be SMALL. 45 Environmental Impacts of Operation 4-41 4.12.6 Socioeconomics 1 This section addresses socioeconomic factors that have the potential to be affected directly or 2 indirectly by changes in operations at GGNS in addition to the aggregate effects of other past, 3 present, and reasonably foreseeable future actions. The primary geographic area of interest 4 considered in this cumulative analysis is Claiborne, Hinds, Jefferson, and Warren Counties 5 where approximately 81 percent of GGNS employees reside (see Table 2-7). This is where the 6 economy, tax base, and infrastructure most likely would be affected since GGNS workers and 7 their families reside, spend their income, and use their benefits within these counties. 8 As discussed in Section 4.10 of this SEIS, continued operation of GGNS would have no impact 9 on socioeconomic conditions in the region during the license renewal term beyond what is 10 already being experienced. Since Entergy has no plans to hire additional non -outage workers 11 during the license renewal term, overall expenditures and employment levels at GGNS are 12 expected to remain relatively unchanged with no additional or increased demand for permanent 13 housing and public services. In addition, since employment levels and tax payments would not 14 change, there would be no population or tax revenue -related land use impacts. Based on this 15 and other information presented in Chapter 4 of this SEIS, there would be no contributory effect 16 from the continued operation of GGNS on socioeconomic conditions in the region beyond what 17 is currently being experienced. The only cumulative contributory effects would come from the 18 other planned activities in the region independent of GGNS operations. T herefore, the staff 19 concludes that the cumulative socioeconomic impacts would be SMALL. 20 4.12.6.1 Environmental Justice 21 The environmental justice cumulative impact analysis assesses the potential for 22 disproportionately high and adverse human health and environmental effects on minority and 23 low-income populations that could result from past, present, and reasonably foreseeable future 24 actions including GGNS operations during the renewal term. Adverse health effects are 25 measured in terms of the risk and rate of fatal or nonfatal adverse impacts on human health. 26 Disproportionately high and adverse human health effects occur when the risk or rate of 27 exposure to an environmental hazard for a minority or low -income population is significant and 28 exceeds the risk or exposure rate for the general population or for another appropriate 29 comparison group. Disproportionately high environmental effects refer to impacts or risk of 30 impact on the natural or physical environment in a minority or low -income community that are 31 significant and appreciably exceed the environmental impact on the larger community. Such 32 effects may include biological, cultural, economic, or social impacts. Some of these potential 33 effects have been identified in resource areas presented in Chapter 4 of this SEIS. Minority and 34 low-income populations are subsets of the general public residing in the area and all would be 35 exposed to the same hazards generated from GGNS operations. As previously discussed in 36 this chapter, the impact from license renewal for all resource areas (e.g., land, air, water, 37 ecology, and human health) would be SMALL. 38 As discussed in Section 4.10.7 of this SEIS, there would be no disproportionately high and 39 adverse impacts to minority and low -income populations from the continued operation of GGNS 40 during the license renewal term. Since Entergy has no plans to hire additional non -outage 41 workers during the license renewal term, employment levels at GGNS are expected to remain 42 relatively unchanged with no additional or increased demand for housing or increased traffic. 43 Based on this information and the analysis of human health and environmental impacts 44 presented in Chapters 4 and 5, it is not likely there would be any disproportionately high and 45 adverse contributory effect on minority and low -income populations from the continued 46 operation of GGNS during the license renewal term. 47 Environmental Impacts of Operation 4-42 4.12.7 Historic and Archaeological Resources 1 This section addresses the direct and indirect effects of license renewal on historic and cultural 2 resources, in and around GGNS, when added to the aggregate effects of other past, present, 3 and reasonably foreseeable actions. Section 2.2.10 discusses the cultural background and 4 known historic and archaeological resources in and around GGNS. 5 As described in Section 4. 10.6, the NRC staff concluded that license renewal would have a 6 SMALL impact on historic and cultural resources at GGNS. However, any future 7 ground-disturbing maintenance and operations activities during the license renewal term could 8 affect undiscovered historic and archaeological resources . In addition, future construction and 9 operation of a new nuclear power plant site at GGNS would have the potential to result in 10 impacts on cultural resources through inadvertent discovery during ground -disturbing activities. 11 Future urbanization near GGNS could also affect historic and archaeological resources. 12 Given the high potential for historic and archaeological resources to be present at GG NS, as 13 well as the existing historic and archaeological resources presented in Section 2.2.10.2, GGNS 14 has procedures regarding protection of cultural resources. Any ground-disturbing maintenance 15 and operations activities during the GGNS license renewal term or construction of a new 16 nuclear power plant would be reviewed in accordance with these procedures. These 17 procedures are designed to ensure that investigations and consultations are conducted as 18 needed and that existing or potentially existing cultural resources are adequately protected. 19 Should historic or archaeological resources be encountered during construction, work would 20 cease until Entergy environmental personnel would perform an evaluation and consider possible 21 mitigation measures through consultation with the Mississippi SHPO. Any future urbanization 22 that might directly or indirectly affect historic or archaeological resources (i.e. inadvertent 23 discovery, viewshed impacts) would be required to comply with applicable State and Federal 24 laws regarding protection of cultural and archaeological resources, and any impacts would be 25 mitigated accordingly. 26 Based on this information, the NRC staff finds that the continued operation of GGNS during the 27 license renewal term would not incrementally contribute to cumulative impacts on historic and 28 archaeological resources within GGNS and in the surrounding area. Therefore, the cumulative 29 impact on historic and archaeological resources during the license renewal term would be 30 SMALL. 31 4.12.8 Summary of Cumulative Impacts 32 The staff considered the potential impacts resulting from the operation of GGNS during the 33 period of extended operation and other past, present, and reasonably foreseeable future actions 34 near GGNS. The preliminary determination is that the potential cumulative impacts would range 35 from SMALL to LARGE, depending on the resource. Table 4-10 summarizes the cumulative 36 impacts on resources areas. 37 Environmental Impacts of Operation 4-43 Table 4-10. Summary of Cumulative Impacts on Resource Areas 1 Resource area Cumulative impact Air Quality Considering the distances to the nearest nonattainment and maintenance areas around GGNS, prevailing wind directions, and the minor nature of air emissions from GGNS, emissions from GGNS operations are not anticipated to affect current attainment or maintenance area status. Accordingly, air emissions from continued operation of the plant and associated impacts on ambient air quality would not be expected to change during the license renewal term.

Based on the above discussion, the NRC staff concludes that combined with the emissions from other past, present, and reasonably foreseeable future actions, cumulative impacts on ambient air quality and global climate change from operations at GGNS would be SMALL. Water Resources The watersheds contributing flow to the two streams on the GGNS site are nearly contained within the site, and the remaining drainage area outside the site area would not be expected to change significantly. Therefore, changes in surface water supply outside the site would not alter the surface water conditions of the site's two streams. No activity at the GGNS site by itself, nor other activities outside the site, would be expected to alter fundamentally the character of the Mississippi River. The cumulative impacts from past, present, and reasonably foreseeable future actions on surface water resources during the license renewal term would be SMALL. In the region around GGNS, public water is obtained from deep underlying aquifers. Past, present and future activities at the GGNS site have not and will not use these aquifers as a source of water. Throughout the region, the groundwater quality of the deep underlying aquifers is protected from land -use activities by thick layers of low permeability geologic deposits and by government regulatory programs. The cumulative impact on groundwater use will be SMALL because abundant good water quality groundwater is and will continue to be readily available for public use. Based on the above considerations, the cumulative impacts from past, present, and reasonably foreseeable future actions on groundwater resources during the licens e renewal term would be SMALL. Aquatic Ecology The direct and indirect impacts to aquatic resources from historical Mississippi River modifications and pollutants and sediments introduced into the river have had a substantial effect on aquatic life and their habitat. The incremental impacts from GGNS are SMALL for aquatic resources because GGNS uses a closed-cycle cooling system and Ranney wells. The cumulative stress from the activities described in Section 4.12.3, spread across the geographic area of interest depends on many factors that NRC staff cannot quantify. This stress may noticeably alter some aquatic resources. The cumulative impacts from the proposed license renewal and other past, present, and reasonably foreseeable projects would be MODERATE. Terrestrial Ecology The NRC staff examined the cumulative effects of the construction of GGNS, agricultural runoff, nearby parks and conservation areas, and climate change. The NRC staff concludes that the minimal terrestrial impacts of continued GGNS operations would not contribute to the overall decline in the condition of terrestrial resources. The NRC staff believes that the cumulative impacts of other and future actions during the term of license renewal on terrestrial habitat and associated species, when added to past, present, and reasonably foreseeable future actions, would be MODERATE.

Environmental Impacts of Operation 4-44 Resource area Cumulative impact Human Health The radiological dose limits for protection of the public and workers have been developed by the NRC and EPA to address the cumulative impact of acute and long-term exposure to radiation and radioactive material. The NRC and the State of Mississippi would regulate any future actions in the vicinity of the GGNS site that could contribute to cumulative radiological impacts. In addition, the cumulative radiological impacts from operation of GGNS, the ISFSI , and a projected additional reactor unit would be required to meet the radiation dose limits in 10 CFR Part 20 and 40 CFR Part 190. For these reasons, cumulative radiological impacts would be SMALL. Socioeconomics As discussed in Section 4. 10, continued operations during the license renewal term would have no impact on socioeconomic conditions in the region beyond those already being experienced. In addition, there would be no disproportionately high and adverse impacts to minority and low -income populations from the continued operations during the license renewal term. The cumulative effects on socioeconomic conditions and environmental justice populations in the region from past, present, and reasonably foreseeable future actions including continued operations combined with other planned activities in the region is not expected to increase appreciably beyond what is currently being experienced. T herefore, cumulative socioeconomic impacts would be SMALL. Cultural Resources As discussed in Section 4. 10.6 of this SEIS, continued operation of GGNS during the license renewal term is likely to have a SMALL impact on historical or archaeological resources. Any future ground -disturbing activities may affect undiscovered historic and archaeological resources; however, any such activity would be reviewed in accordance with Entergy procedures designed to adequately protect historic and archaeological resources. Future urbanization would be governed by appropriate State and Federal laws to mitigate impacts on historic and archaeological resources. Therefore, the cumulative impacts on historic and archaeological resources during the license renewal term would be SMALL. 4.13 References 1 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for 2 protection against radiation." 3 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic licensing of 4 production and utilization facilities." 5 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy , Part 51, "Environmental 6 protection regulations for domestic licensing and related regulatory functions." 7 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for 8 renewal of operating licenses for nuclear power plants." 9 40 CFR Part

81. Code of Federal Regulations, Title 40, Protection of the Environment, Part 81, 10 "Designation of areas for air quality planning purposes."

11 40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 12 "Environmental radiation protection standards for nuclear power operations." 13 50 CFR Part 402. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 402, 14 "Interagency cooperation -Endangered Species Act of 1973, as amended." 15 Environmental Impacts of Operation 4-45 59 FR 7629. Executive Order 12898. Federal actions to address environmental justice in 1 minority populations and low -income populations. Federal Register 59(32):7629 -7634. 2 February 16, 1994. 3 69 FR 52040. U.S. Nuclear Regulatory Commission. Policy statement on the treatment of 4 environmental justice matters in NRC regulatory and licensing actions. Federal Register 5 69(163):52040 -52048. August 24, 2004. 6 74 FR 56264. U.S. Environmental Protection Agency. Mandatory reporting of greenhouse 7 gases; final rule." Federal Register 74(209):56260 -56519. October 30, 2009. 8 Brown A.V., Brown K.B., Jackson D.C. & Pierson W.K. 2005. The lower Mississippi River and its 9 tributaries. In A.C. Benke & C.E. Cushing eds. Rivers of North America. New York, Academi c 10 Press. 11 Caffey, R. H. , P. Coreil, and D. Demcheck. 2002. Mississippi River Water Quality: Implications 12 for Coastal Restoration, Interpretive Topic Series on Coastal Wetland Restoration in Louisiana, 13 Coastal Wetland Planning, Protection, and Restoration Act (eds.), National Sea Grant Library 14 No. LSU-G 002. 15 [CEQ] Council on Environmental Quality. 1997. Environmental Justice: Guidance Under the 16 National Environmental Policy Act. December 10. Available at 17 <http://www.epa.gov/compliance/ej/resources/policy/ej_guidance_nepa_ceq1297.pdf > 18 (accessed 19 July 2012). Agencywide Documents Access and Management System (ADAMS) 19 Accession No. ML082520150. 20 [Entergy] Entergy Operations, Inc. 2009

a. Grand Gulf Nuclear Station Unit 1. 2008 Annual 21 Radiological Environmental Operating Report. Port Gibson, MS. ADAMS No. ML091240225.

22 [Entergy] Entergy Operations, Inc. 2009

b. Grand Gulf Nuclear Station Unit 1. 2008 Annual 23 Radioactive Effluent Release Report. Port Gibson, MS. ADAMS Accession No.

ML091310016. 24 [Entergy] Entergy Operations, Inc. 2010

a. Grand Gulf Nuclear Station Unit 1. 2009 Annual 25 Radiological Environmental Operating Report. Port Gibson, MS. ADAMS Accession 26 No. ML101130028.

27 [Entergy] Entergy Operations, Inc. 2010

b. Grand Gulf Nuclear Station Unit 1. 2009 Annual 28 Radioactive Effluent Release Repor

t. Port Gibson, MS. ADAMS Accession No.

ML101200085. 29 [Entergy] Entergy Operations, Inc. 2011

a. Grand Gulf Nuclear Station, Unit 1, License Renewal 30 Application , Appendix E, Applicant's Environmental Report.

Port Gibson: MS. October 2011. 31 425 p. ADAMS Accession No. ML11308A234. 32 [Entergy] Entergy Operations, Inc. 2011b. Grand Gulf Nuclear Station Unit 1. 2010 Annual 33 Radiological Environmental Operating Report. Port Gibson, MS. ADAMS Accession 34 No. ML111190213. 35 [Entergy] Entergy Operations, Inc. 2011c. Grand Gulf Nuclear Station Unit 1. 2010 Annual 36 Radioactive Effluent Release Report. Port Gibson, MS. ADAMS Accession No. ML111190097. 37 [Entergy] Entergy Operations, Inc. 2012

a. Grand Gulf Nuclear Station Unit 1.

2011 Annual 38 Radiological Environmental Operating Report. Port Gibson, MS. ADAMS Accession 39 No. ML0812606810. 40 [Entergy] Entergy Operations, Inc. 2012

b. Grand Gulf Nuclear Station Unit 1. 2011 Annual 41 Radioactive Effluent Release Report. Port Gibson, MS. ADAMS Accession No.

ML12121A593. 42 Environmental Impacts of Operation 4-46 [Entergy] Entergy Operations, Inc. 2013a. Grand Gulf Nuclear Station Unit 1. 2012 Annual 1 Radiological Environmental Operating Report. Port Gibson, MS. ADAMS Accession No. 2 ML13121A394. 3 [Entergy] Entergy Operations, Inc. 201 3b. Grand Gulf Nuclear Station Unit 1. 2012 Annual 4 Radioactive Effluent Release Report. Port Gibson, MS. ADAMS Accession No. ML13121A244. 5 [EPA] U.S. Environmental Protection Agency. 1999. Consideration of Cumulative Impacts in 6 EPA Review of NEPA Documents. EPA -315-R-99-002. Office of Federal Activities (2252A), 7 Washington, D.C. 8 [EPA] U.S. Environmental Protection Agency. 2011a. eGRID, eGRID2012 Version 1.0. 9 Available at <http://www.epa.gov/cleanenergy/energy -resources/egrid/index.html> (accessed 10 26 June 2012). 11 [EPA] U.S. Environmental Protection Agency. 2011b. Emission Factors for Greenhouse Gas 12 Inventories, last modified November 7, 2011. Available at 13 <http://www.epa.gov/climateleaders/documents/emission -factors.pdf> (accessed 18 Dec 2012). 14 [EPA] U.S. Environmental Protection Agency. 2012

a. "Agriculture." Available at 15 <http://water.epa.gov/polwaste/nps/agriculture.cfm> (accessed 11 May 2012).

16 [EPA] U.S. Environmental Protection Agency. 2012b. Inventory of U.S. Greenhouse Gas 17 Emissions and Sinks: 1990 -2010. EPA 430 R 001. April 15, 2012. Available at 18 <http://www.epa.gov/climatechange/Downloads/ghgemissions/US -GHG-Inventory-2012-Main-19 Text.pdf> (accessed 26 June 2012). 20 [FWS] U.S. Fish and Wildlife Service. 2007. "Pallid Sturgeon (Scaphirhynchus albus) 5-Year 21 Review: Summary and Evaluation." Billings, MT. June 13, 2007. 120 p. Available at 22 <http://ecos.fws.gov/docs/five_year_review/doc1059.pdf> (accessed 10 January 2013). 23 [FWS] U.S. Fish and Wildlife Service. 2012a. Letter from S. Ricks, Mississippi Field Office 24 Supervisor, FWS, to D. Drucker, Project Manager, NRC. Reply to request for concurrence with 25 list of protected species and habitats for Grand Gulf license renewal review. February 3, 2012. 26 ADAMS Accession No. ML12047A113. 27 [FWS] U.S. Fish and Wildlife Service. 2012b. Letter from J.D. Weller, Louisiana Field Office 28 Supervisor, FWS, to D. Wrona, RPB2 Branch Chief, NRC. Reply to request for concurrence with 29 list of protected species and habitats for Grand Gulf license renewal review. February 29, 2012. 30 ADAMS Accession No. ML12082A141. 31 [FWS] U.S. Fish and Wildlife Service. 2012c. Letter from K. Herrington, Panama City Office, 32 FWS, to M. Moser, RERB Aquatic Biologist, NRC. Reply to Inquiry regarding Gulf Sturgeon at 33 Grand Gulf Nuclear Station. July 2, 2012. ADAMS Accession No. ML12226A158. 34 [FWS] U.S. Fish and Wildlife Service. 2012d. "Bayou Darter (Etheostoma rubrum) 5-Year 35 Review: Summary and Evaluation." Jackson, MS: FWS Southeast Region. May 9, 2012. 16 p. 36 Available at <http://ecos.fws.gov/docs/five_year_review/doc3989.pdf> (accessed 10 Jan 2013). 37 [FWS] U.S. Fish and Wildlife Service. 2013. "Guidance for Preparing a Biological Assessment." 38 Accessed September 12, 2013. Available at 39 http://www.fws.gov/midwest/endangered/section7/pdf/BAGuidance.pdf 40 [GGNS] Grand Gulf Nuclear Station. 2008

a. Grand Gulf Nuclear Station (GGNS), Facility 41 No. 0420-00023, Renewal of Existing Synthetic Minor Operating Permit No. 0420

-00023, 42 Correspondence GEXO -2008/00086. November 25, 2008. (ADAMS Accession 43 No. ML12157A448). 44 Environmental Impacts of Operation 4-47 [GGNS] Grand Gulf Nuclear Station. 2008b. Grand Gulf Nuclear Station, Unit 3 COL 1 Application, Part 3, Environmental Report, pages 4 -5 to 4-13 and 6-4, February 2008. ADAMS 2 Accession No ML080640404. 3 [GGNS] Grand Gulf Nuclear Station. 2012

a. Response to Request for Additional Information 4 (RAI) Dated April 23, 2012, Grand Gulf Nuclear Station, Unit 1. ADAMS Accession 5 No. ML12157A173.

6 [GGNS] Grand Gulf Nuclear Station. 2012

b. Response to Request for Additional Information 7 (RAI) Dated May 8, 2012 Grand Gulf Nuclear Station, Unit 1. ADAMS Accession 8 No. ML12158A445. 9 [IEEE] Institute of Electrical and Electronics Engineers, Inc. 2002. National Electrical Safety 10 Code. 11 [IPCC] Intergovernmental Panel on Climate Change. 2011. Renewable Energy Sources and 12 Climate Change Mitigation, Special Report of the IPCC. O. Edenhofer, R. 13 Pichs-Madruga, Y. Sokona, K. Seyboth, P. Matschoss, S. Kadner, T. Zwickel, P. Eickemeier, 14 G. Hansen, S. Schlomer, C. von Stechow, editors. Cambridge University Press, Cambridge, 15 U.K. and New York, NY. Available at

<http://srren.ipcc -16 wg3.de/report/IPCC_SRREN_Full_report.pdf > (accessed 18 April 2012) 17 [LDWF] Louisiana Department of Wildlife and Fisheries. 2012. Letter from A. Bass , Coordinator , 18 Louisiana Natural Heritage Program, to D. Wrona, RPB2 Branch Chief, NRC.

Subject:

Grand 19 Gulf Nuclear Station license renewal. February 1 6, 2012. ADAMS Accession No. 20 ML12060 A 098. 21 [MDAH] Mississippi Department of Archives and History. 2012

a. Letter from G. Williamson, 22 Mississippi Department of Archives and History, to David J. Wrona, NRC.

Subject:

Grand Gulf 23 Nuclear Station, Unit 1, License Renewal 50 -416 MDAH Project Log #01 -171-12 (Previously 24 #02-053-11), Choctaw County. February 28, 2012, ADAMS Accession No. ML12073A084. 25 [MDAH] Mississippi Department of Archives and History. 2012

b. Site file search conducted by 26 K. Wescott, Argonne National Laboratory, and E. Larson, U.S.

Nuclear Regulatory Commission, 27 at the MDAH, Jackson, Mississippi on March 29 and 30, 2012. 28 [MDWFP] Mississippi Department of Wildlife, Fisheries, and Parks. 2012. Letter from 29 A. Sanderson, Ecologist, Mississippi Natural Heritage Program, to D. Wrona, RPB2 Branch 30 Chief, NRC.

Subject:

Reply to request for protected species and habitat information for Grand 31 Gulf license renewal review. February 13, 2012. ADAMS Accession No. ML12055A312. 32 [MRC] Mississippi River Commission. 2012. Mississippi Valley Division: Mississippi River and 33 Tributaries Project. URL Available at: http://www.mvd.usace.army.mil/mrc/mrt/index.php 34 (Accessed on 20 June 2012). 35 Missouri Census Data Center Circular Area Profiling System (CAPS) 2012. Version 10C. Using 36 Data from Summary File 1, 2010 Census Summary of Census Tracts in a 50 -mile radius around 37 the GGNS (32.01 Lat., -91.05 Long.). Accessed June 2012. 38 [NCDC] National Climatic Data Center. 1990. 1989 Local Climatological Data Annual Summary 39 with Comparative Data, Jackson, Mississippi. National Oceanic and Atmospheric 40 Administration, National Environmental Satellite, Data, and Information Service. Available at 41 <http://www7.ncdc.noaa.gov/IPS/lcd/lcd.html > (accessed 22 June 2012). 42 [NCDC] National Climatic Data Center. 2012. 2011 Local Climatological Data Annual Summary 43 with Comparative Data, Jackson, Mississippi (KJAN). National Oceanic and Atmospheric 44 Environmental Impacts of Operation 4-48 Administration, Satellite and Information Service. Available at 1 <http://www7.ncdc.noaa.gov/IPS/lcd/lcd.html > (accessed 19 June 2012). 2 [NEI] Nuclear Energy Institute. 2007. Industry Ground Water Protection Initiative - Final 3 Guidance Document. Washington, DC: Nuclear Energy Institute. NEI 07 -07 (Final]. 4 August 2007. ADAMS Accession No. ML091170588. 5 [NIEHS] National Institute of Environmental Health Sciences. 1999. NIEHS Report on Health 6 Effects from Exposure to Power -Line Frequency Electric and Magnetic Fields. Publication 7 No. 99-4493. Research Triangle Park, NC: NIEHS. 80 p. Available at 8 <http://www.niehs.nih.gov/about/materials/niehsreport.pdf > (accessed 19 July 2012). 9 [NMFS] National Marine Fisheries Service. 2012. Letter from D. Bernhart, Southeast Assistant 10 Regional Administrator for Protected Resources, to D. Wrona, RPB2 Branch Chief, NRC. 11

Subject:

Reply to request for list of species at Grand Gulf Nuclear Station, Unit 1. 12 March 1, 2012. ADAMS Accession No. ML12065A167. 13 [NRC] U.S. Nuclear Regulatory Commission. 1973. Final Environmental Statement Related to 14 the Construction of Grand Gulf Nuclear Station Units 1 and 2. ADAMS Accession 15 No. ML021370537. 16 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 17 for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG -1437, Volumes 1 18 and 2. May 1996. ADAMS Accession Nos. ML040690705 and ML040690738. 19 [NRC] U.S. Nuclear Regulatory Commission. 1999

a. Section 6.3 - Transportation, Table 9.1, 20 Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic 21 Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC:

22 NRC. NUREG -1437, Volume 1, Addendum 1. August 1999. ADAMS Accession 23 No. ML04069 0 720. 24 [NRC] U.S. Nuclear Regulatory Commission. 1999

b. NUREG-1555, Supplement 1, Standard 25 Review Plans for Environmental Reviews for Nuclear Power Plants, Supplement 1: Operating 26 License Renewal. October 1999. Available at: http://www.nrc.gov/reading

-rm/doc-27 collections/nuregs/staff/sr1555/s1/sr1555s1.pdf. 28 [NRC] U.S. Nuclear Regulatory Commission. 2006. Environmental Impact Statement for an 29 Early Site Permit (ESP) at the Grand Gulf ESP Site. Washington, DC: NRC. Final Report. 30 NUREG-1817. April 2006. 876 p. ADAMS Accession No. ML060900037. 31 [NRC] U.S. Nuclear Regulatory Commission. 2012

a. Letter from D. Wrona, RPB2 Branch Chief, 32 NRC, to R. Watson, Louisiana Field Office, FWS.

Subject:

Request for list of protected species 33 within the area under evaluation for the Grand Gulf Nuclear Station, Unit 1, license renewal 34 application. January 19, 2012. ADAMS Accession No. ML11349A001. 35 [NRC] U.S. Nuclear Regulatory Commission. 2012

b. Letter from D. Wrona, RPB2 Branch Chief, 36 NRC, to S. Ricks, Mississippi Field Office, FWS.

Subject:

Request for list of protected species 37 within the area under evaluation for the Grand Gulf Nuclear Station, Unit 1, license renewal 38 application. January 20, 2012. ADAMS Accession No. ML12025A069. 39 [NRC] U.S. Nuclear Regulatory Commission. 2012

c. Letter from D. Wrona, RPB2 Branch Chief, 40 NRC, to D. Bernhart, Southeast Assistant Regional Administrator for Protected Resources, 41 NMFS.

Subject:

Request for list of protected species within the area under evaluation for the 42 Grand Gulf Nuclear Station, Unit 1, license renewal application. January 19, 2012. ADAMS 43 Accession No. ML11350A173. 44 Environmental Impacts of Operation 4-49 [NRC] U.S. Nuclear Regulatory Commission. 2012

d. Letter from D. Wrona, RPB2 Branch Chief, 1 NRC, to S. Surrette, Mississippi Natural Heritage Program, Mississippi Department of Wildlife, 2 Fisheries, and Parks.

Subject:

Request for list of protected species within the area under 3 evaluation for the Grand Gulf Nuclear Station, Unit 1, license renewal application. 4 January 20, 2012. ADAMS Accession No. ML11349A003. 5 [NRC] U.S. Nuclear Regulatory Commission. 2012

e. Letter from D. Wrona, RPB2 Branch Chief, 6 NRC, to C. Michon, Louisiana Natural Heritage Program, Louisiana Department of Wildlife and 7 Fisheries.

Subject:

Request for list of protected species within the area under evaluation for the 8 Grand Gulf Nuclear Station, Unit 1, license renewal application. February 6, 2012. ADAMS 9 Accession No. ML12005A163. 10 [NRC] U.S. Nuclear Regulatory Commission. 2012

f. Letter from D.J. Wrona, NRC, to R.

11 Nelson, Advisory Council on Historic Preservation.

Subject:

Grand Gulf Nuclear Station License 12 Renewal Environmental Review. January 19, 2012. ADAMS Accession No. ML11348A088. 13 [NRC] U.S. Nuclear Regulatory Commission. 2012

g. Letter from D.J. Wrona, NRC, to Phil 14 Boggan, Office of Historic Preservation.

Subject:

Grand Gulf Nuclear Station License Renewal 15 Environmental Review. January 20, 2012. ADAMS Accession No. ML11348A353. 16 [NRC] U.S. Nuclear Regulatory Commission. 2012

h. Letter from D.J. Wrona, NRC, to H.T.

17 Holmes, Mississippi Department of Archives and History.

Subject:

Grand Gulf Nuclear Station, 18 Unit 1, License Renewal Environmental Review. January 19, 2012. ADAMS Accession No. 19 ML11348A090. 20 [NRC] U.S. Nuclear Regulatory Commission. 2012

i. Letters from D.J. Wrona, NRC, to Chief 21 Gregory E. Pike, Choctaw Nation of Oklahoma; The Honorable Phyliss Anderson, Chief, 22 Mississippi Band of Choctaw Indians; Chairman Earl J. Barbry Jr., Tunica

-Biloxi Tribe of 23 Louisiana; and Principal Chief B. Cheryl Smith, Jena Band of Choctaw Indians.

Subject:

24 Request for Scoping Comments Concerning the Grand Gulf Nuclear Station, Unit 1, License 25 Renewal Application Review. January 19, 2012. ADAMS Accession No. ML11342A121. 26 [NRC] U.S. Nuclear Regulatory Commission. 2012

j. Letter from A. B. Wa ng, NRC, to Vice 27 President, Operations, Entergy Operations, Inc.,

Subject:

Grand Gulf Nuclear Station, Unit 1 -28 Issuance of Amendment RE: Extended Power Uprage. J ul y 18, 2012 (TAC No. ME4679) 29 ADAMS Accession No. ML121 210020. 30 [NRC] U.S. Nuclear Regulatory Commission. 2013a. Generic Environmental Impact Statement 31 for License Renewal of Nuclear Plants. Washington, DC: Office of Nuclear Reactor Regulation. 32 NUREG-1437, Revision 1, Volumes 1, 2, and 3. June 2013. ADAMS Accession Nos. 33 ML13106A241, ML13106A242, and ML13106A244. [NRC] U.S. Nuclear Regulatory 34 Commission. 2013b. Standard Review Plans for Environmental Reviews for Nuclear Power 35 Plants, Supplement 1: Operating License Renewal. Washington, D.C .: Office of Nuclear Reactor 36 Regulation. NUREG-1555, Supplement 1, Revision 1. June 2013. ADAMS Accession No. 37 ML13106A246. 38 of coastal 39 waters. ICES Journal of Marine Science, 66:1528 -1537. 40 [USCB] U.S. Census Bureau. 2012. American FactFinder, 2010 American Community Survey 41 and Data Profile Highlights Information on Mississippi Counties: Adams, Amite, Claiborne, 42 Copiah, Franklin, Hinds, Issaquena, Jefferson, Lincoln, Madison, Rankin, Sharkey, Simpson, 43 Warren, Wilkinson, Yazoo; and Louisiana Counties: Caldwell, Catahoula, Concordia, East 44 Carroll, Franklin, Madison, Richland, Tensas. Available at <http://factfinder.census.gov > and 45 <http://quickfacts.census.gov > (accessed April 2012). 46 Environmental Impacts of Operation 4-50 [USFS] U.S. Forest Service. 2003. Decision Notice and Finding of No Significant Impact: Utility 1 Corridor Maintenance for Wildlife Habitat Enhancement. September 2003. 139 p. Meadville, 2 MS: USFS Southern Region 8. ADAMS Accession No. ML12157A550. 3 [USGCRP] U.S. Global Change Research Program. 2009. Global Climate Change Impacts in 4 the United States. Karl TR, Melillo JM, Peterson TC, eds. Cambridge University Press: 5 New York, NY. Available at <http://library.globalchange.gov/products/assessments/2009 -6 national-climate-assessment/2009 -global-climate-change-impacts-in-the-united-states> 7 (accessed 11 May 2012). 8 [USGS] U.S. Geological Survey. 2001. "Mississippi Valley Loess Plains." Available at 9 <http://landcovertrends.usgs.gov/east/eco74Report.html > (accessed 13 June 2012). 10 5-1 5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS 1 This chapter describes environmental impacts from postulated accidents that might occur during 2 the period of extended operation. The term "accident" refers to any unintentional event outside 3 the normal plant operational envelope that results in a release or the potential for release of 4 radioactive materials into the environment. Two classes of postulated accidents are evaluated 5 in NUREG-1437 , Generic Environmental Impact Statement (GEIS) for License Renewal of 6 Nuclear Plants (NRC 1996). These are design -basis accidents (DBAs) and severe accidents. 7 5.1 Design-Basis Accidents 8 To receive U.S. Nuclear Regulatory Commission (NRC) approval to operate a nuclear power 9 facility, an applicant for an initial operating license must submit a safety analysis report (SAR) as 10 part of its application. The SAR presents the design criteria and design information for the 11 proposed reactor and comprehensive data on the proposed site. The SAR also discusses 12 various hypothetical accident situations and the safety features that are provided to prevent and 13 mitigate accidents. The NRC staff reviews the application to determine whether the plant 14 design meets the Commission's regulations and requirements and includes, in part, the nuclear 15 plant design and its anticipated response to an accident. 16 DBAs are those accidents that both the licensee and NRC staff evaluate to ensure that the plant 17 can withstand normal and abnormal transients and a broad spectrum of postulated accidents 18 without undue hazard to the health and safety of the public. A number of these postulated 19 accidents are not expected to occur during the life of the plant, but are evaluated to establish 20 the design basis for the preventive and mitigative safety systems of the facility. The acceptance 21 criteria for DBAs are described i n Title 10 of the Code of Federal Regulations (10 CFR) Part 50, 22 "Domestic Licensing of Production and Utilization Facilities," and 10 CFR Part 100, "Reactor 23 Site Criteria." 24 The environmental impacts of DBAs are evaluated during the initial licensing process, and the 25 ability of the plant to withstand these accidents is demonstrated to be acceptable before 26 issuance of the operating license. The results of these evaluations are found in licensee 27 documentation, such as the applicant's final safety analysis report, the safety evaluation report, 28 the final environmental statement, and Section 5.1 of this supplemental environmental impact 29 statement. A licensee is required to maintain the acceptable design and performance criteria 30 throughout the life of the plant, including any extended -life operation. The consequences for 31 these events are evaluated for the hypothetical maximum exposed individual; as such, changes 32 in the plant environment will not affect these evaluations. Because of the requirements that 33 continuous acceptability of the consequences and aging management programs be in effect for 34 the period of extended operation, the environmental impacts, as calculated for DBAs, should not 35 differ significantly from initial licensing assessments over the life of the plant, including the 36 period of extended operation. Accordingly, the design of the plant relative to DBAs during the 37 period of extended operation is considered to remain acceptable, and the environmental 38 impacts of those accidents were not examined further in the GEIS. 39 The Commission has determined that the environmental impacts of DBAs are of SMALL 40 significance for all plants because the plants were designed to successfully withstand these 41 accidents. Therefore, for the purposes of license renewal, DBAs are designated as a 42 Category 1 issue (Table 5-1). The early resolution of the DBAs makes them a part of the 43 current licensing basis of the plant; the current licensing basis of the plant is to be maintained by 44 Environmental Impacts of Postulated Accidents 5-2 the licensee under its current license and, therefore, under the provisions of 10 CFR 54.30, 1 "Matters Not Subject to Renewal Review," is not subject to review under license renewal. 2 Table 5-1. Issues Related to Postulated Accidents 3 Issue Category Design-basis accidents 1 Severe accidents 2 Two issues related to postulated accidents are evaluated under the National Environmental Policy A ct in the license renewal review, design -basis accidents, and severe accidents . No new and significant information related to DBAs was identified during the review of the 4 Entergy Operations, Inc., (Entergy) Environmental Report (ER) (Enter gy 2011) or evaluation of 5 other available information. Therefore, there are no impacts related to these issues beyond 6 those discussed in the GEIS. 7 5.2 Severe Accidents 8 Severe nuclear accidents are those that are more severe than DBAs because they could 9 result in substantial damage to the reactor core, whether or not there are serious offsite 10 con sequences. In the GEIS, the NRC staff assessed the impacts of severe accidents during the 11 license renewal period, using the results of existing analyses and site -specific information to 12 conservatively predict the environmental impacts of severe accidents for each plant during the 13 renewal period. 14 Severe accidents initiated by external phenomena such as tornadoes, floods, earthquakes, 15 fires, and sabotage have not traditionally been discussed in quantitative terms in final 16 environmental statements and were not specifically considered for the Grand Gulf Nuclear 17 Station (GGNS) site in the GEIS (NRC 1996). However, the GEIS did evaluate existing impact 18 assessments performed by the NRC and by the industry at 44 nuclear plants in the 19 United States and concluded that the risk from beyond -design-basis earthquakes at existing 20 nuclear power plants is SMALL. The GEIS for license renewal performed a discretionary 21 analysis of terrorist acts in connection with license renewal and concluded that the core damage 22 and radiological release from such acts would be no worse than the damage and release 23 expected from internally initiated events. In the GEIS, the Commission concludes that the 24 probability -weighted consequences of severe accidents are SMALL and, additionally, that the 25 risks from other external events are adequately addressed by a generic consideration of 26 internally initiated severe accidents (NRC 1996). 27 Based on information in the GEIS, the Commission found that 28 The probability -weighted consequences of atmospheric releases, fallout onto 29 open bodies of water, releases to ground water, and societal and economic 30 impacts from severe accidents are small for all plants. However, alternatives to 31 mitigate severe accidents must be considered for all plants that have not 32 considered such alternatives. 33 The NRC staff identified no new and significant information related to postulated accidents 34 during the review of Entergy's ER (Entergy 2011, 2012c) or evaluation of other available 35 information. Therefore, there are no impacts related to these issues beyond those discussed in 36 the GEIS. However, in accordance with 10 CFR 51.53(c)(3)(ii)(L), the NRC staff has reviewed 37 Environmental Impacts of Postulated Accidents 5-3 severe accident mitigation alternative s (SAMAs) for GGNS. The results of the review are 1 discussed in Section 5.3. 2 5.3 Severe Accident Mitigation Alternatives 3 If the NRC staff has not previously evaluated SAMAs for the applicant's plant in an 4 environmental impact statement (EIS) or related supplement or in an environmental 5 assessment, 10 CFR 51.53(c)(3)(ii)(L) requires that license renewal applicants consider 6 alternatives to mitigate severe accidents. The purpose of this consideration is to ensure that 7 plant changes (i.e., hardware, procedures, and training) with the potential for improving severe 8 accident safety performance are identified and evaluated. SAMAs have not previously been 9 considered for GGNS; therefore, the remainder of Chapter 5 addresses those alternatives. 10 5.3.1 Overview of SAMA Process 11 This section presents a summary of the results of the SAMA evaluation for GGNS conducted by 12 Entergy, as described in Attachment E of Entergy's ER (Entergy 201 1, 2012c), the NRC staff's 13 review of Entergy's SAMA evaluation provided in detail in Appendix F, and associated requests 14 for additional information (RAIs) issued by the NRC staff and responses from Entergy 15 (Entergy 2012a, 2012b, 2012c, 2012d). The NRC staff performed its review with contract 16 assistance from the Center for Nuclear Waste Regulatory Analyses. 17 The SAMA evaluation for GGNS was conducted with a four -step approach. In the first step, 18 Entergy quantified the level of risk associated with potential reactor accidents using the 19 plant-specific probabilistic risk assessment (PRA) and other risk models. 20 In the second step, Entergy examined the major risk contributors and identified possible ways 21 (SAMAs) of reducing that risk. Common ways of reducing risk are changes to components, 22 systems, procedures, and training. 23 In the third step, Entergy estimated the benefits and the costs associated with each of the 24 candidate SAMAs. Estimates were made of how much each SAMA could reduce risk. Those 25 estimates were developed in terms of dollars in accordance with NRC guidance for performing 26 regulatory analyses. The cost s of implementing the candidate SAMAs also were estimated. 27 In the fourth step , Entergy compared the cost and benefit of each of the remaining SAMAs t o 28 determine whether the SAMA was cost-beneficial, meaning the benefits of the SAMA were 29 greater than the cost (a positive cost -benefit ratio). Finally, the four potentially cost -beneficial 30 SAMAs are evaluated to determine if they are in the scope of license renewal, i.e., are they 31 subject to aging management. 32 5.3.2 Estimate of Risk 33 Entergy submitted an assessment of SAMAs for the GGNS as part of the ER 34 (Entergy 2011, 2012c). The assessments were based on the most recent GGNS PRA available 35 at that time, a plant -specific offsite consequence analysis performed using the MELCOR 36 Accident Consequence Code System 2 (MACCS2) computer code, and insights from the GGNS 37 individual plant examination (IPE) (Entergy 1992) and individual plant examination of external 38 events (IPEEE) (Entergy 1995). 39 Entergy combined two distinct analyses to form the basis for the risk estimates used in the 40 SAMA analysis: (1) the GGNS Level 1 and 2 PRA model, and (2) a supplemental analysis of 41 offsite consequences and economic impacts (essentially a Level 3 PRA model) developed 42 specifically for the SAMA analysis. The SAMA analysis is based on the most recent GGNS 43 Environmental Impacts of Postulated Accidents 5-4 Level 1 and Level 2 PRA model available at the time of the ER, referred to as the 2010 1 extended power uprate (EPU) model. 2 The GGNS core damage frequency (CDF) is approximately 2.9 x 106 per reactor year as 3 determined from quantification of the Level 1 PRA model with the revised Level 2 model. This 4 value was used as the baseline CDF in the SAMA evaluations (Entergy 2012c, 2012d). The 5 CDF is based on the risk assessment for internally initiated events, which includes internal 6 flooding. Entergy did not explicitly include the contribution from external events within the 7 GGNS risk estimates; however, it did account for external event impacts on the potential risk 8 reduction associated with SAMA implementation by multiplying the estimated risk reduction for 9 internal events by a factor of

11. This is discussed further in Sections F.2.2 and F.6.2. Using 10 the calculated risk reduction as a quantitative measure of the potential benefit from SAMA 11 implementation, Entergy performed a cost

-benefit comparison, as described in Section 5.3.5. 12 The breakdown of CDF by initiating event is provided in Table 5-2. As shown in this table, loss 13 of offsite power and power conversion system available transient are the dominant contributors 14 to the CDF. Not listed explicitly in Table 5 -2 because multiple initiators contribute to their 15 occurrence, station blackout s contribute about 37 percent (1.1 x 106 per reactor year) of the 16 total CDF, while anticipated transients without scram contribute about 0.2 percent 17 (4.4 x 109 per reactor year) to the total CDF (Entergy 2012c). 18 The Level 2 PRA model that forms the basis for the GGNS SAMA evaluation is essentially a 19 new model and reflects power uprate conditions. The Level 2 model uses containment event 20 trees (CETs) containing both phenomenological and systemic events. The Level 1 core 21 damage sequences are binned into accident classes (or plant damage states) that provide the 22 interface between the Level 1 and Level 2 CET analysis. The CETs are linked directly to the 23 Level 1 event trees, and CET nodes are evaluated using subordinate trees and logic rules. 24 Table 5-2. GGNS Core Damage Frequency (CDF) for Internal Events 25 Initiating Event CDF (per year)

% CDF Contribution Loss of Offsite Power Initiator 1.2 x 106 40 Power Conversion System Available Transient 5.9 x 107 20 Loss of Power Conversion System Initiator 2.5 x 107 8 Loss of Condensate Feed Water Pumps 2.3 x 107 8 Loss of Instrument Air 1.4 x 107 5 Closure of Main Steam Isolation Valves (Initiator) 1.2 x 107 4 Loss of Service Transformer 21 1.2 x 107 4 Large Loss of Coolant Accident (LOCA) 9.7 x 108 3 Loss of Service Transformer 11 8.3 x 108 3 Loss of Alternating Current Division 2 Initiator 6.2 x 108 2 Other Initiating Events1 3.3 x 108 1 Loss of Alternating Current Division 1 Initiator 2.7 x 108 1 Intermediate LOCA 1.4 x 108 1 Total CDF (Internal Events) 2.9 x 106 100 1 Multiple initiating events, with each contributing 

0.3 percent

or less Environmental Impacts of Postulated Accidents 5-5 The CET considers the influence of physical and chemical processes on the integrity of the 1 containment and on the release of fission products once core damage has occurred. The 2 quantified CET sequences are binned into a set of end states that are subsequently grouped 3 into 13 release categories (or release modes) that provide the input to the Level 3 4 consequence analysis. The frequency of each release category was obtained by summing the 5 frequency of the individual accident progression CET endpoints binned into the release 6 category. Source terms were developed for the release categories using the results of Modular 7 Accident Analysis Program (MAAP 4.0.6) computer code calculations. From these results, 8 source terms were chosen to be representative of the release categories. The results of this 9 analysis for GGNS are provided in the revised Table E.1-9 of ER Attachment E (Entergy 2012c). 10 Entergy computed offsite consequences for potential releases of radiological material using the 11 MACCS2 Version 1.13.1 code and analyzed exposure and economic impacts from its 12 determination of offsite and onsite risks. Inputs for these analyses include plant -specific and 13 site-specific input values for core radionuclide inventory, source term and release 14 characteristics, site meteorological data, projected population distribution and growth within a 15 50-mile (80-kilometer) radius, emergency response evacuation modeling, and local economic 16 data. Radionuclide inventory in the reactor core is based on a plant -specific evaluation and 17 corresponds to that for the extended power uprate to 4,408 megawatts thermal (Entergy 2011). 18 The estimation of onsite impacts (in terms of clean up and decontamination costs and 19 occupational dose) is based on guidance in NUREG/BR -0184 , Regulatory Analysis Technical 20 Evaluation Handbook (NRC 1997). 21 In the ER, the applicant estimated the dose risk to the population within 80 kilometers (50 miles) 22 of the GGNS site to be 0.00609 person-sieverts (Sv) per year (0.609 person-roentgen 23 equivalent in man (rem) per year) (Entergy 2012c). The breakdown of the population dose risk 24 and offsite economic cost risk by containment release mode is summarized in Table 5-3. 25 Medium releases provide the greatest contribution, totaling approximately 67 percent of the 26 population dose risk and 75 percent of the offsite economic cost risk for all timings. High early 27 (H/E) releases alone contribute only about 10 percent, and high releases for all timings 28 contribute 17 percent of the population dose risk. 29 The NRC staff has reviewed Entergy's data and evaluation methods and concludes that the 30 quality of the risk analyses is adequate to support an assessment of the risk reduction potential 31 for candidate SAMAs. Accordingly, the NRC staff based its assessment of offsite risk on the 32 CDFs and offsite doses reported by Entergy. 33 5.3.3 Potential Plant Improvements 34 Entergy's process for identifying potential plant improvements (SAMAs) consisted of the 35 following elements: 36 review of industry documents and consideration of other plant-specific 37 enhancements not identified in published industry documents 38 review of potential plant improvements identified in the GGNS IPE and IPEEE 39 review of potential modifications for the risk-significant events in the current 40 GGNS PRA Levels 1 and 2 models 41 Environmental Impacts of Postulated Accidents 5-6 Table 5-3. Base Case Mean Population Dose Risk and Offsite Economic Cost Risk 1 for Internal Events 2 Release Mode Population Dose Risk 1 Offsite Economic Cost Risk ID 2 Frequency (per year) person-rem/yr % Contribution

$/yr % Contribution H/E 1.0 x 107 6.2 x 102 10 1.7 x 10+2 11 H/I 1.2 x 108 6.2 x 103 1 1.7 x 10+1 1 H/L 9.2 x 108 3.8 x 102 6 9.6 x 10+1 6 M/E 3.7 x 107 1.7 x 101 28 4.8 x 10+2 32 M/I 1.8 x 107 1.2 x 101 20 3.3 x 10+2 22 M/L 3.0 x 107 1.2 x 101 19 3.2 x 10+2 21 L/E 4.1 x 109 4.0 x 104 <0.1 3.0 x 101 <0.1 L/I 3.6 x 108 1.2 x 102 2 2.7 x 10+1 2 L/L 4.4 x 107 7.8 x 102 13 7.4 x 10+1 5 LL/E 2.2 x 109 7.9 x 107 <0.1 1.0 x 103 <0.1 LL/I 2.1 x 109 3.8 x 107 <0.1 9.7 x 104 <0.1 LL/L 7.1 x 109 2.0 x 103 <1  3.4 x 10 <1 NCF 1.4 x 106 5.0 x 104 <0.1 6.4 x 101 <0.1   6.1 x 101 100 1.5 x 10+3 100  1 Unit Conversion Factor:  1 Sv = 100 rem 2 Release Mode Nomenclature (Magnitude/Timing)

Magnitude: High (H) - Greater than 10 percent release fraction for Cesium Iodide Medium (M) - 1 to 10 percent release fraction for Cesium Iodide Low (L) - 0.1 to 1 percent release fraction for Cesium Iodide Low-low (LL) - Less than 0.1 percent release fraction for Cesium Iodide No containment failure (NCF) - Much less than 0.1 percent release fraction for Cesium Iodide Timing: Early (E) - Less than 4 hours Intermediate (I) - 4 to 24 hours Late (L) - Greater than 24 hours Based on this process, Entergy identified an initial set of 249 candidate SAMAs, referred to as 3 Phase I SAMAs. In Phase I of the evaluation, Entergy performed a qualitative screening of 4 the initial list of SAMAs and eliminated SAMAs from further consideration using the 5 following criteria: 6 t he SAMA modified features not applicable to GGNS. 7 the SAMA has already been implemented at GGNS. 8 the SAMA is similar in nature and could be combined with another SAMA 9 candidate. 10 Environmental Impacts of Postulated Accidents 5-7 Based on this screening, 60 of the Phase I SAMA candidates were screened out because they 1 were not applicable to GGNS, 98 candidates were screened out because they had already been 2 implemented at GGNS, and 28 candidates were screened out because they were similar in 3 nature and could be combined with another SAMA candidate. Thus, a total of 186 SAMAs were 4 eliminated, leaving 63 SAMAs for further evaluation. The results of the Phase I screening 5 analysis for each SAMA candidate were provided in a response to an NRC staff RAI 6 (Entergy 2012 a). The remaining SAMAs, referred to as Phase II SAMAs, are listed in 7 Table E.2-2 of Attachment E to the ER in the original submittal (Entergy 2011) and in the 8 revised analysis (Entergy 2012c). In Phase II, a detailed evaluation was performed for each of 9 t he 63 remaining SAMA candidates. 10 The NRC staff concludes that Entergy used a systematic and comprehensive process for 11 identifying potential plant improvements for GGNS, and that the set of SAMAs evaluated in the 12 ER, together with those evaluated in response to NRC staff inquiries, is reasonably 13 comprehensive and, therefore, acceptable. This search included reviewing insights from the 14 GGNS plant -specific risk studies that included internal initiating events, as well as fire, seismic, 15 and other external initiated events, and reviewing plant improvements considered in previous 16 SAMA analyses. 17 5.3.4 Evaluation of Risk Reduction and Costs of Improvements 18 In the ER, the applicant evaluated the risk -reduction potential of the 63 SAMAs that were not 19 screened out in the Phase I analysis and retained for the Phase II evaluation. The SAMA 20 evaluations were performed using generally conservative assumptions. 21 Except for two SAMAs associated with internal fires, Entergy used model re -quantification to 22 determine the potential benefits for each SAMA. The CDF, population dose, and offsite 23 economic cost reductions were estimated using the GGNS 2010 EPU PRA model for the nonfire 24 SAMAs. The changes made to the model to quantify the impact of SAMAs are detailed in 25 Section E.2.3 of Attachment E to the ER (Entergy 2011). Bounding evaluations (or analysis 26 cases) were performed to address specific SAMA candidates or groups of similar SAMA 27 candidates. For the two fire -related SAMAs (SAMA Nos. 54 and 55), the benefit was 28 determined by assuming the CDF contribution for the fire area impacted by the SAMA was 29 reduced to zero and that the resulting benefit was determined by the product of the fraction of 30 the internal events total CDF represented by the fire area CDF and the maximum total internal 31 events benefit. 32 For the SAMAs determined to be potentially cost -beneficial, Table 5-4 lists the assumptions 33 considered to estimate the risk reduction, the estimated risk reduction in terms of percent 34 reduction in CDF, population dose risk and offsite economic cost risk, and the estimated total 35 benefit (present value) of the averted risk. The estimated benefits reported in Table 5-4 reflect 36 the combined benefit in both internal and external events. The determination of the benefits for 37 the various SAMAs is further discussed in Section F.6. 38 Entergy estimated the costs of implementing the 63 Phase II SAMAs through the use of other 39 licensees' estimates for similar improvements and the development of site -specific cost 40 estimates, where appropriate. Information on the assumptions, risk reduction, estimated total 41 benefit, and implementation costs for the 63 Phase II SAMAs is presented in Table F-5. 42 Environmental Impacts of Postulated Accidents 5-8 Table 5-4. Severe Accident Mitigation Alternatives Cost -Benefit Analysis for GGNS. Percentage Risk Reductions are 1 Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) 2 Analysis Case, Analysis Assumption, Individual SAMA, and Cost Estimate

% Risk Reduction CDF PDR OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 28. Increase Availability of Containment Heat Removal Assumption:  Eliminates failure of cooled flow from residual heat removal pump A and B SAMA No. 39-Procedural change to cross

-tie open cycle cooling system to enhance containment spray system

$25,000  17.8% 45.6% 50.2% $2 97 ,000 $8 92 ,000 Case 30. Increase Availability of the Condensate Storage Tank Assumption:  Eliminates failure of high pressure core spray and reactor  core isolation cooling suction SAMA No. 42-Enhance procedures to refill condensate storage tank from demineralized water or service water system
$200,000  4.4% 12.6% 13.5% $77,000 $231,000 Case 43. Increase Recovery Time of Emergency Core Cooling System Upon Loss of Standby Service Water Assumption:  Eliminates failure of standby service water to the low pressure core spray room cooler SAMA No. 59-Increase operator training for alternating operation of the low

-pressure emergency core cooling system pumps (low-pressure coolant injection and low -pressure core spray) for loss of standby service water scenarios

$50,000  4.5% 5.2% 5.5% $53,300 $1 60 ,000 Environmental Impacts of Postulated Accidents 5-9 Analysis Case, Analysis Assumption, Individual SAMA, and Cost Estimate
% Risk Reduction CDF PDR OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 22. Increase Availability of the Diesel Generator System through Heating, Ventilation, and Air Conditioning Improvements Assumption:  Eliminates failure of heating, ventilation, and air conditioning for diesel generator rooms SAMA (Unnumbered) in Response to Request for Additional Information No.

8a-Revise procedures to direct the operator monitoring a running diesel generator to ensure that the ventilation system is running or take action to open doors or use portable fans

$50,000 to $200,000  23.9% 16.6% 12.3% $237,000 $711,000 Environmental Impacts of Postulated Accidents 5-10 Entergy stated the following cost ranges were used based on the review of previous 1 SAMA applications.

2 Table 5-5. Estimated Cost Ranges for SAMA Applications 3 Type of Change Estimated Cost Range Procedural only

$25K to $50K Procedural change with engineering or training required
$50K to $200K Procedural change with engineering and testing or training required $200K to $300K Hardware modification
$100K to >$1,000K Source:  Entergy 2011 Entergy stated that the GGNS site

-specific cost estimates were based on the engineering 4 judgment of project engineers experienced in performing design changes at the facility. The 5 detailed cost estimates considered engineering, labor, materials, and support functions, such as 6 planning, scheduling, health physics, quality assurance, security, safety, and fire watch. T he 7 estimates included a 20 percent contingency on the design and installation costs but did not 8 account for inflation, replacement power during extended outages necessary for SAMA 9 implementation, or increased maintenance or operation costs following SAMA implementation. 10 In response to an NRC staff RAI concerning the applicability of cost estimates taken directly 11 from previous SAMA applications, Entergy stated that engineering judgment by project 12 engineers familiar with the costs of modifications at Entergy plants was used to determine if the 13 cited cost estimates from other SAMA analyses were valid for GGNS. If the GGNS project 14 engineers' rough conceptual cost estimate of the modification was larger than the other plant's 15 cost estimate, the other plant's estimate was adopted without further detailed cost analysis 16 (Entergy 2012a). 17 The NRC staff reviewed the applicant's cost estimates, presented in Table E.2-2 of 18 Attachment E to the ER in the original submittal (Entergy 2011) and as a response to NRC staff 19 RAIs (Entergy 2012a, 2012c). For certain improvements, the NRC staff also compared the cost 20 estimates to estimates developed elsewhere for similar improvements, including estimates 21 developed as part of other licensees' analyses of SAMAs for operating reactors. The NRC staff 22 concludes that, with the above clarifications, the cost estimates provided by Entergy are 23 sufficient and appropriate for use in the SAMA evaluation. 24 5.3.5 Cost-Benefit Comparison 25 If the implementation costs for a candidate SAMA exceeded the calculated benefit, the SAMA 26 was determined to be not cost -beneficial. If the benefit exceeded the estimated cost, the SAMA 27 candidate was considered to be cost -beneficial. In Entergy's original submittal and revised 28 analysis, three SAMA candidates were found to be potentially cost -beneficial 29 (Entergy 2011, 2012c). In response to an RAI by NRC staff concerning potential low-cost 30 alternatives, Entergy determined that a procedure revision to direct that the operator monitoring 31 a running diesel ensure the ventilation system is running, or take action to open doors, or use 32 portable fans would be potentially cost-beneficial (Entergy 2012a, 2012c). Results of the 33 cost-benefit evaluation are presented in Table 5-4 for the four potentially cost -beneficial 34 Environmental Impacts of Postulated Accidents 5-11 SAMAs. Entergy initiated a condition report to evaluate these potentially cost -beneficial SAMAs 1 within the corrective action process. 2 The potentially cost -beneficial SAMAs are: 3 SAMA No. 39-Change procedure to cross tie open cycle cooling system to 4 enhance containment spray system. 5 SAMA No. 42-Enhance procedures to refill condensate storage tank from 6 demineralized water or service water system. 7 SAMA No. 59-Increase operator training for alternating operation of the low 8 pressure emergency core cooling system pumps (low -pressure coolant 9 injection and low pressure core spray) for loss of standby service water 10 scenarios. 11 SAMA (Unnumbered) in Response to RAI No. 8a-Revise procedures to 12 direct the operator monitoring a running diesel generator to ensure that the 13 ventilation system is running or take action to open doors or use portable 14 fans. 15 A sensitivity analysis considered two cases: a discount rate of 7 percent with a 33-year period 16 for remaining plant life and a lower (i.e., more conservative) discount rate of 3 percent with a 17 20-year license renewal period (Entergy 2011). Based on its sensitivity analysis, Entergy did 18 not identify any additional cost -beneficial SAMAs. Sensitivity analysis results were recast in the 19 revised SAMA analysis (Entergy 2012c). In response to an NRC RAI on the unexpected large 20 increase in the sensitivity to the discount rate shown in the revised results, Entergy described 21 that the sensitivity calculation for the lower discount rate of 3 percent inadvertently included the 22 cumulative effect of both the longer time period of remaining plant life of 33 years and the lower 23 discount rate (Entergy 2012d). Without the additional effect from a longer time period, 24 increases in the benefit solely because of a lower discount rate would be smaller than those 25 results reported by Entergy (2012c). 26 Individual (as well as cumulative) increases in the estimated benefits from the sensitivity 27 parameters were smaller than the factor of 3 applied by the applicant to account for uncertainty. 28 In the revised analysis, neither individual nor cumulative sensitivity effects resulted in benefit 29 estimates for individual SAMAs that exceeded GGNS implementation costs beyond the SAMAs 30 previously identified by Entergy to be potentially cost -beneficial. Based primarily on 31 NUREG/BR-0184 (NRC 1997) and discount rate guidelines in NEI 05-01 (NEI 2005), t he 32 cost-benefit analysis performed by Entergy was consistent with the guidance. The applicant 33 considered possible increases in benefits from analysis uncertainties on the results of the SAMA 34 assessment. In the ER (Entergy 2011), Entergy stated that the 95 th percentile value of the 35 GGNS CDF was a factor of 2.38 greater than the mean CDF. A multiplication factor of 3 was 36 selected by the applicant to account for uncertainty. This multiplication factor was applied in 37 addition to a separate multiplication factor of 11 for CDF increases caused by external events. 38 Entergy's assessment accounted for the potential risk -reduction benefits associated with both 39 internal and external events. NRC staff considers the multipliers of 3 for uncertainty and 11 for 40 external events provide adequate margin and are acceptable for the SAMA analysis. 41 5.3.6 Conclusions 42 Entergy considered 249 candidate SAMAs based on risk -significant contributors at GGNS from 43 updated probabilistic safety assessment models, its review of SAMA analyses from other 44 boiling-water reactor (BWR) plants, NRC and industry documentation of potential plant 45 Environmental Impacts of Postulated Accidents 5-12 improvements, and GGNS individual plant examination of internal and external events, including 1 available updates. Phase I screening reduced the list to 63 unique SAMA candidates by 2 eliminating SAMAs that were not applicable to GGNS, had already been implemented at GGNS, 3 or were combined into a more comprehensive or plant -specific SAMA. 4 For the remaining SAMA candidates, Entergy performed a cost -benefit analysis. Entergy's 5 cost-benefit analysis identified three potentially cost-beneficial SAMAs (Phase II SAMA 6 Nos. 39, 42, and 59). In response to an NRC staff RAI concerning potential low-cost 7 alternatives, Entergy identified one additional cost -beneficial SAMA. Sensitivity cases were 8 analyzed for the present value discount rate and time period for remaining plant life. No 9 additional SAMAs were identified as potentially cost -beneficial from the sensitivity analysis. 10 NRC staff reviewed the Entergy SAMA analysis and concludes that, subject to the discussion in 11 this chapter and Appendix F, the methods used and implementation of the methods were 12 sound. On the basis of the applicant's treatment of SAMA benefits and costs, NRC staff finds 13 that the SAMA evaluations performed by Entergy are reasonable and sufficient for the license 14 renewal submittal. 15 The NRC staff agrees with Entergy's conclusion that four candidate SAMAs are potentially 16 cost-beneficial, a decision based on a reasonable treatment of costs, benefits, and 17 uncertainties. This conclusion of a small number of potentially cost -beneficial SAMAs is 18 consistent with the low residual level of risk stated in the GGNS PRA and the fact that Entergy 19 has already implemented the plant improvements identified from the IPE and IPEEE. 20 Finally, the four potentially cost -beneficial SAMAs are evaluated to determine if they are in the 21 scope of license renewal, i.e., are they subject to aging management. This evaluation considers 22 whether the systems, structures, and components (SSCs) associated with these SAMAs: 23 (1) perform their intended function without moving parts or without a change in configuration or 24 properties; and (2) that these SSCs are not subject to replacement based on qualified life or 25 specified time period. Because the potentially cost -beneficial SAMAs do not relate to aging 26 management during the period of extended operation, they do not need to be implemented as 27 part of license renewal in accordance with 10 CFR Part 54. Nevertheless, Entergy issued a 28 condition report under the corrective action process to evaluate these potentially cost -beneficial 29 SAMAs. The NRC staff accepts this course of action. 30 5.4 References 31 [Entergy] Entergy Operations, Inc. 1992. "Individual Plant Examination (IPE) for Grand Gulf 32 Nuclear Station Unit 1." December 1992. 33 [Entergy] Entergy Operations, Inc. 1995. Letter from M.J. Meisner, Entergy, to U.S. NRC 34 Document Control Desk.

Subject:

"Grand Gulf Nuclear Station Docket No.

50-416 License 35 No. NPF-29 Individual Plant Examination of External Events (IPEEE) Schedule Final 36 Submittal." November 15, 1995 (not publicly available). 37 [Entergy] Entergy Operations, Inc. 2011. Grand Gulf Nuclear Station, Unit 1, License Renewal 38 Application , Appendix E, Applicant's Environmental Report, Operating License Renewal Stage . 39 Agencywide Documents Access and Management System (ADAMS) Accession 40 No. ML11308A234. 41 [Entergy] Entergy Operations, Inc. 2012a. Letter from Michael Perito, Entergy, to U.S. Nuclear 42 Regulatory Commission Document Control Desk.

Subject:

"Response to Request for Additional 43 Information (RAI) on Severe Accident Mitigation Alternatives dated May 21, 2012, Grand Gulf 44 Environmental Impacts of Postulated Accidents 5-13 Nuclear Station, Unit 1, Docket No. 50-416, License No. NPF -29." Port Gibson, MS. 1 July 19, 2012. Accessible at ADAMS Accession No. ML12202A056. 2 [Entergy] Entergy Operations, Inc. 2012b. Letter from Michael Perito, Entergy, to U.S. Nuclear 3 Regulatory Commission Document Control Desk.

Subject:

"Response to Request for Additional 4 Information (RAI) on Severe Accident Mitigation Alternatives dated August 23, 2012, Grand Gulf 5 Nuclear Station, Unit 1, Docket No. 50

-416, License No. NPF-29." Port Gibson, MS. 6 October 2, 2012. Accessible at ADAMS Accession No. ML12277A082. 7 [Entergy] Entergy Operations, Inc. 2012c. Letter from Michael Perito, Entergy, to U.S. Nuclear 8 Regulatory Commission Document Control Desk.

Subject:

"Reanalysis of Severe Accident 9 Mitigation Alternatives, Grand Gulf Nuclear Station, Unit 1, Docket No.

50-416, License 10 No. NPF-29." Port Gibson, MS. November 19, 2012. Accessible at ADAMS Accession 11 No. ML12325A174. 12 [Entergy] Entergy Operations, Inc. 2012d. Letter from Kevin J. Mulligan, Entergy, to 13 U.S. Nuclear Regulatory Commission Document Control Desk.

Subject:

"Response to 14 Clarification Questions on Reanalysis of Severe Accident Mitigation Alternatives (SAMA) Letter 15 dated November 19, 2012, Grand Gulf Nuclear Station, Unit 1, Docket No. 50-416, License 16 No. NPF-29." Port Gibson, MS. December 19, 2012. ADAMS Accession No. ML12359A038. 17 [NEI]Nuclear Energy Institute. 2005. "Severe Accident Mitigation Alternative (SAMA) Analysis 18 Guidance Document." NEI 05 -01, Revision A. Washington, DC. November 2005. 19 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 20 for License Renewal of Nuclear Plants. NUREG-1437, Washington, DC. Accessible at 21 <http://www.nrc.gov/reading -rm/doc-collections/nuregs/staff/sr1437/> (accessed 22 August 29, 2012). 23 [NRC] U.S. Nuclear Regulatory Commission. 1997. Regulatory Analysis Technical Evaluation 24 Handbook. NUREG/BR -0184. Washington, DC. ADAMS No. ML050190193. 25

6-1 6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE, 1 SOLID WASTE MANAGEMENT, AND GREENHOUSE GAS EMISSIONS 2 6.1 The Uranium Fuel Cycle 3 This section addresses issues related to the uranium fuel cycle and solid waste management 4 during the period of extended operation (listed in Table 6-1). The uranium cycle includes 5 uranium mining and milling, the production of uranium hexafluoride, isotopic enrichment, fuel 6 fabrication, reprocessing of irradiated fuel, transportation of radioactive materials an d 7 management of low -level wastes and high -level wastes related to uranium fuel cycle activities. 8 The generic potential impacts of the radiological and non -radiological environmental impacts of 9 the uranium fuel cycle and transportation of nuclear fuel and wastes are described in detail in 10 the Generic Environmental Impact Statement (GEIS) (NRC 1996, 1999). They are based, in 11 part, on the generic impacts provided in Title 10, Part 51.51(b) of the Code of Federal 12 Regulations (10 CFR 51.51(b)), Table S-3, "Table of Uranium Fuel Cycle Environmental Data," 13 and in 10 CFR 51.52(c), Table S-4, "Environmental Impact of Transportation of Fuel and Waste 14 to and from One Light-Water-Cooled Nuclear Power Reactor." 15 Table 6-1. Issues Related to the Uranium Fuel Cycle and Solid Waste Management. 16 There are nine generic issues related to the fuel cycle and waste management. There are no 17 site-specific issues. 18 Issues GEIS Sections Category Offsite radiological impacts (individual effects from other than the disposal of spent fuel and high-level waste) 6.1; 6.2.1; 6.2.2.1; 6.2.2.3; 6.2.3; 6.2.4; 6.6 1 Offsite radiological impacts (collective effects) 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6 1 Offsite radiological impacts (spent fuel and high-level waste disposal) 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6 1 Non-radiological impacts of the uranium fuel cycle 6.1; 6.2.2.6; 6.2.2.7; 6.2.2.8; 6.2.2.9; 6.2.3; 6.2.4; 6.6 1 Low-level waste storage and disposal 6.1; 6.2.2.2; 6.4.2; 6.4.3; 6.4.3.1; 6.4.3.2; 6.4.3.3; 6.4.4; 6.4.4.1; 6.4.4.2; 6.4.4.3; 6.4.4.4; 6.4.4.5; 6.4.4.5.1; 6.4.4.5.2; 6.4.4.5.3; 6.4.4.5.4; 6.4.4.6; 6.6 1 Mixed waste storage and disposal 6.4.5.1; 6.4.5.2; 6.4.5.3; 6.4.5.4; 6.4.5.5; 6.4.5.6; 6.4.5.6.1; 6.4.5.6.2; 6.4.5.6.3; 6.4.5.6.4; 6.6 1 Onsite spent fuel 6.1; 6.4.6; 6.4.6.1; 6.4.6.2; 6.4.6.3; 6.4.6.4; 6.4.6.5; 6.4.6.6; 6.4.6.7; 6.6 1 Non-radiological waste 6.1; 6.5; 6.5.1; 6.5.2; 6.5.3; 6.6 1 Transportation 6.1; 6.3.1; 6.3.2.3; 6.3.3; 6.3.4; 6.6, Addendum 1 1 The NRC staff's evaluation of the environmental impacts associated with spent nuclear fuel is 19 addressed in two issues in Table 6 -1, "Offsite radiological impacts (spent fuel and high-level 20 waste disposal)" and "Onsite spent fuel." However, as explained later in this section, the scope 21 of the evaluation of these issues in this supplemental environmental impact statement (SEIS) 22 has been revised. T he issue, "Offsite radiological impacts (spent fuel and high -level waste 23 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-2 disposal)," from Table 6 -1 is not evaluated in this SEIS. In addition, the issue, "Onsite spent 1 fuel" only evaluates the environmental impacts during the license renewal term. 2 For the term of license renewal, the NRC staff did not find any new and significant information 3 related to the remaining uranium fuel cycle and solid waste management issues listed in 4 Table 6-1 during its review of the GGNS environmental report (ER) (Entergy 2011), the site 5 visit, and the scoping process. Therefore, there are no impacts related to these issues beyond 6 those discussed in the GEIS. For these Category 1 issues, the GEIS concludes that the 7 impacts are SMALL, except for the issue, "Offsite radiological impacts (collective effects)," which 8 the NRC has not assigned an impact level. This issue assesses the 100 -year radiation dose to 9 the U.S. population (i.e., collective effects or collective dose) from radioactive effluents released 10 as part of the uranium fuel cycle for a nuclear power plant during the license renewal term 11 compared to the radiation dose from natural background exposure. It is a comparative 12 assessment for which there is no regulatory standard to base an impact level. 13 For the radiological impacts resulting from spent fuel and high-level waste disposal and the 14 onsite storage of spent fuel, which will occur after the reactors have been permanently 15 shutdown, the NRC's Waste Confidence Decision and Rule represented the Commission's 16 generic determination that spent fuel can continue to be stored safely and without significant 17 environmental impacts for a period of time after the end of the licensed life for operation. This 18 generic determination meant that the NRC did not need to consider the storage of spent fuel 19 after the end of a reactor's licensed life for operation in National Environmental Policy Act 20 (NEPA) documents that support its reactor and spent fuel storage application reviews. 21 The NRC first adopted the Waste Confidence Decision and Rule in 1984. The NRC amended 22 the decision and rule in 1990, reviewed them in 1999, and amended them again in 2010 23 (49 FR 34694; 55 FR 38474; 64 FR 68005; and 75 FR 81032 and 81037). The Waste 24 Confidence Decision and Rule are codified in 10 CFR 51.23. 25 On December 23, 2010, the Commission published in the Federal Register a revision of the 26 Waste Confidence Decision and Rule to reflect information gained from experience in the 27 storage of spent fuel and the increased uncertainty in the siting and construction of a permanent 28 geologic repository for the disposal of spent nuclear fuel and high -level waste (75 FR 81032 and 29 81037). In response to the 2010 Waste Confidence Decision and Rule, the states of New York, 30 New Jersey, Connecticut, and Vermont -along with several other parties -challenged the 31 Commission's NEPA analysis in the decision, which provided the regulatory basis for the rule. 32 On June 8, 2012, the United States Court of Appeals, District of Columbia Circuit in New York v. 33 NRC, 681 F.3d 471 (D.C. Cir. 2012) vacated the NRC's Waste Confidence Decision and Rule, 34 after finding that it did not comply with NEPA. 35 In response to the court's ruling, the Commission, in CLI 16 (NRC 2012 a), determined that it 36 would not issue licenses that rely upon the Waste Confidence Decision and Rule until the issues 37 identified in the court's decision are appropriately addressed by the Commission. In CLI 16, 38 the Commission also noted that the decision not to issue licenses only applies to final license 39 issuance; all licensing reviews and proceedings should continue to move forward. 40 In addition, the Commission directed, in SRM-COMSECY-12-0016 (NRC 2012b), that the NRC 41 staff proceed with a rulemaking that includes the development of a generic environmental 42 impact statement (EIS) to support a revised Waste Confidence Rule and to publish both the EIS 43 and the revised decision and rule in the Federal Register within 24 months (by 44 September 2014). The Commission indicated that both the EIS and the revised Waste 45 Confidence Rule should build on the information already documented in various NRC studies 46 and reports, including the existing environmental assessment that the NRC developed as part of 47 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-3 the 2010 Waste Confidence Decision and Rule. The Commission directed that any additional 1 analyses should focus on the issues identified in the court's decision. The Commission also 2 directed that the NRC staff provide ample opportunity for public comment on both the draft EIS 3 and the proposed rule. 4 The revised rule and supporting EIS are expected to provide the necessary NEPA analyses of 5 waste confidence -related human health and environmental issues. As directed by the 6 Commission, the NRC will not issue a renewed license before the resolution of waste 7 confidence -related issues. This will ensure that there w ill be no irretrievable or irreversible 8 resource commitments or potential harm to the environment before waste confidence impacts 9 have been addressed. 10 If the results of the Waste Confidence Rule and supporting EIS identify information that requires 11 a supplement to this SEIS, the NRC staff will perform any appropriate additional NEPA review 12 for those issues before the NRC makes a final licensing decision. 13 6.2 Greenhouse Gas Emissions 14 This section discusses the potential impacts from greenhouse gases (GHGs) emitted from the 15 nuclear fuel cycle. The GEIS does not directly address these emissions, and its discussion is 16 limited to an inference that substantial carbon dioxide (CO

2) emissions may occur if coal- or 17 oil-fired alternatives to license renewal are carried out.

18 6.2.1 Existing Studies 19 Since the development of the GEIS, the relative volumes of GHGs emitted by nuclear and other 20 electricity generating methods have been widely studied. However, estimates and projections 21 of the carbon footprint of the nuclear power lifecycle vary depending on the type of study done. 22 Additionally, considerable debate also exists among researchers on the relative effects of 23 nuclear and other forms of electricity generation on GHG emissions. Existing studies on GHG 24 emissions from nuclear power plants generally take two different forms: 25 (4) qualitative discussions of the potential to use nuclear power to reduce GHG emissions and 26 mitigate global warming, and 27 (5) technical analyses and quantitative estimates of the actual amount of GHGs generated by 28 the nuclear fuel cycle or entire nuclear power plant life cycle and comparisons to the 29 operational or life cycle emissions from other energy generation alternatives. 30 6.2.1.1 Qualitative Studies 31 The qualitative studies consist primarily of broad, large -scale public policy, or investment 32 evaluations of whether an expansion of nuclear power is likely to be a technically, economically, 33 or politically workable means of achieving global GHG reductions. Studies the staff found 34 during the subsequent literature search include the following: 35 Evaluations to determine if investments in nuclear power in developing 36 countries should be accepted as a flexibility mechanism to assist 37 industrialized nations in achieving their GHG reduction goals under the Kyoto 38 Protocols (IAEA 2000, NEA 2002, Schneider 2000). Ultimately, the parties to 39 the Kyoto Protocol did not approve nuclear power as a component under the 40 clean development mechanism (CDM) because of safety and waste disposal 41 concerns (NEA 2002). 42 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-4 Analyses developed to assist governments, including the United States, in 1 making long-term investment and public policy decisions in nuclear power 2 (Hagen et al. 2001, Keepin 1988, MIT 2003). 3 Although the qualitative studies sometimes reference and critique the existing quantitative 4 estimates of GHGs produced by the nuclear fuel cycle or life cycle, their conclusions generally 5 rely heavily on discussions of other aspects of nuclear policy decisions and investment, such as 6 safety, cost, waste generation, and political acceptability. Therefore, these studies typically are 7 not directly applicable to an evaluation of GHG emissions associated with the proposed license 8 renewal for a given nuclear power plant. 9 6.2.1.2 Quantitative Studies 10 A large number of technical studies, including calculations and estimates of the amount of 11 GHGs emitted by nuclear and other power generation options, are available in the literature and 12 were useful in the staff's efforts to address relative GHG emission levels. Examples of these 13 studies include -but are not limited to -Mortimer (1990), Andseta et al. (1998), Spadaro (2000), 14 Storm van Leeuwen and Smith (2008), Fritsche (2006), Parliamentary Office of Science and 15 Technology (POST) (2006), Atomic Energy Authority (AEA) (2006), Weisser (2006), Fthenakis 16 and Kim (2007), and Dones (2007). In addition, Sovacool (2008) provides a review and 17 synthesis of studies in existence through 2008; however, the Sovacool synthesis ultimately uses 18 only 19 of the 103 studies initially considered (the remaining 84 were excluded because they 19 were more than 10 years old, not publicly available, available only in a language other than 20 English, or they presented methodological challenges by relying on inaccessible data, providing 21 overall GHG estimates without allocating relative GHG impacts to different parts of the nuclear 22 lifecycle, or they were otherwise not methodologically explicit). 23 Comparing these studies and others like them is difficult because the assumptions and 24 components of the lifecycles that the authors evaluate vary widely. Examples of areas in which 25 differing assumptions make comparing the studies difficult include the following: 26 energy sources that may be used to mine uranium deposits in the future, 27 reprocessing or disposal of spent nuclear fuel, 28 current and potential future processes to enrich uranium and the energy 29 sources that will power them, 30 estimated grades and quantities of recoverable uranium resources, 31 estimated grades and quantities of recoverable fossil fuel resources, 32 estimated GHG emissions other than CO 2, including the conversion to CO 2 33 equivalents per unit of electric energy produced, 34 performance of future fossil fuel power systems, 35 projected capacity factors for alternatives means of generation, and 36 current and potential future reactor technologies. 37 In addition, studies may vary with respect to whether all or parts of a power plant's lifecycle are 38 analyzed (i.e., a full lifecycle analysis will typically address plant construction, operations, 39 resource extraction -for fuel and construction materials, and decommissioning), whereas a 40 partial lifecycle analysis primarily focuses on operational differences. In addition, as 41 Sovacool (2008) noted, studies vary greatly in terms of age, data availability, and 42 methodological transparency. 43 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-5 In the case of license renewal, a GHG analysis for the portion of the plant's lifecycle attributable 1 to license renewal (operation for an additional 20 years) would not involve GHG emissions 2 associated with construction because construction activities already have been completed at the 3 time of relicensing. In addition, the proposed action of license renewal also would not involve 4 additional GHG emissions associated with facility decommissioning because that 5 decommissioning must occur whether the facility is relicensed or not. However, in many 6 studies, the specific contribution of GHG emissions from construction, decommissioning, or 7 other portions of a plant's lifecycle cannot be clearly separated from one another. In such 8 cases, an analysis of GHG emissions would overestimate the GHG emissions attributed to a 9 specific portion of a plant's lifecycle. As Sovacool (2008) noted, many of the available analyses 10 provide markedly lower GHG emissions per unit of plant output when one assumes that a power 11 plant operates for a longer period of time. Nonetheless, available studies supply some 12 meaningful information on the relative magnitude of the emissions among nuclear power plants 13 and other forms of electric generation, as discussed in the following sections. 14 In Tables 6-2, 6-3, and 6-4, the staff presents the results of the above -mentioned quantitative 15 studies to supply a weight -of-evidence evaluation of the relative GHG emissions that may result 16 from the proposed license renewal compared to the potential alternative use of coal -fired, 17 natural gas -fired, and renewable generation. Most studies from Mortimer (1990) onward 18 (through Sovacool 2008) indicate that uranium ore grades and uranium enrichment processes 19 are leading determinants in the ultimate GHG emissions attributable to nuclear power 20 generation. These studies show that the relatively lower order of magnitude of GHG emissions 21 from nuclear power, when compared to fossil -fueled alternatives (especially natural gas), could 22 potentially disappear if available uranium ore grades drop sufficiently while enrichment 23 processes continued to rely on the same technologies. 24 Sovacool's synthesis of 19 existing studies found that nuclear power generation causes carbon 25 emissions in a range of 1.4 grams of carbon equivalent per kilowatt -hour (g C eq/kWh) to 26 288 g C eq/kWh, with a mean value of 66 g C eq/kWh. The results of his synthesis and the results 27 of others' efforts are included in the tables in this section. 28 6.2.1.3 Summary of Nuclear Greenhouse Gas Emissions Compared to Coal 29 Considering that coal fuels the largest share of electricity generation in the United States and 30 that its burning results in the largest emissions of GHGs for any of the likely alternatives to 31 nuclear power generation, including GGNS, many of the available quantitative studies focused 32 on comparing the relative GHG emissions of nuclear to coal -fired generation. The quantitative 33 estimates of the GHG emissions associated with the nuclear fuel cycle (and, in some cases, the 34 nuclear lifecycle), as compared to an equivalent coal -fired plant, are presented in Table 6-2. 35 The following table does not include all existing studies, but it gives an illustrative range of 36 estimates that various sources have developed. 37 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-6 Table 6-2. Nuclear Greenhouse Gas Emissions Compared to Coal 1 Source GHG Emission Results Mortimer (1990) Nuclear-230,000 tons CO 2 Coal-5,912,000 tons CO 2 Note: Future GHG emissions from nuclear to increase because of declining ore grade. Andseta et al. (1998) Nuclear energy produces 1.4% of the GHG emissions compared to coal. Note: Future reprocessing and use of nuclear -generated electrical power in the mining and enrichment steps are likely to change the projections of earlier authors, such as Mortimer (1990). Spadaro (2000) Nuclear-2.5-5.7 g Ceq/kWh Coal-264-357 g Ceq/kWh Fritsche (2006) (values estimated from graph in Figure 4) Nuclear-33 g Ceq/kWh Coal-950 g Ceq/kWh POST (2006) (nuclear calculations from AEA 2006) Nuclear-5 g Ceq/kWh Coal->1 ,000 g Ceq/kWh Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 6.8 g Ceq/kWh. Future improved technology and carbon capture and storage could reduce coal -fired GHG emissions by 90%. Weisser (2006) (compilation of results from other studies) Nuclear-2.8-24 g C eq/kWh Coal-950-1,250 g Ceq/kWh Sovacool (2008) Nuclear-66 g Ceq/kWh Coal -960-1,050 g Ceq/kWh (coal adopted from Gagnon et al. 2002) 6.2.1.4 Summary of Nuclear Greenhouse Gas Emissions Compared to Natural Gas 2 The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle (and, in 3 some cases, the nuclear lifecycle), as compared to an equivalent natural gas -fired plant, are 4 presented in Table 6-3. The following table does not include all existing studies, but it gives an 5 illustrative range of estimates various sources have developed. 6 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-7 Table 6-3. Nuclear Greenhouse Gas Emissions Compared to Natural Gas 1 Source GHG Emission Results Spadaro (2000) Nuclear-2.5-5.7 g Ceq/kWh Natural g as-120-188 g C eq/kWh Storm van Leeuwen and Smith (2008) Nuclear fuel cycle produces 20 -33% of the GHG emissions compared to natural gas (at high ore grades). Note: Future nuclear GHG emissions will increase because of declining ore grade. Fritsche (2006) (values estimated from graph in Figure 4) Nuclear-33 g Ceq/kWh Cogeneration combined cycle natural g as-150 g C eq/kWh POST (2006) (nuclear calculations from AEA, 2006) Nuclear-5 g Ceq/kWh Natural g as-500 g Ceq/kWh Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 6.8 g Ceq/kWh. Future improved technology and carbon capture and storage could reduce natural gas GHG emissions by 90%. Weisser (2006) (compilation of results from other studies) Nuclear-2.8-24 g C eq/kWh Natural g as-440-780 g C eq/kWh Dones (2007) Author critiqued methods and assumptions of Storm van Leeuwen and Smith (2005), and concluded that the nuclear fuel cycle produces 15-27% of the GHG emissions of natural gas. Sovacool (2008) Nuclear-66 g Ceq/kWh Natural g as-443 g Ceq/kWh (natural gas adopted from Gagnon et al. 2002) 6.2.1.5 Summary of Nuclear Greenhouse Gas Emissions Compared to Renewable Energy 2 Sources 3 The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle (and, in 4 some cases, the nuclear lifecycle), as compared to equivalent renewable energy sources, are 5 presented in Table 6-4. Calculation of GHG emissions associated with these sources is more 6 difficult than the calculations for nuclear energy and fossil fuels because of the large variation in 7 efficiencies and capacity factors because of their different technologies, sources, and locations. 8 For example, the efficiency of solar and wind energy is highly dependent on the wind or solar 9 resource in a particular location. Similarly, the range of GHG emissions estimates for 10 hydropower varies greatly depending on the type of dam or reservoir involved (if used at all). 11 Therefore, the GHG emissions estimates for these energy sources have a greater range of 12 variability than the estimates for nuclear and fossil fuel sources. The following table does not 13 include all existing studies, but it gives an illustrative range of estimates various sources have 14 developed. 15 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-8 Table 6-4. Nuclear Greenhouse Gas Emissions Compared to Renewable Energy Sources 1 Source GHG Emission Results Mortimer (1990) Nuclear-230,000 tons CO 2 Hydropower -78,000 tons CO 2 Wind power -54,000 tons CO 2 Tidal power -52,500 tons CO 2 Note: Future GHG emissions from nuclear are expected to increase because of declining ore grade. Spadaro (2000) Nuclear-2.5-5.7 g Ceq/kWh Solar PV-27.3-76.4 g Ceq/kWh Hydroelectric -1.1-64.6 g Ceq/kWh Biomass-8.4-16.6 g Ceq/kWh Wind-2.5-13.1 g Ceq/kWh Fritsche (2006) (values estimated from graph in Figure 4) Nuclear-33 g Ceq/kWh Solar PV-125 g Ceq/kWh Hydroelectric -50 g Ceq/kWh Wind-20 g Ceq/kWh POST (2006) (nuclear calculations from AEA 2006) Nuclear-5 g Ceq/kWh Biomass-25-93 g Ceq/kWh Solar PV-35-58 g Ceq/kWh Wave/Tidal 50 g Ceq/kWh Hydroelectric-5-30 g Ceq/kWh Wind-4.64-5.25 g Ceq/kWh Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 6.8 g Ceq/kWh. Weisser (2006) (compilation of results from other studies) Nuclear-2.8-24 g C eq/kWh Solar PV-43-73 g Ceq/kWh Hydroelectric-1-34 g Ceq/kWh Biomass-35-99 g Ceq/kWh Wind-8-30 g Ceq/kWh Fthenakis and Kim (2007) Nuclear-16-55 g Ceq/kWh Solar PV-17-49 g Ceq/kWh Sovacool (2008) (adopted from other studies) Nuclear-66 g Ceq/kWh Wind-9-10 g Ceq/kWh Hydroelectric (small, distributed) 13 g Ceq/kWh Biogas digester-11 g C eq/kWh Solar thermal-13 g Ceq/kWh Biomass-14-35 g Ceq/kWh Solar PV-32 g Ceq/kWh Geothermal (hot, dry rock) -38 g Ceq/kWh (solar PV value adopted from Fthenakis et al. 2008; all other renewable generation values adopted from Pehnt 2006) 6.2.2

Conclusions:

Relative Greenhouse Gas Emissions 2 The sampling of data presented in Tables 6-2 , 6-3, and 6-4 demonstrates the challenges of 3 any attempt to determine the specific amount of GHG emission attributable to nuclear energy 4 production sources because different assumptions and calculation methods will yield differing 5 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-9 results. The differences and complexities in these assumptions and analyses will further 1 increase when they are used to project future GHG emissions. Nevertheless, several 2 conclusions can be drawn from the information presented. 3 First, the various studies show a general consensus that nuclear power currently produces 4 fewer GHG emissions than fossil -fuel-based electrical generation (e.g., GHG emissions from a 5 complete nuclear fuel cycle currently range from 2.5 -66 grams of carbon equivalent per kilowatt 6 hour (g C eq/kWh), as compared to the use of coal plants (264-1, 250 g C eq/kWh) and natural gas 7 plants (120 -780 g C eq/kWh)). The studies also provide estimates of GHG emissions from five 8 renewable energy sources based on current technology. These estimates included 9 solar-photovoltaic (17 -125 g C eq/kWh), hydroelectric (1 -64.6 g C eq/kWh), biomass 10 (8.4-99 g C eq/kWh), wind (2.5 -30 g C eq/kWh), and tidal (25-50 g C eq/kWh). The range of these 11 estimates is wide, but the general conclusion is that current GHG emissions from nuclear power 12 generation are of the same order of magnitude as from these renewable energy sources. 13 Second, the studies show no consensus on future relative GHG emissions from nuclear power 14 and other sources of electricity. There is substantial disagreement among the various authors 15 about the GHG emissions associated with declining uranium ore concentrations, future uranium 16 enrichment methods, and other factors, including changes in technology. Similar disagreement 17 exists about future GHG emissions associated with coal and natural gas for electricity 18 generation. Even the most conservative studies conclude that the nuclear fuel cycle currently 19 produces fewer GHG emissions than fossil -fuel-based sources and is expected to continue to 20 do so in the near future. The primary difference between the authors is the projected cross -over 21 date (the time at which GHG emissions from the nuclear fuel cycle exceed those of 22 fossil-fuel-based sources) or whether cross -over will actually occur. 23 Considering current estimates and future uncertainties, it appears that GHG emissions 24 associated with the proposed GGNS relicensing action are likely to be lower than those 25 associated with fossil fuel-based energy sources. The staff bases this conclusion on the 26 following rationale: 27 As shown in Tables 6-2 and 6-3, current estimates of GHG emissions from 28 the nuclear fuel cycle are far below those for fossil fuel-based energy 29 sources. 30 License renewal of a nuclear power plant such as GGNS may involve 31 continued GHG emissions caused by uranium mining, processing, and 32 enrichment, but will not result in increased GHG emissions associated with 33 plant construction or decommissioning (since the plant will have to be 34 decommissioned at some point whether the license is renewed or not). 35 Few studies predict that nuclear fuel cycle emissions will exceed those of 36 fossil fuels within a timeframe that includes the GGNS period of extended 37 operation. Several studies suggest that future extraction and enrichment 38 methods, the potential for higher -grade resource discovery, and technology 39 improvements could extend this timeframe. 40 With respect to the comparison of GHG emissions among the proposed GGNS license renewal 41 action and renewable energy sources: 42 It appears likely that there will be future technology improvements and 43 changes in the type of energy used for mining, processing, manufacturing, 44 and constructing facilities of all types. 45 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-10 Currently, the GHG emissions associated with the nuclear fuel cycle and 1 renewable energy sources are within the same order of magnitude. 2 Because nuclear fuel production is the most significant contributor to possible 3 future increases in GHG emissions from nuclear power -and since most 4 renewable energy sources lack a fuel component -it is likely that GHG 5 emissions from renewable energy sources w ill be lower than those 6 associated with GGNS at some point during the period of extended operation. 7 The staff provides additional discussion on the contribution of GHG to cumulative air quality 8 impacts in Section 4.11.2 of this supplemental EIS. 9 6.3 References 10 75 FR 81032. U.S. Nuclear Regulatory Commission. Consideration of environmental impacts of 11 temporary storage of spent f uel after cessation of reactor operation. Federal Register 12 75(246):81032 -81037. December 23, 2010. 13 75 FR 81037. U.S. Nuclear Regulatory Commission. Waste confidence decision update. 14 Federal Register 75(246):81037 -81076. December 23, 2010. 15 [AEA] AEA Technology. 2006. "Carbon Footprint of the Nuclear Fuel Cycle, Briefing Note." East 16 Kilbride. UK: British Energy Group. March 2006. Available at <http://www.british -energy.com/ 17 documents/carbon_footprint.pd f> (accessed 21 May 2012 ). 18 Andseta S, Thompson MJ, Jarrell JP, Pendergast DR. 1998. CANDU Reactors and Greenhouse 19 Gas Emissions. Proceedings of the 19 th Annual Conference, Canadian Nuclear Society

20 1998 October 18

-21; Toronto, Ontario. Available at <http://www.computare.org/Support% 21 20documents/Publications/Life%20Cycle.htm>

(accessed 21 May 2012). 22 [Entergy] Entergy Operations, Inc. 2011. Grand Gulf Nuclear Station, Unit 1, License Renewal 23 Application , Appendix E, Applicant's Environmental Report, Operating License Renewal Stage. 24 Agencywide Documents Access and Management System (ADAMS)

Accession No. 25 ML11308A234. 26 Dones R. 2007. Critical Note on the Estimation by Storm Van Leeuwen JW and Smith P of the 27 Energy Uses and Corresponding CO 2 Emissions for the Complete Nuclear Energy Chain. 28 Villigen, Switzerland: Paul Sherer Institute. April 2007. Available at 29 <http://gabe.web.psi.ch/pdfs/Critical%20note%20GHG%20PSI.pdf> (accessed 21 May 2012 ). 30 Fritsche UR. 2006. Comparison of Greenhouse -Gas Emissions and Abatement Cost of Nuclear 31 and Alternative Energy Options from a Life -Cycle Perspective. Freiburg, Germany: Oko -Institut. 32 January 2006. Available at <http://www.oeko.de/oekodoc/315/2006 -017-en.pdf> (accessed 33 21 May 2012). 34 Fthenakis VM, Kim HC. 2007. Greenhouse -gas emissions from solar -electric and nuclear 35 power: A life cycle study. Energy Policy 35(4):2549 -2557. 36 [IAEA] International Atomic Energy Agency. 2000. Nuclear Power for Greenhouse Gas 37 Mitigation under the Kyoto Protocol: The Clean Development Mechanism (CDM). Vienna, 38 Austria: IAEA. November 2000. Available at <http://www.iaea.org/Publications/Booklets/ 39 GreenhouseGas/greenhousegas.pdf> (accessed 22 May 2012 ). 40 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-11 Mortimer N. 1990. World warms to nuclear power. SCRAM Safe Energy Journal Dec 89/Jan90. 1 Available at <http://www.no2nuclearpower.org.uk/articles/mortimer_se74.php> (accessed 2 22 May 2012). 3 [NEA and OECD] Nuclear Energy Agency and the Organization for Economic Co -operation and 4 Development. 2002. Nuclear Energy and the Kyoto Protocol. Paris, France: OECD. Available at 5 <http://www.nea.fr/ndd/reports/2002/nea3808 -kyoto.pdf> (accessed 22 May 2012 ). 6 [NRC] U.S. Nuclear Regulatory Commission. Code Manual for MACCS2: Volume 1, User's 7 Guide. Washington, DC. NRC. NUREG/CR -6613. May 1998. ADAMS Accession 8 No. ML063550020. 9 [NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3 -Transportation, Table 9.1, 10 Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic 11 Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: 12 NRC. NUREG -1437, Volume 1, Addendum 1. August 1999. ADAMS Accession 13 No. ML04069720. 14 [NRC] U.S. Nuclear Regulatory Commission. 2012a. "Commission, Memorandum and Order 15 CLI-12-16." August 7, 2012. ADAMS Accession No. ML12220A094. 16 [NRC] U.S. Nuclear Regulatory Commission. 2012b. "SRM-COMSECY-12-0016-Approach for 17 Addressing Policy Issues Resulting from Court Decision To Vacate Waste Confidence Decision 18 and Rule." September 6, 2012. ADAMS Accession No. ML12250A032. 19 [POST] Parliamentary Office of Science and Technology. 2006. Carbon footprint of electricity 20 generation. Postnote 268. October 2006. Available at <http://www.parliament.uk/ 21 documents/post/postpn268.pdf> (accessed 22 May 2012 ). 22 Schneider M. 2000. Climate Change and Nuclear Power. Gland, Switzerland: WWF -World 23 Wildlife Fund for Nature. April 2000. Available at <http://assets.panda.org/downloads/ 24 fullnuclearreprotwwf.pdf> (accessed 22 May 2012 ). 25 Sovacool, BK. 2008. "Valuing the Greenhouse Gas Emissions from Nuclear Power: A Critical 26 Survey." Energy Policy 36:2940-2953. 27 Spadaro JV, Langlois L, Hamilton B. 2000. "Greenhouse Gas Emissions of Electricity 28 Generation Chains: Assessing the Difference." Vienna, Austria: International Atomic Energy 29 Agency. 30 Storm van Leeuwen JW, Smith P. 2008. Nuclear Power -The Energy Balance. Chaam, 31 Netherlands: Ceedata Consultancy. February 2008. Available at <http://www.stormsmith.nl/> 32 (accessed 22 May 2012 ). 33 Weisser D. 2006. A guide to life -cycle greenhouse gas (GHG) emissions from electric supply 34 technologies. Energy 32(9): 1543 -1559. Available at 35 <http://www.iaea.org/OurWork/ST/NE/Pess/assets/GHG_manuscript_pre -36 print_versionDanielWeisser.pdf>

(accessed 22 May 2012).

37

7-1 7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING 1 Environmental impacts from the activities associated with the decommissioning of any reactor 2 before or at the end of an initial or renewed license are evaluated in Supplement 1 of 3 NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear 4 Facilities Regarding the Decommissioning of Nuclear Power Reactors (NRC 2002). The 5 U.S. Nuclear Regulatory Commission (NRC) staff 's (the staff's) evaluation of the environmental 6 impacts of decommissioning -presented in NUREG -0586, Supplement 1-notes a range of 7 impacts for each environmental issue. 8 Additionally, the incremental environmental impacts associated with decommissioning activities 9 resulting from continued plant operation during the renewal term are discussed in 10 NUREG-1437, Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear 11 Plants (NRC 1996, 1999). The GEIS includes a determination of whether the analysis of the 12 environmental issue could be applied to all plants and whether additional mitigation measures 13 would be warranted. Issues were then assigned a Category 1 or a Category 2 designation. 14 Section 1.4 in Chapter 1 explains the criteria for Category 1 and Category 2 issues and defines 15 the impact designations of SMALL, MODERATE, and LARGE. The staff analyzed site-specific 16 issues (Category

2) for Grand Gulf Nuclear Station (GGNS) and assigned them a significance 17 level of SMALL, MODERATE, or LARGE, or not applicable to GGNS because of site 18 characteristics or plant features. There are no Category 2 issues related to decommissioning.

19 7.1 Decommissioning 20 Table 7-1 lists the Category 1 issues in Table B-1 of Title 10 of the Code of Federal 21 Regulations (CFR) Part 51, Subpart A, Appendix B that are applicable to GGNS 22 decommissioning following the renewal term. 23 Table 7-1. Issues Related to Decommissioning 24 Issues GEIS section Category Radiation doses 7.3.1; 7.4 1 Waste management 7.3.2; 7.4 1 Air quality 7.3.3; 7.4 1 Water quality 7.3.4; 7.4 1 Ecological resources 7.3.5; 7.4 1 Socioeconomic impacts 7.3.7; 7.4 1 Decommissioning would occur whether GGNS were shut down at the end of its current 25 operating license or at the end of the period of extended operation. There are no site-specific 26 issues related to decommissioning. 27 A brief description of the staff's review and the GEIS conclusions, as codified in Table B-1, 28 10 CFR Part 51, for each of the issues follows: 29 Radiation doses. Based on information in the GEIS, the NRC noted that "[d]oses to the public 30 will be well below applicable regulatory standards regardless of which decommissioning method 31 Environmental Impacts of Decommissioning 7-2 is used. Occupational doses would increase no more than 1 person-rem (1 person-mSv) 1 caused by buildup of long -lived radionuclides during the license renewal term." 2 Waste management. Based on information in the GEIS, the NRC noted that 3 "[d]ecommissioning at the end of a 20-year license renewal period would generate no more 4 solid wastes than at the end of the current license term. No increase in the quantities of 5 Class C or greater than Class C wastes would be expected." 6 Air quality. Based on information in the GEIS, the NRC noted that "[a]ir quality impacts of 7 decommissioning are expected to be negligible either at the end of the current operating term or 8 at the end of the license renewal term." 9 Water quality. Based on information in the GEIS, the NRC noted that "[t]he potential for 10 significant water quality impacts from erosion or spills is no greater whether decommissioning 11 occurs after a 20 -year license renewal period or after the original 40 -year operation period, and 12 measures are readily available to avoid such impacts." 13 Ecological resources. Based on information in the GEIS, the NRC noted that 14 "[d]ecommissioning after either the initial operating period or after a 20 -year license renewal 15 period is not expected to have any direct ecological impacts." 16 Socioeconomic impacts. Based on information in the GEIS, the NRC noted that 17 "[d]ecommissioning would have some short -term socioeconomic impacts. The impacts would 18 not be increased by delaying decommissioning until the end of a 20 -year relicense period, but 19 they might be decreased by population and economic growth." 20 Entergy Operations, Inc. (Entergy) stated in its environmental report (ER) (Entergy 2011) that it 21 is not aware of any new and significant information on the environmental impacts of GGN S 22 license renewal. The staff has not found any new and significant information during its 23 independent review of Entergy's ER, the site visit, the scoping process, or its evaluation of other 24 available information. Therefore, the NRC staff concludes that there are no impacts related to 25 these issues, beyond those discussed in the GEIS. For all of these issues, the NRC staff 26 concluded in the GEIS that the impacts are SMALL, and additional plant -specific mitigation 27 measures are not likely to be sufficiently beneficial to be warranted. 28 7.2 References 29 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 30 protection regulations for domestic licensing and related regulatory functions." 31 [Entergy] Entergy Operations, Inc. 2011. Grand Gulf Nuclear Station, Unit 1, License Renewal 32 Application. Appendix E, Applicant's Environmental Report. Agencywide Documents Access 33 and Management System (ADAMS) Accession No. ML11308A234. 34 [NRC] U.S. Nuclear Regulatory Commission. 1996. GEIS. NRC. NUREG -1437. May 1996. 35 ADAMS Accession Nos. ML040690705 and ML040690738. 36 [NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3 -Transportation, Table 9.1, 37 Summary of findings on NEPA issues for license renewal of nuclear power plants. In: GEIS. 38 NRC. NUREG -1437, Volume 1, Addendum 1. August 1999. ADAMS Accession 39 No. ML04069720. 40 [NRC] U.S. Nuclear Regulatory Commission. 2002. Final Generic Environmental Impact 41 Statement on Decommissioning of Nuclear Facilities Regarding the Decommissioning of 42 Nuclear Power Reactors. Washington, DC: NRC. NUREG -0586, Supplement 1. 43 November 2002. ADAMS Accession Nos. ML023470304 and ML02350029 5.44 8-1 8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES 1 The National Environmental Policy Act (NEPA) requires the consideration of a range of 2 reasonable alternatives to the proposed action in an environmental impact statement (EIS). In 3 this case, the proposed action is whether to issue a renewed license for Grand Gulf Nuclear 4 Station (GGNS), which will allow the plant to operate for 20 years beyond its current license 5 expiration date. A license is just one of many conditions that a licensee must meet in order to 6 operate its nuclear plant. State regulatory agencies and the owners of the nuclear power plant 7 ultimately decide whether the plant will operate, and economic and environmental 8 considerations play a primary role in this decision. The U.S. Nuclear Regulatory Commission 9 (NRC)'s responsibility is to ensure the safe operation of nuclear power facilities and not to 10 formulate energy policy or encourage or discourage the development of alternative power 11 generation (or replacement power alternatives). 12 The license renewal process is designed to assure safe operation of the nuclear power plant 13 and protection of the environment during the license renewal term. Under the NRC's 14 environmental protection regulations in Title 10, Part 51, of the Code of Federal Regulations 15 (10 CFR Part 51), which implement Section 102(2) of NEPA, renewal of a nuclear power plant 16 operating license requires the preparation of an EIS. 17 To support the preparation of these EISs, the NRC staff (the staff) prepared the Generic 18 Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG -1437, 19 in 1996. The license renewal GEIS was prepared to assess the environmental impacts of 20 continued nuclear power plant operations during the license renewal term. The intent was to 21 determine which environmental impacts would result in essentially the same impact at all 22 nuclear power plants and which ones could result in different levels of impacts at different plants 23 and would require a plant -specific analysis to determine the impacts. For those issues that 24 could not be generically addressed, the NRC develops a plant -specific supplemental 25 environmental impact statement (SEIS) to the GEIS. 26 NRC regulations in 10 CFR 51.71(d) for license renewal require that a SEIS consider and weigh 27 the environmental effects of the proposed action [license renewal]; the 28 environmental impacts of alternatives to the proposed action; and alternatives 29 available for reducing or avoiding adverse environmental effects [.] 30 While the GEIS reached generic conclusions on many environmental issues associated with 31 license renewal, it did not determine which alternatives are reasonable or reach conclusions 32 about site -specific environmental impact levels. As such, the NRC must evaluate environmental 33 impacts of alternatives on a site -specific basis. 34 As stated in Chapter 1 of this SEIS, alternatives to renewing GGNS's operating license must 35 meet the purpose and need for the proposed action. They must do the following: 36 provide an option that allows for power generation capability beyond the term of 37 a current nuclear power plant operating license to meet future system generating 38 needs, as such needs may be determined by State, utility, and, where 39 authorized, Federal (other than NRC) [decisionmakers]. (NRC 1996) 40 The NRC ultimately makes no decision about which alternative (or the proposed action) to carry 41 out because that decision falls to the appropriate energy -planning decisionmakers. 42 Environmental Impacts of Alternatives 8-2 Comparing the environmental effects of these 1 alternatives will help the NRC decide if the 2 adverse environmental impacts of license renewal 3 are great enough to deny the option of license 4 renewal for energy -planning decisionmakers 5 (10 CFR 51.95(c)(4)). If the NRC acts to issue a 6 renewed license, all of the alternatives, including 7 the proposed action, will be available to 8 energy-planning decisionmakers. If the NRC 9 decides not to renew the license, then 10 energy-planning decisionmakers may no longer 11 elect to continue operating GGNS and will have to 12 resort to another alternative -which may or may 13 not be one of the alternatives considered in this 14 section-to meet the energy needs that GGNS 15 now satisfies. 16 In evaluating alternatives to license renewal, 17 energy technologies or options currently in 18 commercial operation are considered, as well as 19 some technologies not currently in commercial 20 operation but likely to be commercially available 21 by the time the current GGNS operating license 22 expires. The current GGNS operating license will expire on November 1, 2024, and reasonable 23 alternatives must be available (constructed, permitted, and connected to the grid) by the time 24 the current GGNS license expires to be considered likely to become available. 25 The staff eliminated alternatives that cannot meet future system needs and whose costs or 26 benefits do not justify inclusion in the range of reasonable alternatives. The staff evaluated the 27 remaining alternatives, which are discussed in -depth in this chapter. Each alternative 28 eliminated from detailed study is briefly discussed in Section 8.5, and a basis for its removal is 29 provided. In total, 16 energy technology options and alternatives to the proposed action were 30 considered (see text box) and then narrowed to the four alternatives considered in 31 Sections 8.1-8.4. The no -action alternative is considered in Section 8.6. 32 The GEIS presents an overview of some energy technologies but does not reach any 33 conclusions about which alternatives are most appropriate. Since 1996, many energy 34 technologies have evolved significantly in capability and cost, while regulatory structures have 35 changed to either promote or impede development of particular alternatives. 36 As a result, the analyses include updated information from sources such as the Energy 37 Information Administration (EIA), other organizations within the U.S. Department of Energy 38 (DOE), the U.S. Environmental Protection Agency (EPA), industry sources and publications , 39 and information submitted by the applicant in its environmental report (ER). 40 The evaluation of each alternative considers the environmental impacts across seven impact 41 categories: (1) air quality, (2) groundwater use and quality, (3) surface water use and quality, 42 (4) ecology, (5) human health, (6) socioeconomics, and (7) waste management. A three -level 43 standard of significance -SMALL, MODERATE, or LARGE -is used to show the intensity of 44 environmental effects for each alternative that is evaluated in depth. The order of presentatio n 45 is not meant to imply increasing or decreasing level of impact, nor does it imply that an 46 energy-planning decisionmaker would select one or another alternative. 47 Alternatives Evaluated In -Depth: new nuclear natural gas -fired combined cycle (NGCC) supercritical coal -fired combination alternative (NGCC, demand -side management, purchased power, and biomass) Other Alternatives Considered: demand-side management wind power solar power hydroelectric power wave and ocean energy geothermal power municipal solid waste biomass oil-fired power fuel cells purchased power delayed retirement

Environmental Impacts of Alternatives 8-3 For each alternative where it is feasible to do so, the NRC considers the environmental effects 1 of locating the alternative at the existing GGNS site. Selecting the existing plant site allows for 2 the maximum use of existing transmission and cooling system infrastructures and minimizes the 3 overall environmental impact. 4 In addition, to ensure that the alternatives analysis is consistent with State and regional energy 5 policies, the NRC reviewed energy relevant statutes, regulations, and policies. The NRC also 6 considered the current generation capacity mix and electricity production data within Mississippi, 7 where GGNS is located and production data for Entergy's six operating companies that operate 8 under a System Agreement. The System Agreement allows the operating companies to share 9 generating capacity power reserves, provides the basis for the planning, construction and 10 operation of electric generation and transmission, and regulates the price for whol esale 11 electricity used or exchanged by the Entergy operating companies (Entergy 2012). In 2010, 12 electric generators in Mississippi had an installed generating capacity of approximately 13 15,691 megawatts electric (MWe). This capacity included units fueled by natural gas 14 (74 percent), coal (16 percent), nuclear (8 percent), and biomass-fired generation (1.5 percent) 15 (EIA 2012 a). In 2010, the electric industry in Mississippi provided approximately 54.5 million 16 megawatt-hours of electricity. Electricity produced in Mississippi was dominated by natural gas 17 (54 percent) followed by coal (25 percent), nuclear (18 percent), and biomass -fired generation 18 (2.8 percent) (EIA 2012 a). 19 Sections 8.1-8.4 describe the environmental impacts of alternatives to license renewal. These 20 alternatives include a new nuclear generation option in Section 8.1; a new natural gas -fired 21 combined-cycle (NGCC) plant in Section 8.2; a new supercritical pulverized coal (SCPC) plant 22 in Section 8.3; and a combination alternative of NGCC, demand -side management (DSM), 23 purchased power, and biomass-fired generation in Section 8.4. A summary of these 24 alternatives considered in depth is provided in Table 8-1. In Section 8.5, alternatives 25 considered but eliminated from detailed study are briefly discussed. Finally, Section 8.6 26 describes environmental effects that may occur if the NRC takes no action and does not issue a 27 renewed license for GGNS. Section 8.7 summarizes the impacts of each of the alternatives 28 considered in detail. 29 Environmental Impacts of Alternatives 8-4 Table 8-1. Summary of Alternatives Considered In Depth 1 New Nuclear Alternative Natural Gas (NGCC) Alternative Supercritical Pulverized Coal (SCPC) Alternative Combination Alternative Summary of Alternative One unit ESBWR nuclear plant Three 530-MWe units for a total of 1,590 MWe Three 583-MWe SCPC units (total of 1,749 MWe) One 530-MWe NGCC unit; Nine 50-MW biomass units (360 MWe total); 280 MWe from DSM; and

305 MWe from purchased power Location At GGNS; Would use existing infrastructure, including Ranney wells, draft cooling tower, and transmission lines At GGNS; Would use existing infrastructure, including Ranney wells, draft cooling tower, and transmission lines An existing power plant site (other than GGNS) in Mississippi; Some infrastructure upgrades may be required NGCC at GGNS; Biomass units at 9 sites throughout Mississippi; DSM and purchased power throughout Mississippi Cooling System Ranney wells

Consumptive water use would be similar to GGNS Unit 1 Ranney wells

Consumptive water use would be less than GGNS Unit 1 Closed-cycle with natural-draft cooling towers; Consumptive water use would be similar to GGNS Unit 1 NGCC unit same as the NGCC alternative but water use would be 1/3 less; Closed

- cycle cooling for biomass uni ts Land Requirements 234 ac (95 ha) (Entergy 2011); 1,000 ac (400 ha) for uranium mining and processing (NRC 1996) 195 acres (79 hectares) (NRC 1996); 5,700 ac (2,307 ha) for wells, collection site, pipeline (NRC 1996) 2,744 ac (1,110 ha) for the plant (NRC 1996); 35,508 ac (14,370 h a) for coal mining and waste disposal (NRC 1996) NGCC unit approximately 1/3 the land as for the NGCC alternative; 15 ac (6 ha) for each 50-MWe biomass unit, for a total of 135 ac (55 ha) (NREL 2003, Palmer Renewable Energy 2011) Work Force 3,150 during construction; 690 during operations (Entergy 2011) 1,900 during construction; 150 during operations (NRC 1996) 4,035 during construction; 404 during operations (NRC 1996) NGCC portion would require 633 during construction and 50 during operations (NRC 1996); Biomass units would require 450 during construction and 198 during operations 8.1 New Nuclear Generation 2 In this section, the NRC evaluates the environmental impacts of a new nuclear generation 3 alternative at the GGNS site. 4 Environmental Impacts of Alternatives 8-5 The NRC considers the construction of a new nuclear plant to be a reasonable alternative to 1 GGNS license renewal because nuclear generation currently provides baseload power in 2 Entergy's service territory and Entergy has expressed interest in adding nuclear generation to 3 its energy portfolio. For example, on October 16, 2003, an application was submitted for an 4 early site permit (ESP) on the existing GGNS site and the NRC issued an ESP on April 7, 2007 5 (NRC 2012a). An ESP is an NRC approval of a site for one or more nuclear power facilities. 6 Before construction and operation of any new nuclear unit(s), Entergy would need to obtain a 7 construction permit and operating license. On February 27, 2008, Entergy submitted an 8 application for a combined operating license (COL) for an Economic Simplified Boiling -Water 9 Reactor (ESBWR) at the GGNS site. On January 9, 2009, Entergy informed the NRC that it 10 was considering alternate reactor design technologies and requested that the NRC suspend its 11 review effort (NRC 2012b). Entergy continues to evaluate the potential for new nuclear 12 generation and could pursue it as an option for meeting long -term baseload needs in the future 13 (Entergy 2009, 2010). Although the ESP does not specify a scheduled timeline, the NRC 14 determined that there is sufficient time for Entergy to prepare and submit an application, build, 15 and operate a new nuclear unit before the GGNS license expires in November 2024. This 16 section presents the environmental impacts of the new nuclear generation alternative, which 17 includes constructing and operating one new nuclear plant at the GGNS site. 18 In evaluating the new nuclear alternative, the NRC assumed that a replacement reactor would 19 be installed on the GGNS site, allowing for the maximum use of existing ancillary facilities such 20 as the cooling system and transmission infrastructure. The GGNS site is situated on 21 2,100 acres (ac) (850 hectares [ha]), of which, approximately 1,000 ac (405 ha), is in a 22 floodplain and not suitable for plant construction. The remaining 1,100 ac (445 ha) would be 23 sufficient for construction of a new nuclear plant (Entergy 2011). The NRC assumed that the 24 replacement reactor would be an ESBWR. Although the NRC has suspended its review of the 25 COL application, it uses information from the ESP EIS in the following sections, where 26 applicable, because it provides a site -specific environmental analysis of a new nuclear plant at 27 the GG NS site. 28 For the purpose of this analysis, the NRC assumed that the new reactor would have a net 29 electrical output of 1,475 MWe, which would be the same output as the existing reactor. 30 Entergy (2008) estimated that 234 ac (95 ha) would be required for new reactor construction for 31 the power block and ancillary facilities, and that sufficient acreage was available on the GGNS 32 site. T he heat-rejection demands of a new nuclear unit would be similar to those of the existing 33 reactor. Therefore , the NRC assumed that the new reactor would use the existing cooling 34 system (including natural draft cooling towers and intake and discharge structures), and that no 35 structural modifications would be needed. The existing transmission lines leaving the site, as 36 well as construction, drinking water and Ranney wells are expected to serve the new reactor 37 with no modifications required. 38 The NRC also considered the installation of multiple small and modular reactors at the GGNS 39 site as an alternative to renewing the GGNS license. The NRC established the Advanced 40 Reactor Program in the Office of New Reactors because of considerable interest in small and 41 modular reactors along with anticipated license applications by vendors. As of December 2012, 42 the NRC has not received any applications. Because there are no applications to construct and 43 operate small modular reactors on a commercial scale, this analysis focused on nuclear 44 generation by larger nuclear units. 45 8.1.1 Air Quality 46 As discussed in Section 2.2.2.1, the GGNS site is located in Claiborne County, Mississippi, 47 which is on the western edge of the Mobile (Alabama) -Pensacola-Panama City 48 Environmental Impacts of Alternatives 8-6 (Florida)-Southern Mississippi Interstate Air Quality Control Region (AQCR) (40 CFR 81.68). 1 The area across the Mississippi River from the site is in the Monroe (Louisiana) -El Dorado 2 (Arkansas) Interstate AQCR (40 CFR 81.92). EPA has designated all of the counties in these 3 AQCRs adjacent to the GGNS site as in compliance with the National Ambient Air Quality 4 Standards (NAAQS) (40 CFR 81.310). The State of Mississippi is in attainment with primary 5 and secondary NAAQS for all criteria pollutants, except De Soto County, which is located about 6 200 miles (322 km) north-northeast of GGNS and part of which is a marginal nonattainment 7 area for the 2008 8 -hour ozone standard. 8 Construction activities for a new nuclear alternative would cause some localized temporary air 9 quality impacts because of fugitive dust emissions from operation of earth -moving and 10 material-handling equipment. Emissions from construction worker vehicles and motorized 11 construction equipment exhaust would be temporary. The NRC assumes that mitigation 12 measures, including wetting of unpaved roads and construction areas, and seeding or mulching 13 bare areas would control and reduce fugitive dust. 14 During operations, a new nuclear alternative would have air emissions similar to those of the 15 existing GGNS plant. These emissions are primarily from testing of emergency generators and 16 diesel pumps and the periodic use of auxiliary boilers or generators during outages (Entergy 17 2011). The NRC expects a new nuclear alternative to have similar air permitting conditions and 18 regulatory requirements as the existing plant. For example, a new nuclear alternative would be 19 subject to conditions in an air permit established by the Mississippi Department of 20 Environmental Quality (MDEQ) (Entergy 2011). 21 Subpart P of 40 CFR Part 51 contains the visibility protection regulatory requirements, including 22 the review of new sources to be constructed in attainment or unclassified areas that may affect 23 visibility in any mandatory Class I Federal area (designated national parks and wilderness 24 areas). If a new nuclear plant were located close to a mandatory Class I Federal area, 25 additional air pollution control requirements may be required. As noted in Section 2.2.2.1, there 26 are no mandatory Class I Federal areas within 186 mi (300 km) of the GGNS site. 27 8.1.1.1 Greenhouse Gases 28 Operation of a new nuclear alternative would have similar effects on climate change as the 29 existing GGNS (which are discussed in Section 4.2). Operation of the reactor does not result in 30 the release of GHGs. However, GHG emissions do result from some activities, such as the 31 periodic use of auxiliary boilers or generators, worker vehicles, and motorized construction 32 equipment exhaust. The impacts on climate from a new nuclear alternative on the GGNS site 33 would be SMALL. 34 8.1.1.2 Conclusion 35 The overall air quality impacts of a new nuclear plant located at the GGNS site would not 36 noticeably alter air quality, therefore, air quality impacts would be SMALL. 37 8.1.2 Groundwater Resources 38 The amount of groundwater required for construction of a new nuclear alternative would be 39 much less than required during plant operation. Water for construction would be obtained from 40 the existing Ranney wells. Groundwater quality and use impacts from construction of a new 41 nuclear alternative are expected to be SMALL. 42 The amount of water required to operate a new nuclear power plant would be similar to that 43 required for the existing power plant. Cooling water would be obtained from the existing 44 Ranney wells. The potable water system would operate from existing wells using similar 45 Environmental Impacts of Alternatives 8-7 chemicals, processes, and withdrawal rates as the existing GGNS facility. Groundwater quality 1 and use impacts from operation of a new nuclear alternative are expected to be SMALL. 2 8.1.3 Surface Water Resources 3 If dredging of streams or rivers occurs during construction, surface water quality immediately 4 downstream of the dredging activities could be temporarily degraded by increases in suspended 5 sediment concentration. During operation, a new nuclear alternative would discharge blowdown 6 from the cooling system at approximately the same rate as the existing unit. Stormwater 7 discharge, blowdown, sanitary, and other effluents, would be regulated under a National 8 Pollutant Discharge Elimination System (NPDES) permit. Given that the discharge rate and 9 composition would be similar to the existing plant and regulated by an NPDES permit and the 10 effects of any dredging needed for construction would be temporary, the impacts to surface 11 water use and quality are expected to be SMALL. 12 8.1.4 Aquatic Ecology 13 Construction activities for the new nuclear alternative (such as construction of heavy -haul roads 14 and the power block) could affect onsite aquatic features, including the Mississippi River near 15 GGNS, Hamilton and Gin Lakes, a borrow pit, three small ponds, streams "A" and "B," and 16 ephemeral drainages. Minimal impacts on aquatic ecology resources are expected because the 17 plant operator would likely implement best management practices (BMPs) to minimize erosion 18 and sedimentation. Stormwater control measures, which would be required to comply with 19 Mississippi NPDES permitting, would minimize the flow of disturbed soils into aquatic features. 20 To bring new materials to the site, the plant operator would dredge near the barge slip to 21 transport some materials using barges, which could result in increased sedimentation and 22 turbidity within aquatic habitats in the Mississippi River. Permits and certifications from the 23 U.S. Army Corps of Engineers and other agencies would require the implementation of BMPs to 24 minimize impacts. Due to the short -term nature of the dredging activities, the hydrological 25 alterations to aquatic habitats would be localized and temporary. 26 During operations, the new nuclear alternative would require a similar amount of cooling water 27 to be withdrawn from Ranney wells and a similar amount of water to be discharged into the 28 Mississippi River as required for GGNS. The number of fish and other aquatic resources 29 affected by cooling water discharge operations, such as thermal stress, would be similar to 30 those of GGNS. 31 Consultation under several Federal acts, including the Endangered Species Act (ESA) and 32 Magnuson-Stevens Act, would be required to assess the occurrence and potential impacts to 33 Federally protected aquatic species and habitats within affected surface waters. Coordination 34 with State natural resource agencies would further ensure that Entergy would take appropriate 35 steps to avoid or mitigate impacts to State-listed species, habitats of conservation concern, and 36 other protected species and habitats. The NRC assumes that these consultations would result 37 in avoidance or mitigation measures that would minimize or eliminate potential impacts to 38 protected aquatic species and habitats. 39 The impacts on aquatic ecology would be minor because erosion and sedimentation would be 40 minimized by BMPs during construction and stormwater and surface water discharges would be 41 managed by regulatory permits similar to the existing plant. Therefore, the staff concludes that 42 impacts on aquatic ecology would be SMALL 43 Environmental Impacts of Alternatives 8-8 8.1.5 Terrestrial Ecology 1 Entergy estimates that construction of a new nuclear alternative, including a reactor unit and 2 auxiliary facilities would affect 234 ac (95 ha) of land on the GGNS site, which is a slightly 3 smaller area of land than that disturbed for construction of GGNS. A new nuclear alternative 4 would use existing site infrastructure, transmission lines, and cooling system to the extent 5 practicable. Thus, only minimal disturbances to undisturbed land would occur for a new nuclear 6 alternative. However, the level of direct impacts would vary based on the specific location of 7 new buildings and infrastructure on the site. Erosion and sedimentation, fugitive dust, and 8 construction debris impacts would be minor with implementation of appropriate BMPs. 9 Construction noise could modify wildlife behavior; however, these effects would be temporary. 10 Road improvements or construction of additional service roads to facilitate construction could 11 result in the temporary or permanent loss of terrestrial habitat. Impacts to terrestrial habitats 12 and species from the operation of a new nuclear alternative would be similar to those of GGNS 13 and would, therefore, be SMALL. Impacts to terrestrial habitats and species from transmission 14 line operation and corridor vegetation maintenance would be similar in magnitude and intensity 15 to those resulting from operating nuclear reactors and would, therefore, be SMALL . The offsite 16 land requirement (1,000 ac [400 ha]) and impacts associated with uranium mining and fuel 17 fabrication to support a new nuclear alternative would be no different from those occurring in 18 support of GGNS. Overall, the impacts from construction of a new nuclear alternative on 19 terrestrial species and habitats would be MODERATE, and the impacts of operation would be 20 SMALL. 21 As discussed under aquatic ecology impacts, consultation with U.S. Fish and Wildlife Service 22 (FWS) under the ESA would avoid potential adverse impacts to Federally listed species or 23 adverse modification or destruction of designated critical habitat. Coordination with State 24 natural resource agencies would further ensure that Entergy would take appropriate steps to 25 avoid or mitigate impacts to State-listed species, habitats of conservation concern, and other 26 protected species and habitats. The NRC assumes that these consultations would result in 27 avoidance or mitigation measures that would minimize or eliminate potential impacts to 28 protected terrestrial species and habitats. Consequently, the impacts of construction and 29 operation of a new nuclear alternative on protected species and habitats would be SMALL. 30 8.1.6 Human Health 31 Impacts on human health from construction of a new nuclear alternative would be similar to 32 impacts associated with the construction of any major industrial facility. Compliance with worker 33 protection rules would control those impacts on workers at acceptable levels. Impacts from 34 construction on the general public would be minimal because the plant operator would limit 35 active construction area access to authorized individuals assuming BMPs are followed. Impacts 36 on human health from the construction of a new nuclear alternative would be SMALL. 37 The human health effects from the operation of a new nuclear alternative would be similar to 38 those of the existing GGNS plant. Therefore, impacts on human health from the operation of a 39 new nuclear alternative would be SMALL. 40 8.1.7 Land Use 41 The GEIS generically evaluates the impacts of constructing and operating various replacement 42 power plant alternatives on land use, both on and off each plant site. The analysis of land use 43 impacts focuses on the amount of land area that would be affected by the construction and 44 operation of a new single -unit nuclear power plant at the GGNS site. 45 Environmental Impacts of Alternatives 8-9 Entergy estimated 234 ac (95 ha) of land would be needed to construct and operate a new 1 single-unit nuclear power plant on the GGNS site (Entergy 2011). A sufficient amount of land is 2 available on the GGNS site for a new nuclear power plant. Maximizing the use of the 3 established infrastructure at the existing nuclear power plant site would further reduce t he 4 amount of additional land needed to support the new unit. Land use impacts from constructing 5 and operating one new unit at the GGNS site would be SMALL. 6 The GEIS also estimated an additional 1,000 acres (400 ha) of land would be affected by 7 uranium mining and processing during the life of the new nuclear alternative. Impacts 8 associated with uranium mining and fuel fabrication to support the new nuclear alternative would 9 generally be no different from those occurring in support of the existing GGNS facility. Since the 10 new unit would be located at GGNS, overall land use impacts from a new nuclear alternative 11 would be SMALL. 12 8.1.8 Socioeconomics 13 Socioeconomic impacts are defined in terms of changes to the demographic and economic 14 characteristics and social conditions of a region. For example, the number of jobs created by 15 the construction and operation of a power plant could affect regional employment, income, and 16 expenditures. 17 This alternative would create two types of jobs: (1) construction jobs, which are transient, short 18 in duration, and less likely to have a long -term socioeconomic impact; and (2) power plant 19 operation jobs, which have a greater potential for permanent, long -term socioeconomic impacts. 20 Workforce requirements for the construction and operation of the new nuclear generation 21 alternative were evaluated to measure its possible effects on current socioeconomic conditions. 22 Entergy estimated a construction workforce of up to 3,150 (maximum) workers would be 23 required to build a single-unit nuclear plant (Entergy 2011). The relative economic impact of 24 construction workers on the local economy and tax base would vary, with the greatest impacts 25 occurring in the communities where the majority of construction workers reside and spend their 26 income. As a result, local communities could experience a short -term economic "boom" from 27 increased tax revenue and income generated by construction worker expenditures and the 28 increased demand for temporary (rental) housing and business services. After completing 29 construction of the new nuclear plant, local communities could experience a return to 30 pre-construction economic conditions. Given the magnitude of the estimated number of 31 workers, socioeconomic impacts during construction in communities near the GGNS site could 32 range from SMALL to LARGE. 33 Entergy estimated that 690 operations workers would be required at a new nuclear power plant , 34 which is equivalent to the number of operations workers at GGNS (Entergy 2011). GGNS 35 operations workers would likely transfer from the existing facility to the new nuclear power plant. 36 This would not have a noticeable effect on socioeconomic conditions in the region. 37 Socioeconomic impacts associated with the operation of a new nuclear alternative at the GGNS 38 site would therefore be SMALL. 39 8.1.9 Transportation 40 Transportation impacts associated with construction and operation of a new nuclear alternative 41 would consist of commuting workers and truck deliveries of construction materials to the power 42 plant site. During periods of peak construction activity, up to 3,150 workers could be commuting 43 daily to the site (Entergy 2011). Workers commuting to the construction site would use site 44 access roads and the volume of traffic on nearby roads could increase substantially during shift 45 Environmental Impacts of Alternatives 8-10 changes. In addition to commuting workers, trucks would be transporting construction materials 1 and equipment to the worksite, thus increasing the amount of traffic on local roads. The 2 increase in vehicular traffic would peak during shift changes, resulting in temporary levels of 3 service impacts and delays at intersections. Materials also could be delivered by barge to the 4 GGNS site. Traffic-related transportation impacts during construction likely would range from 5 MODERATE to LARGE. 6 Traffic-related transportation impacts on local roads would be greatly reduced after construction 7 is completed. The estimated number of operations workers would be 690 (Entergy 2011). 8 Transportation impacts would include daily commuting by the operating workforce, equipment 9 and materials deliveries, and the removal of commercial waste material to offsite disposal or 10 recycling facilities by truck. Traffic-related transportation impacts would be similar to those 11 experienced during current operations at GGNS, because the new unit would employ the same 12 number of workers as GGNS currently employs. Overall, for a new nuclear alternative, 13 transportation impacts would be SMALL during operations. 14 8.1.10 Aesthetics 15 The analysis of aesthetic impacts focuses on the degree of contrast between the new nuclear 16 alternative and the surrounding landscape and the visibility of the new power plant. 17 During construction, clearing and excavation would occur on site. Some of these activities may 18 be visible from offsite roads. Since the GGNS site already appears industrial, construction of 19 the new plant would appear similar to onsite activities during refueling outages. 20 During reactor operations, the visual appearance of the GGNS site would not change since the 21 power block for the new nuclear reactor would look virtually identical to the existing GGNS 22 power block. Adding a new reactor unit would increase the overall size of developed land at the 23 GGNS site. Given the industrial appearance of the GGNS site and the similarity of the new unit 24 to the existing unit, the new reactor unit would blend in with the surroundings . In addition, the 25 amount of noise generated during reactor operations of a new nuclear alternative would be the 26 same as those generated during existing GGNS operations, which consists predominantly of the 27 noise from routine industrial processes and communications. In general, aesthet ic changes 28 would be limited to the immediate vicinity of the GGNS site, and any impacts would be SMALL. 29 8.1.11 Historic and Archaeological Resources 30 The potential for impacts on historic and archaeological resources from a new nuclear 31 alternative would vary greatly depending on the location of the proposed plants on the GGNS 32 site. Any construction on the GGNS site would need to avoid the previously identified Grand 33 Gulf Mound area (Site 22Cb522) and Archaic Period village (22Cb528), as described in 34 Section 2.2.10.2 of this document. As portions of the GGNS site have been previously 35 identified as not containing significant historic and archaeological resources, use of these areas 36 for the new nuclear alternative would result in a SMALL impact on historic and archaeological 37 resources. Alternate plant locations on the GGNS site would need to be surveyed and 38 inventoried for potential resources. Resources found in these surveys would need to be 39 evaluated for eligibility on the National Register of Historic Properties (NRHP) and mitigation of 40 adverse effects would need to be addressed if eligible resources were encountered. The level 41 of impact at these locations would vary depending on the specific resources found to be present 42 in the area of potential effect. However, given that the preference is to use previously surveyed 43 and/or disturbed areas, avoidance of significant historic and archaeological resources should be 44 possible and effectively managed under current laws and regulations. Therefore, the impacts 45 on historic and archaeological resources from the new nuclear alternative would be SMALL. 46 Environmental Impacts of Alternatives 8-11 8.1.12 Environmental Justice 1 The environmental justice impact analysis evaluates the potential for disproportionately high and 2 adverse human health, environmental, and socioeconomic effects on minority and low -income 3 populations that could result from the construction and operation of a new power plant. Adverse 4 health effects are measured in terms of the risk and rate of fatal or nonfatal adverse impacts on 5 human health. Disproportionately high and adverse human health effects occur when the risk or 6 rate of exposure to an environmental hazard for a minority or low -income population is 7 significant and exceeds the risk or exposure rate for the general population or for another 8 appropriate comparison group. Disproportionately high environmental effects refer to impacts or 9 risk of impact on the natural or physical environment in a minority or low -income community that 10 are significant and appreciably exceed the environmental impact on the larger community. 11 Such effects may include biological, cultural, economic, or social impacts. Some of these 12 potential effects have been discussed in the other sections of this chapter. For example, 13 increased demand for rental housing during replacement power plant construction could 14 disproportionately affect low -income populations that rely on inexpensive rental housing. 15 Section 4.9.7, Environmental Justice, presents demographic information about minority and low -16 income populations living near the GGNS site. 17 Potential impacts to minority and low -income populations from the construction of a new nuclear 18 power plant at the GGNS site would mostly consist of environmental and socioeconomic effects 19 (e.g., noise, dust, traffic, employment, and housing impacts). Noise and dust impacts during 20 construction would be short -term and primarily limited to onsite activities. Minority and low -21 income populations residing along site access roads would be directly affected by increased 22 commuter vehicle and truck traffic. However, because of the temporary nature of construction, 23 these effects are not likely to be high and adverse and would be contained to a limited time 24 period during certain hours of the day. Increased demand for rental housing during construction 25 could cause rental costs to rise disproportionately affecting low -income populations living near 26 GGNS who rely on inexpensive housing. However, given the proximity of GGNS to the 27 Jackson and Vicksburg metropolitan areas, some workers could commute to the construction 28 site, thereby reducing the need for rental housing. 29 Potential impacts to minority and low -income populations from nuclear power plant operations 30 would be similar to those of the existing GGNS plant. Radiation doses from the new nuclear 31 power plant are expected to be well below regulatory limits. People living near the power plant 32 would be exposed to the same potential effects from the existing GGNS power plant operations 33 and any impacts would depend on the magnitude of the change in ambient air quality 34 conditions. Permitted air emissions are expected to remain within regulatory standards. 35 Based on this information and the analysis of human health and environmental impacts 36 presented in this section, the construction and operation of a new nuclear power plant would not 37 have disproportionately high and adverse human health and environmental effects on minority 38 and low-income populations living near GGNS. 39 8.1.13 Waste Management 40 During the construction of a new nuclear plant, land clearing and other construction activities 41 would generate waste that could be recycled, disposed of on site, or shipped to an offsite waste 42 disposal facility. Because the new nuclear plant would be constructed on the previously 43 disturbed GGNS site, the amount of wastes produced would be less than comparable 44 construction on an unimproved property. 45 Environmental Impacts of Alternatives 8-12 During the operational stage, normal plant operations, routine plant maintenance, and cleaning 1 activities would generate nonradioactive waste as well as mixed waste, low-level waste, and 2 high-level waste. Quantities of nonradioactive waste (discussed in Section 2.1.3 of this 3 document) and radioactive waste (discussed in Section 6.1 of this document) generated by 4 GGNS would be comparable to that generated by a new nuclear alternative. 5 According to the GEIS (NRC 1996), the generation and management of solid nonradioactive 6 and radioactive waste during the license renewal term is not expected to result in significant 7 environmental impacts. A new single -unit nuclear plant would generate waste streams similar 8 to the existing nuclear plant. Based on this information, waste impacts would be SMALL for a 9 new single -unit nuclear plant located at the GGNS site. 10 8.1.14 Summary of Impacts of New Nuclear Generation 11 Table 8-2 summarizes the environmental impacts of the new nuclear alternative compared to 12 continued operation of GGNS. 13 Table 8-2. Summary of Environmental Impacts of the New Nuclear Alternative 14 Compared to Continued Operation of GGNS 15 Category New Nuclear Generation (use existing infrastructure) Continued GGNS Operation Air Quality SMALL SMALL Groundwater Resources SMALL SMALL Surface Water Resources SMALL SMALL Aquatic Ecology SMALL SMALL Terrestrial Ecology SMALL to MODERATE SMALL Human Health SMALL SMALL Land Use SMALL SMALL Socioeconomics SMALL to LARGE SMALL Transportation SMALL to LARGE SMALL Aesthetics SMALL SMALL Historic and Archaeological Resources SMALL SMALL Waste Management a SMALL SMALL a As described in Chapter 6, the issue, "offsite radiological impacts (spent fuel and high level waste disposal)," is not evaluated in this EIS.

8.2 Natural

Gas -Fired Combined -Cycle Generation 16 In this section, the NRC evaluates the environmental impacts of natural gas -fired 17 combined-cycle (NGCC) generation at the GGNS site. 18 In 2010, natural gas accounted for 54 percent of all electricity generated in Mississippi, a 19 144 percent increase from 10 years earlier in 2000 (EIA 2012b). Natural gas provides the 20 greatest share of electrical power in Mississippi (EIA 2012b). Development of new natural 21 gas-fired plants may be affected by perceived or actual action to limit greenhouse gas (GHG) 22 emissions. Like other fossil fuel sources, natural gas -fired plants are a source of GHG, 23 principally carbon dioxide (CO 2). A gas-fired power plant, however, produces significantly fewer 24 GHGs per unit of electrical output than other fossil fuel -powered plants. In addition, NGCC 25 systems can have high capacity factors and are capable of economically providing baseload 26 power. Natural gas-fired power plants are a feasible and commercially available option for 27 providing baseload electrical generating capacity beyond GGNS's current license expiration. 28 Environmental Impacts of Alternatives 8-13 Therefore, the NRC considered NGCC generation a reasonable alternative to GGNS license 1 renewal. 2 NGCC plants differ considerably from coal -fired boilers and existing nuclear power plants. 3 NGCC plants obtain the majority of their electrical output from a gas -turbine and subsequently 4 generate additional power through a second steam turbine -cycle without any fuel combustion. 5 This combined -cycle approach provides greater thermal efficiency than a single -cycle system, 6 with efficiencies reaching 60 percent (as compared to typical thermal efficiencies of coal -fired 7 plants of 39 percent) (Siemens 2007, NETL 2007). Because the natural gas -fired alternative 8 generates much of its power from a gas -turbine combined -cycle plant and the overall thermal 9 efficiency of this type of plant is high, an NGCC alternative would require less cooling water than 10 GGNS. Thus, the NRC assumed that the NGCC alternative would use the existing cooling 11 system (including natural draft cooling towers and intake and discharge structures), and that the 12 cooling system at GGNS could meet the heat -rejection demands of the NGCC alternative with 13 no structural modifications. 14 To replace the 1,475 MWe that GGNS generates, the NRC considered three hypothetical 15 gas-fired units, each with a net capacity of 530 MWe, for the NGCC alternative. For purposes of 16 this analysis, the hypothetical units would be similar to General Electric's (GE's) H-class 17 gas-fired combined -cycle units. While any number of commercially available combined-cycle 18 units could be installed in a variety of combinations to replace the power GGNS currently 19 produces, GE's H -class units are highly efficient models that would minimize environmental 20 impacts. Other manufacturers, such as Siemens, offer similar high efficiency models. 21 This 1, 590 MWe NGCC plant would consume 70.7 billion cubic feet (ft

3) (2,000 million cubic 22 meters [m 3]) of natural gas annually, assuming an average heat content of 1,020 British thermal 23 unit(s) per cubic feet (BTU/ft 3). Natural gas would be extracted from the ground through wells, 24 then treated to remove impurities (such as hydrogen sulfide), and blended to meet pipeline gas 25 standards before arriving at the plant site. This gas

-fired alternative would produce relatively 26 little waste, primarily in the form of spent catalysts used for control of nitrogen oxide (NO x) 27 emissions. 28 GGNS is situated on a 2,100 ac (850 ha) site. Approximately 1,000 ac (405 ha) are located in a 29 floodplain and not suitable for a NGCC plant, and 169 ac (68 ha) are dedicated to existing 30 GGNS facilities and structures. Entergy's ER concluded that buildable land of sufficient acreage 31 and appropriate location would be available to support an onsite NGCC plant (Entergy 2011). 32 Site crews would clear vegetation, prepare the site surface and relocate existing facilities, if 33 necessary, and begin excavations for foundations and buried utilities before other crews begin 34 actual construction on the plant and associated infrastructure. The three NGCC units would be 35 approximately 100 f eet (ft) (30 meters [m]) tall, with two exhaust stacks up to 150 ft (46 m) tall. 36 Also, offsite impacts would occur as a result of construction of a natural gas pipeline connecting 37 the site to existing infrastructure. 38 8.2.1 Air Quality 39 The GGNS site is located in Claiborne County, Mississippi, which is on the western edge of the 40 Mobile (Alabama) -Pensacola-Panama City (Florida) -Southern Mississippi Interstate Air Quality 41 Control Region (AQCR) (40 CFR 81.68 ). The area across the Mississippi River from the site is 42 in the Monroe (Louisiana) -El Dorado (Arkansas) Interstate AQCR (40 CFR 81.92). EPA has 43 designated all of the counties in these AQCRs adjacent to the GGNS site as in compliance with 44 the National Ambient Air Quality Standards (NAAQS) (40 CFR 81.310). The State o f 45 Mississippi is in attainment with NAAQS for all criteria pollutants, except De Soto County, which 46 Environmental Impacts of Alternatives 8-14 is located about 200 miles (322 km) north-northeast of GGNS and part of which recently was 1 designated as a marginal nonattainment area for the 2008 8 -hour ozone standard. 2 Construction activities for this alternative would generate fugitive dust. However, mitigation 3 measures, including wetting of unpaved roads and construction areas, and seeding or mulching 4 bare areas would minimize fugitive dust. Construction worker vehicles and motorized 5 construction equipment would create exhaust emissions. However, these emissions would end 6 upon completion of construction. 7 Various Federal and state regulations aimed at controlling air pollution would affect a fossil 8 fuel-fired power plant, including an NGCC alternative located in Mississippi. A new NGCC 9 plant, which will be located in an attainment or unclassified area, would qualify as a new 10 major-emitting industrial facility and would be subject to Prevention of Significant Deterioration 11 (PSD) requirements under the Clean Air Act (CAA) (EPA 2012a). The NGCC alternative would 12 need to comply with the standards of performance for electric utility steam generating units set 13 forth in 40 CFR Part 60 Subpart KKKK. The plant also would require an operating permit from 14 MDEQ. 15 If the NGCC alternative were located close to a mandatory Class I area, additional air pollution 16 control requirements would be required (Subpart P of 40 CFR Part 51) as mandated by the 17 Regional Haze Rule. The rule would likely not apply to this NGCC alternative, however, 18 because there are no Class I Federal areas within 186 mi (300 km) of the GGNS site 19 (EPA 2012b). 20 The emissions from the NGCC alternative, projected by the staff based on published EIA data, 21 EPA emission factors, performance characteristics for this alternative, and likely emission 22 controls, would be: 23 sulfur oxides (SO x)-123 tons (111 metric tons [MT]) per year 24 nitrogen oxides (NO x)-469 tons (425 MT) per year 25 particulate matter 10 (PM 10) and 2.5 (PM2.5)-238 tons (216 MT) 26 per year 27 carbon monoxide (CO)-1,082 tons (982 MT) per year 28 carbon dioxide (CO 2)-4.0 million tons (3.6 million MT) per year 29 8.2.1.1 Sulfur Oxide and Nitrogen Oxide 30 As stated above, the NGCC alternative would produce 123 tons (111 MT) per year of SO x and 31 469 tons (425 MT) per year of NO x based on the use of dry low -NO x combustion technology and 32 use of selective catalytic reduction to significantly reduce NO x emissions. The new plant would 33 be subjected to the continuous monitoring requirements of SO 2 and NO x as specified in 34 40 CFR Part 75. 35 8.2.1.2 Greenhouse Gases 36 The NGCC alternative would release GHGs, such as CO 2 and methane. The NGCC alternative 37 would emit approximately 4.0 million tons (approximately 3.6 million MT) per year of CO 2 38 emissions. The plant would be subjected to continuous monitoring requirements for CO 2, as 39 specified in 40 CFR Part 75. 40 On July 12, 2012, EPA issued a final rule tailoring the criteria that determine which stationary 41 sources and modification to existing projects become subject to permitting requirements for 42 GHG emissions under the PSD and Title V Programs of the CAA (77 FR 41051). According to 43 this rule, GHGs are a regulated new source review pollutant under the PSD major source 44 Environmental Impacts of Alternatives 8-15 permitting program if the source is otherwise subject to PSD (for another regulated new source 1 review pollutant) and has a GHG potential to emit equal to or greater than 75,000 tons 2 (68,000 MT) per year of CO 2 equivalent ("carbon dioxide equivalent" adjusts for different global 3 warming potentials for different GHGs). Beginning January 2, 2011, operating permits issued to 4 major sources of GHGs under the PSD or Title V Federal permit programs must contai n 5 provisions requiring the use of Best Available Control Technology (BACT) to limit the emissions 6 of GHGs if those sources would be subject to PSD or Title V permitting requirements. If the 7 NGCC alternative meets the GHG emission thresholds established in the rule, then GHG 8 emissions from this alternative would be regulated under the PSD and Title V permit programs. 9 8.2.1.3 Particulates 10 The NGCC alternative would produce uncontrolled emission of 238 tons (216 MT) per year of 11 particulates, all of which would be emitted as PM 10 and PM2.5. Small amounts of particulate 12 would be released as drift from the cooling tower. However, because the NGCC facility would 13 have a smaller heat rejection demand than GGNS, the drift would be less than what is currently 14 released from the cooling tower at GGNS. 15 As described above, onsite activities during the construction of an NGCC plant would generate 16 fugitive dust as well as exhaust emissions from vehicles and motorized equipment. These 17 impacts would be short-term and construction crews would use applicable dust control 18 measures to minimize dust generation. 19 8.2.1.4 Hazardous Air Pollutants 20 In December 2000, EPA issued regulatory findings (65 FR 79825) on emissions of hazardous 21 air pollutants (HAPs) from electric utility steam -generating units, which identified that natural 22 gas-fired plants emit HAPs such as arsenic, formaldehyde and nickel and stated: 23 . . . the impacts due to HAP emissions from natural gas -fired electric utility steam 24 generating units were negligible based on the results of the study. The 25 Administrator finds that regulation of HAP emissions from natural gas -fired 26 electric utility steam generating units is not appropriate or necessary. 27 As a result of the EPA Administrator's conclusion, the staff finds no significant air quality effects 28 from HAPs. 29 8.2.1.5 Conclusion 30 The impact from SO 2 and NO X emissions would be noticeable and subject to a Title V permit. 31 GHG emissions also would be noticeable; CO 2 emissions would be almost two orders of 32 magnitude larger than the threshold in EPA's tailoring rule for GHG (75,000 tons [68,000 MT] 33 per year of carbon dioxide equivalent) that would trigger a regulated new source review. The 34 overall air quality impacts associated with construction and operation of an NGCC alternative 35 located at the GGNS site would be SMALL to MODERATE. 36 8.2.2 Groundwater Resources 37 The amount of groundwater required for construction of the NGCC alternative would be much 38 less than required during plant operation. Water for construction would be obtained from the 39 existing Ranney wells. Groundwater quality and use impacts from construction of the NGCC 40 alternative are expected to be SMALL. 41 The amount of water required to operate the three -unit NGCC alternative would be less than 42 that required for the existing power plant. Cooling water would be obtained from the existing 43 Ranney wells. Potable water and other plant groundwater requirements would be similar to 44 Environmental Impacts of Alternatives 8-16 GGNS. Groundwater quality and use impacts from operation of the NGCC alternative are 1 expected to be SMALL. 2 8.2.3 Surface Water Resources 3 If dredging of streams or rivers occurs during construction, surface water quality immediately 4 downstream of the dredging activities could be temporarily degraded by increased suspended 5 sediment. During plant operations, an NGC C alternative would discharge cooling system 6 blowdown at approximately half of the current facility rate. Stormwater discharge, blowdown, 7 sanitary, and other effluents would be permitted under an NPDES permit. Given these 8 assumptions, the impacts on surface water use and quality would be SMALL. 9 8.2.4 Aquatic Ecology 10 Construction activities for the NGCC alternative (such as construction of heavy -haul roads, a 11 new pipeline, and the power block) could affect onsite aquatic features, including the Mississippi 12 River near GGNS, Hamilton and Gin Lakes, a borrow pit, three small ponds, streams "A" and 13 "B," and ephemeral drainages. Minimal impacts on aquatic resources are expected because 14 the plant operator would likely implement BMPs to minimize erosion and sedimentation. 15 Stormwater control measures, which would be required to comply with Mississippi NPDES 16 permitting, would minimize the flow of disturbed soils into aquatic habitats. To bring new 17 materials to the site, NRC assumed the plant operator would dredge near the barge slip to 18 transport some materials using barges, which could result in increased sedimentation and 19 turbidity within aquatic habitats in the Mississippi River. Permits and certifications from the 20 U.S. Army Corps of Engineers and other agencies would require the implementation of BMPs to 21 minimize impacts. Due to the short -term nature of the dredging activities, the hydrological 22 alterations to aquatic habitats would be localized and temporary. 23 During operations, the NGCC alternative would require less cooling water to be withdrawn from 24 Ranney wells, and less water to be discharged into the Mississippi River than required for 25 GGNS. Therefore, thermal impacts would be less for the NGCC alternative than GGNS. The 26 cooling system for a new NGCC plant would have similar chemical discharges as GGNS. Air 27 emissions from the NGCC plant would emit particulates that would settle onto the river surface 28 and introduce a new source of pollutants as described in Section 8.1.1. However, the flow of 29 the Mississippi River would likely dissipate and dilute the concentration of pollutants resulting in 30 minimal exposure to aquatic biota. 31 Consultation under several Federal acts, including the ESA and Magnuson -Stevens Act, would 32 be required to assess the occurrence and potential impacts to Federally protected aquatic 33 species and habitats within affected surface waters. Coordination with State natural resource 34 agencies would further ensure that the NGCC operator would take appropriate steps to avoid or 35 mitigate impacts to State-listed species, habitats of conservation concern, and other protected 36 species and habitats. The NRC assumes that these consultations would result in avoidance or 37 mitigation measures that would minimize or eliminate potential impacts to protected aquatic 38 species and habitats. 39 The impacts on aquatic ecology would be minor because construction activities would require 40 BMPs and stormwater management permits. Also, surface water discharge for this alternative 41 would be less than for GGNS. Deposition of pollutants into aquatic habitats from the plant's ai r 42 emissions would be minimal because the concentration of pollutants would be diluted with the 43 river flow. Therefore, the staff concludes that impacts on aquatic ecology would be SMALL. 44 Environmental Impacts of Alternatives 8-17 8.2.5 Terrestrial Ecology 1 Construction of an NGCC alternative would occur on the GGNS site and would use existing 2 transmission lines. Because the onsite land requirement is relatively small (225 ac [91 ha]), the 3 entire NGCC alternative construction footprint would likely be sited in already developed areas 4 of the GGNS site, which would minimize impacts to terrestrial habitats and species. However, 5 the level of direct impacts would vary based on the specific location of new buildings and 6 infrastructure on the site. Offsite construction would occur mostly on land where gas extraction 7 is already occurring. Erosion and sedimentation, fugitive dust, and construction debris impacts 8 would be minor with implementation of BMPs. Construction noise could modify wildlife 9 behavior; however, these effects would be temporary. Road improvements or construction of 10 additional service roads to facilitate construction could result in the temporary or permanent loss 11 of terrestrial habitat. Construction of gas pipelines along existing, previously disturbed utility 12 corridors would result in temporary noise and displacement of wildlife, but would minimize the 13 removal or destruction of undisturbed habitats. Impacts to terrestrial habitats and species from 14 transmission line operation and corridor vegetation maintenance, and operation of the cooling 15 towers would be similar in magnitude and intensity as those resulting from GGNS and would, 16 therefore, be SMALL. Overall, the impacts of construction and operation of an NGCC 17 alternative to terrestrial habitats and species would be SMALL to MODERATE. 18 As discussed under aquatic ecology impacts, consultation with the FWS under the ESA would 19 ensure that the construction and operation of an NGCC alternative would not adversely affect 20 any Federally listed species or adversely modify or destroy designated critical habitat. 21 Coordination with State natural resource agencies would further ensure that the NGCC operator 22 would take appropriate steps to avoid or mitigate impacts to State -listed species, habitats of 23 conservation concern, and other protected species and habitats. The NRC assumes that these 24 consultations would result in avoidance or mitigation measures that would minimize or eliminate 25 potential impacts to protected terrestrial species and habitats. Consequently, the impacts of 26 construction and operation of a new nuclear alternative on protected species and habitats would 27 be SMALL. 28 8.2.6 Human Health 29 Impacts on human health from construction of the NGCC alternative would be similar to impacts 30 associated with the construction of any major industrial facility. Compliance with worker 31 protection rules would control those impacts on workers at acceptable levels. The plant 32 operator would likely follow BMPs, such as limiting active construction area access to 33 authorized individuals. Impacts on human health from the construction of the NGCC alternative 34 would be SMALL. 35 During operations, human health effects of gas -fired generation are generally low. However, in 36 Table 8.2 of the GEIS (NRC 1996), the staff identified cancer and emphysema as potential 37 health risks from gas -fired plants. NO x emissions contribute to ozone formation, which in turn 38 contributes to human health risks. Emission controls on the NGCC alternative can be expected 39 to maintain NO x emissions well below air quality standards established to protect human health, 40 and emissions trading or offset requirements mean that overall NO x releases in the region would 41 not increase. Health risks for workers also may result from handling spent catalysts used for 42 NO x control that may contain heavy metals. However, health risks can be minimized through 43 the use of occupational health and safety procedures and protective equipment. Impacts on 44 human health from the operation of the NGCC alternative would be SMALL. 45 Environmental Impacts of Alternatives 8-18 8.2.7 Land Use 1 The GEIS generically evaluates the impact of constructing and operating various replacement 2 power plant alternatives on land use, both on and off each plant site. The analysis of land use 3 impacts focuses on the amount of land area that would be affected by the construction and 4 operation of a three -unit NGCC power plant at the GGNS site. Locating the new NGCC power 5 plant at the GGNS site would maximize the availability of support infrastructure and reduce the 6 need for additional land. 7 Entergy estimated 195 acres (79 hectares) would be required for construction of power block, 8 support facilities and a natural gas pipeline to the nearest natural gas distribution line for a 9 1,584 MWe NGCC alternative (Entergy 2011). Depending on the location and availability of 10 existing natural gas pipelines, a 100 -ft-wide right -of-way would be needed for a new pipeline. 11 Land use impacts from NGCC construction would be SMALL to MODERATE. 12 In addition to onsite land requirements, land would be required off site for natural gas wells and 13 collection stations. Scaling from GEIS estimates, approximately 5,700 ac (2,307 ha) (based on 14 3,600 ac per 1,000 MWe and 1,584 MWe for NGCC) (NRC 1996) would be required for wells, 15 collection stations, and pipelines to bring the gas to the plant. Most of this land requirement 16 would occur on land where gas extraction already occurs. 17 The elimination of uranium fuel for GGNS would partially offset some of the land requirements 18 for an NGCC alternative. Scaling from GEIS estimates, approximately 1,033 ac (418 ha) (based 19 on 35 ac/yr disturbed per 1,000 MWe for 20 yr) would no longer be needed for mining and 20 processing uranium during the operating life of the plant (NRC 1996). Land use impacts during 21 power plant operations would be SMALL. 22 8.2.8 Socioeconomics 23 Socioeconomic impacts are defined in terms of changes to the demographic and economic 24 characteristics and social conditions of a region. For example, the number of jobs created by 25 the construction and operation of a power plant could affect regional employment, income, and 26 expenditures. 27 The alternative would create two types of jobs: (1) construction jobs, which are transient, short 28 in duration, and less likely to have a long -term socioeconomic impact; and (2) power plant 29 operation jobs, which have a greater potential for permanent, long -term socioeconomic impacts. 30 Workforce requirements for the construction and operation of the NGCC alternative were 31 evaluated for their possible effects on current socioeconomic conditions. 32 Scaling from GEIS estimates, the construction workforce would peak at 1,900 workers. The 33 relative economic impact of this many workers on the local economy and tax base would vary 34 with the greatest impacts occurring in the communities where the majority of construction 35 workers would reside and spend their income. As a result, local communities could experience 36 a short-term economic "boom" from increased tax revenue and income generated by 37 construction expenditures and the increased demand for temporary (rental) housing and 38 business services. 39 After completing the installation of the three-unit NGCC plant, local communities could 40 experience a return to pre -construction economic conditions. Based on this information and 41 given the number of workers, socioeconomic impacts during construction in communities near 42 the GGNS site could range from SMALL to MODERATE. 43 Scaling from GEIS estimates, an NGCC alternative would employ approximately 150 workers 44 during operation. GGNS has an operation workforce of approximately 690. The potential 45 Environmental Impacts of Alternatives 8-19 reduction in overall employment at the GGNS site would likely affect property tax revenue and 1 income in local communities and businesses. In addition, the permanent housing market could 2 also experience increased vacancies and decreased prices if operations workers and their 3 families move out of the region. Socioeconomic impacts during operations of an NGCC 4 alternative could range from SMALL to MODERATE. 5 8.2.9 Transportation 6 Transportation impacts associated with construction and operation of an NGCC alternative 7 would consist of commuting workers and truck deliveries of construction materials. During 8 periods of peak construction activity, up to 1,900 worker would be commuting daily to GGNS, a 9 substantial increase from the GGNS current operational force of 690 workers. The increase in 10 vehicular traffic would peak during shift changes, resulting in temporary levels of service 11 impacts and delays at intersections. Pipeline construction and modification to existing natural 12 gas pipeline systems could also have a temporary impact. Materials also could be delivered by 13 barge or rail. Traffic -related transportation impacts during construction likely would be 14 MODERATE. 15 Traffic-related transportation impacts would be greatly reduced after completing the installation 16 of the NGCC alternative. Transportation impacts would include daily commuting by the 17 operating workforce, equipment and materials deliveries, and the removal of commercial waste 18 material to offsite disposal or recycling facilities by truck. The estimated NGCC alternative 19 operation workforce of approximately 150 is considerably less than the GGNS operation 20 workforce of approximately 690. Traffic-related transportation impacts would be considerably 21 less than current operations because an NGCC alternative would employ far fewer workers than 22 the existing GGNS. Since fuel is transported by pipeline, the transportation infrastructure would 23 experience little to no increased traffic from fuel operations. Overall, transportation impacts 24 would be SMALL during plant operations. 25 8.2.10 Aesthetics 26 The analysis of aesthetic impacts focuses on the degree of contrast between an NGCC 27 alternative and the surrounding landscape and the visibility of an NGCC alternative at the 28 GGNS site. During construction, clearing and excavation would occur on site. Some of these 29 activities may be visible from offsite roads. Since the GGNS site already appears industrial, 30 construction of an NGCC alternative would appear similar to onsite activities during refueling 31 outages. 32 The three NGCC units would be approximately 100 ft (30 m) tall, with exhaust stacks up to 33 150 ft (46 m) tall. The facility would be visible off site during daylight hours, and some 34 structures may require aircraft warning lights. The plant would use the existing natural draft 35 cooling tower, which is over 500 ft (152 m) high (Entergy 2011). Noise generated during NGCC 36 power plant operations would be limited to routine industrial processes and communications. 37 Pipelines delivering natural gas fuel could be audible off site near gas compressor stations. 38 In general, given the industrial appearance of the GGNS site, an NGCC alternative would blend 39 in with the surroundings if the existing GGNS facility remains. Aesthetic changes would be 40 limited to the immediate vicinity of the existing GGNS site, and any impacts would be SMALL. 41 8.2.11 Historic and Archaeological Resources 42 The potential for impacts on historic and archaeological resources from an NGCC alternative 43 would vary greatly depending on the location of the proposed plants on the GGNS site. Any 44 Environmental Impacts of Alternatives 8-20 construction would need to avoid the previously identified Grand Gulf Mound area 1 (Site 22Cb522) and Archaic Period village (22Cb528) as described in Section 2.2.10.2 of this 2 document. As portions of the GGNS site have been previously identified as not containing 3 significant historic and archaeological resources, use of these areas for an NGCC alternative 4 would result in a SMALL impact on historic and archaeological resources. Alternate plant and 5 new pipeline locations would need to be surveyed and inventoried for potential resources. 6 Resources found in these surveys would need to be evaluated for eligibility on the National 7 Register of Historic Places (NRHP) and mitigation of adverse effects would need to be 8 addressed if eligible resources were encountered. The level of impact at these locations would 9 vary depending on the specific resources found to be present in the area of potential effect. 10 However, given that the preference is to use previously surveyed and/or disturbed areas, 11 avoidance of significant historic and archaeological resources should be possible and effectively 12 managed under current laws and regulations. Therefore, the impacts on historic and 13 archaeological resources from the NGCC alternative would be SMALL. 14 8.2.12 Environmental Justice 15 The environmental justice impact analysis evaluates the potential for disproportionately high and 16 adverse human health, environmental, and socioeconomic effects on minority and low -income 17 populations that could result from the construction and operation of a new power plant. As 18 previously discussed in Section 8.1.12, such effects may include human health, biological, 19 cultural, economic, or social impacts. Section 4.10.7, Environmental Justice, presents 20 demographic information about minority and low -income populations residing in the vicinity of 21 the GGNS site. 22 Potential impacts to minority and low -income populations from the construction and operation of 23 an NGCC alternative at the GGNS site would mostly consist of environmental and 24 socioeconomic effects (e.g., noise, dust, traffic, employment, and housing impacts). Noise and 25 dust impacts during construction would be short -term and primarily limited to onsite activities. 26 Minority and low -income populations residing along site access roads would be directly affected 27 by increased commuter and truck traffic. However, because of the temporary nature of 28 construction, these effects are not likely to be high and adverse and would be contained to a 29 limited time period during certain hours of the day. Increased demand for rental housing during 30 construction could cause rental costs to rise disproportionately affecting low -income populations 31 living near GGNS who rely on inexpensive housing. However, given the proximity of GGNS to 32 the Jackson and Vicksburg metropolitan areas, workers could commute to the construction site, 33 thereby reducing the need for rental housing. 34 As discussed in Section 4.10.7.1, 144 of the 294 census block groups located within the 50 -mi 35 (80-km) radius of GGNS were determined to have meaningfully greater minority populations 36 than the other census block groups within the 50 -mi (80-km) radius of GGNS. However, 37 emissions from the NGCC alternative are expected to be maintained within regulatory 38 standards. Accordingly, disproportionately high and adverse impacts on minority and low 39 income populations are not expected. 40 Based on this information and the analysis of human health and environmental impacts 41 presented in this section, the construction and operation of an NGCC alternative would not have 42 disproportionately high and adverse human health and environmental effects on minority and 43 low-income populations in the vicinity of GGNS. 44 Environmental Impacts of Alternatives 8-21 8.2.13 Waste Management 1 During the construction stage of this alternative, land clearing and other construction activities 2 would generate waste that can be recycled, disposed of on site, or shipped to an offsite waste 3 disposal facility. Because an NGCC alternative would most likely be constructed on previously 4 disturbed portions of the GGNS site, the amount of wastes produced during land clearing would 5 be minimal. 6 During the operational stage, spent selective catalytic reduction catalysts used to control NO x 7 emissions would make up the majority of the industrial waste generated by this alternative. 8 Because the specific NO x emission control equipment cannot be specified at this time, the 9 amount of spent catalysts that would be generated during each year of operation of the NGCC 10 alternative also cannot be calculated with precision. However, the amount would be modest. 11 During operations, domestic and sanitary wastes would be expected to decrease from amounts 12 now generated because of a reduced operating workforce for the NGCC alternative in 13 comparison to GGNS. 14 According to the GEIS (NRC 1996) a natural gas -fired plant would generate minimal waste; 15 therefore, waste impacts would be SMALL for an NGCC alternative located at the GGNS site. 16 8.2.14 Summary of Impacts of NGCC Alternative 17 Table 8-3 summarizes the environmental impacts of the NGCC alternative compared to 18 continued operation of GGNS. 19 Table 8-3. Summary of Environmental Impacts of the NGCC Alternative 20 Compared to Continued Operation of GGNS 21 Category NGCC Alternative (use existing infrastructure) Continued GGNS Operation Air Quality SMALL to MODERATE SMALL Groundwater Resources SMALL SMALL Surface Water Resources SMALL SMALL Aquatic Ecology SMALL SMALL Terrestrial Ecology SMALL to MODERATE SMALL Human Health SMALL SMALL Land Use SMALL to MODERATE SMALL Socioeconomics SMALL to MODERATE SMALL Transportation SMALL to MODERATE SMALL Aesthetics SMALL SMALL Historic and Archaeological Resources SMALL SMALL Waste Management a SMALL SMALL a As described in Chapter 6, the issue, "offsite radiological impacts (spent fuel and high level waste disposal)," is not evaluated in this EIS.

8.3 Supercritical

Pulverized Coal -Fired Generation 22 In this section, the NRC evaluates the environmental impacts of supercritical pulverized coal 23 (SCPC) generation. 24 In 2010, coal -fired generation accounted for 25 percent of all electricity generated in Mississippi, 25 a 32 percent decrease from 10 years earlier in 2000 (EIA 2012b). Coal provides the second 26 greatest share of electrical power in Mississippi (EIA 2012b). Historically, coal has been the 27 Environmental Impacts of Alternatives 8-22 largest source of electricity in the United States and is expected to remain so through 2035 1 (EIA 2011a). Supercritical coal -fired plants are a feasible, commercially available option for 2 providing electrical generating capacity beyond GGNS's current license expiration. Therefore, 3 the NRC considered supercritical coal -fired generation a reasonable alternative to GGNS 4 license renewal. 5 Baseload coal units have proven their reliability and can routinely sustain capacity factors as 6 high as 85 percent. Among the technologies available, pulverized coal boilers producing 7 supercritical steam (SCPC boilers) are increasingly common for new coal -fired plants given their 8 generally high thermal efficiencies and overall reliability. Although SCPC facilities are more 9 expensive to construct than subcritical coal -fired plants, SCPC facilities consume less fuel per 10 unit output, reducing environmental impacts. In a supercritical coal -fired power plant, burning 11 coal heats pressurized water. As the supercritical steam and water mixture moves through 12 plant pipes to a turbine generator, the pressure drops and the mixture flashes to steam. The 13 heated steam expands across the turbine stages, which then spin and turn the generator to 14 produce electricity. After passing through the turbine, any remaining steam is condensed back 15 to water in the plant's condenser. 16 To replace the 1,475 MWe that GGNS generates, the NRC considered three hypothetical SCPC 17 units, each with a net capacity of 538 MWe. The hypothetical SCPC alternative would be 18 located at a site other than GGNS because insufficient space exists at the GGNS site to support 19 this alternative (Entergy 2011). The NRC assumes that the SCPC site would be located in 20 Mississippi. Using an existing site (such as an existing power plant site) would maximize 21 availability of infrastructure and reduce disruption to land and populations. However, impacts 22 would be greater if the SCPC alternative were located at a site that has been previously 23 disturbed but not located at an existing power plant site. For example, the site might need new 24 intake and discharge facilities and a new cooling system. The SCPC alternative would use 25 about the same amount of water as GGNS, and the NRC assumes the cooling system would 26 use a closed-cycle system with natural draft cooling towers. 27 Various coal sources are available to coal -fired power plants in Mississippi. For the purpose of 28 this evaluation, the NRC assumes that the SCPC alternative would burn a combination of 29 lignite, bituminous, and subbituminous coal, based on the type of coal used in electric plants in 30 Mississippi. Coal -fired power plants in Mississippi are fueled by coal shipped primarily from 31 Mississippi, Colorado, and Wyoming. EIA reported that in 2009, Mississippi produced electricity 32 from coal with a heating value of 8,541 BTU/lb, sulfur content of 0.53 percent, and ash content 33 of 11.27 percent (EIA 2010a). The NRC used a CO 2 emission factor of 210 lb/million BTU for 34 CO 2 calculations in this evaluation, based on the type of coal burned in Mississippi and CO 2 35 emissions factors for types of coal as reported by the EIA (EIA 2012c). Based on technology 36 forecasts from EIA, the staff expects that the SCPC alternative would operate at a heat rate of 37 8,740 BTU/kWh (EIA 2011b). Depending on the specific site, construction of onsite visible 38 structures could include the boilers, exhaust stacks, intake/discharge structures, transmission 39 lines, and an electrical switchyard. Based on GEIS estimates, the SCPC alternative would 40 require approximately 2,744 ac (1,110 ha) of land, although it is assumed that most of this land 41 would have been previously disturbed. To build the SCPC alternative, site crews would clear 42 the plant site of vegetation, prepare the site surface, and begin excavation before other crews 43 began actual construction on the plant and associated infrastructure. Construction materials 44 would be delivered by rail spur, truck, or barge. 45 The NRC also considered an integrated gasification combined-cycle (IGCC) coal -fired plant. 46 IGCC is an emerging technology for generating electricity with coal that combines modern coal 47 gasification technology with both gas -turbine and steam -turbine power generation. The 48 technology is cleaner than conventional pulverized coal plants because major pollutants can be 49 Environmental Impacts of Alternatives 8-23 removed from the gas stream before combustion. An IGCC alternative would also generate 1 less waste than the pulverized coal -fired alternative. IGCC units do not produce ash or 2 scrubber wastes. In spite of the advantages, the NRC concludes that a new IGCC plant is not a 3 reasonable alternative for the following reasons: 4 The few existing IGCC plants in the United States have considerably smaller 5 capacity (approximately 250 MWe each) than GGNS (1,475 MWe); 6 System reliability of existing IGCC plants has been lower than pulverized coal 7 plants; 8 IGCC plants are more expensive than comparable pulverized coal plants 9 (NETL 2007); 10 Existing IGCC plants have had an extended (though ultimately successful) 11 operational testing period (NPCC 2005); and, 12 A lack of overall plant performance warranties for IGCC plants has hindered 13 commercial financing (NPCC 2005). 14 Mississippi Power is constructing a 582 MWe IGCC plant in Kemper County, Mississippi. The 15 plant is scheduled to begin operations in May 2014 and is experiencing legal, regulatory, and 16 financial challenges (Reuters 2012). 17 8.3.1 Air Quality 18 Mississippi contains three designated air quality control regions

the Northeast Mississippi 19 Intrastate Air Quality Control Region (AQCR); the Mobile (Alabama)

-Pensacola-Panama City 20 (Florida)-Southern Mississippi Interstate AQCR; a nd, the Mississippi Delta Intrastate AQCR 21 (40 CFR 81.62, 40 CFR 81.68, 40 CFR 81.122 ). The State of Mississippi is in attainment with 22 national primary and secondary air quality standards for all criteria pollutants , except De Soto 23 County which is located about 200 miles (322 km) north-northeast of GGNS and part of which is 24 designated as a marginal nonattainment area for the 2008 8 -hour ozone standard. 25 Construction activities for this alternative would generate fugitive dust. However, mitigation 26 measures, including wetting of unpaved roads and construction areas, and seeding or mulching 27 bare areas would minimize fugitive dust. Construction worker vehicles and motorized 28 construction equipment would create exhaust emissions. However, these emissions would end 29 upon completion of construction. 30 Various Federal and State regulations aimed at controlling air pollution would affect the SCPC 31 alternative. A new SCPC plant would qualify as a new major -emitting industrial facility and 32 would require a PSD permit if the location is in attainment or unclassifiable with the NAAQS and 33 a Title V operating permit that would specify limits to emissions of all criteria pollutants. 34 The SCPC alternative would also need to comply with new source performance standards (see 35 40 CFR 60 Subpart Da and limits for particulate matter and opacity (40 CFR 60.42(a)), SO 2 36 (40 CFR 60.43(a)), and NO x (40 CFR 60.44 Subpart Da(a)(1)). If the SCPC alternative were 37 located close to a mandatory Class I area, additional air pollution control requirements would be 38 required (Subpart P of 40 CFR Part 51) as mandated by the Regional Haze Rule. The rule 39 would not apply to this coal -fired alternative, however, because there are no Class I Federal 40 areas within 186 mi (300 km) of the GGNS site (EPA 2012b). 41 Emissions from the SCPC alternative, projected by the staff based on published EIA data, EPA 42 emission factors, and performance characteristics for this alternative and likely emission 43 controls, would be: 44 Environmental Impacts of Alternatives 8-24 sulfur oxides (SO X)-2,869 tons (2,603 MT) per year 1 nitrogen oxides (NO X)-3,118 tons (2,829 MT) per year 2 particulate matter (PM 10)-80 tons (73 MT) per year 3 (PM2.5)-21 tons (19 MT) per year 4 carbon monoxide (CO) -1,547 tons (1,403 MT) per year 5 carbon dioxide (CO 2)-11.1 million tons (10.1 million MT) per year 6 8.3.1.1 Sulfur Oxide and Nitrogen Oxide 7 As stated above, the SCPC alternative would produce 2,869 tons (2,603 MT) total SO X 8 emissions per year. SO 2 emissions from an SCPC alternative would be subject to the 9 requirements of Title IV of the CAA. Title IV regulations were enacted to reduce emissions of 10 SO 2 and NO x by restricting emissions of these pollutants from power plants. Title IV caps 11 aggregate annual power plant SO 2 emissions and imposes controls on SO 2 emissions through a 12 system of marketable allowances. EPA issues one allowance for each ton of SO 2 that a unit is 13 allowed to emit. New units do not receive allowances, but are required to have secured 14 allowances (or offsets) from existing sources to cover their SO 2 emissions. Owners of new units 15 must therefore purchase allowances from owners of other power plants or reduce SO 2 16 emissions at other power plants they own. Allowances can be banked for use in future years. 17 Thus, provided a new SCPC power plant is able to purchase sufficient allowances to operate, it 18 would not add to net regional SO 2 emissions, although it might do so locally. 19 An SCPC alternative at an alternate site would most likely employ various available NO x control 20 technologies, which can involve combustion modifications, post -combustion controls, or both. 21 Combustion modifications include low -NO x burners, overfire air, and operational modifications. 22 Post-combustion processes include selective catalytic reduction and selective non -catalytic 23 reduction. An effective combination of the combustion modifications and post -combustion 24 processes allow the reduction of NO x emissions by up to 95 percent. 25 8.3.1.2 Greenhouse Gases 26 An SCPC alternative would release GHGs, such as CO 2 during operations as well as during 27 mining, processing, and transportation, which the GEIS indicates could contribute to global 28 warming and connected climate changes. The amount of CO 2 released per unit of power 29 produced would depend on the quality of the fuel and the firing conditions and overall firing 30 efficiency of the boiler. As discussed above, the NRC assumes that a coal -fired alternative 31 would burn the same coal as was burned in Mississippi in 2009 with a CO 2 emission factor of 32 210 lb/million BTU. 33 On July 12, 2012, EPA issued a final rule tailoring the criteria that determine which stationary 34 sources and modifications to existing projects become subject to permitting requirements for 35 GHG emissions under the PSD and Title V Programs of the CAA (77 FR 41051). According to 36 this rule, GHGs are a regulated new source review pollutant under the PSD major source 37 permitting program if the source is otherwise subject to PSD (for another regulated new source 38 review pollutant) and has a GHG potential to emit equal to or greater than 75,000 tons 39 (68,000 MT) per year of CO 2 equivalent ("carbon dioxide equivalent" adjusts for different global 40 warming potentials for different GHGs). Beginning January 2, 2011, operating permits issued to 41 major sources of GHGs under the PSD or Title V Federal permit programs must contain 42 provisions requiring the use of Best Available Control Technology (BACT) to limit the emissions 43 of GHGs if those sources would be subject to PSD or Title V permitting requirements. If the 44 SCPC alternative meets the GHG emission thresholds established in the rule, then GHG 45 emissions from this alternative would be regulated under the PSD and Title V permit programs. 46 Environmental Impacts of Alternatives 8-25 8.3.1.3 Particulates 1 As described above, onsite activities during the construction of an SCPC alternative would also 2 generate fugitive dust as well as emissions from vehicles and motorized equipment. These 3 impacts would be intermittent, temporary, and minimized by dust -control measures. 4 During operations, the SCPC alternative would produce 80 tons (73 MT) per year and 21 tons 5 (19 MT) per year of particulate matter PM 10 and PM2.5 , respectively. The SCPC alternative 6 would use fabric filters to remove particulates from flue gases with an expected 99.9 percent 7 removal efficiency (NETL 2007). Coal -handling equipment would introduce fugitive dust 8 emissions when fuel is being transferred to onsite storage and then moved from storage for use 9 in the plant. 10 8.3.1.4 Hazardous Air Pollutants 11 In addition to being major sources of criteria pollutants, coal -fired plants can also be sources of 12 HAPs as a result of hazardous constituents contained in the coal. EPA has determined that 13 coal- and oil-fired electric utility steam -generating units are significant emitters of the following 14 HAPs: arsenic, beryllium, cadmium, chromium, dioxins, hydrogen chloride, hydrogen fluoride, 15 lead, manganese, and mercury (EPA 2000b). EPA concluded that mercury is the HAP of 16 greatest concern and that (1) a link exists between coal combustion and mercury emissions, 17 (2) electric utility steam -generating units are the largest domestic source of mercury emissions, 18 and (3) certain segments of the U.S. population (e.g., the developing fetus and subsistence 19 fish-eating populations) are believed to be at potential risk of adverse health effects resulting 20 from mercury exposures caused by the consumption of contaminated fish (EPA 2000b). 21 Consequently, the SCPC alternative would be subject to the Mercury and Air Toxics Standards 22 rule that was finalized in March 2011. The rule set technology -based emission limitation 23 standards for all HAPs. The rule applies to coal -fired power plants with a capacity of 25 MWe or 24 greater. 25 8.3.1.5 Conclusion 26 While the GElS mentions global warming from unregulated CO 2 emissions and acid rain from 27 SO 2 and NO x emissions as potential impacts, it does not quantify emissions from coal-fired 28 power plants. However, the GElS does imply that air impacts from coal plant operation would 29 be substantial (NRC 1996). The above analysis shows that emissions of air pollutants, 30 including SO x, NO x, CO, and particulates, far exceed those produced by the existing nuclear 31 power plant during operation, as well as those of the other fossil fuel alternatives considered in 32 this section. The NRC analysis of air quality impacts for an SCPC alternative indicates that 33 impacts would have clearly noticeable effects, but given existing regulatory regimes, permit 34 requirements, and emissions controls, the coal -fired alternative would not destabilize air quality. 35 Federal and state regulations would require the installation of pollution control equipment to 36 meet applicable local requirements and permit conditions and may eventually require 37 participation in emissions trading scenarios. Therefore, air impacts from an SCPC alternative 38 located at an alternate site would be MODERATE. 39 8.3.2 Groundwater Resources 40 The amount of groundwater required for construction of the SCPC alternative would be much 41 less than required during plant operation. NRC assumes that ground water use for construction 42 would comply with State and local permit and monitoring requirements. Groundwater quality 43 and use impacts from construction of the SCPC alternative are expected to be SMALL. 44 The amount of water required to operate the SCPC alternative would be similar to that required 45 for GGNS. Potable water and other plant groundwater requirements would be similar to GGNS. 46 Environmental Impacts of Alternatives 8-26 Coal, fly ash, and clinker storage could cause groundwater contamination, but with proper 1 storage facility design and operation, the impacts could be mitigated. Given these assumptions, 2 the impacts to groundwater use and quality would be SMALL. 3 8.3.3 Surface Water Resources 4 The SCPC cooling system would consist of natural draft cooling towers requiring approximately 5 the same amount of water as the existing nuclear plant. Within the service territory, the 6 Mississippi River, other rivers, alluvial aquifers, or reservoirs might be a source of cooling water. 7 If the Mississippi River or its alluvial aquifer w as used, other consumers of surface water are 8 unlikely to be affected because of the large volume of water flowing within the river and in its 9 alluvium. In other rivers, if the amount of water flowing is large, the impact on other surface 10 water users is likely to be minor. If the water flow is moderate and there are few other surface 11 water users, the impact on other surface water users should also be minor. However, impacts 12 on other surface water users could result in the case of a small river with many surface water 13 users. The NRC assumes that the SCPC would not be sited on a small river with many surface 14 water users. These impacts could be mitigated by the use of more efficient cooling technology 15 or other water sources (i.e., import water, perhaps by pipeline from other surface water bodies). 16 If dredging of streams or rivers occurs during construction, surface water quality immediately 17 downstream of the dredging activities could be temporarily degraded by increases in suspended 18 sediment concentration. During plant operation, surface water discharges largely would consist 19 of cooling tower blowdown similar to GGNS. Assuming public sewers are not available, process 20 waste and treated sanitary wastewater effluent may also be discharged to the surface water 21 body. An NPDES permit would regulate discharges. Runoff from coal storage, fly ash, and 22 clinker material would be controlled and regulated by an NPDES permit. Overall, impacts to 23 surface water use and quality would be SMALL. 24 8.3.4 Aquatic Ecology 25 Construction activities for the SCPC alternative (such as construction of heavy -haul roads and 26 the power block) could affect onsite aquatic features. Minimal impacts on aquatic ecology 27 resources are expected because the plant operator would likely implement BMPs to minimize 28 erosion and sedimentation. Stormwater control measures, which would be required to comply 29 with Mississippi NPDES permitting, would minimize the flow of disturbed soils into aquatic 30 habitats. Depending on the available infrastructure at the selected site, the SCPC alternative 31 may require modification or expansion of the existing intake or discharge structures, or 32 construction of new intake and discharge structures. Construction of new or modified intake 33 and discharge structures may require dredging. In addition, dredging may be required to 34 transport new materials to the site, which could result in increased sedimentation and turbidity. 35 Dredging activities would require BMPs for in -water work to minimize sedimentation and 36 erosion. Due to the short -term nature of the dredging activities, the hydrological alterations to 37 aquatic habitats would likely be localized and temporary. 38 During operations, the SCPC alternative would require a similar amount of cooling water as 39 GGNS. However, the cooling water may be withdrawn from surface water bodies, rather than 40 from groundwater. If the cooling water is withdrawn from surface water bodies, aquatic 41 resources may be impacted from impingement and entrainment. Impingement and 42 entertainment would be minimized because NRC assumes that the plant would use a 43 closed-cycle cooling system. A similar amount of water would be discharged as at GGNS. 44 Therefore, thermal impacts would be similar for the SCPC alternative as for GGNS. The cooling 45 system for a new SCPC plant would have similar chemical discharges as GGNS, but the air 46 Environmental Impacts of Alternatives 8-27 emissions from the SCPC plant would emit ash and particulates that could settle onto a river 1 surface and introduce a new source of pollutants. However, the flow of the river would likely 2 dissipate and dilute the concentration of pollutants resulting in minimal exposure to aquatic 3 biota. 4 Consultation under several Federal acts, including the ESA and Magnuson -Stevens Act, would 5 be required to assess the occurrence and potential impacts to Federally protected aquatic 6 species and habitats within affected surface waters. Coordination with Mississippi natural 7 resource agencies would further ensure that the plant operator would take appropriate steps t o 8 avoid or mitigate impacts to state-listed species, habitats of conservation concern, and other 9 protected species and habitats. The NRC assumes that these consultations would result in 10 avoidance or mitigation measures that would minimize or eliminate potential impacts to 11 protected aquatic species and habitats. 12 The impacts on aquatic ecology would be minor because construction activities would require 13 BMPs and stormwater management permits. Deposition of pollutants into aquatic habitats from 14 the plant's air emissions would be minimal because the concentration of pollutants would be 15 diluted with the river flow. Therefore, the staff concludes that impacts on aquatic ecology would 16 be SMALL. 17 8.3.5 Terrestrial Ecology 18 Construction of an SCPC alternative would require 2,744 ac (1,110 ha) of land, which would 19 include construction of the plant and associated infrastructure. The SCPC alternative may 20 require up to 35,508 ac (14,370 ha) of additional land for coal mining and processing. Because 21 of the relatively large land requirement for the site, a portion of the site would likely be land that 22 had not been previously disturbed, which would directly affect terrestrial habitat by destroying 23 existing vegetation communities and displacing wildlife. This alternative could also include 24 construction of new transmission lines and a railroad spur, depending on the specific site, which 25 would require additional habitat loss and fragmentation. Thus, the level of direct impacts would 26 vary substantially based on site selection. Offsite construction would occur mostly on land 27 where coal extraction is ongoing. Erosion and sedimentation, fugitive dust, and construction 28 debris impacts would be minor with implementation of appropriate BMPs. Construction noise 29 could modify wildlife behavior; however, these effects would be temporary. Road improvements 30 or construction of additional service roads to facilitate construction could result in the temporary 31 or permanent loss of terrestrial habitat. Operational impacts to terrestrial habitats and species 32 from transmission line operation and corridor vegetation maintenance, and operation of the 33 cooling system would be similar in magnitude and intensity as those resulting from GGNS. 34 Because of the potentially large area of undisturbed habitat that could be affected from 35 construction of an SCPC alternative, the impacts of construction to terrestrial habitats and 36 species could range from MODERATE to LARGE depending on the specific site location. The 37 impacts of operation would be SMALL to MODERATE. 38 As discussed under aquatic ecology impacts, consultation with FWS under the ESA would avoid 39 potential ly adverse impacts to Federally listed species or adverse modification or destruction of 40 designated critical habitat. Coordination with State natural resource agencies would further 41 ensure that the plant operator would take appropriate steps to avoid or mitigate impacts to 42 State-listed species, habitats of conservation concern, and other protected species and habitats. 43 The NRC assumes that these consultations would result in avoidance or mitigation measures 44 that would minimize or eliminate potential impacts to protected terrestrial species and habitats. 45 Consequently, the impacts of construction and operation of a new nuclear alternative on 46 protected species and habitats would be SMALL. 47 Environmental Impacts of Alternatives 8-28 8.3.6 Human Health 1 Impacts on human health from construction of the SCPC alternative would be similar to impacts 2 associated with the construction of any major industrial facility. Compliance with worker 3 protection rules would control those impacts on workers at acceptable levels. Impacts from 4 construction on the general public would be minimal because the plant operator would likely 5 follow BMPs and limit access to the active construction area to authorized individuals. Impacts 6 on human health from the construction of the SCPC alternative would be SMALL. 7 Coal-fired power plants introduce worker risks from coal and limestone mining, coal and 8 limestone transportation, and disposal of coal combustion residues and scrubber wastes. In 9 addition, there are public risks from inhalation of stack emissions and the secondary effects of 10 eating foods grown in areas subject to deposition from plant stacks. 11 Human health risks of coal -fired power plants are described, in general, in Table 8.2 of the GEIS 12 (NRC 1996). Cancer and emphysema as a result of the inhalation of toxins and particulates are 13 identified as potential health risks to occupational workers and members of the public 14 (NRC 1996). The human health risks associated with coal -fired power plants, both for 15 occupational workers and members of the public, are greater than those of the current GGNS 16 reactor , because of exposures to chemicals such as mercury; SO x; NO x; radioactive elements, 17 such as uranium and thorium contained in coal and coal ash; and polycyclic aromatic 18 hydrocarbon (PAH) compounds, including benzo(a)pyrene. 19 Regulations restricting emissions enforced by either EPA or delegated state agencies have 20 reduced potential health effects, but have not entirely eliminated them. These agencies also 21 impose site -specific emission limits as needed to protect human health. Even if the SCPC 22 alternative were located in a nonattainment area, emission controls and trading or offset 23 mechanisms could prevent further regional degradation; however, local effects could be visible. 24 Many of the byproducts of coal combustion responsible for health effects are largely controlled, 25 captured, or converted in modern power plants, although some level of health effects may 26 remain. 27 Aside from emissions impacts, the SCPC alternative introduces the risk of coal pile fires and for 28 those plants that manage coal combustion residue liquids and sludge in waste impoundments, 29 the release of the waste may result because of a failure of the impoundment. Good 30 housekeeping practices to control coal dust greatly reduce the potential for coal dust explosions 31 or coal pile fires. Although there have been several instances in recent years, sludge 32 impoundment failures are still rare. Free water could also be recovered from such waste 33 streams and recycled and the solid or semi -solid portions removed to permitted offsite disposal 34 facilities. 35 Overall, given extensive health -based regulation and controls likely to be imposed as permit 36 conditions applicable to waste handling and disposal, the staff expects human health impacts 37 from operation of the SCPC alternative at an alternate site to be SMAL L. 38 8.3.7 Land Use 39 The GEIS generically evaluates the impact of constructing and operating various replacement 40 power plant alternatives on land use, both on and off each power plant site. The analysis of 41 land use impacts focuses on the amount of land area that would be affected by the construction 42 and operation of an SCPC power plant at an existing power plant site other than GGNS. 43 Based on scaled GEIS estimates, approximately 2 ,744 ac (1,100 ha) would be needed to 44 support an SCPC alternative to replace GGNS, excluding land needed for coal mining and 45 Environmental Impacts of Alternatives 8-29 processing. It is expected that the SCPC alternative would be located at an existing power plant 1 site or otherwise disturbed industrial site, and thus the land use impacts from construction would 2 range from SMALL to MODERATE. 3 Offsite land use impacts would occur from coal mining, in addition to land use impacts from the 4 construction and operation of the new power plant. Using the GEIS estimate, the SCPC 5 alternative might require up to 35,508 ac (14,370 ha) of land for coal mining and waste disposal 6 during power plant operations, based on an assumption of 22,000 ac (8,903 ha) of land required 7 per 1,000 MWe and a 1,614 MWe SCPC plant (NRC 1996). However, much of the land in 8 existing coal mining areas has already experienced some level of disturbance. 9 The elimination of uranium fuel for GGNS would partially offset some of the land requirements 10 for the SCPC alternative. Scaling from GEIS estimates, approximately 1,033 ac (418 ha) 11 (based on an assumption of 35 ac/yr disturbed per 1,000 MWe) would no longer be needed for 12 mining and processing uranium during the operating life of the SCPC plant (NRC 1996). 13 Overall, land use impacts from SCPC power plant operations would be SMALL to MODERATE 14 depending on the extent of coal mining. 15 8.3.8 Socioeconomics 16 As previously discussed, socioeconomic impacts are defined in terms of changes to the 17 demographic and economic characteristics and social condition of a region. For example, the 18 number of jobs created by the construction and operation of a power plant could affect regional 19 employment, income, and expenditures. This alternative would create two types of jobs

20 (1) construction jobs, which are transient, short in duration, and less likely to have a long

-term 21 socioeconomic impacts; and (2) power plant operation jobs, which have a greater potential for 22 permanent, long -term socioeconomic impacts. Workforce requirements for the construction and 23 operation of the SCPC alternative were evaluated to measure their possible effects on current 24 socioeconomic conditions . 25 Scaling from GEIS estimates, the construction workforce would peak at 4,035 workers. The 26 relative economic impact of this many workers on the local economy and tax base would vary, 27 with the greatest impacts occurring in the communities where the majority of construction 28 workers would reside and spend their income. As a result, local communities could experience 29 a short-term "boom" from increased tax revenue and income generated by construction 30 expenditures and the increased demand for temporary (rental) housing and business services. 31 After construction, local communities could be temporarily affected by the loss of construction 32 jobs, the associated loss in demand for business services, and the rental housing market could 33 experience increased vacancies and decreased prices. The impact of construction on 34 socioeconomic conditions could range from SMALL to MODERATE because of the fluctuation 35 of the workforce. 36 Scaling from GEIS estimates, the workforce during plant operations would be 404 workers. This 37 alternative would result in a loss of approximately 690 relatively high -paying jobs at GGNS, with 38 a corresponding reduction in purchasing activity and tax contributions to the regional economy. 39 However, a larger amount of property taxes may be paid to local jurisdictions under the SCPC 40 alternative as more land may be required for coal -fired power plant operations than GGNS. 41 Therefore, socioeconomic impacts during operations could range from SMALL to MODERATE. 42 8.3.9 Transportation 43 Transportation impacts associated with construction of the SCPC alternative would consist of 44 commuting workers and truck deliveries of construction materials. During periods of peak 45 Environmental Impacts of Alternatives 8-30 construction activity, 4,035 workers could be commuting daily to the site significantly adding to 1 the normal flow of traffic (NRC 1996). Vehicular traffic would peak during shift changes, 2 resulting in temporary levels of service impacts and delays at intersections. Materials also could 3 be delivered by rail or barge, depending on site location. Traffic -related transportation impacts 4 during construction likely would range from MODERATE to LARGE. 5 Once construction of the SCPC alternative is complete, traffic-related transportation impacts on 6 local roads would be greatly reduced. The estimated number of operations workers would be 7 404 (NRC 1996). Traffic on roadways would peak during shift changes, resulting in temporary 8 levels of service impacts and delays at intersections. Frequent deliveries of coal and limestone 9 by rail would cause levels of service impacts on certain roads because of delays at railroad 10 crossings. Onsite coal storage would make it possible to receive several trains per day at a site 11 with rail access. Limestone delivered by rail could also add additional traffic (though 12 considerably less traffic than that generated by coal deliveries). If a site on navigable waters 13 were used, barge delivery of coal and other materials would be feasible. Overall, the SCPC 14 alternative transportation impacts would be SMALL to MODERATE during plant operations. 15 8.3.10 Aesthetics 16 The analysis of aesthetics impacts focuses on the degree of contrast between the SCPC 17 alternative and the surrounding landscape and the visibility of the new SCPC plant at an existing 18 power plant site or a former plant (brownfield) site. Most construction, clearing, and excavation 19 activities would take place within the existing power plant or brownfield site, and these activities 20 could be visible from offsite roads. Since power plant and brownfield sites look industrial, 21 construction -related activities would appear similar to other ongoing industrial activities. 22 The SCPC plant buildings would be approximately 100 ft (30 m) tall, with two to four exhaust 23 stacks up to 150 ft (46 m) tall. The SCPS alternative would be visible offsite during daylight 24 hours and some structures may require aircraft warning lights. Condensate plumes from the 25 cooling towers would add to the visual impact. The cooling towers would be 400 -500 ft 26 (122-152 m) in height. The power block of the SCPC alternative could look very similar to 27 GGNS. Noise generated during power plant operations would be limited to routine industrial 28 processes and communications. 29 In general, given the industrial appearance of existing industrial and brownfield sites, the SCPC 30 alternative would blend in with the surroundings. Aesthetic changes would therefore be limited 31 to the immediate vicinity of the existing power plant and brownfield sites, and any impacts would 32 be SMALL. 33 8.3.11 Historic and Archaeological Resources 34 Lands needed to support construction of an SCPC plant and associated corridors would need to 35 be surveyed for historic and archaeological resources. Resources found in these surveys would 36 need to be evaluated for eligibility on the National Register of Historic Properties (NRHP) and 37 mitigation of adverse effects would need to be addressed if eligible resources were 38 encountered. When constructing an SCPC plant on a previously disturbed former plant 39 (brownfield) site, an inventory may still be necessary if the site has not been previously 40 surveyed or to verify the level of disturbance and evaluate the potential for intact subsurface 41 resources. The potential for impacts on historic and archaeological resources from the SCPC 42 alternative would vary greatly depending on the resource richness and location of the proposed 43 site. However, given that the preference is to use a previously disturbed former plant site, 44 avoidance of significant historic and archaeological resources should be possible and effectively 45 Environmental Impacts of Alternatives 8-31 managed under current laws and regulations. Therefore, the impacts on historic and 1 archaeological resources from the SCPC alternative would be SMALL to MODERATE. 2 8.3.12 Environmental Justice 3 The environmental justice impact analysis evaluates the potential for disproportionately high and 4 adverse human health, environmental, and socioeconomic effects on minority and low -income 5 populations that could result from the construction and operation of a new power plant. As 6 previously discussed in Section 8.1.12, such effects may include human health, biological, 7 cultural, economic, or social impacts. 8 Potential impacts to minority and low -income populations from the construction of an SCPC 9 alternative would mostly consist of environmental and socioeconomic effects (e.g., noise, dust, 10 traffic, employment, and housing impacts). Noise and dust impacts from construction would be 11 short-term and primarily limited to onsite activities. Minority and low -income populations 12 residing along site access roads would be directly affected by increased commuter vehicle 13 traffic during shift changes and truck traffic. However, because of the temporary nature of 14 construction, these effects are not likely to be high and adverse and would be contained to a 15 limited time period during certain hours of the day. Increased demand for rental housing during 16 construction could cause rental costs to rise disproportionately affecting low -income populations 17 who rely on inexpensive housing. However, given the likelihood of locating the SCPC 18 alternative at the site of an existing or former power plant and the proximity of most power plant 19 sites to metropolitan areas, workers could commute to the construction site, thereby reducing 20 the need for rental housing. 21 Potential impacts to minority and low -income populations from operation of an SCPC plant 22 would consist mainly of the effects of emissions. Because permitted emissions are expected to 23 remain within regulatory standards, impacts are not expected to be high and adverse. 24 Based on this information and the analysis of human health and environmental impacts 25 presented in this section, the construction and operation of the SCPC alternative would not have 26 disproportionately high and adverse human health and environmental effects on minority and 27 low-income populations. 28 8.3.13 Waste Management 29 During construction of an SCPC alternative, land clearing and other construction activities would 30 generate waste that could be recycled, disposed of on site, or shipped to an offsite waste 31 disposal facility. Because the alternative would be constructed at an existing power plant site, 32 or a previously disturbed site, the amounts of wastes produced during land clearing would be 33 reduced. 34 The burning of coal generates coal combustion products (CCP) such as bottom ash or fly ash (a 35 dry solid) and sludge (a semi -solid byproduct of emission control system operation). According 36 to the American Coal Ash Association, in 2010, approximately 130 million tons of CCPs were 37 generated by coal -fueled electric utilities. Fly ash accounted for over 67 million tons of CCP, 38 bottom ash accounted for over 17 million tons, and scrubber sludge about 22 million tons. 39 Approximately 38 percent of the fly ash and 42 percent of the bottom ash was recycled. 40 Approximately 48 percent of the scrubber sludge was recycled (ACAA 2010). The boilers 41 comprising the SCPC alternative are assumed to have the following pollution control devices: 42 fabric filter for particulate control, operating at 99 .9 percent removal 43 efficiency; 44 Environmental Impacts of Alternatives 8-32 wet calcium carbonate SO 2 scrubber, operating at 95 percent removal 1 efficiency; and 2 l ow-NO x burners with overfire air and selective catalytic reduction for nitrogen 3 oxide controls capable of attaining a NO x removal of 86 percent. 4 This coal-fired alternative would produce roughly 696,839 tons (632,173 MT) of ash, and 5 50 percent (348,420 tons [316,086 MT]) of the ash would be recycled for beneficial use. 6 Disposal of the remaining waste could have noticeable effects. However, proper disposal, 7 monitoring, and management practices as required by local ordinances and State regulations 8 would minimize these impacts. After closure of the waste site and revegetation, the land could 9 be available for other uses. 10 The impacts from waste generated during operation of this SCPC alternative would be 11 MODERATE because the impacts would be clearly visible but would not destabilize important 12 resources. 13 8.3.14 Summary of Impacts of SCPC Alternative 14 Table 8-4 summarizes the environmental impacts of the SCPC alternative compared to 15 continued operation of GGN S. 16 Table 8-4. Summary of Environmental Impacts of the SCPC Alternative 17 Compared to Continued Operation of GGNS 18 Category SCPC Alternative Continued GGNS Operation Air Quality MODERATE SMALL Groundwater Resources SMALL SMALL Surface Water Resources SMALL SMALL Aquatic Ecology SMALL SMALL Terrestrial Ecology SMALL to LARGE SMALL Human Health SMALL SMALL Land Use SMALL to MODERATE SMALL Socioeconomics SMALL to MODERATE SMALL Transportation SMALL to LARGE SMALL Aesthetics SMALL SMALL Historic and Archaeological Resources SMALL to MODERATE SMALL Waste Management a MODERATE SMALL a As described in Chapter 6, the issue, "offsite radiological impacts (spent fuel and high level waste disposal)," is not evaluated in this EIS.

8.4 Combination

Alternative 19 In this section, the NRC evaluates the environmental impacts from a combination of 20 alternatives. This combination includes 530 MWe from one NGCC unit similar to the units 21 described in Section 8.2, 360 MWe from biomass-fired units, 280 MWe from demand -side 22 management (DSM), and 305 MWe from purchased power. 23 The NRC assumed that one new NGCC unit of the type described in Section

8.2 would

be 24 constructed and installed at the GGNS site with a capacity of 530 MWe. The NRC estimates 25 that it would require about one third of the area necessary for the alternative considered in 26 Section 8.2 and that construction and operational effects would scale accordingly. 27 Environmental Impacts of Alternatives 8-33 The NRC assumed that biomass -fired generation, located in Mississippi, would replace 1 360 MWe of GGNS output. Electricity generation from biomass -fired generation is currently the 2 only commercially available renewable resource in operation in Mississippi, with a total of 3 235 MWe installed capacity (EIA 2012a). The development of biomass resources is also 4 consistent with Entergy's Strategic Resource Plan (SRP). The SRP estimates about 700 MWe 5 of new renewable energy generation (spread across Entergy's six current operating companies) 6 will come from biomass -fired generation from 2009 to 2019 (Entergy 2009). The SRP 7 concluded that by 2019, commercially available renewable energy is expected to be limited 8 primarily to biomass -fired generation in Mississippi. Mississippi currently does not require 9 electric utilities to generate a portion of their electricity from renewable sources. 10 The NRC assumed a DSM program would replace 280 MWe of GGNS output. Although 11 Mississippi does not require DSM programs, Entergy commissioned a study by ICF International 12 to calculate possible savings through a DSM program (ICF 2009). According to the study, the 13 potential energy savings across Entergy's six operating companies could reach 729 MWe by 14 2019 and 1,050 MWe by 2029 (Entergy 2009). Because Entergy Mississippi, Inc. (EMI) 15 represents 13 percent of Entergy's total energy sales, the NRC estimates that the potential 16 savings would reach 95 MWe by 2019 and 136 MWe by 2029 in Mississippi. In addition, the 17 Federal Energy Regulatory Commission (FERC) evaluated potential energy savings using DSM 18 in 5- and 10-year horizons for four development scenarios that varied in level of participation 19 (FERC 2009). FERC's analysis indicates that by the year 2019, the achievable participation 20 scenario would yield a 1,602 MWe peak demand reduction in Mississippi (FERC 2009). Since 21 EMI provides 34 percent of Mississippi's electricity generation, if these demand reductions were 22 achieved, it would translate to a reduction of 539 MWe for EMI. The 280 MWe reduction in 23 energy use for this alternative falls between the ICF International and FERC study outcomes 24 projecting potential DSM savings. Therefore, the NRC finds 280 MWe of DSM savings to be a 25 reasonable portion of the combination alternative. No major construction would be necessary 26 for the DSM component of the combination alternative. 27 For the combination alternative, the NRC assumes that nine 50 MWe biomass -fired units with a 28 capacity factor of 80 percent would be required to replace 360 MWe of GGNS output. Biomass 29 resources typically include forest residue, primary mill residues, secondary mill residues, and 30 urban wood residues (NREL 2005). The biomass -fired units would be similar in appearance 31 and operation to fossil fuel -fired power plants. The technology used for conversion of biomass 32 to electricity would be direct combustion, which involves the burning of biomass, producing hot 33 gases which, in turn, boil water to produce steam. The steam is used to spin a turbine that 34 generates electricity. Biomass combustion systems also require feedstock storage and 35 handling systems, as well as a cooling water system with cooling towers. The NRC assumes 36 that approximately 15 ac (6 ha) of land would be required for each 50 -MWe plant, for a total of 37 135 ac (55 ha) (NREL 2003, Palmer Renewable Energy 2011). The combustion of biomass 38 resources would affect air quality, but would generate fewer SO 2 and NO x emissions per unit of 39 energy delivered than coal. In addition, environmental impacts would occur from harvesting 40 wood resources. Biomass -fired power plants generate greater emissions than either natural 41 gas or nuclear plants of equal electrical generation capacity (NREL 1999). 42 For the combination alternative, 305 MWe would be purchased to replace that amount of GGNS 43 generation. In its Strategic Resource Plan, Entergy's Reference Planning Scenario assumes 44 that by the time GGNS's license expir es in November 2024, EMI will purchase 500 MWe from 45 non-Entergy generation (Entergy 2009). Therefore, it is reasonable to assume that 305 MWe 46 will be available for purchase. The impacts of purchased power could be wide -ranging, 47 depending on the energy type and location selected. The power would likely come from the 48 most common types of energy generation in the region: gas, coal, or nuclear plants. 49 Environmental Impacts of Alternatives 8-34 Construction and operation impacts would be similar to those described in Sections 8.1 1 through 8.3. The purchased power would either be purchased from existing plants, or from new 2 plant construction, depending on the availability of power sources. Additional impacts could 3 occur if new plants need to be built to produce the additional 305 MWe of power. 4 8.4.1 Air Quality 5 Air quality impacts would result primarily from the energy generated from the NGCC and 6 biomass-fired units. There also would be impacts to air quality from the purchased power 7 portion of the alternative, with the magnitude of impact dependent on the source of the 8 purchased power. As described in Section 8.4, the purchased power would likely come from 9 the most common types of energy generation in the region: gas, coal, or nuclear plants. 10 Therefore, air quality impacts would be similar to those described in Sections 8.1.1, 8.2.1, and 11 8.3.1. Impacts to air quality from the NGCC portion would be similar to the impacts in 12 Section 8.2.1, but scaled down by approximately one -third. 13 Mississippi contains three designated air quality control regions

the Northeast Mississippi 14 Intrastate Air Quality Control Region (AQCR); the Mobile (Alabama)

-Pensacola-Panama City 15 (Florida)-Southern Mississippi Interstate AQCR; a nd, the Mississippi Delta Intrastate AQCR 16 (40 CFR 81.62, 40 CFR 81.68, 40 CFR 81.122 ). The State of Mississippi is in attainment with 17 national primary and secondary air quality standards for all criteria pollutants , except De Soto 18 County which is located about 200 miles (322 km) north-northeast of GGNS and part of which is 19 designated as a marginal nonattainment area for the 2008 8 -hour ozone standard. 20 Construction activities for this alternative would generate fugitive dust. However, mitigation 21 measures, including wetting of unpaved roads and construction areas, and seeding or mulching 22 bare areas would minimize fugitive dust. Construction worker vehicles and motorized 23 construction equipment would create exhaust emissions. However, these emissions would end 24 upon completion of construction. 25 Various Federal and State regulations aimed at controlling air pollution would impact NGCC and 26 biomass-fired facilities located in Mississippi. Both the NGCC plant and biomass -fired units 27 would be subject to NAAQS, which would limit emissions for criteria pollutants and reflect 28 existing ambient air quality at the selected location. Biomass -fired generation produces air 29 quality impacts similar to that of coal. Emissions from the 50-MWe facilities may not be large 30 individually, but cumulatively could have more significant air quality impacts. Both the NGCC 31 and biomass -fired plants would qualify as new major emitting industrial facilities and would be 32 subject to PSD requirements under the Clean Air Act (CAA) (EPA 2012 a). The NGCC and 33 biomass-fired plants would require Title V operating permits that would specify limits to 34 emissions of all criteria pollutants. The NGCC portion of the alternative would need to comply 35 with new source performance standards (40 CFR Part 60 Subpart KKKK) and the biomass -36 portion of the alternative would need to comply with 40 CFR Part Subpart Db. If the NGCC or 37 biomass-fired plants were located close to a mandatory Class I area, additional air pollution 38 control requirements might be required (Subpart P of 40 CFR Part 51) as mandated by the 39 Regional Haze Rule. The rule would not apply to this alternative, however, because there are 40 no Class I Federal areas in Mississippi or within 186 -mi (300-km) of the GGNS site 41 (EPA 2012b). 42 The emissions from the NGCC portion of the combination alternative, projected by the staff 43 based on published EIA data, EPA emission factors, and performance characteristics for this 44 alternative, and likely emission controls, would be: 45 Environmental Impacts of Alternatives 8-35 sulfur oxides (SO X)-41 tons (37 MT) per year 1 nitrogen oxides (NO X)-156 tons (142 MT) per year 2 p(PM 10) and 2.5 (PM2.5)-79 tons (72 MT) per 3 year 4 carbon monoxide (CO)-361 tons (327 MT) per year 5 carbon dioxide (CO 2)-1.3 million tons (1.2 million MT) per year 6 National Energy Technology Laboratory (NETL) estimated emissions factors for biomass -fired 7 power plants by averaging 34 biomass facilities in California and based on a heat rate of 8 13.8 MMBTU/MWh. Emissions from the nine biomass -fired plants considered in this alternative 9 could vary based on technology or other factors. The emissions from all nine of the 10 biomass-fired plants under the combination alternative, based on emissions factors and the heat 11 rate estimated by National Renewable Energy Laboratory (NREL) would be: 12 SO X-126 tons (114 MT) per year 13 NO X-2,681 tons (2,432 MT) per year 14 (PM 10) and (PM2.5)-650 tons (590 MT) 15 per year 16 CO-13,560 tons (12,302 MT) per year 17 8.4.1.1 Sulfur Oxide and Nitrogen Oxide 18 The natural gas -fired plant would produce SO x and NO x based on the use of the dry low -NO x 19 combustion technology and selective catalytic reduction to significantly reduce NO x emissions. 20 Both the NGCC and biomass -fired plants would be subject to the continuous monitoring 21 requirements of SO 2 and NO x specified in 40 CFR Part 75. 22 8.4.1.2 Greenhouse Gases 23 Both the NGCC and biomass -fired plants would release GHGs, such as CO 2 and methane, and 24 would be subject to continuous monitoring requirements for CO 2, as specified in 25 40 CFR Part 75. 26 On July 12 2012, EPA issued a rule tailoring the criteria that determine which stationary sources 27 and modifications to existing projects become subject to permitting requirements for GHG 28 emissions under the PSD and Title V Programs of the CAA (77 FR 41051). According to this 29 rule, GHGs are a regulated new source review pollutant under the PSD major source permitting 30 program if the source is otherwise subject to PSD (for another regulated new source review 31 pollutant) and has a GHG potential to emit equal to or greater than 75,000 tons (68,000 MT) per 32 year of CO 2 equivalent ("carbon dioxide equivalent" adjusts for different global warming 33 potentials for different GHGs). Beginning January 2, 2011, operating permits issued to major 34 sources of GHGs under the PSD or Title V Federal permit programs must contain provisions 35 requiring the use of Best Available Control Technology (BACT) to limit the emissions of GHGs if 36 those sources would be subject to PSD or Title V permitting requirements. If the alternative 37 meets the GHG emission thresholds established in the rule, then GHG emissions from this 38 alternative would be regulated under the PSD and Title V permit programs. 39 8.4.1.3 Particulates 40 Both the NGCC and biomass -fired plants would produce particulates. For the biomass-fired 41 plants, fugitive particulate matter emissions would be produced from the wood fuel receiving, 42 Environmental Impacts of Alternatives 8-36 processing, and storage operations, but they could be minimized using enclosures and a water 1 misting system (Palmer Renewable Energy 2011). 2 As described above, construction activities associated with both the NGCC and biomass -fired 3 plants would generate fugitive dust as well as exhaust emissions from vehicles and motorized 4 equipment. These impacts would be short-term and would be minimized by dust control 5 measures. 6 8.4.1.4 Hazardous Air Pollutants 7 In December 2000, EPA issued regulatory findings (EPA 2000) on emissions of HAPs from 8 electric utility steam -generating units, which identified that natural gas -fired plants emit HAPs 9 such as arsenic, formaldehyde and nickel and stated that 10 . . . the impacts due to HAP emissions from natural gas -fired electric utility steam 11 generating units were negligible based on the results of the study. The 12 Administrator finds that regulation of HAP emissions from natural gas -fired 13 electric utility steam generating units is not appropriate or necessary. 14 As a result of the EPA's conclusion, the staff finds no significant air quality effects from HAPs for 15 the NGCC portion of the combination alternative. The biomass -fired plants would also release 16 HAPs, but each 50 -MWe unit is likely to emit less than 10 tons/yr (9.1 MT/yr) of any individual 17 HAP or 25 tons/yr (22.7 MT/yr) for any combination of HAPs (Palmer Renewable Energy 2011). 18 8.4.1.5 Conclusion 19 Air quality impacts would result primarily from the NGCC and biomass -fired portions of the 20 combination alternative. The purchased power portion would likely come from gas, coal, and/or 21 nuclear sources, the largest sources of power generation in Mississippi. The impacts to air 22 quality from gas, coal, and nuclear power are described in Sections 8.1.1, 8.2.1, and 8.3.1, but 23 they would be proportionally smaller. Air quality impacts from the DSM portion of the 24 combination alternative would be negligible. Based on this information, the overall air quality 25 impacts of the combination alternative would be SMALL to MODERATE. 26 8.4.2 Groundwater Resources 27 Twenty-one percent of the power supplied by this alternative will be purchased power from 28 some combination of natural gas, coal, or nuclear power plants. The impact of these types of 29 power plants on groundwater use and quality are described in Sections 8.1 through 8.3. 30 Impacts on groundwater for these types of facilities have been characterized as SMALL for both 31 operation and construction. If power is purchased from existing facilities, impacts would be 32 smaller than that described in Sections 8.1 through 8.3 because no construction would occur. 33 Impacts on groundwater use and quality for purchased power would be SMALL. 34 Twenty-four percent of the power supplied by this alternative would come from biomass -fired 35 generation. A biomass -fired plant would be similar in appearance and operation to a coal -fired 36 power plant. Groundwater would be consumed to construct the new plants. The amount of 37 construction water consumed would be much less than the amount consumed by long -term 38 operation of the biomass-fired plants. Potable water and other plant groundwater requirements 39 would be about one -third of GGNS requirements. Impacts from biomass -fired generation on 40 groundwater use and quality would be SMALL. 41 Thirty-six percent of the power supplied by this alternative would come from the combustion of 42 natural gas. The hydrologic impact of this type of power plant on groundwater use and quality 43 would be less than that described in Section 8.2 because one NGCC unit, rather than three 44 Environmental Impacts of Alternatives 8-37 NGCC units, would be built for the combination alternative. Therefore, impacts on groundwater 1 use and quality would be SMALL. 2 Nineteen percent of the power for this alternative would come from DSM and impacts on 3 groundwater use and quality would be SMALL. 4 The impact of the combination alternative on groundwater use and quality would be SMALL. 5 8.4.3 Surface Water Resources 6 Twenty-one percent of the power supplied by this alternative will be purchased power from 7 some combination of gas, coal, or nuclear power plants. The impact of these types of power 8 plants on surface water use and quality are SMALL and are described in Sections 8.1 through 9 8.3. The impact of the purchased power portion of this alternative on surface water would be 10 SMALL. 11 Twenty-four percent of the power supplied by this alternative would come from biomass -fired 12 generation. If dredging of streams or rivers occurs during construction of the biomass facilities, 13 surface water quality immediately downstream of the dredging activities could be temporarily 14 degraded by increases in suspended sediment concentration. In addition, the biomass facilities 15 would require cooling water. Within the service territory, the Mississippi River, other rivers, or 16 reservoirs might be a source of cooling water. The small size of these facilities means the 17 impact on surface water use and quality would be SMALL. 18 Thirty-six percent of the power supplied by this alternative would come from the combustion of 19 natural gas. The hydrologic impact of this type of power plant on surface water use and quality 20 is described in Section 8.2. During plant operations, the NGCC plant in the combination 21 alternative would discharge cooling system blowdown at approximately one-sixth of the existing 22 GGNS rate. Stormwater discharge, blowdown, sanitary, and other effluents would be permitted 23 under an NPDES permit. The impacts on surface water use and quality from the NGCC portion 24 of this alternative would be SMALL. 25 Nineteen percent of the power for this alternative would come from DSM and impacts on 26 surface water use and quality would be SMALL. 27 The impact of the combination alternative on surface water use and quality would be SMALL. 28 8.4.4 Aquatic Ecology 29 Construction activities for the combination alternative (such as construction of heavy -haul roads, 30 and the power blocks for the NGCC and biomass -fired plants) could affect onsite aquatic 31 features at GGNS for the NGCC plant and onsite aquatic features that may occur where the 32 biomass-fired plants would be built. Minimal impacts on aquatic ecology resources are 33 expected because BMPs would likely be used to minimize erosion and sedimentation. 34 Stormwater control measures, which would be required to comply with Mississippi NPDES 35 permitting, would minimize the flow of disturbed soils into aquatic features. Depending on the 36 available infrastructure at the selected biomass-fired plant sites, new or expanded intake and 37 discharge structures may be required. Construction of new or modified intake and discharge 38 structures may require dredging. In addition, dredging may be required to transport new 39 materials to the NGCC and biomass -fired plant sites, which could result in increased 40 sedimentation and turbidity. Dredging activities would require BMPs for in -water work to 41 minimize sedimentation and erosion. Due to the short -term nature of the dredging activities, the 42 hydrological alterations to aquatic habitats would likely be localized and temporary. 43 Environmental Impacts of Alternatives 8-38 During operations, the NGCC plant would require approximately one -third of the cooling water 1 to be discharged into the Mississippi River compared to the NGCC alternative analyzed in 2 Section 8.2. Therefore, the thermal impacts would be less for the combination alternative than 3 for license renewal and the NGCC alternative. The cooling system for a new NGCC plant would 4 have similar chemical discharges as GGNS, but the air emissions from the NGCC plant would 5 emit particulates that would settle onto the river surface and introduce a new source of 6 pollutants that would not exist if GGNS continued operating. However, the flow of the 7 Mississippi River would dissipate pollutants, which would minimize the exposure of fish and 8 other aquatic organisms to pollutants. 9 During operations, the biomass -fired plants would require cooling water. If cooling water is 10 withdrawn from and discharged into surface water bodies, aquatic resources may be impacted 11 from impingement, entrainment, and thermal stress. Impingement, entertainment, and thermal 12 stress would be minimized because the NRC assumes that the biomass -fired plants would use 13 closed-cycle cooling systems. 14 Consultation under several Federal acts, including the ESA and Magnuson -Stevens Act, would 15 be required to assess the occurrence and potential impacts to Federally protected aquatic 16 species and habitats within affected surface waters. Coordination with State natural resource 17 agencies would further ensure that the plant operators would take appropriate steps to avoid or 18 mitigate impacts to State-listed species, habitats of conservation concern, and other protected 19 species and habitats. The NRC assumes that these consultations would result in avoidance or 20 mitigation measures that would minimize or eliminate potential impacts to protected aquatic 21 species and habitats. 22 The DSM portion of this alternative would have little to no impact on aquatic resources because 23 there would be little to no water required. 24 The impacts to aquatic resources from purchased power would be similar to those already 25 described for the NGCC, SCPC, and nuclear alternatives. If power is purchased at existing 26 plants, the impacts would likely be smaller than those analyzed for the NGCC, SCPC, and 27 nuclear alternatives because no construction impacts would occur. 28 The impacts on aquatic ecology would be minor for the combination alternative because 29 construction activities would require BMPs and stormwater management permits and the 30 discharge for this alternative would be similar to or less than for GGNS. Therefore, the impacts 31 on aquatic ecology would be SMALL. 32 8.4.5 Terrestrial Ecology 33 The NGCC component of this alternative would be smaller and require less land than the NGCC 34 plant described in Section 8.

2. This alternative assumes that the NGCC plant would be located 35 on the GGNS site, and predominantly previously developed or pre

-disturbed land would be 36 affected. The impacts of construction and operation of this alternative on terrestrial species and 37 habitats would be SMALL because of this alternative's extensive use of developed land. The 38 DSM portion of this alternative would have no impact on terrestrial species and habitats. The 39 purchased power portion of the alternative would have wide -ranging impacts that are hard to 40 specifically assess because this portion of the alternative could include a mixture of coal, gas, 41 and nuclear across many different sites. However, the purchased power portion of this 42 alternative would be more likely to intensify already existing effects at power generating facilities 43 than create wholly new effects on terrestrial species and habitats. The biomass portion of this 44 alternative would disturb a total of 135 ac (55 ha) over nine sites (an average of 15 ac [6 ha] per 45 site). Depending on the location of the biomass -fired plant sites, terrestrial habitat could be 46 destroyed or fragmented during construction. Particulate air pollution resulting from operation of 47 Environmental Impacts of Alternatives 8-39 the biomass -fired plants could accumulate in waterways and wetlands and be taken up by 1 plants and animals. However, air emissions could be reduced by the use of advanced 2 technologies aimed at lowering emissions. Because of the difficulty of characterizing impacts 3 resulting from this combination alternative, the staff concludes that impacts could range from 4 SMALL to MODERATE. 5 As discussed under aquatic ecology impacts, consultation with FWS under the ESA would avoid 6 potential adverse impacts to Federally listed species or adverse modification or destruction of 7 designated critical habitat. Coordination with State natural resource agencies would further 8 ensure that plant operators would take appropriate steps to avoid or mitigate impacts to 9 State-listed species, habitats of conservation concern, and other protected species and habitats. 10 The NRC assumes that these consultations would result in avoidance or mitigation measures 11 that would minimize or eliminate potential impacts to protected terrestrial species and habitats. 12 Consequently, the impacts of construction and operation of a new nuclear alternative on 13 protected species and habitats would be SMALL. 14 8.4.6 Human Health 15 Impacts on human health from construction of the NGCC, biomass -fired and purchased power 16 portions of this alternative would be similar to impacts associated with the construction of any 17 major industrial facility. Compliance with worker protection rules would control those impacts on 18 workers at acceptable levels. Impacts from construction on the general public would be minimal 19 since limiting active construction area access to authorized individuals is expected assuming the 20 plant operator follows BMPs. Impacts on human health from the construction of the NGCC, 21 biomass-fired and purchased power portions of this alternative would be SMALL. 22 Construction and operation impacts for the DSM portion of this alternative would be minimal and 23 localized to activities such as weatherization efficiency of an end -user's home or facility. The 24 GEIS notes that the environmental impacts are likely to be centered on indoor air quality 25 (NRC 1996). This is because of increased weatherization of the home in the form of extra 26 insulation and reduced air turnover rates from the reduction in air leaks. However, the actual 27 impact is highly site specific and not yet well established. Impacts on human health from the 28 construction activities involved in the DSM portion of this alternative would be SMALL. 29 Human health effects of gas -fired generation are generally low, although in Table 8.2 of the 30 GEIS (NRC 1996), the staff identified cancer and emphysema as potential health risks from 31 gas-fired plants. NO x emissions contribute to ozone formation, which in turn contributes to 32 human health risks. Emission controls on the NGCC portion of this alternative can be expected 33 to maintain NO x emissions well below air quality standards established to protect human health, 34 and emissions trading or offset requirements mean that overall NO x releases in the region would 35 not increase. Health risks for workers may also result from handling spent catalysts used for 36 NO x control that may contain heavy metals. Impacts on human health from the operation of the 37 NGCC portion of the combination alternative would be SMALL. 38 Using biomass for energy consists of the direct burning of forest residue/wood waste, which 39 would likely include forest residue, primary mill residues, secondary mill residues, or urban 40 wood residues. Given this method of fuel for power generation, the health impacts would be 41 similar to those found in a fossil -fuel power generation facility. As discussed in the NGCC and 42 the SCPC alternatives, regulations restricting emissions enforced by either EPA or delegated 43 state agencies have reduced the potential health effects from plant emissions, but have not 44 entirely eliminated them. These agencies also impose site -specific emission limits as needed to 45 protect human health. As discussed in the NGCC and SCPC alternatives, proper emissions 46 controls would protect workers and the public from the harmful effects of burning the biomass 47 Environmental Impacts of Alternatives 8-40 fuel. Therefore, impacts to human health from the biomass portion of the combination 1 alternative would be SMALL. 2 Purchased power most likely would come from natural gas, coal, or nuclear power generating 3 plants. The human health impacts from the operation of these types of plants are discussed in 4 detail in the NGCC, SCPC, and nuclear alternatives sections of this chapter. The human health 5 impacts from the operation of power -generation plants that would provide purchased power are 6 SMALL. 7 Overall, human health risks to occupational workers and to members of the public from the 8 combination alternative would be SMALL. 9 8.4.7 Land Use 10 The GEIS generically evaluates the impact of constructing and operating various replacement 11 power plant alternatives on land use, both on and off each plant site. The analysis of land use 12 impacts focuses on the amount of land area that would be affected by the construction and 13 operation of a combination alternative consisting of a natural gas -fired power plant (one NGCC 14 unit), biomass -fired power plants, DSM, and purchased power. 15 Land use impacts for the NGCC plant would be approximately one -third of that described for the 16 NGCC alternative discussed in Section 8.2.7 as it would require three units and the combination 17 alternative would require one unit. 18 The biomass power plants would require approximately 15 ac (6 ha) per 50 -MWe unit for a total 19 of 135 ac (55 ha) on an industrial zoned brownfield site. Forest residue and wood waste are 20 byproducts of the timber industry, and thus activities associated with the production of this 21 feedstock will occur regardless of whether a biomass -fired power plant is available to use the 22 feedstock. Accordingly, the land use impacts associated with the production of this feedstock 23 will be the same regardless whether the feedstock is used for electricity generation or not. 24 However, additional land would be required for storing, loading, and transporting forest residue 25 and wood waste power plant feedstock. Ultimately, land use impacts would depend on the 26 characteristics of the affected forested lands and the effects of storing, loading and transporting 27 the biomass feedstock. DSM would have little to no direct land use impacts. However, quickly 28 replacing old inefficient appliances and other equipment could generate waste material and 29 potentially increase the size of landfills. However, given time for program development and 30 implementation, the cost of replacements, and the average life of an appliance; the replacement 31 process likely would be gradual. For example, older appliances would be replaced by more 32 efficient appliances as they fail (especially in the case of frequently replaced items, such as light 33 bulbs). In addition, many appliances and industrial equipment have substantial recycling value 34 and would not be disposed of in landfills. 35 Purchased power would also have no direct land use impacts. However, impacts could occur if 36 existing power plants in the region could not support the demand for purchased power. The 37 construction of any new replacement power generating facilities could substantially impact 38 existing land -use. Purchased power from coal- and natural gas -fired plants could also have a 39 noticeable impact on land use due to the amount of land required for coal mining and gas 40 drilling. Wind energy projects would have a noticeable land -use impact because of the large 41 amount of land required for wind farms. However, new replacement power generating facilities 42 could be constructed at existing power plant sites to minimize land use impacts. Impacts could 43 also be minimized by collocating any new transmission lines within existing right -of-ways. 44 The elimination of uranium fuel for GGNS would partially offset some of the land requirements 45 for the NGCC and biomass-fired power plant. Scaling from GEIS estimates, approximately 46 Environmental Impacts of Alternatives 8-41 1,033 ac (418 ha) (based on 35 ac/yr disturbed per 1,000 MWe for 20 y ears (see GEIS 6.2.2.6) 1 and 1 , 475 MWe for GGNS) would no longer be needed for mining and processing uranium 2 during the operating life of these power plants (NRC 1996). Based on this information, overall 3 land use impacts from the construction and operation of the combination alternative could range 4 from SMALL to LARGE. 5 8.4.8 Socioeconomics 6 As previously discussed, socioeconomic impacts are defined in terms of changes to the 7 demographic and economic characteristics and social conditions of a region. For example, the 8 number of jobs created by the construction and operation of NGCC and biomass-fired plants 9 could affect regional employment, income, and expenditures. This alternative would create two 10 types of jobs: (1) construction jobs, which are transient, short in duration, and less likely to have 11 a long-term socioeconomic impact; and (2) power plant jobs, which have a greater potential for 12 permanent, long -term socioeconomic impacts. Workforce requirements for the construction and 13 operation of an NGCC power plant, biomass -fired power plants, DSM, and purchased power 14 components of this combination alternative were evaluated to estimate their possible effects on 15 current socioeconomic conditions. 16 The NGCC component would be one -third the size of the NGCC alternative discussed in 17 Section 8.2.8, and would require about 633 construction workers during peak construction and 18 50 operations workers. Fifty construction workers are required for each biomass -fired plant, 19 totaling 450 construction workers if all nine units are constructed at the same time. Each 20 biomass unit is assumed to require 22 operations workers, for a total of 198 operations workers 21 for this component of the combination alternative. 22 The DSM component could generate additional employment, depending on the nature of the 23 conservation programs and the need for direct measure installations in homes and office 24 buildings. Jobs would likely be few and scattered throughout the region, and would not have a 25 noticeable effect on the local economy. 26 Purchased power from existing power plants would not generate any additional employment 27 opportunities as there would be no change in power plant operations or workforce. However, 28 new employment opportunities could be created if new electrical power generating facilities 29 were needed to support the demand for purchased power. Construction of a new replacement 30 power facility could cause noticeable short -term socioeconomic impacts, similar to those 31 described previously for the other replacement power alternatives. Operation of new 32 replacement power generating facilities would cause long-term socioeconomic impacts through 33 job creation, new housing demand, increased tax contribution, and additional purchasing 34 activity. Construction and operational impacts would vary depending on the location and type of 35 replacement power generating facility. Therefore, impacts from purchased power could range 36 from SMALL to LARGE. 37 This combination alternative would also result in a loss of approximately 690 relatively 38 high-paying jobs at GGNS, with a corresponding reduction in purchasing activity and tax 39 contributions to the regional economy. However, a larger amount of property taxes may be paid 40 to local jurisdictions from the NGCC, biomass, DSM, and purchased power components as 41 more land may be required to support this combination alternative than GGNS. 42 Because of the relatively small number of construction workers needed for the NGCC and 43 biomass-fired plants and the various locations of the biomass -fired plants, the socioeconomic 44 impact of construction on local communities and the tax base would be SMALL. Given the 45 small number of operations workers required, socioeconomic impacts associated with operation 46 of this combination alternative would also be SMALL. Construction and operational impacts 47 Environmental Impacts of Alternatives 8-42 from purchased power would range from SMALL to LARGE. Therefore, overall socioeconomic 1 impacts from this combination alternative could range from SMALL to LARGE. 2 8.4.9 Transportation 3 Transportation impacts during the construction and operation of the NGCC and biomass 4 components of this combination alternative would be less than the impacts for any of the 5 previous alternatives discussed in Sections 8.1.9, 8.2.9, and 8.3.9. This is because the 6 construction workforce for each component and the volume of materials and equipment to be 7 transported to each respective construction site would be smaller than each of the other 8 alternatives. Additionally, the transportation impacts would not be concentrated as they are in 9 the other alternatives; they would be spread out over a wider area. 10 During construction, commuting workers and trucks transporting construction materials and 11 equipment to the work site would increase the amount of traffic on local roads. The increase in 12 vehicular traffic would peak during shift changes, resulting in temporary levels of service 13 impacts and delays at intersections. Transporting heavy and oversized components on local 14 roads could have a noticeable impact over a large area. Some components and materials also 15 could be delivered by rail or barge, depending on location. Traffic -related transportation impacts 16 during construction could range from SMALL to MODERATE in the vicinity of the NGCC power 17 plant at GGNS and biomass power plant units, depending on current road capacities and 18 average daily traffic volumes. During operations, transportation impacts from the NGCC and 19 biomass portions of the combination alternative would be less noticeable than during 20 construction and would be SMALL. 21 No incremental operations impacts would be expected for the DSM or purchased power 22 components of this alternative. As previously discussed, purchased power from existing power 23 plants would not generate any additional employment opportunities as there would be no 24 change in power plant operations or workforce. Traffic volumes on local roads would remain 25 unchanged. 26 However, traffic conditions could be substantially impacted i f new electrical power generating 27 facilities were needed to support the demand for purchased power. Construction of new power 28 generating facilities would cause noticeable short -term transportation impacts on local roads 29 due to the increased volume of worker and truck delivery traffic required to build the new power 30 plant, especially during shift changes. However, traffic volumes would decrease after 31 construction is completed. Construction and operations -related transportation impacts would 32 vary depending on the location and type of facility. Therefore, impacts from purchased power 33 could range from SMALL to LARGE. 34 Based on this information, overall transportation impacts from the combination alternative could 35 range from SMALL to LARGE. 36 8.4.10 Aesthetics 37 The analysis of aesthetics impact focuses on the degree of contrast between the NGCC and 38 biomass power plants and surrounding landscapes and the visibility of a new NGCC plant at 39 GGNS and the new biomass plants. In general, aesthetic changes would be limited to the 40 immediate vicinity of these power plants, although minor visual impacts may be associated with 41 the staging, processing, and transport of biomass feedstock. 42 Aesthetic impacts from the NGCC plant component of the combination alternative would be 43 essentially the same as those described for the NGCC alternative in Section 8.2.10, except 44 there would be one unit rather than three. Plant infrastructure generally would be smaller and 45 Environmental Impacts of Alternatives 8-43 less noticeable than GGNS containment and turbine buildings. In addition to the plant 1 structures, construction of the natural gas pipeline would have a short -term impact. In general, 2 aesthetic changes would be limited to the immediate vicinity of GGNS and would be SMALL. 3 Most noise generated during NGCC plant operations would be limited to industrial processes 4 and communications. Pipelines delivering natural gas fuel could be audible off site near gas 5 compressor stations. Noise during construction activities for the NGCC alternative may be 6 detectable off site, but would be for a short duration. Pipeline companies and the plant operator 7 would need to adhere to local ordinances regarding maximum noise levels during construction 8 and operations. Therefore, impacts from noise would be SMALL. 9 The biomass plant would look similar to other fossil fuel power plants with a boiler stack and 10 cooling towers. In addition, it would have feedstock storage, handling, and processing facilities, 11 similar to a timber mill. Combustion exhaust and cooling steam plumes may be visible in close 12 proximity to the plant depending on atmospheric conditions. Noise during construction activities 13 and plant operations may be detectable off site. The plant operator would need to adhere to 14 local ordinances regarding maximum noise levels during construction and operations. 15 Therefore, impacts from noise would be SMALL. 16 No aesthetic or noise impacts would be expected for the DSM and purchased power 17 components of this alternative. However, impacts could occur if new electrical power 18 generating facilities were needed to support the demand for purchased power. Impacts would 19 vary depending on the location and type of power generating facility. If constructed at an 20 existing power plant site, aesthetic changes would be limited and any impacts could range from 21 SMALL to MODERATE due to the industrial appearance of the site . However, if constructed in 22 a rural and previously undisturbed area, the effects could range from MODERATE to LARGE. 23 Therefore, aesthetic impacts from purchased power could range from SMALL to LARGE. 24 Based on this information, overall aesthetic impacts from the combination alternative could 25 range from SMALL to LARGE. 26 8.4.11 Historic and Archaeological Resources 27 Impacts on historic and archaeological resources from the NGCC and biomass power plant 28 components of this alternative would be similar to those discussed for the NGCC alternative in 29 Section 8.

2. A cultural resource survey and inventory would be needed before construction 30 could begin for either alternative.

Resources found in these surveys would need to be 31 evaluated for eligibility on the National Register of Historic Properties (NRHP) and mitigation of 32 adverse effects would need to be addressed if eligible resources were encountered. 33 Construction of either alternative on a brownfield site could minimize impacts to historic and 34 archaeological resources, however a survey should still be performed to inventory cultural 35 resources and verify level of disturbance. Given that the sites for biomass -fired units are small 36 in size (approximately 15 acres) and a preference is given to use previously disturbed 37 brownfield sites, avoidance of significant historic and archaeological resources should be 38 possible and effectively managed under current laws and regulations. Impacts to historic and 39 archaeological resources from the NGCC and biomass portions of this alternative would be 40 SMALL to MODERATE. 41 No direct impacts on historic and archaeological resources are expected from DSM or 42 purchased power

. If new transmission lines were needed to convey power to consumers 43 previously served by GGNS, surveys similar to those discussed for the NGCC unit would need 44 to be performed. However, transmission lines would likely be collocated with in existing right

-of-45 ways minimizing any impacts to historic and archaeological resources, making direct impacts 46 SMALL. 47 Environmental Impacts of Alternatives 8-44 Indirectly, construction of new electrical power generating facilities and any new transmissio n 1 lines needed to support the increased demand for power from the closure of GGNS could 2 impact archaeological and historic resources. Any areas potentially affected by construction 3 and operation would need to be surveyed and evaluated for NRHP eligibility. The potential for 4 impacts on historic and archaeological resources would vary greatly depending on the location 5 of the proposed sites; however, using previously disturbed sites could greatly minimize impacts 6 to historic and archaeological resources. Areas with the greatest sensitivity could be avoided or 7 effectively managed under current laws and regulations. Impacts would also vary by type of 8 energy power facility chosen and the level of ground disturbance it would require for 9 construction and operation. Therefore, depending on the resource richness of the sites chosen 10 for construction and the type of electrical power generating facility chosen, the impacts could 11 range from SMALL to LARGE. 12 The potential for impacts on historic and archaeological resources from the combination 13 alternative would vary greatly depending on the resource richness of the location of the 14 proposed sites associated with each component of the alternative . Therefore, the overall impact 15 on historic and archaeological resources could range from SMALL to LARGE. 16 8.4.12 Environmental Justice 17 The environmental justice impact analysis evaluates the potential for disproportionately high and 18 adverse human health, environmental, and socioeconomic effects on minority and low -income 19 populations that could result from the construction and operation of a combination of NGCC and 20 biomass-fired plants, and DSM and purchased power activities. As previously discussed in 21 Section 8.1.12, such effects may include human health, biological, cultural, economic, or social 22 impacts. 23 Potential impacts to minority and low -income populations from the construction and operation of 24 a new NGCC and biomass power plants would mostly consist of environmental and 25 socioeconomic effects (e.g., noise, dust, traffic, employment, and housing impacts). Noise and 26 dust impacts during construction would be short -term and primarily limited to onsite activities. 27 Minority and low -income populations residing along site access roads would be directly affected 28 by increased commuter vehicle traffic during shift changes and truck traffic. However, because 29 of the temporary nature of construction, these effects are not likely to be high and would be 30 contained to a limited time period during certain hours of the day. Increased demand for rental 31 housing during construction could cause rental costs to rise disproportionately affecting low -32 income populations living near GGNS for the NGCC plant and the biomass -fired plant locations 33 who rely on inexpensive housing. However, given the small number of construction workers 34 and the possibility that workers could commute to the construction site, the potential increased 35 demand for rental housing would not be significant. No incremental human health or 36 environmental impacts related to construction would be expected from the purchased power or 37 DSM component of this alternative. 38 Minority and low -income populations living in close proximity to the power generating facilities 39 could be disproportionately affected by emissions associated with NGCC power plant and 40 biomass operations. However, because emissions are expected to remain within regulatory 41 standards, impacts from emissions are not expected to be high and adverse. 42 Low-income populations could benefit from weatherization and insulation programs in a DSM 43 energy conservation program. This could have a greater effect on low -income populations than 44 the general population, as low -income households generally experience greater home energy 45 burdens than the average household. Low-income populations could also be disproportionately 46 affected by increased utility bills due to the cost of purchased power. However, programs, such 47 Environmental Impacts of Alternatives 8-45 as the Mississippi Low Income Home Energy Assistance Program, are available to assist low -1 income families in paying for increased electrical costs, thus mitigating the adverse 2 socioeconomic impact of this alternative on low -income populations. 3 Overall, the construction and operation of the NGCC and biomass -fired plants, and DSM and 4 purchased power activities would not have disproportionately high and adverse human health 5 and environmental effects on minority and low -income populations. 6 8.4.13 Waste Management 7 During the construction stage for the NGCC plant, land clearing and other construction activities 8 would generate wastes that could be recycled, disposed of on site, or shipped to an offsite 9 waste disposal facility. During the operational stage, spent selective catalytic reduction 10 catalysts, which control NO X emissions from the NGCC plant, would make up the majority of 11 waste generated by this alternative. 12 For DSM, there may be an increase in wastes generated during installation or implementation of 13 energy conservation measures, such as appropriate disposal of old appliances, installation of 14 control devices, and building modifications. New and existing recycling programs would help 15 minimize the amount of generated waste. 16 For the purchased power portion of this alternative, the types of waste generated would be 17 similar to the alternatives described in Sections 8.1.13, 8.2.13, and 8.3.13. 18 During construction of a the biomass -fired plants, land clearing and other construction activities 19 would generate waste that could be recycled, disposed of on site, or shipped to an offsite waste 20 disposal facility. A wood biomass -fired plant may use as fuel the residues from forest clear cut 21 and thinning operations, noncommercial species, or harvests of forests for energy purposes. In 22 addition to the gaseous emissions, wood ash is the primary waste product of wood combustion. 23 Waste would be handled in accordance with appropriate Mississippi Commission of 24 Environmental Quality waste management regulations (MSCEQ 2012). 25 Overall, waste impacts from the combination alternative would be SMALL. 26 8.4.14 Summary of Impacts of Combination Alternative 27 Table 8-5 summarizes the environmental impacts of the combination alternative compared to 28 continued operation of GGNS. 29 Environmental Impacts of Alternatives 8-46 Table 8-5. Summary of Environmental Impacts of the Combination Alternative 1 Compared to Continued Operation of GGNS 2 Category Combination Alternative Continued GGNS Operation Air Quality SMALL to MODERATE SMALL Groundwater Resources SMALL SMALL Surface Water Resources SMALL SMALL Aquatic Ecology SMALL SMALL Terrestrial Ecology SMALL to MODERATE SMALL Human Health SMALL SMALL Land Use SMALL to LARGE SMALL Socioeconomics SMALL to LARGE SMALL Transportation SMALL to LARGE SMALL Aesthetics SMALL to LARGE SMALL Historic and Archaeological Resources SMALL to LARGE SMALL Waste Management a SMALL SMALL a As described in Chapter 6, the issue, "offsite radiological impacts (spent fuel and high level waste disposal)," is not evaluated in this EIS.

8.5 Alternatives

Considered But Dismissed 3 8.5.1 Demand-Side Management 4 Demand-side management (DSM) includes energy efficiency programs designed to improve the 5 energy efficiency of facilities and equipment, reduce energy demand through behavioral 6 changes (energy conservation), and demand response initiatives aimed to lessen customer 7 usage or change energy use patterns during peak periods (ICF 2009). Energy conservation 8 and energy efficiency would not require the addition of new generating capacity. To be 9 considered a viable alternative, a DSM alternative would need to reduce the baseload demand 10 within Entergy's Mississippi service territory by 1,475 MWe, which is equivalent to the amount 11 GGNS provides. 12 In a 2009 staff report, the Federal Energy Regulatory Commission (FERC) outlined the results 13 of a national assessment of demand response potential, required of FERC by Section 529 of the 14 Energy Independence and Security Act of 2007. The report evaluated potential energy savings 15 in 5- and 10-year horizons for four development scenarios: Business As Usual, Expanded 16 Business As Usual, Achievable Participation, and Full Participation, each representing greater 17 demand response program opportunities and proportionally increasing levels of customer 18 participation (FERC 2009). FERC's Mississippi -specific analysis indicates that by 2019, the Full 19 Participation scenario, in which the greatest level of reduction would occur, would yield a 20 2,247 MWe peak demand reduction in Mississippi (18.6 percent of projected peak demand). 21 The Business as Usual scenario suggests that demand response programs would yield a 22 reduction of 75 MWe (0.6 percent of projected peak demand) (FERC 2009). Entergy 23 Mississippi provides 33.7 percent of Mississippi's electricity, indicating that if Entergy achieved 24 the full participation demand reductions, it would yield a reduction of 765 MWe. This amount 25 would not be sufficient to replace the 1,475 MWe GGNS provides. In addition, according to an 26 ICF International study, the potential savings from energy conservation and energy efficiency 27 across Entergy's six operating companies could reach 729 MWe by 2019 and 1,0 50 MWe by 28 2029, adjusted for a reasonable implementation and approval timeline. Mississippi offers 29 voluntary financial incentive programs, an energy efficiency leasing program for public 30 institutions and hospitals, and low interest loans for energy efficiency projects, but it does not 31 require utilities to participate in DSM programs to reduce energy demand. While significant 32 Environmental Impacts of Alternatives 8-47 energy savings are possible in Mississippi through DSM, the NRC nevertheless does not 1 consider DSM to be a reasonable alternative to license renewal of GGNS. NRC evaluated an 2 alternative with DSM programs in combination with an NGCC plant, biomass -fueled plants, and 3 purchased power in Section 8.4. 4 8.5.2 Wind Power 5 As an intermittent energy source, the feasibility of wind generation to serve as baseload power 6 depends on the availability, constancy, and accessibility of wind resources within a specific 7 region. At the current stage of wind energy technology, DOE's National Renewable Energy 8 Laboratory (NREL) considers areas with annual average wind speeds around 6.5 meters per 9 second (m/s) (21 ft/s) and greater (at a height of 80 m [262 ft]) to have a wind resource suitable 10 for wind development (NREL 2012a). The majority of Mississippi has wind speeds between 4.0 11 and 5.0 m/s, although a small area in the northwest part of the state has wind speeds of 5.5 m/s 12 (NREL 2012a). NREL has estimated the windy land area and wind energy potential, including 13 potential megawatts of rated capacity and estimated potential annual wind energy generation, 14 for each state (NREL 2012b). According to their analyses, Mississippi does not have sufficient 15 wind resources for any utility -scale wind energy generation. 16 In addition, the issue of intermittent wind, and subsequent intermittent generation of power, 17 must be overcome for wind generation to provide baseload power by 2024 when the current 18 GGNS operating license expires. Currently, limited viable energy storage opportunities exist, 19 although research is ongoing to connect wind farms with storage technologies such as pumped 20 water storage, batteries, and compressed air energy storage (CAES) (EAC 2008). EIA is not 21 projecting any growth in pumped water storage capacity through 2035 (EIA 2011a). As 22 described below, the potential for new hydroelectric development in Mississippi is limited. 23 Therefore, the NRC concludes that the use of pumped water storage in combination with wind 24 farms is unlikely in Mississippi. A CAES plant is another potential storage option that could 25 possibly serve as a way for wind to provide baseload power. A CAES plant compresses air in 26 an underground storage cavern. To extract the stored energy, compressed air is combusted, 27 through a gas -turbine connected to an electrical generator (NREL 2010a). Currently, besides 28 pumped hydropower storage, deployment of storage technologies in the United States has been 29 limited to a 110 -MWe CAES facility in Alabama and two planned CAES projects with a 30 combined capacity of 450 MWe (NREL 2010a, Sandia 2012). Current and proposed CAES 31 projects have a much smaller capacity than would be necessary to replace GGNS; therefore, 32 the NRC concludes that the use of CAES in combination with wind turbines to generate 33 1,475 MWe in Mississippi is unlikely. 34 Another solution to overcoming intermittency is the concept of interconnected wind farms. Wind 35 farms located at a great distance from one another and connected through the transmission grid 36 could increase the capacity factor compared to a single wind farm in one location. As more 37 farms are interconnected, the probability that they will all experience the same wind 38 environment decreases, and the array acts more like a single wind farm with a steady wind 39 speed (Archer et al. 2007). In Mississippi, however, the wind generation potential is so low that 40 even when combined with energy storage or interconnected wind farms, it is very unlikely that 41 wind could serve as baseload power to replace GGNS. 42 Offshore Wind. The potential for offshore wind generation off the coast of Mississippi is not 43 likely sufficient to replace GGNS. Although the wind resources are generally stronger in 44 offshore areas, the wind speeds off the coast of Mississippi and Louisiana are weak compared 45 to offshore resources in other areas of the United States. Off shore from the Louisiana coast, 46 wind speeds range between 7.0-8.0 m/s at 90 m compared to 9.0 -10.0 m/s at 90 m off the 47 coast of the Northeast United States where the only utility -scale offshore wind farm has been 48 Environmental Impacts of Alternatives 8-48 approved (NREL 2010b). Texas has the most potential for offshore wind development in the 1 gulf coast with wind speeds reaching between 7.5 -9.0 m/s (NREL 2010b), and is the only State 2 in the region to express interest in developing offshore wind energy resources. The Texas 3 General Land Office has approved leases for offshore wind projects; however none have started 4 construction (offshorewindfarm.net 2012). Currently, no wind energy projects are proposed off 5 the coasts of Mississippi or Louisiana (offshorewindfarm.net 2012). 6 The capital costs for offshore wind projects are much greater than the costs for land -based wind 7 projects, which will likely prohibit offshore wind development in the near future. A paper 8 published by the U.S. Offshore Wind Collaborative estimates that initial capital costs for offshore 9 wind projects are 30 to 60 percent greater than for land -based wind projects. Construction 10 costs are 33 percent higher for offshore wind farms (USOWC 2009). Foundations for wind 11 turbines are much more expensive because they must be designed to withstand high winds and 12 waves. Costs for facility foundations, towers, transmission, and installation are much more 13 expensive than those for land -based farms (USOWC 2009). In addition, the current 14 commercially available offshore wind turbines may not be able to withstand major hurricanes. 15 Currently, the most stringent class of specifications for wind turbines assumes gusts no stronger 16 than 70 m/s, while Category 4 and 5 hurricanes, which often come through coastal Mississippi 17 and Louisiana, can have gusts greater than 80 m/s (NREL 2010c). 18 Conclusion. Given the low wind resource potential both on and off shore in Mississippi and the 19 surrounding region, high costs, and intermittency experienced in wind generation, the NRC does 20 not consider wind to be a reasonable alternative to license renewal. 21 8.5.3 Solar Power 22 Solar power, including solar photovoltaic and concentrated solar power technologies, produce 23 power generated from sunlight. Photovoltaics convert sunlight directly into electricity using solar 24 cells, made from silicon or cadmium telluride (NREL 2012c). By contrast, concentrating solar 25 power uses heat from the sun to boil water and produce steam to drive a turbine connected to a 26 generator to produce electricity (NREL 2012c). 27 In 2010, according to EIA, neither Mississippi, nor any of the surrounding States of Alabama, 28 Louisiana, or Arkansas produced any large -scale electricity from solar energy (NREL 2012d). 29 DOE's National Renewable Energy Laboratory (NREL) reports that Mississippi has average 30 solar insolation useful for solar applications ranging between 4.0 -5.9 kWh/m 2/day 31 (NREL 2012d). For utility -scale development, insolation levels below 6.5 kWh/m 2/day are not 32 considered economically viable given current technologies (BLM/DOE 2010). There is more 33 potential for solar development with local photovoltaic applications, such as rooftop solar panels 34 than through utility -scale solar facilities. In addition, a solar facility can only generate electricity 35 when the sun is shining. Energy storage can be used to overcome intermittency for solar 36 facilities, however, current and foreseeable storage technologies have a much smaller capacity 37 than would be necessary to replace GGNS (as described above in the discussion of wind 38 power). Taking all of the factors above into account, it is unlikely that solar photovoltaic or 39 concentrated solar power technologies could serve as baseload power in Mississippi. Given the 40 modest levels of solar energy available throughout the State, the lack of any installed solar 41 capacity in Mississippi and the weather -dependent intermittency of solar power, the NRC does 42 not currently consider solar energy to be a reasonable alternative to license renewal. 43 8.5.4 Hydroelectric Power 44 Hydroelectric power uses the force of water to turn turbines, which spins a generator to produce 45 electricity. In a run-of-the-river system, the force of a river current provides the force to create 46 Environmental Impacts of Alternatives 8-49 the needed pressure for the turbine. In a storage system, water is accumulated in reservoirs 1 created by dams and is released as needed to generate electricity. DOE's Idaho National 2 Environmental Engineering Laboratory completed a comprehensive survey of hydropower 3 resources in Mississippi in 1997. Mississippi has little hydroelectric potential, with a total 4 generating potential of 92 -128 MWe (INEEL 1997). EIA reported that Mississippi did not 5 generate any electricity from conventional hydroelectric power in 2010 (EIA 2012 a). Given the 6 small potential capacities and actual power generation of hydroelectric facilities in Mississippi, 7 the NRC does not consider hydroelectric power to be a reasonable alternative to license 8 renewal. 9 8.5.5 Wave and Ocean Energy 10 Wave energy is generated by the movement of a device either floating on the surface of the 11 ocean or anchored to the ocean floor. Kinetic energy from waves pumps fluid through turbines 12 to create electric power (DOE 2009). Waves, currents, and tides are often predictable and 13 reliable, making them attractive candidates for potential renewable energy generation. 14 There are modest wave energy resources available off the Gulf Coast. However, wave energy 15 technology is still in the early stages of development. The potential for wave and ocean energy 16 in Mississippi is limited because the Gulf of Mexico is shallow and semi -enclosed (TCPA 2008). 17 Because most technologies are relatively undeveloped (and none are developed on the scale of 18 GGNS), and because the Gulf of Mexico has limited potential for wave and ocean energy, the 19 NRC did not consider wave and ocean energy as a reasonable alternative to GGNS license 20 renewal. 21 8.5.6 Geothermal Power 22 Geothermal technologies extract the heat contained in geologic formations to produce steam to 23 drive a conventional steam turbine generator. Facilities producing electricity from geothermal 24 energy have demonstrated capacity factors of 95 percent or greater, making geothermal energy 25 eligible as a source of baseload electric power. However, the feasibility of geothermal power 26 generation to provide baseload power depends on the regional quality and accessibility of 27 geothermal resources. Utility-scale geothermal energy generation requires geothermal 28 reservoirs with a temperature above 200

°F (93 °C). Utility-scale power plants range from small 29 300 kWe to 50 MWe and greater (TEEIC 2012)

. In general, geothermal resources are 30 concentrated in the western United States. Specifically, these resources are found in Alaska, 31 Arizona, California, Colorado, Hawaii, Idaho, Montana, Nevada, New Mexico, Oregon, Utah, 32 Washington, and Wyoming (USGS 2008). The largest geothermal generation project in 33 Mississippi was a 0.5 MWe geothermal coproduction demonstration project completed in 2011, 34 which was funded by a Department of Energy's Research Partnership to Secure Energy for 35 America (RPSEA) grant (GEA 2012). The project generated electricity from water produced as 36 a byproduct of oil production. The 6 -month demonstration project has since been concluded. 37 The high cost to produce electricity using geothermal coproduction limited its commercial 38 deployment, though the demonstration project established its technical viability 39 (ElectraTherm 2012). No other electricity is currently being produced from geothermal 40 resources in Mississippi (DOE 2012). Given the low resource potential in Mississippi, the NRC 41 does not consider geothermal to be a reasonable alternative to GGNS license renewal. 42 8.5.7 Municipal Solid Waste 43 Municipal solid waste combustors use three types of technologies -mass burn, modular, and 44 refuse-derived fuel. Mass burning is currently the method used most frequently in the 45 Environmental Impacts of Alternatives 8-50 United States and involves no (or little) sorting, shredding, or separation. Consequently, toxic or 1 hazardous components present in the waste stream are combusted, and toxic constituents are 2 exhausted to the air or become part of the resulting solid wastes. As of 2010, approximately 3 86 waste-to-energy plants are in operation in 24 states, processing 97,000 tons of municipal 4 solid waste per day (ERC 2010). These waste -to-energy plants have an aggregate capacity of 5 2,572 MWe and can operate at capacity factors greater than 90 percent. The average 6 waste-to-energy plant produces about 50 MWe, with some reaching 77 MWe (ERC 2010). No 7 waste-to-energy facilities operate in Mississippi (ERC 2010). More than 29 average -sized 8 plants would be necessary to provide the same level of output as GGNS, increasing national 9 waste-to-energy generation by 57 percent. 10 The decision to burn municipal waste to generate energy is usually driven by the need for an 11 alternative to landfills rather than energy considerations. Given the improbability that additional 12 stable supplies of municipal solid waste would be available to support approximately 29 new 13 facilities and that no waste -to-energy plants operate in Mississippi, the NRC does not consider 14 municipal solid waste combustion to be a reasonable alternative to GGNS license renewal. 15 8.5.8 Biomass 16 Biomass resources used for biomass -fired generation include crop residues, switch grass, forest 17 residues, methane from landfills, methane from animal manure management, primary wood mill 18 residues, secondary wood mill residues, urban wood wastes, and methane from domestic 19 wastewater treatment. Using biomass -fired generation for baseload power depends on the 20 geographic distribution, available quantities, constancy of supply, and energy content of 21 biomass resources. As described in more detail in Section 8.4, the technology used for 22 conversion of biomass to electricity would be direct combustion. 23 In the GEIS, the NRC indicated a wood waste facility could provide baseload power and operate 24 with capacity factors between 70 and 80 percent (NRC 1996). Mississippi generated only 25 236 MWe from biomass fuels in 2010 (EIA 2012b). It is unlikely that Mississippi could increase 26 its capacity by adding 1,475 MWe of electricity from biomass -fired generation by the time 27 GGNS's license expires in 2024. 28 Biomass-fired generation plants generally are small and can reach capacities of 50 MWe, 29 meaning that 30 new facilities would be required before 2024. In addition, according to an 30 NREL report, Mississippi has almost 16 million tons/year total available biomass resources 31 (NREL 2005). For the hypothetical biomass plant using wood residue described in Section 8.4, 32 approximately 2,000 tons/day of fuel would be consumed to support one 50 MWe unit 33 (ARI 2007). Based on a similar consumption rate, all of the available biomass in Mississippi 34 could support 1,000 MWe of power generation. Therefore, there would be insufficient biomass 35 in Mississippi to support 1,475 MWe of biomass -fired generation. In addition, small plant sizes 36 (20-50 MWe) lead to higher capital costs per kWh. Biomass-fired power plants typically are 37 less efficient than other energy sources; the biomass industry average is 20 percent compared 38 to 35 percent average efficiency for U.S. electricity generation. An inefficient power plant can 39 be more sensitive to changes in the price of fuel inputs (i.e., wood waste). High capital costs 40 combined with low efficiency have led to electricity prices ranging from $0.08 to $0.12/kWh 41 (NREL 2003). Given the large amount of biomass resources required to replace GGNS 42 compared to available resources, and potentially high cost, the NRC does not consider biomass 43 a reasonable alternative to GGNS. The NRC evaluated an alternative with biomass -fired 44 generation in combination with an NGCC plant, DSM, and purchased power in Section 8.4. 45 Environmental Impacts of Alternatives 8-51 8.5.9 Oil-Fired Power 1 EIA projects that oil -fired plants will account for a 2 percent increase in new electricity 2 generation from 2010 to 203 0 in the United States (EIA 2008b). In Mississippi, the percent of 3 electricity from oil -fired generation fell from 7.9 percent to 0.1 percent from 2000 to 2012 4 (EIA 2012a). 5 The variable costs of oil -fired generation tend to be greater than those of nuclear or coal -fired 6 operations, and oil -fired generation tends to have greater environmental impacts than natural 7 gas-fired generation. The high cost of oil has resulted in a steady decline in its use for electricity 8 generation. Given the high cost of oil and the decline in use of oil -fired power plants in 9 Mississippi over the past 10 years, the NRC does not consider oil -fired generation a reasonable 10 alternative to GGNS license renewal. 11 8.5.10 Fuel Cells 12 Fuel cells oxidize fuels without combustion and its environmental side effects. Fuel cells 13 function as an energy conversion technology that allows the energy stored in hydrogen to be 14 converted back into electrical energy for end use (EIA 2008a). The only byproducts (depending 15 on fuel characteristics) are heat, water, and CO

2. Hydrogen fuel can come from a variety of 16 hydrocarbon resources. Natural gas typically is used as the hydrogen source.

17 Presently, fuel cells are not economically or technologically competitive with other alternatives 18 for electricity generation. EIA projects that fuel cells may cost $6,835 per installed kW (total 19 overnight capital costs, 2010 dollars), which is high compared to other alternative technologies 20 analyzed in this section (EIA 2010b). More importantly, fuel cell units are likely to be small in 21 size (approximately 10 MWe). It would be extremely costly to replace the power GGNS 22 provides; it would require approximately 148 units and modifications to the existing transmission 23 system. Given the immature status of fuel cell technology and high cost, the NRC does not 24 consider fuel cells to be a reasonable alternative to GGNS license renewal. 25 8.5.11 Purchased Power 26 Under a purchased power alternative, no new generating capacity would necessarily be built 27 and operated by Entergy. Instead, 1 ,475 MWe would be purchased from other generators. 28 Those generators could be located anywhere within or outside Entergy's service territory. 29 Entergy's six operating companies rely on purchased power for a third of their energy needs 30 (Entergy 2009). Entergy's Strategic Resource Plan states that the six operating companies plan 31 on purchasing 1,4 00 MWe in limited -term purchases (1- to 5-year contracts) by 2025 32 (Entergy 2010). Limited -term purchases expose the utility and its customers to risk associated 33 with market price volatility and power availability. In its Strategic Resource Plan, Entergy 34 outlines how it plans to manage this risk by seeking to limit the amounts of limited -term 35 purchased power used to meet reliability requirements. Entergy also recognizes that the 36 amount of uncommitted capacity in the region is declining, and that purchased power may not 37 provide sufficient resources. In that case, Entergy acknowledges that it may need to build more 38 capacity than currently anticipated (Entergy 2009). For Entergy to replace the 1,475 MWe 39 provided by GGNS, it would have to double its amount of planned power purchases. If a 40 sufficient amount of additional energy from existing plants is not available, new power plants 41 would need to be constructed. Depending on location, the incorporation of new generation 42 sources from locations that are remote or distant from load centers likely would involve 43 significant expenditures in transmission infrastructure expansions. The NRC does not consider 44 purchased power to be a reasonable alternative to GGNS license renewal. 45 Environmental Impacts of Alternatives 8-52 8.5.12 Delayed Retirement 1 Currently, Entergy owns or controls 20,559 MWe of electricity generation and fails to meet the ir 2 system reliability requirement by approximately 1 GW (Entergy 2009). This conclusion is based 3 on current capacity ratings of the existing operating facilities, the expected peak load 4 requirement, and the planning reserve margin target (Entergy 2011). In addition, the projected 5 growth in demand over the next 20 years is expected to be 600 MW e/yr (Entergy 2011). Any 6 currently operating units scheduled for retirement that could be delayed would be needed to 7 meet this projected growth in demand and would be unavailable to replace existing generation. 8 Therefore, the NRC does not consider delayed retirement to be a reasonable alternative to 9 GGNS license renewal. 10 8.6 No-Action Alternative 11 This section examines environmental effects that would occur if the NRC took no action. No 12 action in this case means that the NRC decides to not issue a renewed operating license for 13 GGNS and the license expires at the end of the current license term, in November 2024. Under 14 the no-action alternative, the plant would shut down at or before the end of the current license. 15 After shutdown, plant operators would initiate decommissioning in accordance with 16 10 CFR 50.82. 17 This section addresses only those impacts that arise directly as a result of plant shutdown. The 18 environmental impacts from decommissioning and related activities already have been 19 addressed in several other documents, including Supplement 1 of NUREG -0586, Final Generic 20 Environmental Impact Statement on Decommissioning of Nuclear Facilities Regarding the 21 Decommissioning of Nuclear Power Reactors (NRC 2002); Chapter 7 of the license renewal 22 GEIS (NRC 1996); and Chapter 7 of this SEIS. These analyses either directly address or bound 23 the environmental impacts of decommissioning whenever Entergy ceases operating GGNS. 24 Even with a renewed operating license, GGNS will eventually shut down, and the environmental 25 effects addressed in this section will occur at that time. Since these effects have not otherwise 26 been addressed in this SEIS, the impacts will be addressed in this section. As with 27 decommissioning effects, shutdown effects are expected to be similar whether they occur at the 28 end of the current license or at the end of a renewed license. 29 8.6.1 Air Quality 30 Shutdown of GGNS would result in a reduction in emissions from activities related to plant 31 operation, such as use of diesel generators and employee vehicles. The staff determined that 32 these emissions would have a SMALL impact on air quality during the renewal term (see 33 Chapter 4); therefore, if emissions decrease, the impact to air quality would also decrease and 34 would be SMALL. 35 8.6.2 Groundwater Resources 36 Shutdown of GGNS would result in a reduction in groundwater use over that of continued plant 37 operation. Since it was determined that continued plant operations would have a SMALL impact 38 on groundwater use and quality during the renewal term (see Chapter 4), the impacts of 39 shutdown on groundwater use and quality would also be SMALL. 40 Environmental Impacts of Alternatives 8-53 8.6.3 Surface Water Resources 1 Shutdown of GGNS would result in a reduction in surface water use over that of continued plant 2 operation. Since it was determined that continued plant operations would have a SMALL impact 3 on surface water use and quality during the renewal term (see Chapter 4), the impacts of 4 shutdown on surface water use and quality would also be SMALL. 5 8.6.4 Aquatic Ecology 6 If the plant were to cease operating, impacts on aquatic ecology would decrease because the 7 plant would withdraw and discharge less water than it does during operations. Shutdown would 8 reduce the already SMALL impacts on aquatic ecology. 9 8.6.5 Terrestrial Ecology 10 If the plant were to cease operating, the terrestrial ecology impacts would be SMALL, assuming 11 that no additional land disturbances on or off site would occur during decommissioning 12 activities. 13 8.6.6 Human Health 14 In Chapter 4 of this SEIS, the staff concluded that the impacts of continued plant operation on 15 human health would be SMALL. After cessation of plant operations, the amounts of radioactive 16 material released to the environment in gaseous and liquid forms, all of which are currently 17 within respective regulatory limits, would be reduced or eliminated. Therefore, the staff 18 concludes that the impact of plant shutdown on human health would also be SMALL. In 19 addition, the potential for a variety of accidents would also be reduced to only those associated 20 specifically with shutdown activities and fuel handling. In Chapter 5 of this SEIS, the staff 21 concluded that impacts of accidents during operation would be SMALL. It follows, therefore, 22 that impacts on human health from a reduced suite of potential accidents after reactor operation 23 ceases would also be SMALL. Therefore, the staff concludes that impacts on human health 24 from the no -action alternative would be SMALL. 25 8.6.7 Land Use 26 Plant shutdown would not affect onsite land use. Plant structures and other facilities would 27 remain in place until decommissioning. Most transmission lines connected to GGNS would 28 remain in service after the plant stops operating. Maintenance of most existing transmission 29 lines would continue as before. The transmission lines could be used to deliver the output of 30 any new replacement power -generating facilities added to the GGNS site. Impacts on land use 31 from plant shutdown would be SMALL. 32 8.6.8 Socioeconomics 33 Plant shutdown would have a noticeable impact on socioeconomic conditions in the 34 communities located in the immediate vicinity of GGNS. Should GGNS shut down, there would 35 be immediate socioeconomic impact from the loss of jobs (some, though not all, of the 36 690 employees would begin to leave), and tax payments may be reduced. Since the majority of 37 GGNS employees reside in Claiborne, Hinds, Jefferson, and Warren Counties, socioeconomic 38 impacts from plant shutdown would be concentrated in these counties, with a corresponding 39 reduction in purchasing activity and tax contributions to the regional economy. Revenue losses 40 from GGNS operations would directly affect Claiborne County and other state taxing districts 41 Environmental Impacts of Alternatives 8-54 that are most reliant on the nuclear plant's tax revenue. The impact of the job loss, however, 1 may not be as noticeable given the amount of time required for decommissioning of the existing 2 facilities and the proximity of GGNS to metropolitan areas. The socioeconomic impacts of plant 3 shutdown (which may not entirely cease until after decommissioning) would, depending on the 4 jurisdiction, range from SMALL to LARGE. 5 8.6.9 Transportation 6 Traffic volumes on the roads in the vicinity of GGNS would be reduced after plant shutdown. 7 Most of the reduction in traffic volume would be associated with the loss of jobs at the nuclear 8 power plant. The number of deliveries to the power plant would be reduced until 9 decommissioning. Transportation impacts would be SMALL as a result of plant shutdown. 10 8.6.10 Aesthetics 11 Plant structures and other facilities would remain in place until decommissioning. Once 12 operations cease there would be no plume from the cooling tower. Therefore, aesthetic impacts 13 of plant shutdown would be SMALL. 14 8.6.11 Historic and Archaeological Resources 15 In Chapter 4, the staff concluded that the impacts of continued plant operation on historic and 16 archaeological resources would be SMALL. Onsite land use would not be affected immediately 17 by the cessation of operations. Plant structures and other facilities are likely to remain in place 18 until decommissioning. A separate environmental review would be conducted for 19 decommissioning that would address the protection of known historic and archaeological 20 resources at GGNS. Therefore, the impacts on historic and archaeological resources from plant 21 shutdown would be SMALL. 22 8.6.12 Environmental Justice 23 Impacts to minority and low -income populations would depend on the number of jobs and the 24 amount of tax revenues lost by communities in the immediate vicinity of the power plant after 25 GGNS ceases operations. Closure of GGNS would reduce the overall number of jobs (there 26 are currently 690 employees working at GGNS) and tax revenue attributed to nuclear plant 27 operations. The reduction in tax revenue could decrease the availability of public services in 28 Claiborne County. This could disproportionately affect minority and low -income populations that 29 may have become dependent on these services. See also Appendix J of NUREG -0586, 30 Supplement 1 (NRC 2002), for additional discussion of these impacts. 31 8.6.13 Waste Management 32 If the no-action alternative were implemented, the generation of high -level waste would stop, 33 and generation of low -level and mixed waste would decrease. Waste management impacts 34 from implementation of the no -action alternative are expected to be SMALL. 35 8.6.14 Summary of Impacts of Combination Alternative 36 Table 8-6 summarizes the environmental impacts of the no -action alternative compared to 37 continued operation of GGNS. 38 Environmental Impacts of Alternatives 8-55 Table 8-6. Summary of Environmental Impacts of the No -action Alternative 1 Compared to Continued Operation of GGNS 2 Category No-action Alternative Continued GGNS Operation Air Quality SMALL SMALL Groundwater Resources SMALL SMALL Surface Water Resources SMALL SMALL Aquatic Ecology SMALL SMALL Terrestrial Ecology SMALL SMALL Human Health SMALL SMALL Land Use SMALL SMALL Socioeconomics SMALL to LARGE SMALL Transportation SMALL SMALL Aesthetics SMALL SMALL Historic and Archaeological Resources SMALL SMALL Waste Management a SMALL SMALL a As described in Chapter 6, the issue, "offsite radiological impacts (spent fuel and high level waste disposal)," is not evaluated in this EIS.

8.7 Alternatives

Summary 3 In this chapter, the staff considered the following alternatives to GGNS license renewal: new 4 nuclear generation; NGCC generation; supercritical coal -fired generation; and a combination 5 alternative of natural gas, biomass -fired generation, DSM, and purchased power. No action by 6 NRC and its effects also were considered. The impacts for all alternatives to GGNS license 7 renewal are summarized in Table 8 -7. 8 The environmental impacts of the proposed action (issuing a renewed GGNS operating license) 9 would be SMALL for all impact categories, except for the Category 1 issue, "Offsite radiological 10 impacts (collective effects)" which the Commission concluded that the impacts are acceptable. 11 The issue, "Offsite radiological impacts (spent fuel and high level waste disposal" was not 12 reviewed in this SEIS because it relies on the Commission's Waste Confidence Decision 13 (WCD). The WCD was vacated on June 8, 2012, by the U.S. Court of Appeals for the District of 14 Columbia Circuit. The WCD is explained in more detail in Chapter 6 of this SEIS. 15 In conclusion, the environmental impacts from all other alternatives would be larger than the 16 impacts associated with license renewal. As Table 8 -7 shows, all other alternatives capable of 17 meeting the needs currently served by GGNS entail potentially greater impacts than the 18 proposed action of license renewal of GGNS. To make up the lost generation if license renewal 19 is denied, the no -action alternative would necessitate the implementation of one or a 20 combination of alternatives, all of which have greater impacts than the proposed action. Hence, 21 the staff concludes that the no -action alternative will have environmental impacts greater than or 22 equal to the proposed license renewal action. 23 In this chapter, the NRC staff considered the following alternatives to GGNS license renewal: 24 new nuclear generation; NGCC generation; supercritical coal -fired generation; a combination 25 alternative of natural gas, biomass, DSM and purchased power. No action by NRC and its 26 effects were also considered. The impacts for GGNS license renewal and for all alternatives to 27 GGNS license renewal are summarized in Table 8 -7. 28 In conclusion, the environmentally preferred alternative is the license renewal of GGNS. All 29 other alternatives capable of meeting the needs currently served by GGNS entail potentially 30 Environmental Impacts of Alternatives 8-56 greater impacts than the proposed action of license renewal of GGNS. In order to make up the 1 lost generation if license renewal is denied, the no -action alternative necessitates the 2 implementation of one or a combination of alternatives, all of which have greater impacts than 3 the proposed action. Hence, the NRC staff concludes that the no -action alternative will have 4 environmental impacts greater than or equal to the proposed license renewal action. 5 Environmental Impacts of Alternatives 8-57 Table 8-7. Summary of Environmental Impacts of Proposed Action and Alternatives 1 Alternative Air Quality Groundwater and Surface Water Resources Aquatic and Terrestrial Ecology Human Health Land Use Socioeconomics (including Transportation and Aesthetics) Archaeological and Historic Resources Waste Management License renewal SMALL SMALL SMALL SMALL SMALL SMALL SMALL SMALL New nuclear at GGNS site SMALL SMALL SMALL to MODERATE SMALL SMALL SMALL to LARGE SMALL SMALL NGCC at GGNS site SMALL to MODERATE SMALL SMALL to MODERATE SMALL SMALL to MODERATE SMALL to MODERATE SMALL SMALL SCPC at alternate site MODERATE SMALL SMALL to LARGE SMALL SMALL to MODERATE SMALL to LARGE SMALL to MODERATE MODERATE Combination alternative SMALL to MODERATE SMALL SMALL to MODERATE SMALL SMALL to LARGE SMALL to LARGE SMALL to LARGE SMALL No-action alternative SMALL SMALL SMALL SMALL SMALL SMALL TO LARGE SMALL SMALL Environmental Impacts of Alternatives 8-58 8.8 References 1 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 2 protection regulations for domestic licensing and related regulatory functions." 3 40 CFR Part 51. Code of Federal Regulations, Title 40, Protection of Environment, Part 51 , 4 "Requirements for Preparation, Adoption, and Submittal of Implementation Plans." 5 40 CFR Part 60. Code of Federal Regulations, Title 40, Protection of Environment, Part 60, 6 "Standards of Performance for New Stationary Sources." 7 40 CFR 81.68. Code of Federal Regulations, Title 40, Protection of Environment, Part 81.68, 8 "Mobile (Alabama) -Pensacola-Panama City (Florida) -Southern Mississippi Interstate Air Quality 9 Control Region." 10 65 FR 79825. U.S. Environmental Protection Agency. "Regulatory finding on the emissions of 11 hazardous air pollutants from electric utility steam generating units." Federal Register 12 65 (245): 79825. December 20, 2000. 13 [ACAA] American Coal Ash Association. 2010. "Coal Combustion Products Production & Use 14 Statistics, ACAA 2010 CCP Survey Results, and Production & Use Charts." Available at 15 <http://acaa.affiniscape.com/associations/8003/files/2010_CCP_Survey_FINAL_102011.pdf > 16 (accessed 21 September 2012). 17 [ARI] Alternative Resources, Inc. 2007. Final Report of Findings. Independent Third -Party 18 Environmental Review of Russell Biomass Project. September 20. 19 Archer, CL, Jacobson MZ. 2007. Supplying baseload power and reducing transmission 20 requirements by interconnecting wind farms. Journal of Applied Meteorology and Climatology 21 46(11)1701 -1717. Available at <http://www.stanford.edu/group/efmh/winds/aj07_jamc.pdf> 22 (accessed 25 March 2012). 23 [DOE] U.S. Department of Energy. Office of Energy Efficiency and Renewable Energy. 2009. 24 "Ocean Energy Technology Overview." Available at 25 <http://www1.eere.energy.gov/femp/pdfs/44200.pdf > (accessed 20 June 2012). 26 [DOE] Department of Energy. Office of Energy Efficiency and Renewable Energy. 2012. 27 "Geothermal Projects Database 2012." Available at 28 <http://www4.eere.energy.gov/geothermal/projects > (accessed 20 June 2012). 29 [BLM, DOE] U.S. Department of the Interior, Bureau of Land Management (BLM) and DOE. 30 2010. Draft Programmatic Environmental Impact Statement for Solar Energy Development in 31 Six Southwestern States (DES 10 -59; DOE/EIS -0403). December. Available at 32 <http://www.solareis.anl.gov/documents/dpeis/index.cfm> (accessed 12 October 2012) 33 [EAC] Electricity Advisory Committee. 2008. Bottling Electricity: Storage as a Strategic Tool for 34 Managing Variability and Capacity Concerns in the Modern Grid. December 2008. Available at 35 <http://www.beaconpower.com/files/EAC_Report_Energy_Storage_Manage_Grid_Variability_D 36 ec%202008.pdf > (accessed 24 May 2012). 37 [EIA] U.S. Energy Information Administration. 2008

a. The Impact of Increased Use of Hydrogen 38 on Petroleum Consumption and Carbon Dioxide Emissions. Available at 39 <http://www.eia.gov/oiaf/servicerpt/hydro/hfct.html

> (accessed 24 May 2012). 40 [EIA] U.S. Energy Information Administration. 2008b. Annual Energy Outlook 2011 with 41 Projections to 2030. Available at <http://205.254.135.7/oiaf/archive/aeo08/index.html > 42 (accessed 21 June 2012). 43 Environmental Impacts of Alternatives 8-59 [EIA] U.S. Energy Information Administration. 2010a. Cost and Quality of Fuels for Electric 1 Plants, November. Available at <http://205.254.135.7/electricity/cost_quality/pdf/cqa2009.pdf > 2 (accessed 20 June 2012). 3 [EIA] U.S. Energy Information Administration 2010

b. Updated Capital Cost Estimates for 4 Electricity Generation Plants. November. Available at 5 <http://www.eia.gov/oiaf/beck_plantcosts/pdf/updatedplantcosts.pdf> (accessed 25 May 2012).

6 [EIA] U.S. Energy Information Administration. 2011a. Annual Energy Outlook 2011 with 7 Projections to 2035. April. Available at 8 <http://www.eia.gov/forecasts/archive/aeo11/pdf/0383(2011).pdf > (accessed 25 May 2012). 9 [EIA] U.S. Energy Information Administration. 2011b. Assumptions to the Annual Energy 10 Outlook 2011. Washington, DC: DOE/EIA. July 2011. 11 [EIA] U.S. Energy Information Administration. 2012a. Mississippi Electricity Profile, 2010 Edition. 12 Available at <http://205.254.135.7/electricity/state/mississippi/ > (accessed 25 May 2012). 13 [EIA] U.S. Energy Information Administration. 2012b. Mississippi Renewable Energy Profile, 14 2010 Edition. Available at <http://205.254.135.7/renewable/state/mississippi/index.cfm > 15 (accessed 24 May 2012). 16 [EIA] U.S. Energy Information Administration 2012c. Emission Factors and Global Warming 17 Potentials. Available at <http://www.eia.gov/oiaf/1605/emission_factors.html> (accessed 18 20 June 2012). 19 ElectraTherm, 2012. Mississippi Oilfield Generates Low -Temperature, Emission Free 20 Geothermal Energy at the Wellhead. Available at 21 <http://electratherm.com/docs/Denbury%20White%20Paper.pdf > (accessed 20 June 2012). 22 [Entergy] Entergy Operations, Inc. 2008. Grand Gulf Nuclear Station, Unit 3 COL Applications, 23 Part 3 Environmental Report. 24 [Entergy] Entergy Operations, Inc. 2009. Strategic Resource Plan. Available at 25 <http://www.entergy -neworleans.com/content/irp/Chapters1_12.pdf> (accessed 6 June 2012). 26 [Entergy] Entergy Operations, Inc. 2010. 2009 Strategic Resource Plan Refresh. September. 27 [Entergy] Entergy Operations, Inc. 2011. Grand Gulf Nuclear Station, Unit 1, License Renewal 28 Application , Appendix E, Applicant's Environmental Report. Agencywide Documents Access 29 and Management System (ADAMS) Accession No. ML11308A234. 30 [Entergy] Entergy Operations, Inc. 2012. Hot Topics: System Agreement. Available at 31 <http://www.entergy.com/content/about_entergy/hot_topics/system_agreement.pdf> (accessed 32 14 June 2012). 33 [EPA] U.S. Environmental Protection Agency. 2012

a. New Source Review. July 3, 2012. 34 Available at <http://www.epa.gov/nsr/>

(accessed 23 July 2012). 35 [EPA] U.S. Environmental Protection Agency. 2012

b. List of 156 Mandatory Class I Federal 36 Areas. Available at

<http://www.epa.gov/visibility/class1.html> (accessed 20 June 2012). 37 [EPRI] Electric Power Research Initiative. 2011. Mapping and Assessment of the United States 38 Ocean Wave Energy Resource. Available at 39 <http://www1.eere.energy.gov/water/pdfs/mappingandassessment.pdf > (access ed 40 20 June 2012). 41 Environmental Impacts of Alternatives 8-60 [FERC] Federal Energy Regulatory Commission. 2009. A National Assessment of Demand 1 Response Potential. Staff Report. June. Available at <http://www.ferc.gov/legal/staff -reports/06 -2 09-demand-response.pdf> (accessed 25 March 2012). 3 [GEA] Geothermal Energy Association. 2012. Annual Geothermal Power Production and 4 Development Report. Available at 5 <http://www.geo -energy.org/reports/2012AnnualUSGeothermalPowerProductionandDevelopme6 ntReport_Final.pdf> (accessed 25 May 2012). 7 [ICF] ICF, International. 2009. Entergy New Orleans Demand Side Management Potential 8 Study: Summary. Available at 9 <http://www.entergy -neworleans.com/content/irp/Entergy_ENO_Potential_Study_v10_2009_04 10 _28.pdf> (accessed 19 June 2012). 11 [INEEL] Idaho National Engineering and Environmental Laboratory. 1997. U.S. Hydropower 12 Resource Assessment for Mississippi. November. Available at 13 <http://hydropower.inel.gov/resourceassessment/pdfs/states/ms.pdf > (accessed 24 May 2012). 14 [MSCEQ] Mississippi Commission of Environmental Quality. 2005. Regulation SW -2: 15 Nonhazardous Solid Waste Management Regulations and Criteria. Available at: 16 http://www.deq.state.ms.us/newweb/MDEQRegulations.nsf/c70604500020692b86256e1200585 17 8cb/cd70fb66996fc55f86256bd100530dad?OpenDocument (Accessed Nov 2012) 18 [NETL] National Energy Technology Laboratory. 2007. Cost and Performance Baseline for 19 Fossil Energy Plants, Vol. 1, Bituminous Coal and Natural Gas to Electricity. DOE/NETL 20 2007/1281, Final Report, U.S. Department of Energy, Pittsburgh, Pennsylvania. Revision 1, 21 August. Available at <http://www.netl.doe.gov/energy -analyses/baseline_studies.html> 22 (accessed 20 June 2012). 23 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 24 for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG -1437. May 1996. 25 [NRC] U.S. Nuclear Regulatory Commission. 2002. Final Generic Environmental Impact 26 Statement on Decommissioning of Nuclear Facilities Regarding the Decommissioning of 27 Nuclear Power Reactors. Washington, DC: NRC. NUREG -0586, Supplement 1. 28 November 2002. ADAMS Accession Nos. ML023470304 and ML023500295. 29 [NRC] U.S. Nuclear Regulatory Commission. NRC 2012a. Issued Early Site Permit -Grand Gulf 30 Site. Available at <http://www.nrc.gov/reactors/new -reactors/esp/grand -gulf.html> (accessed 31 14 June 2012). 32 [NRC] U.S. Nuclear Regulatory Commission. NRC 2012b. Grand Gulf, Unit 3 Application. 33 Available at <http://www.nrc.gov/reactors/new -reactors/col/grand -gulf.html> (accessed 34 14 June 2012). 35 [NREL] National Renewable Energy Laboratory 1999. The Value of the Benefits of 36 U.S. Biomass Power. Available at <http://www.nrel.gov/docs/fy00osti/27541.pdf > (accessed 37 19 June 2012). 38 [NREL] National Renewable Energy Laboratory. 2003. Biopower Technical Assessment: State 39 of the Industry and Technology. March. Available at <http://www.fs.fed.us/ccrc/topics/urban -40 forests/docs/Biopower_Assessment.pdf> (accessed 19 June 2012). 41 [NREL] National Renewable Energy Laboratory. 2005. A Geographic Perspective on the 42 Current Biomass Resource Availability in the United States. Technical Report 43 NREL/TP-560-39181. 44 Environmental Impacts of Alternatives 8-61 [NREL] National Renewable Energy Laboratory 2010a. The Role of Energy Storage with 1 Renewable Electricity Generation. Available at <http://www.nrel.gov/docs/fy10osti/47187.pdf > 2 (accessed 20 June 2012). 3 [NREL] National Renewable Energy Laboratory. 2010b. Offshore 90 -Meter Wind Maps and 4 Wind Resource Potential. June 2010. Available at 5 <http://www.windpoweringamerica.gov/windmaps/offshore.asp > (accessed 20 June 2012). 6 [NREL] National Renewable Energy Laboratory. 2010c. Large-Scale Offshore Wind Power in 7 the United States: Assessment of Opportunities and Barriers. September. Available at 8 <http://www.nrel.gov/wind/pdfs/40745.pdf > (accessed 24 May 2012). 9 [NREL] National Renewable Energy Laboratory. 2010d. 2008 Solar Technologies Market 10 Report. January. Available at <http://www1.eere.energy.gov/solar/pdfs/46025.pdf> (accessed 11 20 June 2012). 12 [NREL] National Renewable Energy Laboratory. 2012a. "Utility-Scal e Land-Based 80-Meter 13 Wind Maps." Available at <http://www.windpoweringamerica.gov/wind_maps.asp > (accessed 14 24 May 2012). 15 [NREL] National Renewable Energy Laboratory. 2012b. "Wind Resource Potential." Available at 16 <http://www.windpoweringamerica.gov/windmaps/resource_potential.asp> (accessed 17 24 May 2012). 18 [NREL] National Renewable Energy Laboratory. 2012c. "Solar Photovoltaic Technology Basics." 19 Available at <http://www.nrel.gov/learning/re_photovoltaics.html > (accessed 20 June 2012). 20 [NREL] National Renewable Energy Laboratory. 2012d. "Solar Maps." Available at 21 <http://www.nrel.gov/gis/solar.html > (accessed 24 May 2012). 22 Offshorewindfarm.net. "Map of Offshore Wind Energy Activity in North America" (accessed 23 20 June 2012). 24 Reuters. 2012. "Southern Co. Appeals Mississippi's C oal-plant Rate Hike Denial." Available at 25 <http://in.reuters.com/article/2012/07/09/utilities -southern-kemper-idINL2E8I9EOC20120709 > 26 (accessed 31 July 2012). 27 Palmer Renewable Energy, LLC. 2011. 35 MW Biomass -fired Power Plant Conditional 28 Approval. Available at <http://www.mass.gov/dep/public/hearings/precpa_en.pdf > (accessed 29 20 June 2012). 30 [Sandia] Sandia National Laboratories. 2012. Energy Storage Systems: ARRA Energy Storage 31 Demonstrations. Available at <http://www.sandia.gov/ess/docs/ARRA_StorDemos_4 11.pdf> 32 (accessed 20 June 2012). 33 [Siemens] Siemens Power Generation. 2007. Technical Data: Combined Cycle Power Plant 34 Performance Data. Available at 35 <http://www.powergeneration.siemens.com/products -solutions-services/power -plant-36 soln/combined-cycle-power-plants/technical -data> (accessed 20 June 2012). 37 [TEEIC] Tribal Energy and Environmental Information Center. Utility-Scale and Direct Use 38 Geothermal Energy Generation. Available at 39 <http://teeic.anl.gov/er/geothermal/restech/scale/index.cfm > (accessed 20 June 2012). 40 [TCPA] Texas Comptroller of Public Accounts. 2008. The Energy Report 2008. Austin, TX. 41 Available at <http://www.window.state.tx.us/specialrpt/energy/> (accessed 17 October 2011). 42 Environmental Impacts of Alternatives 8-62 [USGS] U.S. Geological Survey. 2008. Assessment of Moderate- and High-Temperature 1 Geothermal Resources of the United States. Available at <http://pubs.usgs.gov/24 2 f s/2008/3082/pdf/fs2008 -3082.pdf> (accessed 24 May 2012). 3 [USOWC] U.S. Offshore Wind Collaborative 2009. U.S Offshore Wind Energy: A Path Forward. 4 A Working Paper of the U.S. Offshore Wind Collaborative. October. Available at 5 <http://www.usowc.org/pdfs/PathForwardfinal.pdf > (accessed 7 June 2012). 6 9-1

9.0 CONCLUSION

1 This draft supplemental environmental impact statement (SEIS) contains the environmental 2 review of Entergy Operations , Inc.'s (Entergy's) application for a renewed operating license for 3 Grand Gulf Nuclear Station , Unit 1 (G G N S), as required by Title 10 of the Code of Federal 4 Regulations Part 51 (10 CFR Part 51), the U.S. Nuclear Regulatory Commission's (NRC 's) 5 regulations that implement the National Environmental Policy Act (NEPA). This chapter 6 presents conclusions and recommendations from the site-specific environmental review of 7 G G N S and summarizes site-specific environmental issues of license renewal that the NRC staff 8 (staff) noted during the review. Section

9.1 summarizes

the environmental impacts of license 9 renewal; Section

9.2 presents

a comparison of the environmental impacts of license renewal 10 and energy alternatives; Section

9.3 discusses

unavoidable impacts of license renewal, energy 11 alternatives, and resource commitments; and Section

9.4 presents

conclusions and staff 12 recommendations . 13 9.1 Environmental Impacts of License Renewal 14 Based on the staff's review of site -specific environmental impacts of license renewal presented 15 in this SEIS, the staff concludes that issuing a renewed license would have SMALL impacts. 16 The site-specific review included applicable Category 2 issues and uncategorized issues. The 17 staff considered mitigation measures for each Category 2 issue, as applicable. The staff 18 concluded that no additional mitigation measure is warranted. 19 The staff also considered cumulative impacts of past, present, and reasonably foreseeable 20 future actions, regardless of what agency (Federal or non -Federal) or person undertakes them. 21 The staff concluded in Section 4.1 2 that cumulative impacts of GGNS's license renewal would 22 be SMALL for all areas , except aquatic and terrestrial resources. For aquatic resources, the 23 staff concluded that the cumulative impact would be MODERATE. For terrestrial resources, the 24 cumulative impacts would be MODERATE . 25 9.2 Comparison of Alternatives 26 In the conclusion to Chapter 8, the staff considered the following alternatives to GGNS license 27 renewal: 28 new nuclear, 29 natural gas -fired combined -cycle (NGCC), 30 supercritical pulverized coal , 31 combination alternative of NGCC, biomass, demand -side management and 32 purchased power , and 33 no-action. 34 The NRC staff concluded that the environmental impacts of renewal of the operating license for 35 GGNS would be smaller than those of feasible and commercially viable alternatives. The 36 no-action alternative would have SMALL environmental impacts in most areas , with the 37 exception of socioeconomic impact

s. Continued operation would have SMALL environmental 38 impacts in all areas. The staff concluded that continued operation of the existing GGNS is the 39 environmentally preferred alternative

. 40 Conclusion 9-2 9.3 Resource Commitments 1 9.3.1 Unavoidable Adverse Environmental Impacts 2 Unavoidable adverse environmental impacts are impacts that would occur after implementation 3 of all workable mitigation measures. Carrying out any of the energy alternatives considered in 4 this SEIS, including the proposed action, would result in some unavoidable adverse 5 environmental impacts. 6 Minor unavoidable adverse impacts on air quality would occur because of emission and release 7 of various chemical and radiological constituents from power plant operations. Nonradiological 8 emissions resulting from power plant operations are expected to comply with 9 U.S. Environmental Protection Agency emissions standards. Chemical and radiological 10 emissions are not expected to exceed the National Emission Standards for hazardous air 11 pollutants. 12 During nuclear power plant operations, workers and members of the public would face 13 unavoidable exposure to radiation and hazardous and toxic chemicals. Workers would be 14 exposed to radiation and chemicals associated with routine plant operations and the handling of 15 nuclear fuel and waste material. Workers would have higher levels of exposure than members 16 of the public, but doses would be administratively controlled and would not exceed standards or 17 administrative control limits. In comparison, the alternatives involving the construction and 18 operation of a non -nuclear power generating facility also would result in unavoidable exposure 19 to hazardous and toxic chemicals to workers and the public. 20 The generation of spent nuclear fuel and waste material, including low -level radioactive waste, 21 hazardous waste, and nonhazardous waste , also would be unavoidable. In comparison, 22 hazardous and nonhazardous wastes also would be generated at non -nuclear power generating 23 facilities. Wastes generated during plant operations would be collected, stored, and shipped for 24 suitable treatment, recycling, or disposal in accordance with applicable Federal and State 25 regulations. Because of the costs of handling these materials, power plant operators would be 26 expected to carry out all activities and optimize all operations in a way that generates the 27 smallest amount of waste possible. 28 9.3.2 Short-Term Versus Long -Term Productivity 29 The operation of power generating facilities would result in short -term uses of the environment, 30 as described in Chapters 4, 5, 6, 7, and

8. "Short-term" is the period of time that continued 31 power generating activities take place.

32 Power plant operations require short -term use of the environment and commitment of resources 33 (e.g., land and energy), indefinitely or permanently. Certain short -term resource commitments 34 are substantially greater under most energy alternatives, including license renewal, than under 35 the no-action alternative because of the continued generation of electrical power and the 36 continued use of generating sites and associated infrastructure. During operations, all energy 37 alternatives require similar relationships between local short -term uses of the environment and 38 the maintenance and enhancement of long -term productivity. 39 Air emissions from power plant operations introduce small amounts of radiological and 40 nonradiological constituents to the region around the plant site. Over time, these emissions 41 would result in increased concentrations and exposure, but they are not expected to impact air 42 quality or radiation exposure to the extent that public health and long -term productivity of the 43 environment would be impaired. 44 Conclusion 9-3 Continued employment, expenditures, and tax revenues generated during power plant 1 operations directly benefit local, regional, and State economies over the shor t term. Local 2 governments investing project -generated tax revenues into infrastructure and other required 3 services could enhance economic productivity over the long term. 4 The management and disposal of spent nuclear fuel, low -level radioactive waste, hazardous 5 waste, and nonhazardous waste requires an increase in energy and consumes space at 6 treatment, storage, or disposal facilities. Regardless of the location, the use of land to meet 7 waste disposal needs would reduce the long -term productivity of the la nd. 8 Power plant facilities are committed to electricity production over the short term. After 9 decommissioning these facilities and restoring the area, the land could be available for other 10 future productive uses. 11 9.3.3 Irreversible and Irretrievable Commitments of Resources 12 This section describes the irreversible and irretrievable commitment of resources that have 13 been noted in this SEIS. Resources are irreversible when primary or secondary impacts limit 14 the future options for a resource. An irretrievable commitment refers to the use or consumption 15 of resources that are neither renewable nor recoverable for future use. Irreversible and 16 irretrievable commitment of resources for electrical power generation include the commitment of 17 land, water, energy, raw materials, and other natural and man made resources required for 18 power plant operations. In general, the commitment of capital, energy, labor, and material 19 resources also are irreversible. 20 The implementation of any of the energy alternatives considered in this SEIS would entail the 21 irreversible and irretrievable commitment of energy, water, chemicals, and -in some cases -22 fossil fuels. These resources would be committed during the license renewal term and over the 23 entire life cycle of the power plant, and they would be unrecoverable. 24 Energy expended would be in the form of fuel for equipment, vehicles, and power plant 25 operations and electricity for equipment and facility operations. Electricity and fuel would be 26 purchased from offsite commercial sources. Water would be obtained from existing water 27 supply systems. These resources are readily available, and the amounts required are not 28 expected to deplete available supplies or exceed available system capacities. 29 9.4 Recommendations 30 The NRC staff's preliminary recommendation is that the adverse environmental impacts of 31 license renewal for G G N S are not great enough to deny the option of license renewal for 32 energy-planning decisionmakers. This recommendation is based on the following: 33 the analysis and findings in NUREG -1437, Volumes 1 and 2, Generic 34 Environmental Impact Statement for License Renewal of Nuclear Plants , 35 the environmental report submitted by E ntergy , 36 consultation with Federal, State, and local agencies, 37 the NRC's environmental review, and 38 consideration of public comments received during the scoping process. 39

10-1 10.0 LIST OF PREPARERS 1 Members of the U.S. Nuclear Regulatory Commission 's (NRC's) Office of Nuclear Reactor 2 Regulation (NRR) prepared this supplemental environmental impact statement (SEIS) with 3 assistance from other NRC organizations and contract support from Argonne National 4 Laboratory (ANL), Pacific Northwest National Laboratory (PNNL), the Center for Nuclear Waste 5 Regulatory Analyses (CNWRA) and a private contractor. Table 10-1 identifies each 6 contributor's name, affiliation, and function or expertise. 7 Table 10-1. List of Preparers 8 Name Affiliation Function or Expertise NRC D. Wrona NRR Management oversight M. Wong NRR Management oversight D. Drucker NRR Project management W. Rautzen NRR Radiological, human health and alternatives S. Klementowicz NRR Radiological, human health and alternatives B. Ford NRR Hydrology and alternatives M. Moser NRR Aquatic ecology and alternatives B. Grange NRR Terrestrial ecology and alternatives E. Larson NRR Cultural resources , cumulative impacts and alternatives J. Rikhoff NRR Socioeconomic, environmental justice, and land use and alternatives E. Keegan NRR Air quality and meteorology (climatology), alternatives and nonradiological waste management N. Martinez NRR Air quality and meteorology (climatology) J. Dozier NRR Severe Accident Mitigation Alternatives Contractor(a)(b)(c) J. Quinn ANL Hydrology and alternatives K. Wescott ANL Cultural resources and alternatives E. Moret ANL Alternatives Y. Chang ANL Air quality and meteorology (climatology) and alternatives D. Anderson PNNL Socioeconomic, environmental justice, and land use R. Benke CNWRA Severe Accident Mitigation Alternatives E. R. Schmidt Contractor Severe Accident Mitigation Alternatives (a) ANL is operated by UChicago Argonne, LLC, for the U.S. Department of Energy . (b) PNNL is operated by Battelle for the U.S. Department of Energy. (c) CNWRA is a federally funded research and development center sponsored by the NRC.

11-1 11.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS 1 TO WHOM COPIES OF THIS SEIS ARE SENT 2 Name and Title Affiliation and Address Chief Phyliss Anderson Tribal Nation -Mississippi Band of Choctaw Indians P.O. Box 6010 Choctaw Branch Choctaw, MS 39350 Principal Chief B. Cheryl Smith Tribal Nation -Jena Band of Choctaw Indians P.O. Box 14 Jena, LA 71342 Chief Gregory Pyle Tribal Nation -Choctaw Nation of Oklahoma P. O. Box 1210 Durant, OK 74702-1210 Chairman Earl J. Barbry, Jr. Tribal Nation -Tunica-Biloxi Tribe of Louisiana P.O. Box 1589 Marksville, LA 71351 Reid Nelson, Director Advisory Council on Historic Preservation Office of Federal Agency Programs 1100 Pennsylvania Avenue, NW , Suite 803 Washington, DC 20004 David Bernhart, Assistant Regional Administrator National Marine Fisheries Service , Southeast Regional Office 263 13th Avenue, South Saint Petersburg, FL 33701 Stephen Ricks, Field Supervisor U.S. Fish and Wildlife Service , Mississippi Field Office 6578 Dogwood View Parkway, Suite A Jackson, MS 39213 Jeffrey Weller, Field Supervisor U.S. Fish and Wildlife Service, Louisiana Field Office 646 Cajundome Blvd., Suite 400 Lafayette, LA 70506 Andy Sanderson, Ecologist Mississippi, Department of Wildlife, Fisheries and Parks 2148 Riverside Drive Jackson, MS 39202 Amity Bass, Ecologist Louisiana, Department of Wildlife and Fisheries P.O. Box 98000 Baton Rouge, LA 70898-9000 Greg Williamson , Review and Compliance Officer Mississippi State Historic Preservation Office P.O. Box 571 Jackson, MS 39205 Phil Boggan, Deputy Director Louisiana State Historic Preservation Office P.O. Box 44247 Baton Rouge, LA 70804 James Johnston, Administrator Claiborne County, Mississippi, Office of the Administrator P.O. Box 689 510 Main St. Port Gibson, MS 39150 Fred Reeves, Mayor City of Port Gibson, Mississippi 1005 College Street Port Gibson, MS 39150 Debra Chambliss, Deputy City Clerk Office of the Mayor, Port Gibson, Mississippi 1005 College Street Port Gibson, MS 39150 List of Agencies, Organizations, and Persons To Whom Copies of This SEIS Are Sent 11-2 Name and Title Affiliation and Address Bryan Collins, Chief, Energy and Transportation Branch Mississippi Department of Environmental Quality P.O. Box 2261 Jackson, MS 39225 B. J. Smith, Director Mississippi Division of Radiological Health 3150 Lawson St. P.O. Box 1700 Jackson, MS 39215-1700 Cheryl Chubb, Project Manager Louisiana Department of Environmental Quality 602 North Fifth Street Baton Rouge, LA 70802 Patricia Hemphill, Deputy Chief, Programs & Project Management U.S. Army Corps of Engineers, Vicksburg District 4155 East Clay Street Vicksburg, MS 39183 -3435 Jan Hillegas, Acting Chair Green Party of Mississippi 8 Gumtree Drive Oxford, MS 38655 Heinz Mueller, Chief, Environmental Assessment Branch U.S. Environmental Protection Agency, Region 4 Room 9T-25 Office of Environmental Accountability , Atlanta Federal Center, 61 Forsyth Street, SW Atlanta, GA 30303-3104 EIS Filing Section U.S. Environmental Protection Agency 1200 Pennsylvania Ave., NW Washington, D.C. 20004 Also sent via EPA's e-NEPA Web site 12-1 12.0 INDEX 1 A 2 accidents, 2-1, 2-6, 5-1, 5-3, 5-4, 5-5, A-3, F-3, 3 F-6, F-10, F-11, F-12, F-16, F-17, F-33, F-35, 4 F-40, F-41 5 Advisory Council on Historic Preservation 6 (ACHP), 21, 1-7, 4-24, 4-53, 11-1, D-1, E-1 7 aesthetic, 4-26, 8-10, 8-11, 8-20, 8-44, 8-45, 8 8-56 9 alternatives, iii, xviii , 1-6, 4-33, 5-3, 5-12, 5-13, 10 6-3, 6-5, 6-6, 8-1, 8-2, 8-3, 8-9, 8-18, 8-26, 11 8-30, 8-34, 8-40, 8-41, 8-42, 8-43, 8-44, 8-47, 12 8-53, 8-57, 8-58, 9-1, 9-2, 9-3, 10-1, B-10 , F-1, 13 F-2, F-23, F-24, F-44, F-45 14 archaeological resources, xvii , 1-7, 2-78, 15 2-79, 2-81, 2-82, 3-2, 4-21, 4-25, 4-45, 4-46, 16 4-48, 8-11, 8-20, 8-32, 8-45, 8-46, 8-56 , B-9 , 17 D-1 18 B 19 biota, 2-39, 2-40, 2-41, 2-44, 2-46, 4-6, 4-39, 20 8-17, 8-28, B-2 21 boiling water reactor, xxi , 2-1, 3-1 22 burnup, 2-1, 12-1, B-14 23 C 24 Choctaw Nation of Oklahoma, 1-7, 4-24, 4-53, 25 11-1, D-1,D-2, E-1 , E-3 26 chronic effects, 1-3, 4-1, 4-13, 4-18, B-8 27 Clean Air Act (CAA), xx , 2-22, 2-23, 2-85, 28 8-14 , 8-15, 8-25, 8-36, 8-37, C-2 29 closed-cycle cooling, 4-40, 4-41 , 4-47, 8-23, 30 8-28, 8-39, B-5 31 Coastal Zone Management Act (CZMA), xx , 32 C-2 33 cold shock, 4-41 34 cooling system, xvi, xvii , 1-4, 1-6, 2-12, 2-15, 35 2-34, 4-6, 4-8, 4-9, 4-40, 4-41, 4-47, 5-8, 5-9, 36 5-12, 8-3, 8-5, 8-7, 8-8, 8-13, 8-16, 8-17 , 8-23, 37 8-27, 8-28, 8-39, B-1, B-2, B-3, B-4, F-7, F-30, 38 F-32, F-37, F-42, F-43 39 core damage frequency (CDF), xiii, xiv, xx , 40 5-4, 5-5, 5-8, 5-12, F-1, F-2, F-4, F-6, F-7, F-8, 41 F-9, F-10, F-11, F-12, F-13, F-14, F-15, F-16, F-42 20, F-21, F-23, F-24, F-25, F-26, F-27, F-28, F-43 29, F-30, F-31, F-32, F-33, F-34, F-35, F-36, F-44 37, F-38, F-41, F-42, F-43 45 Council on Environmental Quality (CEQ), xx , 46 1-4, 4-26, 4-38, 4-49 47 critical habitat, 2-55, 2-58, 2-59, 2-60, 2-62, 48 2-63, 2-64, 2-84, 4-10, 4-11, 4-13, 4-14, 8-8, 49 8-18, 8-29, 8-40, C-3 50 cultural resources, 2-81, 4-25, 4-45, 8-45, C-1 51 D 52 demography, 2-66 53 design-basis accident, xx , 4-31, 5-1 , 5-2, B-10 54 discharges, 2-9, 2-11, 2-12, 2-22, 2-31, 2-33, 55 2-35, 2-39, 2-40, 2-42, 2-43, 2-45, 2-55, 2-63, 56 2-90, 4-5, 4-6, 4-7, 4-8, 4-12, 4-14, 4-37, 4-41, 57 8-5, 8-7, 8-13, 8-16, 8-17, 8-23, 8-27, 8-39, 58 8-40, 8-55, B-1, B-3, B-8 59 dose, xxvi, xxvii , 2-6, 4-17, 4-18, 4-19, 4-43, 60 4-44, 4-48, 5-6, 5-8, 6-2, B-7 , B-11 , B-12 , F-1, 61 F-3, F-4, F-9, F-18, F-24, F-25, F-40, F-41 62 dredging, 2-33, 2-39, 8-7, 8-16, 8-17, 8-27, 63 8-38, 8-39 64 E 65 education, 2-67, 3-2, 4-21, B-9 66 electromagnetic fields, xxiii , 1-3, 4-1, 4-8, 67 4-20, B-6 , B-8 68 Index 12-2 endangered and threatened species, xvii , 1 1-7, 2-56, 2-83, 3-2, 4-10, 4-40, 4-41, B-7 , D-1 2 Endangered Species Act (ESA), vi, xviii, xxiii , 3 1-7, 1-8, 2-54, 2-55, 2-58, 2-63, 2-65, 2-85, 4 2-89, 4-1, 4-9, 4-10, 4-11, 4-49, 8-7, 8-8, 8-17, 5 8-18 , 8-28, 8-29, 8-39, 8-40, C-3, D-1 6 entrainment, 4-40, 8-28, 8-39, B-2, B-4 7 environmental justice (EJ), xviii , 1-3, 1-6, 8 2-85, 3-2, 4-1, 4-21, 4-26, 4-31, 4-45, 4-48, 9 4-49, 8-11 , 8-21, 8-32, 8-46, 10-1, B-1, B-15 10 EPA, 4-18 11 essential fish habitat (EFH), 2-54, 2-92, C-3, 12 D-1 13 eutrophication , 4-54 14 F 15 Fish and Wildlife Coordination Act (FWCA), 16 C-3 17 G 18 GEIS, 4-17 19 Generic Environmental Impact Statement 20 (GEIS), iii, v, xv, xvi, xvii, xviii, xix, xxiv , 1-3, 1-4, 21 1-5, 1-6, 1-8, 1-9, 2-70, 2-92, 3-1, 3-2, 3-3, 4-1, 22 4-2, 4-3, 4-4, 4-5, 4-6, 4-7, 4-8, 4-9, 4-10, 4-15, 23 4-16, 4-19, 4-20, 4-21, 4-22, 4-23, 4-26, 4-33, 24 4-52, 4-54, 5-1, 5-2, 5-3, 5-14, 6-1, 6-2, 6-3, 25 6-12, 7-1, 7-2, 7-3, 8-1, 8-2, 8-9, 8-12, 8-18, 26 8-19, 8-22, 8-23, 8-25, 8-29, 8-30, 8-31, 8-41, 27 8-42, 8-52, 8-54, 8-62, 9-3, B-1, B-10 28 greenhouse gases, xxiv , 2-22, 2-69, 2-84, 29 4-35, 4-49, 6-3, 6-12, 8-13 30 ground water, 4-17 31 groundwater, xvii , 1-6, 2-15, 2-33, 2-34, 2-35, 32 2-36, 2-37, 2-67, 2-68, 2-86, 3-1, 4-4, 4-5, 4-6, 33 4-17, 4-18, 4-32, 4-38, 4-47, 8-2, 8-7, 8-16, 34 8-26 , 8-27, 8-28, 8-38, 8-55, B-1, B-4, B-5, 35 B-10 , C-1 36 H 37 hazardous waste, 2-8, 9-2, 9-3, C-3 38 heat shock, 4-12, 12-2, B-4 39 high-level waste, xvi , 1-4, 6-1, 6-2, 8-12, 8-57, 40 B-10 , B-11 , B-12 , B-13 , B-14 41 I 42 impingement, 4-40, 8-28, 8-39, B-2, B-4 43 independent spent fuel storage installation 44 (ISFSI), xxiv , 2-6, 2-69, 4-34, 4-44, 4-48, A-2 45 Indian tribes, 2-80, 4-26, 4-31 46 invasive species, 4-43 47 J 48 Jena Band of Choctaw Indians, 1-7, 4-24, 49 4-54, 11-1, D-1, D-2, E-1 , E-2 50 L 51 long-term dose, F-41 52 Louisiana Division of Historic Preservation, 53 1-7 54 Louisiana Natural Heritage Program, 1-7, 55 4-51, 4-53, D-1, D-2, E-2 56 low-level waste, 6-1, 8-12, A-2, A-3, B-13 57 M 58 Magnuson-Stevens Fishery Conservation 59 and Management Act (MSA), xxvi , 1-7, 8-7, 60 8-17, 8-28, C-3 61 Marine Mammal Protection Act (MMPA), xxv , 62 C-3 63 maximum occupational doses, 4-16, B-8 64 Mississippi Band of Choctaw Indians, 1-7, 65 4-24, 4-53, 11-1, D-1, E-1 , E-2 66 Mississippi Department of Archives and 67 History, xxv , 1-7 , 2-79, 2-85, 2-89, 2-94, 4-25, 68 4-51, 4-53 69 Index 12-3 Mississippi Natural Heritage Program, xxv , 1 1-7, 2-55 , 2-90, 2-91, 4-52, 4-53, D-1, E-2 2 mitigation, xvi , 1-4, 1-6, 4-15, 4-17, 4-20, 4-37, 3 4-46, 5-3, 7-1, 7-2, 8-6, 8-8, 8-11, 8-14, 8-17, 4 8-18, 8-21, 8-24, 8-28, 8-29, 8-32, 8-35, 8-40, 5 8-45, 9-1, 9-2, E-3 6 mixed waste, 2-7, 8-12, 8-57, B-14 7 N 8 National Environmental Policy Act (NEPA), 9 xv, xvi, xvii, xxvi , 1-1, 1-5, 1-6, 1-8, 2-82, 2-91, 10 2-92, 3-3, 4-10, 4-24, 4-26, 4-38, 4-49, 4-50, 11 4-52, 5-2, 6-2, 6-3, 6-12, 7-3, 8-1, 9-1, 11-2, 12 B-1, B-11 , B-13 13 National Marine Fisheries Service (NMFS), 14 xxvi , 1-7, 2-54, 2-55, 2-56, 2-83, 2-92, 4-10, 15 4-52, 4-53, 11-1, C-3, D-1, D-2, E-2 , E-3 16 National Pollutant Discharge Elimination 17 System (NPDES), xxvi , 2-9, 2-11, 2-31, 2-33, 18 2-90, 4-12, 4-14, 4-37, 4-41, 8-7, 8-16, 8-17, 19 8-27, 8-39, B-2, C-1, C-2, C-4 20 Native American tribes, 2-80, 4-31 21 no-action alternative, iii, xviii, xix , 4-9, 4-38, 22 4-42, 8-2, 8-54, 8-55, 8-57, 8-58, 9-1, 9-2 23 nonattainment, 2-24, 3-2, 4-35, 4-47, 8-6, 24 8-14, 8-24, 8-29, 8-35, B-7 25 O 26 once-through cooling, 2-15, B-2, B-3, B-4 27 P 28 peak dose, B-12 29 postulated accidents, 4-31, 5-1, 5-2, 5-3, A-4 30 power uprate, xxiii , 4-44, 5-4, 5-5, A-3, F-2, F-3 31 pressurized water reactor, 3-1 32 R 33 radon, 4-17, 12-3, B-10 , B-11 34 Ranney wells, 2-11, 2-12, 2-33, 2-34, 2-35, 35 4-4, 4-5, 4-41, 4-47, 8-4, 8-5, 8-7, 8-16, 8-17, 36 B-5 37 reactor, xv, xvi, xxviii , 1-5, 2-1, 2-6, 2-9, 2-11, 38 2-12, 2-15, 2-25, 2-26, 2-27, 2-36, 2-82, 4-5, 39 4-6, 4-22, 4-34, 4-37, 4-38, 4-40, 4-41, 4-44, 40 4-48, 5-1, 5-2, 5-3, 5-4, 5-5, 5-8, 5-13, 6-2, 6-5, 41 6-11, 7-1, 8-5, 8-6, 8-8, 8-10, 8-29, 8-55, A-2, 42 A-3, A-4, B-5 , B-11 , F-1, F-2, F-3, F-6, F-7, F-43 12, F-14, F-16, F-23, F-24, F-29, F-30, F-31, F-44 33, F-37, F-39, F-42, F-44 45 refurbishment, xviii , 3-1, 3-2, 3-3, 4-2, 4-3, 4-9, 46 4-11, 4-13, 4-19, 4-22, 4-26, 4-36, B-1, B-2, B-47 4, B-7 , B-8 , B-9 , F-41 48 replacement power, xxviii , 5-11, 8-1, 8-9, 8-11, 49 8-18 , 8-30, 8-42, 8-43, 8-55, F-39, F-41, F-42 50 S 51 salinity gradients, 4-3, B-1 52 scoping, iii, xv, xvii, xix , 1-2, 1-3, 1-6, 4-2, 4-3, 53 4-4, 4-6, 4-7, 4-8, 4-15, 4-16, 4-17, 4-21, 4-25, 54 4-34, 6-2, 7-2, 9-4, A-1, E-1 , E-2 55 seismic, xxviii , 2-26, 5-7, F-1, F-10, F-11, F-15, 56 F-21, F-23, F-24 57 severe accident mitigation alternative 58 (SAMA), vii, xiii, xiv, xviii, xxviii , 5-3, 5-4, 5-7, 59 5-8, 5-9, 5-10, 5-11, 5-12, 5-13, 5-14, 9-1, E-3 , 60 F-1, F-2, F-3, F-6, F-8, F-9, F-10, F-11, F-15, 61 F-17, F-18, F-19, F-20, F-21, F-22, F-23, F-24, 62 F-25, F-26, F-27, F-28, F-29, F-30, F-31, F-32, 63 F-33, F-34, F-35, F-36, F-37, F-38, F-39, F-40, 64 F-42, F-43, F-44, F-45, F-46 65 severe accidents, xviii , 4-31, 5-1, 5-2, 5-3, 66 B-10 , E-3 , F-1, F-6, F-11, F-15, F-17, F-23, 67 F-41, F-42 68 solid waste, xviii , 2-7, 2-8, 6-1, 6-2, 7-2, 8-52, 69 B-15 , C-1, C-3 70 Index 12-4 spent fuel, xvi , 1-4, 2-6, 4-44, 6-1, 6-2, 6-11, 1 8-13 , 8-22, 8-34, 8-48, 8-57, A-1, A-2, A-3, 2 B-10 , B-11 , B-12 , B-13 , B-14 3 State Historic Preservation Office (SHPO), 4 xxviii , 2-81, 2-93, 4-24, 4-25, 4-46, 11-1, B-9 , 5 C-3, D-1, D-2, E-2 6 State Pollutant Discharge Elimination 7 System (SPDES), C-1 8 stormwater, 8-8, 8-17, 8-28, 8-40, C-4 9 surface runoff, 2-39, 2-45, 4-39, 4-40, 4-41, 10 4-42, 4-43, 4-48 11 surface water, 2-11, 2-15, 2-31, 3-1, 4-3, 4-17, 12 4-31, 4-32, 4-37, 4-41, 4-47, 8-2, 8-7, 8-8, 8-16, 13 8-17, 8-27, 8-28, 8-38, 8-39, 8-55, B-1, B-5, 14 C-1, C-2 15 T 16 taxes, 2-75, 2-77, 4-24, 8-31, 8-43 17 transmission line corridors, 2-10, 2-54, 2-55, 18 2-64, 2-65, 4-9, 4-10, 4-13, 4-14, 4-25, 4-42 19 transmission lines, 2-10, 2-18, 2-47, 2-54, 20 2-55, 2-57, 2-64, 2-81, 4-1, 4-2, 4-8, 4-9, 4-13, 21 4-14, 4-19, 4-20, 4-21, 4-25, 4-42, 8-4, 8-5, 8-8, 22 8-17, 8-18, 8-23 , 8-28, 8-42, 8-45, 8-55, B-6 , 23 B-7 , B-10 24 tritium, 2-36, 4-5, 4-6 25 Tunica-Biloxi Tribe of Louisiana, 1-7 , 4-24, 26 4-54, 11-1, E-1 27 U 28 U.S. Department of Energy (DOE), xx , 4-20, 29 8-2, 8-49, 8-50, 8-51 , 8-60, 8-61, 8-62, 10-2, 30 B-12 31 U.S. Environmental Protection Agency 32 (EPA), xv, xxiii , 1-1, 2-7, 2-8, 2-9, 2-10, 2-22, 33 2-23, 2-24, 2-25, 2-33, 2-35, 2-36, 2-67, 2-68, 34 2-70, 2-84, 2-86, 2-87, 4-5, 4-10, 4-12, 4-14, 35 4-18, 4-35, 4-38, 4-39, 4-42, 4-43, 4-48, 4-49, 36 4-50, 6-2, 8-1, 8-2, 8-6, 8-14, 8-15, 8-16, 8-24, 37 8-25, 8-26, 8-29, 8-36, 8-37, 8-41, 8-60, 8-61, 38 9-1, 9-2, 11-2, B-1, B-13 , C-1, C-2, C-3 39 U.S. Fish and Wildlife Service (FWS), xxiii , 40 1-7, 2-25, 2-54, 2-55, 2-56, 2-57, 2-58, 2-59, 41 2-60, 2-61, 2-62, 2-63, 2-65, 2-83, 2-84, 2-87, 42 2-88, 2-93, 4-10, 4-11, 4-12, 4-13, 4-15, 4-50, 43 4-51, 4-53, 8-8 , 8-18, 8-29, 8-40, 11-1, C-3 44 U.S. Fish and Wildlife Servi ce (FWS), 45 Louisiana Field Office, 1-7, 11-1 46 U.S. Fish and Wildlife Service (FWS), 47 Mississippi Field Office, 1-7 48 uranium, xxvi , 2-1, 2-6, 4-43, 6-1, 6-2, 6-4, 6-5, 49 6-7, 6-8, 6-9, 6-10, 8-4, 8-8, 8-9, 8-19, 8-29, 50 8-30, 8-42, B-10 , B-13 , B-14 51 W 52 wastewater, 2-8, 2-9, 2-31, 2-33, 2-90, 4-3, 53 8-27, 8-52, B-2 54 Y 55 Yucca Mountain, B-12 , B-13 , B-14 56 APPENDIX A 1 COMMENTS RECEIVED ON THE GGNS ENVIRONMENTAL REVIEW 2

A-1 A. COMMENTS RECEIVED ON THE GGNS ENVIRONMENTAL REVIEW 1 A.1 Comments Received During the Scoping Period 2 The scoping process began on December 29, 2011, with the publication of the U.S. Nuclear 3 Regulatory Commission's (NRC's) Notice of Intent to conduct scoping in the Federal Register 4 (76 FRN 81996). The scoping process included two public meetings held at the Port Gibson 5 City Hall, Port Gibson, Mississippi, on January 31, 2012. Approximately 30 people attended the 6 meetings. After the NRC's prepared statements pertaining to the license renewal process, the 7 meetings were open for public comments. Attendees provided oral statements that were 8 recorded and transcribed by a certified court reporter. Transcripts of the two meetings are 9 available using the NRC's Agencywide Documents Access and Management System (ADAMS). 10 ADAMS Public Electronic Reading Room is accessible at http://www.nrc.gov/reading -11 rm/adams.html. Transcripts for the afternoon and evening meetings are listed under Accession 12 Numbers ML12037A222 and ML12037A223, respectively. 13 Table A-1 identifies the individuals who provided comments and an accession number to 14 identify the source document of the comments in ADAMS. 15 Table A-1. Individuals Who Provided Comments During the Scoping Comment Period 16 Commenter Affiliation (If Stated) Comment Source ADAMS Accession Number Jan Hillegas Green Party of Mississippi Regulations.gov ML12060A334 Fred Reeves Mayor of Port Gibson Evening transcript ML12037A223 Debra Chambliss City of Port Gibson Evening transcript ML12037A223 Note - No comments were received during the afternoon meeting. 17 Comments received during the scoping comment period applicable to this environmental review 18 are presented in this section along with the NRC response. The comments that are general or 19 outside the scope of the environmental review for Grand Gulf Nuclear Station (GGNS) license 20 renewal are not included here but can be found in the Scoping Summary Report (ADAMS 21 Accession No. ML12201A623). Unless otherwise identified, comments presented in this section 22 are from Ms. Jan Hillegas. 23 A.1.1 Waste Management 24 Comment: I did not receive an answer to my question (Transcript, p. 35) about "the 25 approximate square footage or cubic yards" of radioactive waste now on site and "how much 26 more accumulates every year." Mr. Smith's answer (Transcript, pp. 36 -38) in terms of bundles, 27 canisters, and so on, gave no dimensions. Please provide the dimensions and capacities of the 28 containers and of the stored waste. And the NRC's Environmental Review needs to calculate 29 and evaluate the onsite storage of spent fuel under current and other possible conditions 30 through at least 2044. 31 Appendix A A-2 Response: There are two broad classifications of radioactive waste generated at GGNS

1 high-level and low

-level waste. High-level radioactive waste results primarily from the fuel that 2 has been used in a nuclear power reactor and is "spent" or is no longer efficient in generating 3 power to the reactor to produce electricity. Low -level radioactive waste results from reactor 4 operations and typically consists contaminated protective shoe covers and clothing, wiping rags, 5 mops, filters, reactor water treatment residues, equipment, and tools. 6 GGNS does not permanently store low -level radioactive waste on site. As stated on page 3 -16 7 of the applicant's Environmental Report (ADAMS Accession No. ML11308A234): GGNS 8 transports low level radioactive waste to a licensed processing facility in Tennessee where the 9 wastes are further processed prior to being sent to a facility such as EnergySolutions in Clive, 10 Utah. 11 GGNS stores its spent nuclear fuel in its spent fuel pool and in dry casks. The spent fuel pool is 12 a strong structure, constructed of steel -reinforced concrete walls with a stainless steel liner, and 13 filled with water. The spent fuel pool is located inside the plant's protected area. The NRC 14 regularly inspects GGNS's spent fuel storage program to ensure the safety of the spent fuel 15 stored in the spent fuel pool. 16 GGNS also stores spent nuclear fuel in NRC approved dry cask canisters made of leak-tight 17 welded and bolted steel. These containers are approximately 16 feet high with an approximate 18 exterior diameter of 6 feet. A canister with spent fuel is placed in a concrete cask forming a dry 19 cask storage system. A typical dry cask storage system is detailed at the following website: 20 http://www.nrc.gov/waste/spent -fuel-storage/diagram -typical-dry-cask-system.html. The 21 concrete casks used at GGNS are approximately 20 feet high with an exterior diameter of 22 11 feet and are stored on a concrete pad within a secure area . The NRC regularly inspects 23 GGNS's dry cask storage system to ensure it complies with NRC requirements. The latest NRC 24 inspection report of the GGNS ISFSI is available at ADAMS Accession No. ML12303A002. 25 As reported on page 5 of the GGNS ISFSI Inspection Report 05000416/2012009 (ADAMS 26 Accession No. ML12303A002) dated October 26, 2012:

"The current ISFSI pad can hold 40 27 casks with provisions for four additional spaces to allow for cask unloading, if required. Future 28 plans are to add a second pad that will increase the capacity of the ISFSI to 88 storage 29 locations with 4 spare locations."

Currently, 17 GGNS ISFSI storage locations are occupied. 30 Every other year, GGNS adds five to seven casks to the ISFSI. 31 The existing license expiration date for GGNS is November 1, 2024. The requested renewal 32 would extend the license expiration date to November 1, 2044. The NRC's safety requirements 33 for the storage of spent nuclear fuel during licensed operations ensures that the expected 34 increase in the volume of spent fuel during the license renewal term can be safely stored on site 35 with small environmental effects. 36 Determining the square feet, cubic yards, and bundles of GGNS spent fuel is n ot necessary for 37 the license renewal environmental review decision -making process. 38 High-level radioactive waste is discussed in Section 6.1 of this SEIS. 39 A.1.2 Extended Power Uprate 40 Comment: Mayor Fred Reeves asked "what effect would the current upgrade at Grand Gulf 41 have to do with the process?" (Transcript, p. 39) The only answer he was given was that "The 42 EPU process that [is] currently ongoing is its own independent process. There are aspect[s] of 43 the plant modifications that are going on that could impact our review, but we have processes in 44 place to account for that." (Transcript, pp. 39 -40) Please provide Mayor Reeves and me with 45 an actual answer to his question: What effect will the upgrade have on the processing of the 46 Appendix A A-3 application for license renewal? The NRC's Environmental Review needs to evaluate all 1 aspects of the upgraded plant, after it has been operating at the upgraded capacity, before 2 being able to make a credible report on the environmental impacts of consuming more land and 3 water, having more personnel on -site, storing more spent fuel, transporting low -level waste, etc. 4 Comment from Mayor Reeves: My other question is what effect would the current upgrade at 5 Grand Gulf have to do with the process? Would that have an impact on the process? 6 Response: This comment expresses concern that the NRC's license renewal review should 7 consider the impacts of the GGNS extended power uprate (EPU) license amendment request. 8 The NRC granted the EPU license amendment request for GGNS on July 18, 2012 (ADAMS 9 Accession No. ML 121210020). In accordance with 10 CFR 51.21, the NRC prepared an 10 Environmental Assessment (EA) with a Finding of No Significant Impact (FONSI) for the EPU. 11 The EA w as published in the Federal Register (77 FR 41814) on July 16, 2012, and can be 12 found at ADAMS Accession No. ML12167A257. 13 The license renewal environmental review process for GGNS considers environmental impacts 14 based on the reactor power level requested in the EPU license amendment request. The 15 impacts on land use are discussed in Section 4.1 of this SEIS. The impacts on water are 16 discussed in Sections 4.4 and 4.5. A discussion of the number of employees at the site during 17 the license renewal term is provided in Section 4.10.2 of this SEIS. The impacts of spent fuel , 18 low-level waste, and transportation of radioactive materials are discussed in Section 6.1 of th is 19 SEIS. 20 A.1.3 Extended Power Uprate/Process 21 Comment: I asked about the date of the announcement of what turns out to have been a 22 "license amendment request" (Transcript, p. 61) to increase the capacity of Grand Gulf, which 23 was granted without general public knowledge, and the expansion is now under construction. 24 Please provide the date of that request and the steps in the process between the filing of the 25 request and the commencement of expansion, including any required public notices, meetings 26 or comment periods, and whether those included any news releases in addition to Federal 27 Register publication or legal ads. The NRC's Environmental Review needs to evaluate all 28 aspects of the impacts of the additional capacity on Grand Gulf, the Mississippi River, and all 29 people and properties possibly affected by any catastrophic events at the expanded plant. 30 Response: This comment incorrectly asserts that an extended power uprate (EPU) license 31 amendment request to increase the maximum reactor core power operating limit at GGNS was 32 granted on or before February 27, 2012. This comment was received on February 27, 2012, 33 and at that time a decision to grant or deny the EPU request had not been made. 34 Entergy Operations, Inc., et al., submitted an EPU license amendment request (ADAMS 35 Accession No. ML1002660403) on September 8, 2010, supplemented by 47 letters, dated from 36 November 18, 2010 to June 12, 2012. 37 The NRC published a Notice of Consideration of Issuance of Amendments to Facility Operating 38 Licenses, Proposed No Significant Hazards Consideration Determination, and Opportunity for a 39 Hearing in the Federal Register (76 FR 1464) on January 11, 2011, regarding the GGNS EPU 40 license amendment request with a 60 -day public comment period. The NRC made a proposed 41 determination that the GGNS EPU amendment request involved no significant hazards 42 consideration. Under the NRC regulations in 10 CFR 50.92, this means that operation of the 43 facility in accordance with the proposed amendment would not (1) involve a significant increase 44 in the probability or consequences of an accident previously evaluated; or (2) create the 45 possibility of a new or different kind of accident from any accident previously evaluated; or 46 Appendix A A-4 (3) involve a significant reduction in a margin of safety. No comments were received on this 1 notice. 2 In addition, in accordance with 10 CFR 51.21, the NRC prepared a draft Environmental 3 Assessment (EA) with a preliminary Finding of No Significant Impact (FONSI) for the proposed 4 action. The draft EA was published in the Federal Register (77 FR 27804) with a 30 -day public 5 comment period that ended on June 11, 2012. No comments were received on this draft EA. 6 The final EA was published in the Federal Register (77 FR 41814) on July 16, 2012, and can be 7 found at ADAMS Accession No. ML12167A257. The EPU license amendment request was 8 granted on July 18, 2012, and can be found at ADAMS Accession No. ML121210020 . 9 The license renewal environmental review process for GGNS considers environmental impacts 10 based on the reactor power level requested in the EPU license amendment request. The 11 environmental impacts on GGNS and vicinity are discussed in Chapter 4 and the environmental 12 impacts of postulated accidents are discussed in Chapter 5 of this SEIS . 13 APPENDIX B 1 NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE 2 RENEWAL OF NUCLEAR POWER PLANTS 3

B-1 B. NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE 1 RENEWAL OF NUCLEAR POWER PLANTS 2 The table in this appendix summarizes the National Environmental Policy Act (NEPA) issues 3 that the applicant was required to consider for potential environmental impacts in developing its 4 license renewal application environmental report submitted to the U.S. Nuclear Regulatory 5 Commission (NRC) on November 1, 2011. On June 20, 2013, the NRC published a final rule 6 (78 FR 37282) revising the list of issues requiring consideration. 7 In addition to the issues listed in the table in this appendix, the NRC also considered the new 8 issues contained in the June 20, 2013, final rule. The new Category 1 (generic) issues include 9 geology and soils, exposure of terrestrial organisms to radionuclides, exposure of aquatic 10 organisms to radionuclides, human health impact from chemicals, and physical occupational 11 hazards. Radionuclides released to groundwater, effects on terrestrial resources (non -cooling 12 system impacts), minority and low -income populations (i.e., environmental justice), and 13 cumulative impacts were added as new Category 2 (site-specific) issues. The June 20, 2013, 14 final rule revised list of NEPA issues is found in Table B-1 in Append ix B, Subpart A, to Title 10 15 of the Code of Federal Regulations, Part 51, "Environmental Protection Regulations for 16 Domestic Licensing and Related Regulatory Functions,"

(10 CFR Part 51). Data supporting this 17 revised list are contained in NUREG

-1437, Generic Environmental Impact Statement for 18 License Renewal of Nuclear Plants. 19 Table B-1. Summary of Issues and Findings 20 Issue Type of Issue Findings Surface Water Quality, Hydrology, and Use Impacts of refurbishment on surface water quality Generic SMALL. Impacts are expected to be negligible during refurbishment because best management practices are expected to be employed to control soil erosion and spills. Impacts of refurbishment on surface water use Generic SMALL. Water use during refurbishment will not increase appreciably or will be reduced during plant outage. Altered current patterns at intake and discharge structures Generic SMALL. Altered current patterns have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Altered salinity gradients Generic SMALL. Salinity gradients have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Altered thermal stratification of lakes Generic SMALL. Generally, lake stratification has not been found to be a problem at operating nuclear power plants and is not expected to be a problem during the license renewal term. Temperature effects on sediment transport capacity Generic SMALL. These effects have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term.

Appendix B B-2 Issue Type of Issue Findings Scouring caused by discharged cooling water Generic SMALL. Scouring has not been found to be a problem at most operating nuclear power plants and has caused only localized effects at a few plants. It is not expected to be a problem during the license renewal term. Eutrophication Generic SMALL. Eutrophication has not been found to be a problem at operating nuclear power plants and is not expected to be a problem during the license renewal term. Discharge of chlorine or other biocides Generic SMALL. Effects are not a concern among regulatory and resource agencies, and are not expected to be a problem during the license renewal term. Discharge of sanitary wastes and minor chemical spills Generic SMALL. Effects are readily controlled through a National Pollutant Discharge Elimination System (NPDES) permit and periodic modifications, if needed, and are not expected to be a problem during the license renewal term. Discharge of other metals in wastewater Generic SMALL. These discharges have not been found to be a problem at operating nuclear power plants with cooling-tower-based heat dissipation systems and have been satisfactorily mitigated at other plants. They are not expected to be a problem during the license renewal term. Water use conflicts (plants with once -through cooling systems) Generic SMALL. These conflicts have not been found to be a problem at operating nuclear power plants with once-through heat dissipation systems. Water use conflicts (plants with cooling ponds or cooling towers using makeup water from a small river with low flow) Site-Specific SMALL OR MODERATE. The issue has been a concern at nuclear power plants with cooling ponds and at plants with cooling towers. Impacts on in -stream and riparian communities near these plants could be of moderate significance in some situations. See 10 CFR 51.53(c)(3)(ii)(A). Aquatic Ecology (all plants) Refurbishment Generic SMALL. During plant shutdown and refurbishment there will be negligible effects on aquatic biota because of a reduction of entrainment and impingement of organisms or a reduced release of chemicals. Accumulation of contaminants in sediments or biota Generic SMALL. Accumulation of contaminants has been a concern at a few nuclear power plants but has bee n satisfactorily mitigated by replacing copper alloy condenser tubes with those of another metal. It is not expected to be a problem during the license renewal term. Entrainment of phytoplankton and zooplankton Generic SMALL. Entrainment of phytoplankton and zooplankton has not been found to be a problem at operating nuclear power plants and is not expected to be a problem during the license renewal term.

Appendix B B-3 Issue Type of Issue Findings Cold shock Generic SMALL. Cold shock has been satisfactorily mitigated at operating nuclear plants with once -through cooling systems, has not endangered fish populations, or been found to be a problem at operating nuclear power plants with cooling towers or cooling ponds, and is not expected to be a problem during the license renewal term. Thermal plume barrier to migrating fish Generic SMALL. Thermal plumes have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Distribution of aquatic organisms Generic SMALL. Thermal discharge may have localized effects but is not expected to affect the larger geographical distribution of aquatic organisms. Premature emergence of aquatic insects Generic SMALL. Premature emergence has been found to be a localized effect at some operating nuclear power plants but has not been a problem and is not expected to be a problem during the license renewal term. Gas supersaturation (gas bubble disease) Generic SMALL. Gas supersaturation was a concern at a small number of operating nuclear power plants with once-through cooling systems but has been satisfactorily mitigated. It has not been found to be a problem at operating nuclear power plants with cooling towers or cooling ponds and is not expected to be a problem during the license renewal term. Low dissolved oxygen in the discharge Generic SMALL. Low dissolved oxygen has been a concern at one nuclear power plant with a once -through cooling system but has been effectively mitigated. It has not been found to be a problem at operating nuclear power plants with cooling towers or cooling ponds and is not expected to be a problem during the license renewal term. Losses from predation, parasitism, and disease among organisms exposed to sublethal stresses Generic SMALL. These types of losses have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Stimulation of nuisance organisms (e.g., shipworms) Generic SMALL. Stimulation of nuisance organisms has been satisfactorily mitigated at the single nuclear power plant with a once -through cooling system where previously it was a problem. It has not been found to be a problem at operating nuclear power plants with cooling towers or cooling ponds and is not expected to be a problem during the license renewal term.

Appendix B B-4 Issue Type of Issue Findings Aquatic Ecology (for plants with once -through and cooling pond heat dissipation systems) Entrainment of fish and shellfish in early life stages Site-Specific SMALL, MODERATE, OR LARGE. The impacts of entrainment are small at many plants but may be moderate or even large at a few plants with once -through and cooling -pond cooling systems. Further, ongoing efforts in the vicinity of these plants to restore fish populations may increase the numbers of fish susceptible to intake effects during the license renewal period, such that entrainment studies conducted in support of the original license may no longer be valid. See 10 CFR 51.53(c)(3)(ii)(B). Impingement of fish and shellfish Site-Specific SMALL, MODERATE, OR LARGE. The impacts of impingement are small at many plants but may be moderate or even large at a few plants with once -through and cooling -pond cooling systems. See 10 CFR 51.53(c)(3)(ii)(B). Heat shock Site-Specific SMALL, MODERATE, OR LARGE. Because of continuing concerns about heat shock and the possible need to modify thermal discharges in response to changing environmental conditions, the impacts may be of moderate or large significance at some plants. See

10 CFR 51.53(c)(3)(ii)(B). Aquatic Ecology (for plants with cooling-tower-based heat dissipation systems) Entrainment of fish and shellfish in early life stages Generic SMALL. Entrainment of fish has not been found to be a problem at operating nuclear power plants with this type of cooling system and is not expected to be a problem during the license renewal term. Impingement of fish and shellfish Generic SMALL. The impacts of impingement have not been found to be a problem at operating nuclear power plants with this type of cooling system and are not expected to be a problem during the license renewal term. Heat shock Generic SMALL. Heat shock has not been found to be a problem at operating nuclear power plants with this type of cooling system and is not expected to be a problem during the license renewal term. Impacts of refurbishment on groundwater use and quality Generic SMALL. Extensive dewatering during the original construction on some sites will not be repeated during refurbishment on any sites. Any plant wastes produced during refurbishment will be handled in the same manner as in current operating practices and are not expected to be a problem during the license renewal term.

Appendix B B-5 Issue Type of Issue Findings Groundwater use conflicts (potable and service water; plants that use <100 gallons per minute [gpm]) Generic SMALL. Plants using less than 100 gpm are not expected to cause any groundwater use conflicts. Groundwater use conflicts (potable and service water, and dewatering plants that use >100 gpm) Site-Specific SMALL, MODERATE, OR LARGE. Plants that use more than 100 gpm may cause groundwater use conflicts with nearby groundwater users. See 10 CFR 51.53(c)(3)(ii)(C). Groundwater use conflicts (plants using cooling towers withdrawing makeup water from a small river) Site-Specific SMALL, MODERATE, OR LARGE. Water use conflicts may result from surface water withdrawals from small water bodies during low flow conditions which may affect aquifer recharge, especially if other groundwater or upstream surface water users come on line before the time of license renewal. See 10 CFR 51.53(c)(3)(ii)(A). Groundwater use conflicts (Ranney wells) Site-Specific SMALL, MODERATE, OR LARGE. Ranney wells can result in potential groundwater depression beyond the site boundary. Impacts of large groundwater withdrawal for cooling tower makeup at nuclear power plants using Ranney wells must be evaluated at the time of application for license renewal. See 10 CFR 51.53(c)(3)(ii)(C). Groundwater quality degradation (Ranney wells) Generic SMALL. Groundwater quality at river sites may be degraded by induced infiltration of poor -quality river water into an aquifer that supplies large quantities of reactor cooling water. However, the lower quality infiltrating water would not preclude the current uses of groundwater and is not expected to be a problem during the license renewal term. Groundwater quality degradation (saltwater intrusion) Generic SMALL. Nuclear power plants do not contribute significantly to saltwater intrusion. Groundwater quality degradation (cooling ponds in salt marshes) Generic SMALL. Sites with closed -cycle cooling ponds may degrade groundwater quality. Because water in salt marshes is brackish, this is not a concern for plants located in salt marshes. Groundwater quality degradation (cooling ponds at inland sites) Site-Specific SMALL, MODERATE, OR LARGE. Sites with closed-cycle cooling ponds may degrade groundwater quality. For plants located inland, the quality of the groundwater in the vicinity of the ponds must be shown to be adequate to allow continuation of current uses. See 10CFR 51.53(c)(3)(ii)(D).

Appendix B B-6 Issue Type of Issue Findings Terrestrial Ecology Refurbishment impacts Site-Specific SMALL, MODERATE, OR LARGE. Refurbishment impacts are insignificant if no loss of important plant and animal habitat occurs. However, it cannot be known whether important plant and animal communities may be affected until the specific proposal is presented with the license renewal application. See 10 CFR 51.53(c)(3)(ii)(E). Cooling tower impacts on crops and ornamental vegetation Generic SMALL. Impacts from salt drift, icing, fogging, or increased humidity associated with cooling tower operation have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Cooling tower impacts on native plants Generic SMALL. Impacts from salt drift, icing, fogging, or increased humidity associated with cooling tower operation have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Bird collisions with cooling towers Generic SMALL. These collisions have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Cooling pond impacts on terrestrial resources Generic SMALL. Impacts of cooling ponds on terrestrial ecological resources are considered to be of small significance at all sites. Power line right -of-way management (cutting and herbicide application) Generic SMALL. The impacts of right -of-way maintenance on wildlife are expected to be of small significance at all sites. Bird collisions with power lines Generic SMALL. Impacts are expected to be of small significance at all sites. Impacts of electromagnetic fields on flora and fauna Generic SMALL. No significant impacts of electromagnetic fields on terrestrial flora and fauna have been identified. Such effects are not expected to be a problem during the license renewal term. Floodplains and wetland on power line right-of-way Generic SMALL. Periodic vegetation control is necessary in forested wetlands underneath power lines and can be achieved with minimal damage to the wetland. No significant impact is expected at any nuclear power plant during the license renewal term.

Appendix B B-7 Issue Type of Issue Findings Threatened or Endangered Species Threatened or endangered species Site-Specific SMALL, MODERATE, OR LARGE. Generally, plant refurbishment and continued operation are not expected to adversely affect threatened or endangered species. However, consultation with appropriate agencies would be needed at the time of license renewal to determine whether threatened or endangered species are present and whether they would be adversely affected. See 10 CFR 51.53(c)(3)(ii)(E). Air Quality Air quality during refurbishment (nonattainment and maintenance areas) Site-Specific SMALL, MODERATE, OR LARGE. Air quality impacts from plant refurbishment associated with license renewal are expected to be small. However, vehicle exhaust emissions could be cause for concern at locations in or near nonattainment or maintenance areas. The significance of the potential impact cannot be determined without considering the compliance status of each site and the numbers of workers expected to be employed during the outage. See 10CFR 51.53(c)(3)(ii)(F). Air quality effects of transmission lines Generic SMALL. Production of ozone and oxides of nitrogen is insignificant and does not contribute measurably to ambient levels of these gases. Land Use Onsite land use Generic SMALL. Projected onsite land use changes required during refurbishment and the renewal period would be a small fraction of any nuclear power plant site and would involve land that is controlled by the applicant. Power line right -of-way Generic SMALL. Ongoing use of power line rights -of-way would continue with no change in restrictions. The effects of these restrictions are of small significance. Human Health Radiation exposures to the public during refurbishment Generic SMALL. During refurbishment, the gaseous effluents would result in doses that are similar to those from current operation. Applicable regulatory dose limits to the public are not expected to be exceeded. Occupational radiation exposures during refurbishment Generic SMALL. Occupational doses from refurbishment are expected to be within the range of annual average collective doses experienced for pressurized -water reactors and boiling -water reactors. Occupational mortality risk from all causes, including radiation, is in the mid-range for industrial settings.

Appendix B B-8 Issue Type of Issue Findings Microbiological organisms (occupational health) Generic SMALL. Occupational health impacts are expected to be controlled by the continued application of accepted industrial hygiene practices to minimize worker exposures. Microbiological organisms (public health)(plants using lakes or canals, or cooling towers or cooling ponds that discharge to a small river) Site-Specific SMALL, MODERATE, OR LARGE. These organisms are not expected to be a problem at most operating plants, except possibly at plants using cooling ponds, lakes, or canals that discharge to small rivers. Without site -specific data, it is not possible to predict the effects generically. See 10 CFR 51.53(c)(3)(ii)(G). Noise Generic SMALL. Noise has not been found to be a problem at operating plants and is not expected to be a problem at any plant during the license renewal term. Electromagnetic fields -acute effects (electric shock) Site-Specific SMALL, MODERATE, OR LARGE. Electric shock resulting from direct access to energized conductors or from induced charges in metallic structures has not been found to be a problem at most operating plants and generally is not expected to be a problem during the license renewal term. However, site -specific review is required to determine the significance of the electric shock potential at the site. See 10 CFR 51.53(c)(3)(ii)(H). Electromagnetic fields -chronic effects Uncategorized UNCERTAIN. Biological and physical studies of 60 -Hz electromagnetic fields have not found consistent evidence linking harmful effects with field exposures. However, research is continuing in this area and a consensus scientific view has not been reached. Radiation exposures to public (license renewal term) Generic SMALL. Radiation doses to the public will continue at current levels associated with normal operations. Occupational radiation exposures (license renewal term) Generic SMALL. Projected maximum occupational doses during the license renewal term are within the range of doses experienced during normal operations and normal maintenance outages, and would be well below regulatory limits. Socioeconomic Impacts Housing impacts Site-Specific SMALL, MODERATE, OR LARGE. Housing impacts are expected to be of small significance at plants located in a medium- or high-population area and not in an area where growth control measures, that limit housing development, are in effect. Moderate or large housing impacts of the workforce, associated with refurbishment, may be associated with plants located in sparsely populated areas or in areas with growth control measures that limit housing development. See 10 CFR 51.53(c)(3)(ii)(I).

Appendix B B-9 Issue Type of Issue Findings Public services: public safety, social services, and tourism and recreation Generic SMALL. Impacts to public safety, social services, and tourism and recreation are expected to be of small significance at all sites. Public services: public utilities Site-Specific SMALL OR MODERATE. An increased problem with water shortages at some sites may lead to impacts of moderate significance on public water supply availability. See 10 CFR 51.53(c)(3)(ii)(I). Public services: education (refurbishment) Site-Specific SMALL, MODERATE, OR LARGE. Most sites would experience impacts of small significance but larger impacts are possible depending on site- and project -specific factors. See 10 CFR 51.53(c)(3)(ii)(I). Public services: education (license renewal term) Generic SMALL. Only impacts of small significance are expected Offsite land use (refurbishment) Site-Specific SMALL OR MODERATE. Impacts may be of moderate significance at plants in low population areas. See 10 CFR 51.53(c)(3)(ii)(I). Offsite land use (license renewal term) Site-Specific SMALL, MODERATE, OR LARGE. Significant changes in land use may be associated with population and tax revenue changes resulting from license renewal. See 10 CFR 51.53(c)(3)(ii)(I). Public services: transportation Site-Specific SMALL, MODERATE, OR LARGE. Transportation impacts (level of service) of highway traffic generated during plant refurbishment and during the term of the renewed license are generally expected to be of small significance. However, the increase in traffic associated with the additional workers and the local road and traffic control conditions may lead to impacts of moderate or large significance at some sites. See 10 CFR 51.53(c)(3)(ii)(J). Historic and archaeological resources Site-Specific SMALL, MODERATE, OR LARGE. Generally, plant refurbishment and continued operation are expected to have no more than small adverse impacts on historic and archaeological resources. However, the National Historic Preservation Act requires the Federal agency to consult with the State Historic Preservation Officer to determine whether there are properties present that require protection. See 10 CFR 51.53(c)(3)(ii)(K). Aesthetic impacts (refurbishment) Generic SMALL. No significant impacts are expected during refurbishment. Aesthetic impacts (license renewal term) Generic SMALL. No significant impacts are expected during the license renewal term.

Appendix B B-10 Issue Type of Issue Findings Aesthetic impacts of transmission lines (license renewal term) Generic SMALL. No significant impacts are expected during the license renewal term. Postulated Accidents Design-basis accidents Generic SMALL. The NRC staff has concluded that the environmental impacts of design -basis accidents are of small significance for all plants. Severe accidents Site-Specific SMALL. The probability weighted consequences of atmospheric releases, fallout onto open bodies of water, releases to groundwater, and societal and economic impacts from severe accidents are small for all plants. However, alternatives to mitigate severe accidents must be considered for all plants that have not considered such alternatives. See 10 CFR 51.53(c)(3)(ii)(L). Uranium Fuel Cycle and Waste Management (impacts discussed further in Chapter 6 of this SEIS) Offsite radiological impacts (individual effects from other than the disposal of spent fuel and high-level waste) Generic SMALL. Offsite impacts of the uranium fuel cycle have been considered by the Commission in Table S -3 of this part. Based on information in the GEIS, impacts on individuals from radioactive gaseous and liquid releases, including radon -222 and technetium -99, are small. Appendix B B-11 Issue Type of Issue Findings Offsite radiological impacts (collective effects) Generic The 100-year environmental dose commitment to the U.S. population from the fuel cycle, high -level waste, and spent fuel disposal is calculated to be about 14,800 person-rem, or 12 cancer fatalities, for each additional 20 -year power reactor operating term. Much of this, especially the contribution of radon releases from mines and tailing piles, consists of tiny doses summe d over large populations. This same dose calculation can theoretically be extended to include many tiny doses over additional thousands of years, as well as doses outside the United States. The result of such a calculation would be thousands of cancer fatalities from the fuel cycle, but this result assumes that even tiny doses have some statistical adverse health effects which will not ever be mitigated (for example, no cancer cure in the next thousand years), and that these doses projected over thousands of years are meaningful. However, these assumptions are questionable. In particular, science cannot rule out the possibility that there will be no cancer fatalities from these tiny doses. For perspective, the doses are very small fractions of regulatory limits, and even smaller fractions of natural background exposure to the same populations. Nevertheless, despite all the uncertainty, some judgment as to the regulatory NEPA implications of these matters should be made and it makes no sense to repeat the same judgment in every case. Even taking the uncertainties into account, the Commission concludes that these impacts are acceptable in that these impacts would not be sufficiently large to require the NEPA conclusion, for any plant, that the option of extended operation under 10 CFR Part 54 should be eliminated. Accordingly, while the Commission has not assigned a single level of significance for the collective effects of the fuel cycle, this issue is considered Category 1 (Generic).

Appendix B B-12 Issue Type of Issue Findings Offsite radiological impacts (spent fuel and high-level waste disposal) Generic For the high -level waste and spent fuel disposal component of the fuel cycle, there are no current regulatory limits for offsite releases of radionuclides for the current candidate repository site. However, if it is assumed that limits are developed along the lines of the 1995 National Academy of Sciences (NAS) report, "Technical Bases for Yucca Mountain Standards," and that in accordance with the Commission's Waste Confidence Decision, 10 CFR 51.23, a repository can and likely will be developed at some site which will comply with such limits, peak doses to virtually all individuals will be 100 milliroentgen equivalent man (millirem) per year or less. However, while the Commission has reasonable confidence that these assumptions will prove correct, there is considerable uncertainty since the limits are yet to be developed, no repository application has been completed or reviewed, and uncertainty is inherent in the models used to evaluate possible pathways to the human environment. The NAS report indicated that 100 millirem per year should be considered as a starting point for limits for individual doses, but notes that some measure of consensus exists among national and international bodies that the limits should be a fraction of the 100 millirem per year. The lifetime individual risk from 100 millirem annual dose limit is about 3 x 10-3. Estimating cumulative doses to populations over thousands of years is more problematic. The likelihood and consequences of events that could seriously compromise the integrity of a deep geologic repository were evaluated by the U.S. Department of Energy in the "Final Environmental Impact Statement: Management of Commercially Generated Radioactive Waste," October 1980. The evaluation estimated the 70 -year whole-body dose commitment to the maximum individual and to the regional population resulting from several modes of breaching a reference repository in the year of closure, after 1,000 years, after 100,000 years, and after 100,000,000 years. Subsequently, the NRC and other Federal agencies have expended considerable effort to develop models for the design and for the licensing of a high-level waste repository, especially for the candidate repository at Yucca Mountain. More meaningful estimates of doses to the population may be possible in the future as more is understood about the performance of the proposed Yucca Mountain repository. Such estimates would involve great uncertainty, especially with respect to cumulative population doses over thousands of years. The standard proposed by the NAS is a limit on maximum individual dose. The relationship of potential new regulatory requirements, based on the NAS report, and

Appendix B B-13 Issue Type of Issue Findings Offsite radiological impacts (spent fuel and high-level waste disposal) [continued from previous page] Generic cumulative population impacts has not been determined, although the report articulates the view that protection of individuals will adequately protect the population for a repository at Yucca Mountain. However, the U.S. Environmental Protection Agency's (EPA) generic repository standards in 40 CFR Part 191 generally provide an indication of the order of magnitude of cumulative risk to the population that could result from the licensing of a Yucca Mountain repository, assuming the ultimate standards will be within the range of standards now under consideration. The standards in 40 CFR Part 191 protect the population by imposing the amount of radioactive material released over 10,000 years. The cumulative release limits are based on the EPA's population impact goal of 1,000 premature cancer deaths worldwide for a 100,000-metric ton (MTHM)repository. Nevertheless, despite all the uncertainty, some judgment as to the regulatory NEPA implications of these matters should be made and it makes no sense to repeat the same judgment in every case. Even taking the uncertainties into account, the Commission concludes that these impacts are acceptable in that these impacts would not be sufficiently large to require the NEPA conclusion, for any plant, that the option of extended operation under 10 CFR Part 54 should be eliminated. Accordingly, while the Commission has not assigned a single level of significance for the impacts of spent fuel and high-level waste disposal, this issue is considered in Category 1 (Generic). Nonradiological impacts of the uranium fuel cycle Generic SMALL. The nonradiological impacts of the uranium fuel cycle resulting from the renewal of an operating license for any plant are found to be small. Low-level waste storage and disposal Generic SMALL. The comprehensive regulatory controls that are in place and the low public doses being achieved at reactors ensure that the radiological impacts to the environment will remain small during the term of a renewed license. The maximum additional onsite land that may be required for low -level waste storage during the term of a renewed license and associated impacts will be small. Nonradiological impacts on air and water will be negligible. The radiological and nonradiologica l environmental impacts of long -term disposal of low-level waste from any individual plant at licensed sites are small. In addition, the Commission concludes that there is reasonable assurance that sufficient low -level waste disposal capacity will be made available when needed for facilities to be decommissioned consistent with NRC decommissioning requirements.

Appendix B B-14 Issue Type of Issue Findings Mixed waste storage and disposal Generic SMALL. The comprehensive regulatory controls and the facilities and procedures that are in place ensure proper handling and storage, as well as negligible doses and exposure to toxic materials for the public and the environment at all plants. License renewal will not increase the small, continuing risk to human health and the environment posed by mixed waste at all plants. The radiological and nonradiological environmental impacts of long-term disposal of mixed waste from any individual plant at licensed sites are small. In addition, the Commission concludes that there is reasonable assurance that sufficient mixed waste disposal capacity will be made available when needed for facilities to be decommissioned consistent with NRC decommissioning requirements. Onsite spent fuel Generic SMALL. The expected increase in the volume of spent fuel from an additional 20 years of operation can be safely accommodated on site with small environmental effects through dry or pool storage at all plants if a permanent repository or monitored retrievable storage is not available. Nonradiological waste Generic SMALL. No changes to generating systems are anticipated for license renewal. Facilities and procedures are in place to ensure continued proper handling and disposal at all plants. Transportation Generic SMALL. The impacts of transporting spent fuel enriched up to 5 percent uranium -235 with average burnup for the peak rod to current levels approved by the NRC up to 62,000 megawatt days per metric ton uranium (MWd/MTU) and the cumulative impacts of transporting high-level waste to a single repository, such as Yucca Mountain, Nevada are found to be consistent with the impact values contained in 10 CFR 51.52(c), Summary Table S-4, "Environmental Impact of Transportation of Fuel and Waste to and from One Light -Water-Cooled Nuclear Power Reactor." If fuel enrichment or burnup conditions are not met, the applicant must submit an assessment of the implications for the environmental impact values reported in 10 CFR 51.52. Appendix B B-15 Issue Type of Issue Findings Decommissioning Radiation doses Generic SMALL. Doses to the public will be well below applicable regulatory standards regardless of which decommissioning method is used. Occupational doses would increase no more than 1 man-rem caused by the buildup of long -lived radionuclides during the license renewal term. Waste management Generic SMALL. Decommissioning at the end of a 20 -year license renewal period would generate no more solid wastes than at the end of the current license term. No increase in the quantities of Class C or greater than Class C wastes would be expected. Air quality Generic SMALL. Air quality impacts of decommissioning are expected to be negligible either at the end of the current operating term or at the end of the license renewal term. Water quality Generic SMALL. The potential for significant water quality impacts from erosion or spills is no greater whether decommissioning occurs after a 20 -year license renewal period or after the original 40 -year operation period, and measures are readily available to avoid such impacts. Ecological resources Generic SMALL. Decommissioning after either the initial operating period or after a 20 -year license renewal period is not expected to have any direct ecological impacts. Socioeconomic impacts Generic SMALL. Decommissioning would have some short -term socioeconomic impacts. The impacts would not be increased by delaying decommissioning until the end of a 20-year license renewal period, but they might be decreased by population and economic growth. Environmental Justice Environmental justice Uncategorized NONE. The need for and the content of an analysis of environmental justice will be addressed in plant -specific reviews. Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51

APPENDIX C 1 APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS 2

C-1 C. APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS 1 The Atomic Energy Act of 1954, as amended (42 USC § 2011 et seq.), authorizes the 2 U.S. Nuclear Regulatory Commission (NRC) to enter into agreement with any State to assume 3 regulatory authority for certain activities (see 42 USC § 2012 et seq.). For example, through the 4 Agreement State Program, Mississippi assumed regulatory responsibility over certain 5 byproduct, source, and quantities of special nuclear materials not sufficient to form a critical 6 mass. The Division of Radiological Health, Mississippi Department of Health, administers the 7 Mississippi State Agreement Program. 8 In addition to carrying out some Federal programs, State legislatures develop their own laws. 9 State statutes supplement, as well as implement, Federal laws for protection of air, water 10 quality, and groundwater. State legislation may address solid waste management programs, 11 locally rare and endangered species, and historic and cultural resource

s. 12 The Clean Water Act (33 USC

§ 1251 et seq., herein referred to as CWA) allows for primary 13 enforcement and administration through State agencies, given that the State program is at least 14 as stringent as the Federal program. The State program must conform to the CWA and to the 15 delegation of authority for the Federal National Pollutant Discharge Elimination System 16 (NPDES) program from the U.S. Environmental Protection Agency (EPA) to the State. The 17 primary mechanism to control water pollution is the requirement for direct dischargers to obtain 18 an NPDES permit, or in the case of States where the authority has been delegated from the 19 EPA, a State Pollutant Discharge Elimination System permit, under the CWA. In Mississippi, 20 the Mississippi Department of Environmental Quality issues and enforces NPDES permits. 21 One important difference between Federal regulations and certain State regulations is the 22 definition of waters that the State regulates. Certain State regulations may include underground 23 waters, whereas the CWA only regulates surface waters. The Mississippi Department of 24 Environmental Quality is charged with conserving, managing and protecting the surface water 25 and groundwater resources of Mississippi (MDEQ 2013). 26 C.1 Federal and State Environmental Requirements 27 Grand Gulf Nuclear Station (GGNS) is subject to Federal and State requirements for its 28 environmental program. 29 Table C-1 lists the principle Federal and State environmental regulations and laws associated 30 with the environmental review of the GGNS license renewal application. 31 Table C-1. Federal and State Environmental Requirements 32 Law/regulation Requirements Current operating license and license renewal Atomic Energy Act (42 U.S.C. § 2011 et seq.) This Act is the fundamental U.S. law on both the civilian and the military uses of nuclear materials. On the civilian side, it provides for both the development and the regulation of the uses of nuclear materials and facilities in the United States. The Act requires that civilian uses of nuclear materials and facilities be licensed, and it empowers the NRC to establish by rule or order, and to enforce, such standards to govern these uses as "the Commission may deem necessary or desirable in order to protect health and safety and minimize danger to life or property."

Appendix C C-2 Law/regulation Requirements 10 CFR Part 51. Title 10 Code of Federal Regulations (10 CFR) Part 51 , Energy "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions." This part contains environmental protection regulations applicable to the NRC's domestic licensing and related regulatory functions. 10 CFR Part 54 "Requirements for Renewal of Operating Licenses for Nuclear Power Plants." This part focuses on managing adverse effects of aging rather than noting all aging mechanisms. The rule is intended to ensure that important systems, structures, and components will maintain their intended function during the period of extended operation. 10 CFR Part 50 "Domestic Licensing of Production and Utilization Facilities. " Regulations that the NRC issues under the Atomic Energy Act of 1954, as amended (68 Stat. 919), and Title II of the Energy Reorganization Act of 1974 (88 Stat. 1242), provide for the licensing of production and utilization facilities. This part also gives notice to all persons who knowingly supply-to any licensee, applicant, contractor, or subcontractor -components, equipment, materials, or other goods or services that relate to a licensee 's or applicant 's activities subject to this part, that they may be individually subject to NRC enforcement action for violation of § 50.5. Air quality protection Clean Air Act (CAA) (42 USC § 7401 et seq.) The Clean Air Act (CAA) is a comprehensive Federal law that regulates air emissions. Among other things, this law authorizes EPA to establish National Ambient Air Quality Standards (NAAQS) to protect public health and public welfare and to regulate emissions of hazardous air pollutants. EPA has promulgated NAAQS for six criteria pollutants: sulfur dioxide, nitrogen dioxide, carbon monoxide (CO), ozone, lead, and particulate matter. All areas of the United States must maintain ambient levels of these pollutants below the ceilings established by the NAAQS. Mississippi Air and Water Pollution Control Act (Mississippi Code

§§ 49-17-1 to 49-17-43) The Mississippi Air and Water Pollution Control Act authorizes the setting of ambient air quality standards as necessary to protect the public health and welfare and emission standards for the purpose of controlling air contamination, air pollution, and the sources of air pollution.

Land use resources protection Coastal Zone Management Act (16 USC § 1451 et seq.) The Coastal Zone Management Act (CZMA) was established to preserve, protect, develop and where possible, restore or enhance, the resources of the Nation's coastal zone. Water resources protection Clean Water Act (CWA) (33 USC § 1251 et seq.) and the NPDES (40 CFR 122) The Clean Water Act (C WA) establishes the basic structure for regulating discharges of pollutants into the waters of the United States and regulating quality standards for surface waters. Wild and Scenic River Act (16 USC § 1271 et seq.) The Wild and Scenic River Act created the National Wild and Scenic Rivers System, which was established to protect the environmental values of free flowing streams from degradation by affecting activities, including water resources projects. Safe Drinking Water Act (42 USC § 300f et seq.) The Safe Drinking Water Act (SDWA) is the principal Federal law that ensures safe drinking water for the public. Under the SDWA, EPA is required to set standards for drinking water quality and oversees all states, localities, and water suppliers that implement these standards. Mississippi Department of Environmental Quality Regulation WPC-1 Wastewater Regulations for National Pollutant Discharge Elimination System (NPDES) Permits, Underground Injection Control (UIC) Permits, State Permits, Water Quality Based Effluent Limitations and Water Quality Certification

Appendix C C-3 Law/regulation Requirements Waste management and pollution prevention Resource Conservation and Recovery Act (RCRA) (42 USC § 6901 et seq.) RCRA gives EPA authority to control hazardous waste. Before a material can be classified as a hazardous waste, it first must be a solid waste as defined under the Resource Conservation and Recovery Act (RCRA). Hazardous waste is classified under Subtitle C of the RCRA. Parts 261 , "Identification and Listing of Hazardous Waste," and 262, "Standards Applicable to Generators of Hazardous Waste," of 40 CFR contain all applicable generators of hazardous waste regulations. Pollution Prevention Act (42 USC § 13101 et seq.) The Pollution Prevention Act formally established a national policy to prevent or reduce pollution at its source whenever feasible. The Act supplies funds for state and local pollution prevention programs through a grant program to promote the use of pollution prevention techniques by business. Protected species Endangered Species Act (ESA) (16 USC § 1531 et seq.) The Endangered Species Act (ESA) forbids any government agency, corporation, or citizen from taking (e.g., harming or killing) endangered animals without an Endangered Species Permit. The ESA also requires Federal agencies to consult with the U.S. Fish and Wildlife Service or National Marine Fisheries Service if any Federal action may adversely affect any listed species or designated critical habitat. Magnuson-Stevens Fishery Conservation and Management Act (MSA)

(P.L. 94-265), as amended through January 12, 2007 The Magnuson-Stevens Fishery Conservation and Management Act (MSA) includes requirements for Federal agencies to consider the impact of Federal actions on essential fish habitat and to consult with the National Marine Fisheries Service if any activities may adversely affect essential fish habitat.

Marine Mammal Protection Act (MMPA) (16 USC § 1361 et seq.) The Marine Mammal Protection Act (MMPA) prohibits the take of marine mammals in U.S. waters or by U.S. citizens on the high seas without an MMPA Take Permit issued by the National Marine Fisheries Service . MMPA also prohibits importation of marine mammals and marine mammal products into the United States. Fish and Wildlife Coordination Act (16 USC § 661 et seq.) To minimize adverse impacts of proposed actions on fish and wildlife resources and habitat, the Fish and Wildlife Coordination Act requires that Federal agencies consult Government agencies regarding activities that affect, control, or modify waters of any stream or bodies of water. It also requires that justifiable means and measures be used in modifying plans to protect fish and wildlife in these waters. Historic preservation National Historic Preservation Act (NHPA) (16 USC § 470 et seq.) The National Historic Preservation Act (NHPA) directs Federal agencies to consider the impact of their actions on historic properties. To comply with NHPA, Federal agencies must consult with State Historic Preservation Officers and, when applicable, tribal historic preservations officers. NHPA also encourages state and local preservation societies. C.2 Operating Permits and Other Requirements 1 Table C-2 lists the permits and licenses issued by Federal, State, and local authorities for 2 activities at GGNS. 3 Appendix C C-4 Table C-2. Licenses and Permits 1 Permit Number Dates Responsible Agency Operating license NPF-2 9 Issued: 11/1/198 4 Expires: 1 1/1/2024 NRC 401 Water Quality Certification None Issued: 2/5/19 74 Expires: None Mississippi Air and Water Pollution Control Commission NPDES Permit MS0029521 Expires: 0 8/31/201 6 Mississippi Department of Environmental Quality (M DE Q) Baseline Stormwater General NPDES Permit MSR000883 Expires: 09/28/15 M DE Q Large Construction General Permit - Discharge of stormwater to waters of the State MSR10-5946 Expires: 12/31/15 M DE Q Air Permit - Operation of air emission sources (emergency diesel generators, diesel engines and pumps, diesel fueled outage equipment, and cooling towers) 0420-00023 Expires: 05/31/09 Timely renewal application was submitted; therefore, permit has been administratively continued. M DEQ Hazardous waste generator identification MSD000644617 Expires: N/A M DE Q Groundwater withdrawal MS-GW-02972 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-02971 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-02970 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-02969 Expires: 09/25/2016 M DE Q Groundwater withdrawal MS-GW-00371 Expires: 09/25/20 1 6 M DE Q Groundwater withdrawal MS-GW-16714 Expires: 03/10/20 20 MDEQ Groundwater withdrawal MS-GW-02967 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-14989 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-15026 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-02979 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-02978 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-02977 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-02976 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-02975 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-02974 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-02973 Expires: 09/25/2016 MDEQ Underground diesel fuel storage 5913 Expires: 06/30/2014 M DE Q Transportation of radioactive waste through Mississippi 4600 Expires: 06/30/2014 Mississippi Emergency Management Agency Radioactive and hazardous materials shipments 061013550003V Expires: 06/30/2014 U.S. Department of Transportation Taking of migratory birds MB798276-0 Expires: 03/31/2014 U.S. Fish & Wildlife Service Shipment of radioactive material into Tennessee to a disposal/processing facility T-MS002-L13 Expires: 12/31/2013 Tennessee Department of Environmental Conservation Source: Entergy 2011 Appendix C C-5 C.3 References 1 [Entergy] Entergy Operations, Inc. 2011. Grand Gulf Nuclear Station, Unit 1, License Renewal 2 Application. Appendix E, Applicant's Environmental Report. October 2011. ADAMS Accession 3 No. ML11308A234 4 [MDEQ] Mississippi Department of Environmental Quality. 201

3. Home - The Office of Land 5 and Water Resources. Available at http://www.deq.state.ms.us/mdeq.nsf/page/l%26w_home 6 (accessed 8 January 201 3). 7

APPENDIX D 1 CONSULTATION CORRESPONDENCE 2

D-1 D. CONSULTATION CORRESPONDENCE 1 D.1 Background 2 The Endangered Species Act of 1973, as amended; the Magnuson Stevens Fisheries 3 Management Act of 1996, as amended; and the National Historic Preservation Act of 1966 4 (NHPA) require that Federal agencies consult with applicable State and Federal agencies and 5 groups before taking action that may affect threatened or endangered species, essential fish 6 habitat, or historic and archaeological resources, respectively. Table D-1 contains a list of 7 correspondence between the U. S. Nuclear Regulatory Commission (NRC) and other agencies 8 pursuant to compliance with these Federal acts. 9 Table D-1. Consultation Correspondence 10 Author Recipient Date of Letter/Email NRC (D. Wrona) Advisory Council on Historic Preservation (R. Nelson) January 19, 2012 (ML11348A088 ) NRC (D. Wrona) Tribal Nation - Mississippi Band of Choctaw Indians (P. Anderson) January 19, 2012 (ML11342A121) NRC (D. Wrona) Tribal Nation - Jena Band of Choctaw Indians (B. Smith) January 19, 2012 (ML11342A121) NRC (D. Wrona) Tribal Nation - Choctaw Nation of Oklahoma (G. Pyle) January 19, 2012 (ML11342A121) NRC (D. Wrona) Tribal Nation - Tunica -Biloxi Tribe of Louisiana (E. Barbry) January 19, 2012 (ML11342A121) NRC (D. Wrona) National Marine Fisheries Service (D. Bernhart) January 19, 2012 (ML11350A173) NRC (D. Wrona) U.S. Fish & Wildlife Service (USFWS), Louisiana Field Office (R. Watson) January 19, 2012 (ML11349A001) NRC (D. Wrona) Mississippi State Historic Preservation Office (SHPO) January 19, 2012 (ML11348A090 ) NRC (D. Wrona) Mississippi Natural Heritage Program (S. Surrette) January 20, 2012 (ML11349A003) NRC (D. Wrona) USFWS, Mississippi Field Office (S. Ricks) January 20, 2012 (ML11348A354) NRC (D. Wrona) Louisiana SHPO (P. Boggan) January 20, 2012 (ML11348A353 ) USFWS Mississippi Field Office (S. Ricks) NRC (D. Drucker) February 3, 2012 (ML12047A113) NRC (D. Wrona) Louisiana Natural Heritage Program (C. Michon) February 6, 201 2 (ML12005A163 ) Mississippi Natural Heritage Program (A. Sanderson) NRC (D. Wrona) February 13, 2012 (ML12055A312) Tribal Nation - Mississippi Band of Choctaw Indians (C. Wallace) NRC (D. Wrona) February 13, 2012 (ML12047A127) Appendix D D-2 Author Recipient Date of Letter/Email Louisiana Natural Heritage Program (C. Michon) NRC (D. Wrona) February 16, 2012 (ML12060A098) Mississippi SH PO (G. Williamson ) NRC (D. Wrona) February 28, 20 12 (ML12073A084 ) USFWS Louisiana Field Office (J. Weller) NRC (D. Wrona) February 29, 20 12 (ML12082A141) Jena Band of Choctaw Indians (D. Master s) NRC (Chief, Rules, Announcements, & Directives Branch) March 1, 2012 (ML12089A020) National Marine Fisheries Service (D. Bernhart) NRC (D. Wrona) March 1, 2012 (ML12065A167) Choctaw Nation of Oklahoma (J. Jacobs) NRC (D. Wrona) March 26, 2012 (ML12101A124) CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDEN CE APPENDIX E1 CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE 2

E-1 E. CHRONOLOGY OF ENVIRONMENTAL REVIEW 1 CORRESPONDENCE 2 This appendix contains a chronological listing of correspondence between the U.S. Nuclear 3 Regulatory Commission (NRC) and external parties as part of its environmental review for 4 Grand Gulf Nuclear Station (GGNS). All documents are available electronically from the NRC's 5 Public Electronic Reading Room found on the Internet at the following Web address: 6 http://www.nrc.gov/reading -rm.html. From this site, the public can gain access to the NRC's 7 Agencywide Documents Access and Management System (ADAMS), which provides text and 8 image files of the NRC's public documents in ADAMS. The ADAMS accession number for each 9 document is included in the following list. 10 E.1 Environmental Review Correspondence 11 Table E-1 lists the environmental review correspondence, by date, beginning with the request 12 by Entergy to renew the operating license for GGNS. 13 Table E-1. Environmental Review Correspondence 14 Date Correspondence Description ADAMS No. October 28, 2011 Transmittal of license renewal application (LRA) for GGNS, Unit 1 ML11308A052 November 9, 2011 Receipt and availability of GGNS, Unit 1 LRA ML11293A013 December 16, 2011 Determination of acceptability and sufficiency for docketing, proposed review schedule, and opportunity for a hearing regarding the application from Entergy Operations, Inc. (Entergy), for renewal of the operating license for GGNS, Unit 1 ML11335A340 December 22, 2011 Notice of intent to prepare an environmental impact statement (EIS) and conduct scoping process for license renewal for GGNS, Unit 1 ML11342A073 January 6, 2012 Forthcoming meeting to discuss the license renewal process and environmental scoping for GGNS, Unit 1, LRA review ML11362A433 January 19, 2012 GGNS LRA review Advisory Council on Historic Preservation ML11348A088 January 19, 2012 Mississippi Band of Choctaw Indians -request for comments concerning GGNS LRA review ML11342A121 January 19, 2012 Choctaw Nation of Oklahoma -request for comments concerning GGNS LRA review ML11342A121 January 19, 2012 Tunica-Biloxi Tribe of Louisiana -request for comments concerning GGNS LRA review ML11342A121 January 19, 2012 Jena Band of Choctaw Indians -request for comments concerning GGNS LRA review ML11342A121

Appendix E E-2 Date Correspondence Description ADAMS No. January 19, 2012 Request for list of protected species within the area under evaluation for the GGNS, Unit 1, license renewal review application, U.S. Fish & Wildlife Service (USFWS), Louisiana Field Office ML11349A001 January 19, 2012 GGNS LRA review, Mississippi State Historic Preservation Office (SHPO) ML11348A090 January 19, 2012 GGNS LRA review, National Marine Fisheries Service (NMFS) ML11350A173 January 20, 2012 GGNS LRA review Louisiana SHPO ML11348A353 January 20, 2012 Request for list of protected species within the area under evaluation for GGNS license renewal review application, Mississippi Natural Heritage Program ML11349A003 January 20, 2012 Request for list of protected species within the area under evaluation for GGNS license renewal review application, USFWS, Mississippi Field Office ML11348A354 January 31, 20 12 Transcript from afternoon public scoping meeting ML12037A222 January 31, 20 12 Transcript from evening public scoping meeting ML12037A223 February 3, 20 12 Response from USFWS, Mississippi Field Office, to NRC request for list of protected species within the area under evaluation for GGNS LRA review ML12047A113 February 6, 20 12 Request for list of protected species within the area under evaluation for GGNS, Unit 1, license renewal review application, Louisiana Natural Heritage Program ML12005A163 February 1 3, 20 12 Response from Mississippi Natural Heritage Program to NRC request for list of protected species within the area under evaluation for GGNS LRA review ML12055A312 February 1 3, 20 12 Response from Mississippi Band of Choctaw Indians to NRC request for comments on GGNS LRA review ML12047A127 February 1 3, 20 12 Scoping comment from the National Park Service referencing the GGNS LRA review ML12048A674 February 16, 20 12 Response from Louisiana Natural Heritage Program to NRC request for list of protected species within the area under evaluation for GGNS LRA review ML12060A098 February 27, 20 12 Scoping comments from J. Hil legas, Green Party of Mississippi ML12060A334 February 28, 20 12 Mississippi SHPO response to NRC letter referencing GGNS LRA review ML12073A084 February 29, 20 12 Response from USFWS, Louisiana Field Office, to NRC request for list of protected species within the area under evaluation for GGNS LRA review ML12082A141 March 1, 2012 Response from Jena Band of Choctaw Indians to NRC request for comments concerning GGNS LRA review ML12089A020

Appendix E E-3 Date Correspondence Description ADAMS No. March 1, 2012 Response from NMFS to NRC request for comments concerning GGNS LRA review ML12065A167 March 22, 2012 Transmittal of environmental audit plan to Entergy ML12060A112 March 26, 2012 Response from Choctaw Nation of Oklahoma to NRC request for comments concerning GGNS LRA review ML12101A124 April 23, 20 12 Transmittal of environmental requests for additional information (RAIs) ML12083A188 May 8, 2012 Transmittal of air RAIs ML12123A081 May 21, 2012 Transmittal of severe accident mitigation alterative (SAMA) RAI s ML12115A101 May 23, 2012 Entergy response to environmental RAIs ML12157A173 June 6, 2012 Entergy response to air RAIs ML12158A445 July 19, 2012 Entergy response to SAMA RAIs ML12202A056 August 23, 2012 Transmittal of 2 nd round SAMA RAIs ML12227A735 September 7, 2012 Schedule change letter ML12242A545 October 10, 2012 Entergy partial response to 2 nd round SAMA RAIs ML12277A082 November 19, 2012 Entergy complete response to 2 nd round SAMA RAIs ML12325A174 December 19, 2012 Entergy response to SAMA clarification questions ML12359A038 February 26, 2013 Schedule change letter ML13002A430 April 16, 2013 Scoping Summary Report ML12201A623 August 15, 2013 Schedule change letter ML13207A156

APPENDIX F1 U.S. NUCLEAR REGULATORY COMMISSION STAFF EVALUATION OF 2 SEVERE ACCIDENT MITIGATION ALTERNATIVES FOR 3 GRAND GULF NUCLEAR STATION IN SUPPORT OF 4 LICENSE RENEWAL APPLICATION REVIEW 5

Appendix F F-1 F. U.S. NUCLEAR REGULATORY COMMISSION STAFF EVALUATION 1 OF SEVERE ACCIDENT MITIGATION ALTERNATIVES FOR GRAND 2 GULF NUCLEAR STATION IN SUPPORT OF LICENSE RENEWAL 3 APPLICATION REVIEW 4 F.1 Introduction 5 Entergy Operations, Inc. (Entergy or the applicant) submitted an assessment of severe accident 6 mitigation alternatives (SAMAs) for Grand Gulf Nuclear Station, Unit 1 (GGNS), in Section 4.21 7 and Attachment E of the Environmental Report (ER) (Entergy 2011). This assessment was 8 based on the most recent revision to the GGNS probabilistic risk assessment (PRA), including 9 an internal events model and a plant -specific offsite consequence analysis performed using the 10 MELCOR Accident Consequence Code System 2 (MACCS2) computer code, as well as 11 insights from the GGNS individual plant examination (IPE) (Entergy 1992) and individual plant 12 examination of external events (IPEEE) (Entergy 1995). In identifying and evaluating potential 13 SAMAs, Entergy considered SAMAs that addressed the major contributors to core damage 14 frequency (CDF) and population dose at GGNS, as well as insights and SAMA candidates 15 found to be potentially cost beneficial from the analysis of nine other boiling-water reactor 16 (BWR) nuclear power generating stations. Entergy initially identified a list of 2 49 potential 17 SAMAs. This list was reduced to 63 unique SAMA candidates by eliminating SAMAs that 18 (a) were not applicable to GGNS, (b) had already been implemented at GGNS, or (c) were 19 combined into a more comprehensive or plant -specific SAMA. Entergy concluded in the ER that 20 th ree candidate SAMAs are potentially cost beneficial. 21 As a result of the review of the SAMA assessment, the U.S. Nuclear Regulatory Commission 22 (NRC) staff issued request s for additional information (RAI s) to Entergy by letters dated 23 May 21, 2012, (NRC 2012a) and August 23, 2012 (NRC 2012b). Key questions concerned: 24 changes and updates to Level 1 and Level 2 PRA models that most affect 25 CDF, 26 differences in CDF values and importance measures reported in the ER, 27 the impact of open items and issues from the peer review of the PRA, 28 the process used to assign release categories to containment event tree 29 (CET) end states for incorporating Level 1 results into the Level 2 analysis, 30 selection of representative sequences for each release category in the 31 Level 2 analysis, 32 the impact of new information on fire and seismic initiated sequences, and 33 further information on the cost -benefit analysis of several specific candidate 34 SAMAs and low -cost alternatives. 35 Entergy submitted additional information by letters dated July 19, 2012 (Entergy 2012a), 36 October 2, 2012 (Entergy 2012b), November 19, 2012 (Entergy 2012c), and 37 December 19, 2 012 (Entergy 2012d). In response to the staff RAIs, Entergy provided further 38 information on: 39 the history and key changes to PRA models, 40 the resolution of peer review comments, 41 Appendix F F-2 the development of the Level 2 containment release model, 1 the reasons for differences between CDF values given in the submittal, 2 the results of an updated cost -benefit analysis based on resolution of CDF 3 differences, 4 the impact of new information on external events, and 5 the cost of various SAMAs and potential low -cost alternatives. 6 Entergy's responses addressed the staff's concerns and resulted in the identification of one 7 additional potentially cost -beneficial SAMA. 8 An assessment of the SAMAs for GGNS is presented below. 9 F.2 Estimate of Risk for GGNS 10 Section F.2.1 summarizes Entergy's estimates of offsite risk at GGNS. The summary is 11 followed by the staff's review of Entergy's risk estimates in Section F.2.2. 12 F.2.1 Entergy's Risk Estimates 13 Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA 14 analysis:

(1) the GGNS Level 1 and 2 PRA model, which is an updated version of the IPE 15 (Entergy 1992), and (2) a supplemental analysis of offsite consequences and economic impacts 16 (essentially a Level 3 PRA model) developed specifically for the SAMA analysis. The original 17 SAMA analysis was based on the most recent GGNS Level 1 and Level 2 PRA model available 18 at the time of the ER, referred to as the 2010 extended power uprate (EPU) model 19 (Entergy 2011). Subsequent to the original submittal, errors were found in the interpretation o f 20 the results of the Level 2 model that led Entergy to change the Level 2 model and cost

-benefit 21 analysis (Entergy 2012b, 2012c, 2012d). The results discussed in this appendix are for the 22 updated analysis. The corrections to the model are discussed in Section F.2.2. The scope of 23 the current GGNS PRA does not include external events. 24 The GGNS CDF is approximately 2.9 x 106 per reactor -year as determined from quantification 25 of the Level 1 PRA model with the revised Level 2 model. This value was used as the baseline 26 CDF in the SAMA evaluations (Entergy 2012c, 2012d). The CDF is based on the risk 27 assessment for internally initiated events, which includes internal flooding. Entergy did not 28 explicitly include the contribution from external events within the GGNS risk estimates; however, 29 it did account for the potential risk reduction benefits associated with external events by 30 multiplying the estimated benefits for internal events by a factor of

11. This is discussed further 31 in Sections F.2.2 and F.6.2. 32 The breakdown of CDF by initiating event is provided in Table F-1. As shown in this table, loss 33 of offsite power and power conversion system available transient are the dominant contributors 34 to the CDF. While not listed explicitly in Table F-1 because they can occur as a result of 35 multiple initiators, Entergy stated that station blackout s contribute about 37 percent 36 (1.1 x 106 per reactor

-year) of the total CDF; anticipated transients without scram contribute 37 about 0.2 percent (4.4 x 109 per reactor -year) to the total CDF (Entergy 2012c). 38 The Level 2 GGNS PRA model that forms the basis for the SAMA evaluation is essentially a 39 new model and reflects power uprate conditions. The Level 2 model uses CETs containing both 40 phenomenological and systemic events. The Level 1 core damage sequences are binned into 41 accident classes (or plant damage states) that provide the interface between the Level 1 and 42 Appendix F F-3 Level 2 CET analysis. The CETs are linked directly to the Level 1 event trees and CET nodes 1 are evaluated using subordinate trees and logic rules. 2 The CET considers the influence of physical and chemical processes on the integrity of the 3 containment and on the release of fission products once core damage has occurred. The 4 quantified CET sequences are binned into a set of end states that are subsequently grouped 5 into 13 release categories (or release modes) that provide the input to the Level 3 consequence 6 analysis. The frequency of each release category was obtained by summing the frequency of 7 the individual accident progression CET endpoints binned into the release category. Source 8 terms were developed for the release categories using the results of Modular Accident Analysis 9 Program (MAAP 4.0.6) computer code calculations. From these results, source terms were 10 chosen to be representative of the release categories. The results of this analysis for GGNS 11 are provided in the revised Table E.1-9 of ER Attachme nt E (Entergy 2012c). 12 Entergy computed offsite consequences for potential releases of radiological material using the 13 MACCS2 Version 1.13.1 code and analyzed exposure and economic impacts from its 14 determination of offsite and onsite risks. Inputs for these analyses include plant -specific and 15 site-specific input values for core radionuclide inventory, source term and release 16 characteristics, site meteorological data, projected population distribution and growth within a 17 50-mi le (mi) (80-kilometer (km)) radius, emergency response evacuation modeling, and local 18 economic data. Radionuclide inventory in the reactor core is based on a plant -specific 19 evaluation and corresponds to that for the EPU power of 4,408 megawatts thermal (MWt) 20 (Entergy 2011, Attachment E). The estimation of onsite impacts (in terms of clean -up and 21 decontamination costs and occupational dose) is based on guidance in NUREG/BR -0184 , 22 Regulatory Analysis Technical Evaluation Handbook (NRC 1997a). Additional details on the 23 input parameter assumptions are discussed below. 24 Appendix F F-4 Table F-1. Grand Gulf Nuclear Station Core Damage Frequency (CDF) for Internal Events 1 Initiating Event CDF (per year)

% CDF Contribution Loss of Offsite Power Initiator 1.2 x 106  40 Power Conversion System Available Transient 5.9 x 107  20 Loss of Power Conversion System Initiator 2.5 x 107   8 Loss of Condensate Feed Water Pumps 2.3 x 107   8 Loss of Instrument Air 1.4 x 107   5 Closure of Main Steam Isolation Valves (Initiator) 1.2 x 107   4 Loss of Service Transformer 21 1.2 x 107   4 Large Loss of Coolant Accident (LOCA) 9.7 x 108   3 Loss of Service Transformer 11 8.3 x 108   3 Loss of Alternating Current Division 2 Initiator 6.2 x 108   2 Other Initiating Events1 3.3 x 108   1 Loss of Alternating Current Division 1 Initiator 2.7 x 108   1 Intermediate LOCA 1.4 x 108   1 Total Core Damage Frequency (Internal Events) 2.9 x 106 100 1 Multiple initiating events with each contributing 0.3 percent or less In the E R, the applicant estimated the dose risk to the population within 80 km (50 mi) of the 2 GGNS site to be 0.00609 person-sieverts (Sv) per year (0.609 person-roentgen equivalent in 3 man (rem) per year) (Entergy 2012c). The breakdown of the population dose risk by 4 containment release mode is summarized in Table F-2. Medium releases provide the greatest 5 contribution, totaling approximately 67 percent of the population dose risk and 75 percent of the 6 offsite economic cost risk for all timings. High early (H/E) releases alone contribute only about 7 10 percent, and high releases for all timings contribute 17 percent of the population dose risk.

8 F.2.2 Review of Entergy's Risk Estimates 9 Entergy's determination of offsite risk at GGNS is based on three major elements of analysis: 10 the Level 1 and 2 risk models that form the bases for the 1992 IPE submittal 11 (Entergy 1992), and the external event analyses of the 1995 IPEEE submittal 12 (Entergy 1995); 13 the major modifications to the IPE model that have been incorporated in the 14 GGNS 2010 EPU PRA; and 15 the combination of offsite consequence measures from MACCS2 analyses 16 with release frequencies and radionuclide source terms from the Level 2 PRA 17 model. 18 Appendix F F-5 Table F-2. Base Case Mean Population Dose Risk and Offsite Economic Cost Risk 1 for Internal Events 2 Each analysis element was reviewed to determine the acceptability of Entergy's risk estimates 3 for the SAMA analysis, as summarized further in this section. 4 F.2.2.1 Internal Events CDF Model 5 The staff's review of the GGNS IPE is described in an NRC letter dated March 7, 1996 6 (NRC 1996). From its review of the IPE submittal, the staff concluded that the IPE process is 7 capable of identifying the most likely severe accidents and severe accident vulnerabilities, and 8 Release Mode Population Dose Risk 1 Offsite Economic Cost Risk ID 2 Frequency (per year) person-rem/yr % Contribution

$/yr % Contribution H/E 1.0 x 107 6.2 x 102   10 1.7 x 10+2   11 H/I 1.2 x 108 6.2 x 103   1 1.7 x 10+1   1 H/L 9.2 x 108 3.8 x 102   6 9.6 x 10+1   6 M/E 3.7 x 107 1.7 x 101   28 4.8 x 10+2   32 M/I 1.8 x 107 1.2 x 101   20 3.3 x 10+2   22 M/L 3.0 x 107 1.2 x 101   19 3.2 x 10+2   21 L/E 4.1 x 109 4.0 x 104   <0.1 3.0 x 101   <0.1 L/I 3.6 x 108 1.2 x 102   2 2.7 x 10+1   2 L/L 4.4 x 107 7.8 x 102   13 7.4 x 10+1   5 LL/E 2.2 x 109 7.9 x 107   <0.1 1.0 x 103   <0.1 LL/I 2.1 x 109 3.8 x 107   <0.1 9.7 x 104   <0.1 LL/L 7.1 x 109 2.0 x 103   <1 3.4 x 10+0   <1 NCF 1.4 x 106 5.0 x 104   <0.1 6.4 x 101   <0.1 Total 2.9 x 106 6.1 x 101   100 1.5 x 10+3   100 1 Unit Conversion Factor:  1 Sv = 100 rem 2 Release Mode Nomenclature (Magnitude/Timing)

Magnitude: High (H) - Greater than 10 percent release fraction for Cesium Iodide Medium (M) - 1 to 10 percent release fraction for Cesium Iodide Low (L) - 0.1 to 1 percent release fraction for Cesium Iodide Low-Low (LL) - Less than 0.1 percent release fraction for Cesium Iodide No containment failure (NCF) - Much less than 0.1 percent release fraction for Cesium Iodide Timing: Early (E) - Less than 4 hours Intermediate (I) - 4 to 24 hours Late (L) - Greater than 24 hours Appendix F F-6 therefore, that the GGNS IPE has met the intent of Generic Letter (GL) 88-20 (N RC 1988). 1 Although no vulnerabilities were identified in the IPE, 11 improvements were identified by 2 Entergy. The ER stated that five of these improvements have been implemented, one was 3 considered to be no longer applicable, and five were retained as potential SAMAs. 4 The internal events CDF value from the 1992 IPE (1.7 x 105 per reactor -year) is near the 5 average of the values reported for other General Electric (GE) BWR 5/6 units. Figure 11.2 of 6 NUREG-1560, Volume 2, Individual Plant Examination Program: Perspectives on Reactor 7 Safety and Plant Performance Parts 2 -5, Final Report (NRC 1997b) shows that the IPE -based 8 total internal events CDF for GE BWR 5/6 plants ranges from 1 x 106 per year to 4 x 104 per 9 year, with an average CDF for the group of 2 x 105 per year. Other plants have updated the 10 values for CDF subsequent to the IPE submittals to reflect modeling and hardware changes. 11 The internal events CDF result for GGNS used for the SAMA analysis (2.9 x 106 per year) is 12 somewhat lower than that for other plants of similar vintage. 13 GGNS was one of the units analyzed in considerable detail in the analysis of the risk of five 14 nuclear power plants found in NUREG -1150, Severe Accident Risks: An Assessment for Five 15 U.S. Nuclear Power Plants (NRC 1990). NUREG -1150 stated that the mean internal events 16 CDF for GGNS was 4 x 106 per year, which is very similar to the current Entergy estimate. 17 There have been four revisions to the IPE Level 1 model since the 1992 IPE submittal. A listing 18 of the changes made to the GGNS PRA since the original IPE submittal was provided in the ER 19 (Entergy 2011) and is summarized in Table F-3, including information requested by the NRC 20 (Entergy 2012a, 2012d). A comparison of internal events CDF between the 1992 IPE and the 21 current PRA model indicates a decrease of about a factor of six in the total CDF (from 22 1.7 x 105 per reactor -year to 2.9 x 106 per reactor -year). This reduction can be attributed to 23 incorporation of plant -specific data, improved modeling details, and removal of conservatism. 24 Appendix F F-7 Table F-3. Major GGNS Probabilistic Safety Assessment (PSA) Models 1 PSA Model Summary of Significant Changes from Prior Model CDF (per year) LERF (per year) 1992 (IPE) 1.7 x 105 5.2 x 107 1997 (R1) Incorporation of updated plant -specific data for system maintenance and testing unavailability Incorporation of updated plant -specific data for initiating event frequencies Incorporation of updated plant -specific data for certain important components (i.e., diesel generators, high pressure core spray, and reactor core isolation cooling pumps) Various modeling changes to system models to correct minor modeling errors and incorporate modifications since the original IPE 5.5 x 106 Not Updated 2002 (R2) Modeling changes to reflect installation of new type of plant service water radial well pumps and support systems Addition of heating, ventilation, and air conditioning (HVAC) systems to the model, including addition of the new standby service water pump -house high temperature alarm Modeling of changes to the backup scram valves and logic in the anticipated transient without scram portion of the fault tree Use of more comprehensive human reliability analysis methods Us e of the convolution method for recovery of loss of offsite power (LOSP) Addition of an interfacing systems LOCA initiator Inclusion of operating data through December 31 , 2000 4.3 x 106 2.0 x 107 2010 (R3) Update of plant-specific data and initiator frequencies (through August 2006) and generic initiator frequencies New initiators: loss of service transformer, reactor vessel rupture, Loss of control rod drive, and Break (LOCA) outside of containment Major changes to LOSP modeling Inclusion of modeling for loss of emergency core cooling system pumps due to containment failure Revision of instrument air system modeling to incorporate new plant air compressors Revision of modeling of control rod drive -less credit for control rod drive 2.7 x 106 1.4 x 107 2010 (EPU) Power level change (13 percent EPU) Hardware changes Procedural changes Operational changes 2.9 x 106 1.5 x 107 (Note 1) Note 1. This LERF value is from the Revision 3 EPU LERF model and is different from the Table F-2 value for the High Early (H/E) release category, which was obtained from the full Level 2 model (Entergy 2012d). Refer to additional discussion in Section F.2.2. Appendix F F-8 The GGNS 2010 EPU model reflects GGNS design, component failure, and unavailability data 1 as of August 2006, modified to reflect the EPU configuration. Entergy states that there have 2 been no major plant hardware changes or procedural modifications since August 2006 that 3 would have a significant impact on the results of the SAMA analysis. In response to the staff 4 RAIs, Entergy (2012a) clarified what was meant by "significant" and also stated that a review of 5 plant equipment performance since August 2006 indicated no degradation issues that would 6 impair the SAMA analysis (Entergy 2011). A change that would have a significant impact is 7 described as a grade A (extremely important and necessary to assure the technical adequacy or 8 quality of the PRA) or grade B (important and necessary to address, but may be deferred until 9 the next model update) model change request (MCR). The MCR database is used to track 10 plant changes, procedure revisions, nuclear licensing revisions, and model improvements that 11 impact the PRA models. The RAI response stated that there were one grade A and 12 grade B 12 MCRs. The single grade A MCR involved modeling for the temporary condition when a 13 low-pressure feedwater heater is taken out of service and would not impact the SAMA analysis; 14 the grade B MCRs either impacted the fire model and not the SAMA model, involved systems 15 that are not risk -significant, or would result in a decrease in risk (Entergy 2012a). The staff 16 concludes that there have been no major plant hardware changes or procedural modifications 17 since August 2006 that would have a significant impact on the results of the SAMA analysis. 18 In response to a staff RAI, Entergy explained that the maintenance rule system health reports 19 indicated no equipment reliability issues that would impair the SAMA analysis and that the plant 20 data issues identified during the expert panel reviews of the model updates or during the expert 21 panel review of the Level 2 cutsets were resolved in the model used for the SAMA analysis 22 (Entergy 2012b). 23 Although Entergy suggested the unavailability of the high-pressure core spray (HPCS) system 24 and the B diesel -driven fire pump had increased recently, Entergy also stated that the 25 unavailability for these systems remains within the error band of the unavailability distribution 26 (Entergy 2012b). Based on this response and the staff's review of the GGNS SAMA analysis, 27 the staff concludes that, while the inclusion of more recent plant data might increase the CDF 28 contribution for these two systems, it would not be expected to change the conclusions related 29 to cost-beneficial SAMAs. 30 The staff considered the peer reviews and other assessments performed for the GGNS PRA 31 and the potential impact of the review findings on the SAMA evaluation. The most relevant of 32 these are the peer review of the GGNS 1997, Revision 1 model and the staff review of the 33 GGNS 2010 EPU model as part Entergy's EPU application. 34 The 1997 (Revision

1) Level 1 and large early release frequency (LERF) model was 35 peer-reviewed before the 2002 PRA, Revision 2, using the BWR Owners Group (BWROG) 36 process. The review team used the BWROG Probabilistic Safety Assessment (PSA) Peer 37 Review Certification Implementation Guidelines, Revision 3, January 1997. Entergy stated that 38 all of the "A" priority (extremely important and necessary to address to ensure the technical 39 adequacy of the PSA) PRA peer review comments have been addressed and incorporated into 40 the GGNS PRA model, as appropriate. It also stated that all of the "B" priority (important and 41 necessary to address but may be deferred until the next PSA update) comments have been 42 addressed, except for one documentation item related to the internal flood modeling.

43 In response to a staff RAI concerning A and B priority comments addressed by internal reviews 44 in which Entergy concluded that changes to the model were not needed or the fact and 45 observation was incorrect, Entergy stated that (a) those which were considered incorrect 46 involved documentation issues that would not impact the SAMA PRA, (b) involved comments on 47 the Level 2 model, which has since been completely updated, or (c) for the other observations 48 Appendix F F-9 for which no change was considered necessary, provided a discussion of additional information 1 concerning the issues and confi rmed that the disposition remained valid at the EPU power and 2 the SAMA assessment (Entergy 2012a, 2012b). Entergy (2012b) provided clarification for 3 Observation 85 concerning the Level 1 general transient event tree. Despite a disposition 4 statement that no changes were necessary, Entergy stated that the structure of the event tree 5 was changed subsequent to the peer review, and that the changes addressed the concern 6 raised in the observation. 7 The staff review of Entergy 's EPU application is documented in a safety evaluation report (SER) 8 (NRC 2012c). In Section 2.13.1 of t he EPU SER, the technical evaluation of the EPU focused 9 on the impact on CDF and LERF while operating at EPU conditions. In its review of PRA 10 quality, the staff noted the disposition of an additional nine findings on the Level 2 model. The 11 internal flooding issue was determined to be solely a documentation issue, while eight of the 12 nine Level 2 issues were resolved in the Level 2 model used for the SAMA analysis. In 13 response to an RAI concerning the impact on the SAMA analysis, Entergy stated that vacuum 14 breaker failures and low suppression pool level were incorporated in the SAMA Level 2 model 15 and that personnel hatch seal failure was negligible when compared with hatch failure due to 16 either overpressurization or buckling (Entergy 2012a). The staff found that the Level 2 issue s 17 were acceptably addressed and concluded that failure to model vacuum breakers, low 18 suppression pool level, and personnel hatch seal would not significantly impact the delta risk 19 results for the EPU application. 20 The EPU SER states: 21 Based on its evaluation, the NRC staff concludes that the GGNS PRA models 22 used to support the risk evaluation for this application have sufficient scope, level 23 of detail, and technical adequacy to support the evaluation of the EPU. 24 The SER further states: 25 The NRC staff concludes that the licensee 's evaluation of the impact of the 26 proposed EPU on at -power risk from internal events is reasonable and concludes 27 that the base risk due to the proposed EPU is acceptable and that there are no 28 issues that rebut the presumption of adequate protection provided by the 29 licensee meeting the currently specified regulatory requirements. 30 The staff concludes that, while the EPU application is focused on delta CDF and LERF as 31 opposed to absolute values, these conclusions do lend support for the adequacy for the SAMA 32 application. 33 The staff noted that the LERF value of 1.48 x 107 per year (rounded to 1.5 x 107 per year in 34 Table F-3) given in the ER for the EPU model is different from the value of 1.04 x 107 per year 35 (rounded to 1.0 x 107 per year in Table F-2) for the H/E release category. In response to an 36 RAI, Entergy (2012d) stated that the value of 1.48 x 107 per year is from a separate Revision 3 37 EPU LERF model and the value of 1.04 x 107 per year is from the full Level 2 model. In the 38 analysis for GGNS, LERF is not a dominant contributor to the population dose risk or economic 39 cost risk. The staff concludes that the H/E release category frequency obtained from the full 40 Level 2 analysis (along with the other release category frequencies) is appropriate for use in the 41 SAMA consequence analysis. 42 In the ER, Entergy describes two internal expert panel reviews of the Revision 2 and Revision 3 43 models before their finalization. Various departments (Training, Operations, Engineering, and 44 Nuclear Safety) within the GGNS organization were invited to participate. Each of the top 100 45 cutsets was reviewed individually. In addition, cutsets from accident sequences representing 46 approximately 99 percent of the total CDF also were reviewed if there were no cutsets from 47 these sequences in the top 100. The focus of the review was to identify poor assumptions, 48 Appendix F F-10 over-simplifications, incorrect credit for human actions, sequence timing errors, system 1 modeling errors, and incorrect event probabilities. The reviews resulted in modifications to the 2 model and to the credit given for human actions. 3 In response to an RAI, Entergy briefly described the process and procedures for assuring 4 technical quality of PRA updates since the peer review. The PRA maintenance and update 5 procedure describes the process for maintaining the PRA models current with the as -built and 6 as operated plants and gives specific instructions for identifying model change requests, 7 documenting those requests, and incorporating those requests into the PRA model. The PRA 8 analysts performing model updates are experienced, trained professionals, and each change is 9 reviewed by a second, experienced, trained PRA analyst. In addition, as described above, 10 expert panel reviews are used to enhance the technical quality of the PRA updates. Changes 11 from the expert panel review for an update are immediately incorporated into that update of 12 the model (Entergy 2012a). 13 In the original SAMA submittal (Entergy 2011), Entergy took the internal events CDF to be the 14 sum of all the Level 2 release categories including the no containment failure (NCF) sequences. 15 This summation resulted in a CDF value of 2.05 x 106 per year compared to the CDF from the 16 Level 1 analysis value of 2.92 x 106 per year. In response to a staff RAI to explain this 17 difference, Entergy stated that the Level 2 results were misinterpreted because it was assumed 18 that the NCF sequences were adequately modeled and the resulting frequencies were valid. 19 From investigating the reasons for the difference, Entergy found the assumption to be invalid, 20 and it subsequently used the CDF value from the Level 1 model in a reanalysis of the SAMAs. 21 Additionally, Entergy identified and addressed a number of discrepancies in the Level 2 22 recovery rule file. Typically, Level 2 model changes would not be expected to impact the 23 Level 1 result; however, incorporated changes led to the CDF value of 2.93 x 106 per year 24 used in the revised SAMA analysis (Entergy 2012b, 2012c, 2012d). 25 Given that the GGNS internal events PRA model has been peer -reviewed and the peer review 26 findings were all addressed, that the model has been reviewed by the staff as part of the EPU 27 application approval, that Entergy has satisfactorily addressed staff questions regarding the 28 PRA, and that the misinterpretation of Level 2 results discussed above has been corrected in 29 the revised SAMA analysis, the staff concludes that the internal events Level 1 PRA model is of 30 sufficient quality to support the SAMA evaluation. 31 F.2.2.2 External Events 32 As stated above, the GGNS PRA does not include external events. The SAMA submittals cite 33 the GGNS IPEEE to assess the impact of seismic, internal events and other external events. 34 The final GGNS IPEEE was submitted in 1995 (Entergy 1995), in response to Supplement 4 of 35 GL 88-20 (NRC 1991a). Except for one potential seismic vulnerability, no fundamental 36 weaknesses or vulnerabilities to severe accident risk in regard to the external events were 37 identified in the GGNS IPEEE. In a letter dated March 16, 2001 (NRC 2001), the staff stated 38 that, on the basis of its review of the PRA and IPEEE submittal, the staff concludes that the 39 GGNS IPEEE process is capable of identifying the most likely severe accidents and severe 40 accident vulnerabilities and, therefore, the GGNS IPEEE has met the intent of Supplement 4 to 41 GL 88-20. 42 Seismic Events 43 The GGNS IPEEE seismic analysis was a reduced scope seismic margins assessment (SMA) 44 following NRC guidance (NRC 1991a, 1991b). The SMA was performed using a Safe 45 Shutdown Equipment List with plant walkdowns in accordance with the guidelines and 46 procedures in Electrical Power Research Institute (EPRI) Report NP-6041-SL (EPRI 1991). 47 Appendix F F-11 Since GGNS is a reduced scope SMA plant, the original design -basis safe shutdown 1 earthquake (SSE) ground response spectra and corresponding in -structure response spectra 2 were used as the review level earthquake (RLE) input for the walkdown and evaluation. The 3 SMA approach is deterministic in nature and does not result in probabilistic risk information. As 4 a reduced scope plant, the determination of high confidence of low probability of failure values 5 also is not required. 6 The IPEEE submittal (Entergy 1995) concludes that GGNS is seismically rugged and that all 7 components identified in the Safe Shutdown Path meet the seismic requirements. All 8 anchorage to these components was found to be rugged. One potential vulnerability to a 9 seismic event was identified, which has been corrected. The potential vulnerability involved the 10 standby service water (SSW) piping in the Control Building where the grouted condition of 11 several penetrations into the building were not accounted for in the stress analysis of the piping 12 systems. To correct the situation and to meet design requirements, the grout was removed and 13 a design change was issued to repair the penetration. The as-found grouted condition was 14 evaluated for operability considerations and was determined not to be an operability concern. In 15 addition, a number of "design enhancements " were implemented, including issuance of a new 16 standard to address seismic housekeeping problems, securing of "S" hooks on lighting fixtures, 17 installation of missing clips and screws on several items, and revision to several design -basis 18 calculations (NRC 200 1). 19 Based on the results of the IPEEE seismic assessment as described above, Entergy stated in 20 the ER that since seismic events are not dominant contributors to external event risk and 21 quantitative analysis of these events is not practical, they are assumed negligible in estimation 22 of the external events multiplier. An August 2010 NRC report, "Generic Issue 199 (GI -199), 23 Implications of Updated Probabilistic Seismic Hazard Estimates in Central and Eastern United 24 States on Existing Plants" (NRC 2010) shows a decrease in GGNS seismic CDF, using 2008 25 U.S. Geological Survey (USGS) seismic hazards curve when compared against 1994 Lawrence 26 Livermore National Lab Hazard Curves, but an increase compared to the seismic CDF based on 27 the EPRI hazard curves . Based on a simplified approach to estimate CDF from a seismic 28 margins analysis and using the latest published USGS seismic hazards information, the staff 29 estimates the GGNS seismic CDF is about 1 x 105 per year and is not negligible. In response 30 to a staff RAI (Entergy 2012a), Entergy discussed the impact of this seismic CDF on the SAMA 31 analysis. This topic is discussed further in Section F.3.2 and in the subsection on high winds, 32 floods, and other external events of this section. 33 Fire Events 34 The GGNS IPEEE fire assessment is a fire PRA that uses key assumptions and the general 35 approach specified in the EPRI Fire PRA Implementation Guide (EPRI 1994) and the 36 Fire-Induced Vulnerability Evaluation (FIVE) methodology (EPRI 1992). Additionally, the fire 37 PRA incorporates information from the GGNS Fire Hazards Analysis. 38 The overall approach involved four tasks: develop fire -induced sequences, develop fire 39 scenarios , evaluate fire damage sequences and their uncertainties, and document and verify 40 the analysis. In implementing these tasks, four levels of fire area screening were employed: 41 (1) screen fire compartments inside containment 42 (2) screen compartments with no safe shutdown o r PRA equipment 43 (3) screen assuming all equipment i n compartment fails 44 (4) credit detailed recovery 45 Fires inside containment were screened out because there are few combustible loads to ignite a 46 fire inside containment and a fire in containment would have a minor impact on the ability to 47 Appendix F F-12 safely shutdown the plant because of the limited safe shutdown equipment and cables located 1 inside containment. For the other screening steps, conditional core damage probabilities 2 (CCDPs) were determined using the IPE internal events PRA with increasing refinements 3 concerning the extent of fire damage and recovery actions and a screening CDF criteria of 4 1 x 106 per year. Thirteen fire areas not screened out after the last screening step were 5 subjected to a more detailed analysis incorporating fire modeling to support fire propagation and 6 suppression analyses, location of critical targets, definition of accident scenarios, evaluation of 7 CCDPs for the scenarios, apportioning the compartment fire frequency among the scenarios, 8 and evaluation of the probability of suppression before damage occurs. The estimated fire CDF 9 for the unscreened areas is 8.9 x 106 per reactor-year. 10 The GGNS IPEEE fire PRA was reviewed by Sandia National Laboratory (SNL). The SNL 11 review concluded that: 12 Based on the GGNS IPEEE submittal and the response to RAIs on the submittal, 13 the reviewers recommend that a sufficient level of documentation and 14 appropriate bases for analysis have been established to conclude that the 15 subject licensee submittal has met the intent of GL 88-20 (NRC 200 1). 16 While no vulnerabilities with respect to fire were identified, the IPEEE submittal identifies one 17 plant improvement related to reducing the impact of fires. The licensee stated that upgrades of 18 existing thermo-lag barriers were scheduled to be completed by the end of 1996 (Entergy 1995). 19 In a subsequent response to an IPEEE RAI, Entergy stated that the upgrades had been 20 completed (Entergy 1998). 21 The ER includes a listing of all fire areas, screened and unscreened, in Table E.1-10. The CDF 22 for the unscreened fire areas is provided below in Table F-4. In response to an RA I 23 (Entergy 2012a), Entergy confirmed that these fire zone CDFs are directly from the IPEEE and 24 are based on the IPE internal events model. Given that the current EPU internal events CDF is 25 considerably lower than that from the IPE, the staff concludes that if the EPU PRA had been 26 used to determine the CCDPs, the fire CDF would most likely be reduced. In response to a staff 27 RAI to assess recent fire research and guidance in NUREG/CR -6850 , EPRI/NRC-RES Fire 28 PRA Methodology for Nuclear Power Facilities (NRC 2005), Entergy (2012a) cited a 29 December 2010 industry assessment (NEI 2010) that concluded: 30 Based on the results and insights from industry fire PRAs, it has been identified 31 that the methods described in NUREG/CR -6850/EPRI TR -1011989 contain 32 excess conservatisms that bias the results and skew insights. While the prior 33 frequently asked question process made some incremental progress in 34 addressing areas of excessive conservatism, many more remain in need of 35 enhancement. 36 In the staff's view, it is not clear if applying the new guidance to the GGNS fire assessment 37 would result in excessive conservatism or not. The staff, however, notes the GGNS fire PRA 38 makes use of CCDPs from the IPE internal events PRA to assess the impact of a fire. Based 39 on the NRC review of existing information, the staff expects that the CCDPs using the EPU 40 model would be lower than the CCDPs from the IPE model and, thus, would result in a lower fire 41 CDF. Therefore, any increase in fire risk to using NUREG/CR -6850/EPRI TR -1011989, would 42 be at least partially offset by the expected reduction in fire risk associated with using the EPU 43 internal events models rather than the IPE models. 44 Considering that the GGNS fire PRA model has been reviewed by the staff for the IPEEE, and 45 that Entergy has addressed staff RAIs regarding the fire PRA, the staff concludes that the fire 46 PRA model, as discussed above, provides an acceptable basis for identifying and evaluating the 47 benefits of SAMAs. 48 Appendix F F-13 Table F-4. GGNS Fire IPEEE Core Damage Frequency (CDF) Results for 1 Unscreened Compartments 2 High Winds, Floods, and Other External Events 3 The GGNS IPEEE analysis of high winds, floods, and other external events followed the 4 recommendations in GL 88-20, Supplement

4. The methodology employed a screening 5 approach following the criteria of the 1975 Standard Review Plan (SRP). 6 The GGNS IPEEE submittal states that the plant's current licensing basis conforms with the 7 1975 SRP criteria for high winds, tornado loads, and tornado

-generated missiles. The submittal 8 notes that all safety -related structures and components, except the SSW system components, 9 are protected against high winds, tornado wind loads, and tornado -generated missiles. For 10 these components, a walkdown by Entergy confirmed that damage from high winds or tornado 11 wind loads are not a concern and a frequency assessment of tornado -generated missiles was 12 performed. This frequency was estimated to be 7.7 x 109 per reactor-year, an acceptably low 13 value (NRC 200 1). 14 With regard to external flooding, the IPEEE submittal states that the plant's current licensing 15 basis for flood protection meets the 1975 SRP criteria. Therefore, in accordance with the 16 guidance in NUREG -1407, Procedural and Submittal Guidance for the Individual Plant 17 Examination of External Events (IPEEE) for Severe Accident Vulnerabilities, external floods can 18 Fire Compartment Fire Compartment Description Compartment CDF (per year)

% Contribution to Unscreened Fire CDF CC502 Control Room 3.9 x 106 43 CC202 Division 1 Switchgear Room 9.4 x 107 11 CA301 Auxiliary Building Corridors.

139'-0" Elevation A422, 1A324 6.7 x 107 8 CA201 Auxiliary Building Corridors. 119'-0" Elevation 6.4 x 107 7 CC210 Division 3 (HPCS) Switchgear Room 6.1 x 107 7 CA101 Auxiliary Building Corridors. 93'-0" Elevation 5.7 x 107 7 CC215 Division 2 Switchgear Room 4.1 x 107 5 CT100 Turbine Building Floor, 93'-0" Elevation 3.2 x 107 4 CC402 Cable Spreading Room 2.8 x 107 3 CC104 Hot Machine Shop 2.4 x 107 3 CC302 HVAC Equipment Room 2.1 x 107 2 CD306 Division 3 (HPCS) Diesel Generator Room 1.7 x 107 2 CT200 Turbine Building Floor, 113'-0" Elevation 7.1 x 109 <1 Total 8.9 x 106 100 a a Column values may not total 100 percent because of rounding.

Appendix F F-14 be screened out as a significant hazard (NRC 1991b). In addition, the licensee performed 1 reevaluations of the potential flooding from the Mississippi River and the probable maximum 2 precipitation (PMP) induced flood (for site watershed). As part of their response to GL 89-22, 3 the licensee also addressed Generic Safety Issue (GSI) 103, Design for Probable Maximum 4 Precipitation, and made use of the latest rainfall data (Hydro Meteorological Reports (HMR) 5 No. 51 and 52). While the roof drains and overflows were found adequate, GGNS implemented 6 several improvements including: increase d maintenance on drainage structures, revised 7 procedures to explicitly include at -grade former Unit 2 doors, and revised procedures to 8 periodically inspect roof drains and overflows to ensure they are not blocked. In addition, 9 consideration of the new PMP led to the identification of five further improvements in local 10 drainage and flood prevention provisions. These improvements were not implemented at the 11 time of the IPEEE and, while listed in Table E.2-1 of the ER, are stated to not be cost beneficial 12 due to the minor risk from external flooding. The response to a staff RAI to provide further 13 support for this disposition is discussed below in Section F.3.2. 14 A review of transportation and nearby facility accidents confirmed that there were no severe 15 accident vulnerabilities from these accidents. The licensee found that the plant 's current 16 licensing basis for these events meets the 1975 SRP criteria. 17 As stated in the ER (Entergy 2011), a multiplier of 11 was used to adjust the internal event risk 18 benefit associated with a SAMA to account for external events. This multiplier was based on a 19 fire CDF equal to the sum of the screened and unscreened fire zone CDF values or 20 approximately 2.74 x 105 per year and the assumption that seismic and other external events 21 are negligible. Using the original Level 1 internal event CDF of 2.92 x 106 per year the ratio of 22 external to internal event CDFs is 9.4, which leads to a multiplier of 10.4 which was rounded up 23 to 11. In response to an RAI concerning the impact of the GI -199 (NRC 2010) estimated 24 seismic CDF, Entergy states that use of the GI -199 estimate of approximately 1 x 105 per year 25 along with the IPEEE fire CDF for unscreened fire zones of 8.9 x 106 per year results in an 26 external events multiplier of 7 using the 2.93 x 106 per year internal event CDF and the 27 continued use of the multiplier of 11 more than compensates for the impact of the seismic CDF 28 (Entergy 2012c). The staff agrees that the use of the unscreened fire CDF is valid and that the 29 use of the multiplier of 11 appropriately incorporates the impact of seismic risk. 30 Given that the GGNS IPEEE external events assessments has been reviewed by the staff, and 31 that Entergy has satisfactorily addressed staff questions regarding the assessment, the staff 32 concludes that the external events assessments, combined with the results of the analysis of 33 the impacts of new fire and seismic information, is of sufficient quality to support the SAMA 34 evaluation. 35 F.2.2.3 Level 2 Fission Product Release Analysis 36 The staff reviewed the general process used by Entergy to translate the results of the Level 1 37 PRA into containment releases, as well as the results of the Level 2 analysis, as described in 38 the ER and in responses to staff RAIs (Entergy 2012a, 2012b, 2012c). Plant damage states 39 (PDSs) provide the link between the Level 1 and Level 2 CET analyses. In the PDS analyses, 40 Level 1 results are grouped together according to characteristics that define the status of the 41 reactor, containment, core cooling and heat removal systems at the time of core damage. The 42 PDSs identify which CET the Level 1 results are to be transferred. The information specifically 43 transferred through the PDSs and the direct linking of the Level 1 model with the Level 2 model 44 is: 45 Equipment failures in Level 1. The repair or recovery of failed equipment is 46 not allowed unless an explicit evaluation has been performed as part of the 47 Level 2 analysis. 48 Appendix F F-15 Reactor pressure vessel (RPV) status. The RPV pressure condition is 1 explicitly transferred from the Level 1 analysis to the CET. 2 Containment status. The containment status is explicitly transferred from the 3 Level 1 analysis to the CET. 4 Differences in accident sequence timing are transferred with the Level 1 5 sequences. Timing affects such sequences as: station blackout, internal 6 flooding, and containment bypass (interfacing systems LOCA). 7 The Level 2 analysis is linked to the Level 1 model by extending the model to include the CET, 8 which characterizes the accident phenomena. The CET considers the influence of physical and 9 chemical processes on the integrity of the containment and on the release of fission products. 10 The ER lists and describes 15 functional nodes incorporated in the GGNS Level 2 CETs. These 11 nodes (or branches or questions) address events occurring before vessel breach (including post 12 core damage depressurization and the potential for in -vessel recovery), the phenomena 13 associated ex -vessel accident progression (including early drywell and containment failure 14 caused by hydrogen ignition, high pressure melt ejection, steam explosions, and vapor 15 suppression failure) and the impact of mitigating systems on containment integrity including 16 containment sprays, containment heat removal, and containment venting. 17 The CET end points represent the outcomes of possible containment accident progression 18 sequences with each end point representing a complete sequence from initiator to release to 19 the environment. Associated with each CET end point or end state is an atmospheric 20 radionuclide source term including the timing, magnitude, and other conditions associated with 21 the release. Because of the large number of CET end points, they are grouped into release 22 categories (RCs). Entergy has established 13 RCs based on magnitude of release (four levels) 23 and timing of containment failure relative to the time of the declaration of a general emergency 24 (three time groups) with one RC for NCF. In response to a staff RAI, Entergy states that the 25 CET end points were assigned to the appropriate RC based on consideration of several 26 fundamental variables, including Level 1 accident sequence, initial containment failure mode, 27 RPV pressure at RPV breach, water availability for containment spray or flooding, and auxiliary 28 building effectiveness (Entergy 2012a). As previously stated for the updated analysis, the 29 frequency of the NCF release category was determined from the difference between the Level 1 30 CDF and the sum of frequencies for the other release categories (Entergy 2012c). 31 In developing the response to the staff RAI concerning the difference between the Level 1 and 32 Level 2 results, Entergy discovered and corrected a number of discrepancies in the Level 2 33 analysis. Despite having a relatively minor impact on the release category frequencies, these 34 corrections were described and incorporated in the updated analysis (Entergy 2012c, 2012d). 35 The release characteristic for each RC was determined from the results of MAAP 4.0.6 36 calculations for representative sequences selected for the RC. In response to staff RAIs 37 concerning the selection of representative sequences and the resulting release magnitude and 38 timings, Entergy identified the representative sequence for each RC and described the basis for 39 the selection. The predominant accident class (based on frequency) that contributes to each of 40 the radionuclide release categories was first identified. Once the accident class was identified, 41 the timings and magnitudes of the releases from the results of the various Level 2 MAAP runs 42 for that accident class were reviewed to select an appropriate sequence to represent the 43 release category (Entergy 2012a). 44 In response to a staff RAI to justify the representative sequence as the sequence with the 45 highest frequency versus selecting a sequence with a higher source term and a lower but still 46 important frequency, Entergy, in its updated analysis, revised the Level 3 consequence analysis 47 Appendix F F-16 to use the sequence with the highest source term (in terms of cesium iodide release fraction) to 1 represent each release category (Entergy 2012b, 2012c). 2 In the original ER Figure E.1-1, the NCF or negligible release category accounted for 44 percent 3 of the total release frequency, yet the offsite consequences from this release category were not 4 provided. In response to a staff RAI, Entergy revised the consequence analysis to incorporate 5 releases appropriate for the no -containment -failure category (Entergy 2012c). 6 As stated above, the current GGNS Level 2 PRA model is a complete revision of that used in 7 the IPE. No vulnerabilities were identified in the IPE back -end (i.e., Level 2) analysis performed 8 by the applicant. Risk related insights and improvements discussed in the IPE submittal were 9 discussed previously. The staff and contractor review of the IPE Level 2 analysis concluded 10 that the applicant has made reasonable use of the PRA techniques in performing the back -end 11 analysis and that the techniques employed are capable of identifying severe accident 12 vulnerabilities (NRC 1996). 13 In response to a staff RAI regarding the steps taken to assure the technical adequacy of the 14 new Level 2 model, Entergy stated that: 15 The developing contractor performed a self assessment of the Level 2 model 16 against the American Society of Mechanical Engineering (ASME)/American 17 Nuclear Society (ANS) PRA Standard implemented in accordance with 18 Regulatory Guide 1.200 (NRC 2009). 19 A technical acceptance review was performed by Entergy, with comments 20 resolved by the contractor. 21 An expert panel review of the Level 2 cutsets was performed as further 22 assurance of the quality of the Level 2 PRA. The expert panel consisted of 23 members of the Grand Gulf engineering, PRA, and operations departments. 24 From its review of the Level 2 methodology, Entergy's responses to staff RAIs, and the 25 subjection of the Level 2 model to an internal self -assessment and expert panel review, the staff 26 concludes that the Level 2 PRA, as used in the revised SAMA analysis, provides an acceptable 27 basis for evaluating the benefits associated with various SAMAs. 28 F.2.2.4 Level 3 Consequence Analysis 29 Entergy used the MACCS2 Version 1.13.1 code and a core inventory from a plant-specific 30 calculation to determine the offsite consequences from potential releases of radioactive material 31 (Entergy 2011). Using the ORIGEN 2.1 code, Entergy calculated the core inventory for 32 4 ,408 MWt, which is consistent with the EPU to 115 percent of the originally licensed 33 thermal power that was approved in July 2012. 34 The staff reviewed the process used by Entergy to extend the containment performance 35 (Level 2) portion of the PRA to an assessment of offsite consequences (Level 3 PRA model). 36 Source terms used to characterize fission product releases for the applicable containment 37 release categories and the major input assumptions used in the offsite consequence analyses 38 were considered. In response to a staff RAI on radionuclides from the core inventory used in 39 the radiological dose calculation, the applicant confirmed that all radionuclides listed in 40 Table E.1-12 of Attachment E to the ER (Entergy 2011) were included in the Level 3 analysis 41 (Entergy 2012a). Entergy clarified that consideration was given to the 24 -month refueling cycles 42 in the core radionuclide inventory determination and confirmed that no additional changes are 43 planned or being considered that would affect the core radionuclide inventory (Entergy 2012a). 44 Plant-specific input to the assessment includes the core release fractions and source terms for 45 each release category (Entergy 2011, Table E.1-9), site-specific meteorological data, projected 46 Appendix F F-17 population distribution and expected growth out to the year 2044 within an 80 -km (50-mi) radius, 1 emergency evacuation modeling, and economic data. This information is provided in 2 Section E.1.5 of Attachment E to the ER (Entergy 2011). Because the staff review determined 3 Entergy's source term information is consistent with NRC guidance (NEI 2005) and includes 4 satisfactory responses to NRC questions, the staff concludes that Entergy's source term 5 estimates are acceptable for use in the SAMA analysis. 6 Entergy considered site -specific meteorological data for the calendar years 2005 through 2009 7 and selected meteorological data from 2009 for the analysis as input to the MACCS2 code 8 because they resulted in the highest release quantities (Entergy 2011). Meteorological data 9 was acquired from the meteorological monitoring system at GGNS and regional National 10 Weather Service stations. Meteorological data included wind speed, wind direction, 11 atmospheric stability class, precipitation, and atmospheric mixing heights. In response to an 12 NRC RAI on the source of precipitation data, modeling of precipitation events, and precipitation 13 influence on calculated doses, Entergy stated that the total population dose and offsite 14 economic cost were calculated in determining the meteorological dataset for use in the SAMA 15 analysis (Entergy 2012a). 16 Missing meteorological data were estimated by data substitution using valid data from the 17 previous hour and other elevations on the meteorological tower. In response to questions on 18 the amount of missing data, Entergy clarified that 1 hour of precipitation data and 95 hours of 19 lower wind data were missing in the 8,760 -hour data set for 2009. When missing temperature 20 data were included, data substitution for missing data was applied to less than 3 percent of the 21 meteorological records (Entergy 2012a). The sources of data and models for atmospheric 22 dispersion used by the applicant are consistent with standard industry practice and acceptable 23 for calculating consequences from potential airborne releases of radioactive material. Because 24 multiple years of meteorological data were considered by the applicant and the annual data set 25 that resulted in the largest total population dose and offsite economic cost was selected for the 26 SAMA analysis, the staff finds that the data selection was performed in accordance with NRC 27 guidance (NEI 2005) and, thus, the meteorological data are appropriate for use in the SAMA 28 analysis. 29 Entergy projected population distribution and expected growth within a radius of 80 km (50 mi) 30 out to the year 2044 to account for an anticipated 33 -year period of remaining plant life for 31 13 years remaining on the original operating license plus a 20 -year license renewal period 32 (Entergy 2011). For counties or parishes with declining population projections, census data 33 from earlier years were used to avoid underestimating future population and estimated 34 population doses. The Entergy assessment incorporated U.S. Census 2010 data 35 (Enercon 2011). Entergy also used data on Louisiana and Mississippi state tourism to calculate 36 a transient to permanent population ratio to increase the projected population to account for 37 visitors (Entergy 2011). The applicant provided additional information on the incorporation of 38 transient population into the SAMA analysis (Entergy 2012a). Transient population was 39 determined from annual visitor numbers for the state and an average stay duration. The ratio of 40 transient additions to the permanent population was assumed to be the same for each county or 41 parish in the state. The staff considers the methods and assumptions for estimating population 42 reasonable and acceptable for purposes of the SAMA evaluation because its review of 43 Entergy's assessment determined that Entergy considered appropriate data sources, used a 44 reasonable approach for applying data, followed NRC guidance (NEI 2005), and added 45 conservatism by not accounting for projected population decline. 46 Entergy analyzed evacuation travel times for the Mississippi and Louisiana sides of the 47 Mississippi River within the 16-km (10-mi) emergency planning zone (Entergy 2011). The 48 analysis stated that 100 percent of the population would be prepared to begin evacuation within 49 Appendix F F-18 195 minutes from emergency notification for evacuation and 100 percent of the population could 1 be evacuated in 250 minutes or less following an evacuation order. The applicant concluded 2 that use of this information is still relevant because population within the emergency planning 3 zone has declined since the analysis in 2006. Entergy performed sensitivity analyses on 4 MACCS2 input parameters for an increased evacuation time delay and for a slower evacuation 5 speed. Consequence deviations were found to be less than 1 percent (Entergy 2011). 6 The staff notes that the percentage of population evacuated within the emergency planning 7 zone used by Entergy in the SAMA analysis exceeded the generic value of 99.5 percent 8 (NRC 1997 a, Section 5.7.1). However, the staff finds the applicant's value to be acceptable 9 because, based on the staff's review of the applicant's analysis, the staff determined that the 10 value was derived from a recent site -specific analysis that adequately considered the spatial 11 distribution of individuals in the two counties and one parish included within the emergency 12 planning zone, accounted for response differences due to the time of the week when the 13 evacuation order could be given, and addressed the influence of potential inclement weather 14 conditions. Given that the applicant performed a site -specific analysis to determine evacuation 15 assumptions and parameters, showed radiological consequence results were insensitive to 16 changes to certain evacuation parameters in a sensitivity study, and furnished a rationale for the 17 current appropriateness of the previously collected site -specific data, the staff concludes that 18 the evacuation assumptions and analysis are reasonable and acceptable for the purposes of the 19 SAMA analysis at GGNS. 20 Entergy used regional economic data from the 2007 U.S. Census of Agriculture, the 21 U.S. Department of Commerce, the U.S. Bureau of Labor Statistics, and the Consumer Price 22 Index for estimating farm and nonfarm values. County representation within a spatial element 23 was based on the county with the greatest area contribution. Data for certain counties and 24 parishes were not incorporated into the analysis because of small area contributions within a 25 spatial element. Regional crop values, obtained from 2007 U.S. Census of Agriculture data, 26 were summed with the 80 -km (50-mi) area and applied to the MACCS2 crop categories. 27 The staff considers these data sources used by the applicant to be current and finds them 28 acceptable for the SAMA analysis. Entergy estimated present dollar values based on the 29 internal events PRA at GGNS. Onsite economic costs provided the greatest contribution, about 30 70 percent of the total dollar value. Offsite economic costs contributed about 16 percent to the 31 total dollar value (Entergy 2012c, Table 4.21-1) for a discount rate of 7 percent, 20 -year license 32 renewal period, and updated CDF of 2.9 x 106 per year. Offsite population doses and onsite 33 doses contributed 13 and 1 percent of the total dollar value, respectively. Section F.6 provides 34 more detailed information on the cost -benefit calculation and its evaluation. 35 In summary, the staff reviewed Entergy's assessments of the source term, radionuclide 36 releases, meteorological data , projected population distribution, emergency response, and 37 regional economic data and evaluated Entergy's responses to the staff's requests for additional 38 information, as previously described in this subsection. Based on the staff's review, the staff 39 concludes that Entergy's consequence analysis is acceptable and Entergy's methodology to 40 estimate offsite consequences for GGNS and consideration of parameter sensitivities provide 41 an acceptable basis to assess the risk reduction potential for candidate SAMAs. Accordingly, 42 the staff based its assessment of offsite risk on the CDFs, population doses, and offsite 43 economic costs reported by Entergy. 44 F.3 Potential Plant Improvements 45 The process for identifying potential plant improvements (SAMAs), an evaluation of that 46 process, and the improvements evaluated in detail by Entergy are discussed in this section. 47 Appendix F F-19 F.3.1 Process for Identifying Potential Plant Improvements 1 Entergy's process for identifying potential plant improvements consisted of the following 2 elements: 3 review of industry documents and consideration of other plant-specific 4 enhancements not identified in published industry documents, 5 review of potential plant improvements identified in the GGNS IPE and 6 IPEEE, and 7 review of the risk -significant events in the current GGNS PRA Levels 1 and 2 8 models modifications for inclusion in the comprehensive list of SAMA 9 candidates. 10 Based on this process, Entergy identified an initial set of 249 candidate SAMAs, referred to as 11 Phase I SAMAs. In Phase I of the evaluation, Entergy performed a qualitative screening of the 12 initial list of SAMAs and eliminated SAMAs from further consideration using the following 13 criteria: 14 the SAMA modified features not applicable to GGNS, 15 the SAMA has already been implemented at GGNS, or 16 the SAMA is similar in nature and could be combined with another SAMA 17 candidate. 18 Based on this screening, 60 of the Phase I SAMA candidates were screened out because they 19 were not applicable to GGNS, 98 were screened out because they had already been 20 implemented at GGNS, and 28 were screened out because they were similar in nature and 21 could be combined with another SAMA candidate. Thus, a total of 186 SAMAs were eliminated, 22 leaving 63 for further evaluation. The results of the Phase I screening analysis for each SAMA 23 candidate were provided in a response to a staff RAI (Entergy 2012 a). The remaining SAMAs, 24 referred to as Phase II SAMAs, are listed in Table E.2-2 of Attachment E to the ER in the 25 original submittal (Entergy 2011) and in the revised analysis (Entergy 2012c). In Phase II, a 26 detailed evaluation was performed for each of the 63 remaining SAMA candidates, as discussed 27 in Sections F.4 and F.6 below. 28 F.3.2 Review of Entergy's Process 29 Entergy's efforts to identify potential SAMAs included explicit consideration of potential SAMAs 30 primarily for internal events because the current GGNS PRA does not include external events. 31 Potential SAMAs for external events were included based on the GGNS IPEEE probabilistic 32 analysis of internal fires and deterministic analysis of seismic and other external events. 33 The initial SAMA list was developed primarily from the review of generic industry SAMAs 34 (NEI 2005), as well as SAMAs from nine previous BWR license renewal applications. To this 35 list, a number of SAMAs were added based on improvements identified in the IPE and IPEEE. 36 Finally, SAMAs were added based on the review of the GGNS PRA Level 1 and Level 2 37 LERF results. 38 Entergy provided a tabular listing of the Level 1 PRA basic event CDF importances, down to a 39 risk reduction worth (RRW) of 1.005. SAMAs affecting these basic events would have the 40 greatest potential for reducing risk. An RRW of 1.005 corresponds to a reduction in CDF of 41 approximately 0.5 percent, given 100 percent reliability of the SAMA. Based on the maximum 42 averted cost risk including external events and uncertainty (see Section F.6.1 below), this 43 Appendix F F-20 equates to a benefit of approximately $17,000. This is well below the minimum implementation 1 cost associated with a procedure change given by Entergy of $25,000 (refer to Section F.5) and 2 is not cost beneficial. All basic events in the Level 1 listing were reviewed to identify potential 3 SAMAs and the listing annotated to indicate the Phase II SAMAs mitigating the failure 4 associated with the basic event. All basic events, except flag events, which do not represent 5 failures, were addressed by one or more Phase II SAMAs either from the list based on the 6 generic industry SAMAs or GGNS specific SAMAs (Entergy 2011). 7 Entergy also provided and reviewed the basic events with large early release frequency RRWs 8 down to 1.005. All basic events in the Level 2 LERF (or release category H/E) listing were 9 reviewed to identify potential SAMAs and all were addressed by one or more Phase II SAMAs, 10 except those that are flag or split fractions for which no SAMA would be appropriate 11 (Entergy 2011). The staff notes that because LERF makes up only about 10 percent of the CDF 12 and cost risk, LERF basic events with RRW less than about 1.1 would not be expected to be 13 cost beneficial unless they are also important to CDF. 14 As a result of the review of the Level 1 and Level 2 LERF basic events, four additional SAMAs 15 were identified as most of the basic events were addressed by SAMAs in the generic list. 16 Entergy also considered the potential plant improvements described in the GGNS IPE and 17 IPEEE in the identification of plant -specific candidate SAMAs. As a result of the review of the 18 IPE, 11 improvements were identified and are listed in Table E.2-1 of Attachment E of the ER. 19 The ER stated that five of these improvements have been implemented, one considered no 20 longer applicable and five retained as potential SAMAs. 21 As a result of the IPEEE, eight potential improvements concerning external flooding were 22 identified and are listed in Table E.2-1 of Attachment E of the ER. The ER stated that three of 23 these improvements have been implemented, but five are stated to not be cost beneficial 24 because of the minor risk from external flooding. They are: 25 Remove the wooden foot bridge crossing the northwest ditch near its 26 upstream end. 27 Remove the 38-cm (15-inch) corrugated metal pipe located in the small 28 auxiliary ditch parallel to the northwest ditch. 29 Re-hang the security fence gates west of the control building. 30 Grade down and remove the access road, the raised berm parallel to the 31 access road, and curbs adjacent to the access road. 32 Replace the C8 x 1.5 channel forming the flood barrier across the SSW A 33 equipment hatch opening. 34 In response to a staff RAI to provide further support for this disposition, Entergy stated that site 35 topography has changed considerably since the time of the IPEEE, and it addressed the current 36 status of the items listed above. All were either no longer applicable or otherwise adequately 37 addressed. Although the channel identified in the last bullet has not been replaced, Entergy 38 described features of the interior of the pump house, which minimize the impact of flooding, and 39 it stated that contingency actions are available to place sand bags in front of the doors 40 (Entergy 2012b). 41 In addition, Entergy stated it had re-evaluated the site during the 2011 Mississippi River fl ood 42 and determined it to be adequately protected against external flooding. The NRC resident and 43 region inspectors performed a review of the flooding procedures and site actions for seasonal 44 extreme flooding of the Mississippi River. Additionally, the inspectors performed an inspection 45 Appendix F F-21 of the protected area to identify any modifications to the site that would inhibit site drainage or 1 that would allow ingress past a barrier during a probable maximum precipitation event. No 2 recommendations for improved flo od protection were identified. Further, Entergy provided an 3 estimate of $2 , 300 in the original response (Entergy 2012a) and $2 ,200 in the revised analysis 4 (Entergy 2012c) for the benefit associated with the above probable maximum pr ecipitation 5 flooding modifications assuming they would eliminate the potential for core damage. This was 6 based on the IPEEE -assessed frequency of the probable maximum participation with coincident 7 wind wave activity. Based on the disposition of the cited improvements, the results of the recent 8 inspection and the low benefit associated with the modifications, the staff agrees with the 9 Entergy treatment of external flooding for the SAMA analysis. 10 Entergy also considered SAMAs for the two largest fire risk contributors based on the IPEEE 11 evaluation whose results are summarized in Table F-4. 12 The staff review of the Phase I SAMA screening identified a number of questions concerning the 13 adequacy of the basis for not considering the SAMA in the Phase II analysis. In response to an 14 RAI, Entergy (Entergy 2012b, 2012c, 2012d) stated that: 15 The Division 3 direct current (DC) system used for the HPCS is independent 16 of the other DC buses; hence, a SAMA to reduce the DC dependence 17 between high -pressure injection and the automatic depressurization system 18 has essentially been implemented at GGNS. 19 GGNS does not have another security or other emergency generator beyond 20 the three now installed that could be used for providing DC power through 21 direct connections to necessary loads following a station blackout. Therefore, 22 providing a procedure for this connection is not feasible. Also, for 23 nonstation -blackout situations, the benefit is less than the potential cost. 24 GGNS SAMA No. 6, improve 4.16 -kV bus cross-tie ability, already includes 25 installing key-locked control switches to enable alternating current bus 26 cross-ties; hence, a separate, new SAMA is not necessary. 27 The benefit of a SAMA to provide capability for alternate injection via the 28 react or water cleanup system was evaluated and found to be less than the 29 associated cost. Extensive modifications would be required to use the 30 reactor water cleanup system for alternate injection. Piping modifications and 31 a source of water would be needed because the only existing reactor water 32 cleanup suction source is the reactor pressure vessel itself. Key-locked 33 switches would have to be installed to permit bypassing existing reactor water 34 cleanup interlocks to permit use for injection. Also, the system has power 35 dependencies with the other alternate injection systems which would have to 36 be modified to obtain a significant benefit. 37 The severe accident guidelines implemented at GGNS included 38 considerations of flooding the reactor pressure vessel and/or containment to 39 various levels relative to the core and/or core debris and the impact on the 40 need for containment venting. No further restrictions are deemed 41 appropriate. 42 Simulator training at GGNS includes training on severe accident scenarios. 43 The staff review of the identification of SAMAs from the Level 1 and Level 2 importance analysis 44 identified several basic events for which the associated SAMA required further explanation or 45 justification. For several human error basic events with high failure probabilities, Entergy was 46 Appendix F F-22 asked to consider improvements in procedures or training. In response, Entergy described 1 each of the events as being combined with other human error basic events in the recovery rule 2 application process so that the combined failure rate was lower and supported by procedures 3 and training already in place. For several significant valve failures for high-pressure injection 4 systems, Entergy was asked to consider the potential for lower cost alternatives than the 5 SAMAs originally considered. In response, Entergy described the valves and stated that review 6 of generic SAMAs did not identify any feasible lower cost alternative. The potential for manually 7 opening the HPCS minimum flow isolation valve was considered and determined not to be 8 feasible in the time available (Entergy 2012a, 2012b). 9 As stated above, the GGNS IPEEE used a seismic margins assessment, which neither provided 10 quantitative risk information nor deterministic seismic capacities for specific GGNS systems, 11 structures, or components. It is thus not possible to identify and evaluate GGNS-specific 12 SAMAs to mitigate seismic risk. Based on the conclusions of the IPEEE seismic assessment 13 "-that Grand Gulf Nuclear Station is seismically rugged and that all components identified in 14 the Safe Shutdown Path have adequately considered the seismic input. All anchorage to these 15 components was found to be rugged ," the low GGNS internal events CDF, and the staff 16 observation that SAMAs to mitigate the impact of seismic events are expected to be relatively 17 costly and therefore are not likely to be cost beneficial, the staff concludes that the exclusion of 18 seismic-specific SAMAs from the evaluation is acceptable. 19 On the basis of its review of the foregoing information, the staff concludes that the set of SAMAs 20 evaluated in the ER, together with those identified in response to staff RAIs, addresses the 21 major contributors to both internal and external event CDF. 22 The staff questioned the applicant about additional potentially lower cost alternatives to some of 23 the SAMAs evaluated (NRC 2012a), including: 24 Revise procedures for operators to manually initiate emergency diesel 25 generator (EDG) heating, ventilation, and HVAC if the existing automatic logic 26 fails and/or procedures for the plant auxiliary operators to check on any 27 automatic start of the EDG could allow HVAC failures to be discovered and 28 might eliminate the need for alarms. 29 Provide directions to use jumpers to bypass the low reactor pressure interlock 30 instead of installing a bypass switch to allow operators to bypass interlock 31 circuitry. 32 Consider using other air compressors (service air) that might be connected to 33 the instrument air system instead of providing new compressors. 34 Consider improving control room fire -detection system response for a limited 35 number of key cabinets. 36 In response to the RAIs, the applicant addressed the suggested lower cost alternatives 37 (Entergy 2012a), which are discussed further in Section F.6.2. 38 The staff notes that the set of SAMAs submitted is not all -inclusive because additional, possibly 39 even less expensive, design alternatives can always be proposed. However, the staff 40 concludes that the benefits of any additional modifications are unlikely to exceed the benefits of 41 the modifications evaluated and that the alternative improvements likely would not cost less 42 than the least expensive alternatives evaluated, when the subsidiary costs associated with 43 maintenance, procedures, and training are considered. 44 The staff concludes that Entergy used a systematic and comprehensive process for identifying 45 potential plant improvements for GGNS, and that the set of SAMAs evaluated in the ER, 46 Appendix F F-23 together with those evaluated in response to staff inquiries, is reasonably comprehensive and, 1 therefore, acceptable. This search included reviewing insights from the GGNS plant-specific 2 risk studies that included internal initiating events as well as fire, seismic and other externa l 3 initiated events, and reviewing plant improvements considered in previous SAMA analyses. 4 F.4 Risk Reduction Potential of Plant Improvements 5 In the ER, the applicant evaluated the risk -reduction potential of the 63 SAMAs that were not 6 screened out in the Phase I analysis and retained for the Phase II evaluation. The SAMA 7 evaluations were performed using generally conservative assumptions. 8 Except for two SAMAs associated with internal fires, Entergy used model re -quantification to 9 determine the potential benefits for each SAMA. The CDF, population dose, and offsite 10 economic cost reductions were estimated using the GGNS 2010 EPU PRA model for the 11 non-fire SAMAs. The changes made to the model to quantify the impact of SAMAs are detailed 12 in Section E.2.3 of Attachment E to the ER (Entergy 2011). Bounding evaluations (or analysis 13 cases) were performed to address specific SAMA candidates or groups of similar SAMA 14 candidates. For the two fire -related SAMAs (SAMA Nos. 54 and 55), the benefit was 15 determined by assuming the CDF contribution for the fire area impacted by the SAMA was 16 reduced to zero and that the resulting benefit was determined by the product of the fraction of 17 the internal events total CDF represented by the fire area CDF and the maximum total internal 18 events benefit. 19 Table F-5 lists the assumptions considered to estimate the risk reduction for each of the 20 evaluated SAMAs, the estimated risk reduction in terms of percent reduction in CDF, population 21 dose risk and offsite economic cost risk, and the estimated total benefit (present value) of the 22 averted risk. The estimated benefits reported in Table F-5 reflect the combined benefit in both 23 internal and external events. The determination of the benefits for the various SAMAs is further 24 discussed in Section F.6. 25 Phase II evaluation, Cases 6 and 10, were used to evaluate SAMA No. 7 (install an additional, 26 buried offsite power source) and SAMA No. 18 (protect transformers from fire), respectively. 27 Entergy stated that for these cases, loss of offsite power (LOSP) initiating event frequencies 28 were multiplied by the ratios of 19/24 and 9/24 to account for severe weather and plant -centered 29 causes of LOSP, respectively. In response to a staff RAI concerning the source of these 30 values, Entergy stated that of the 24 LOSP events applicable to GGNS, 5 were weather -related, 31 15 were plant- or switchyard -related, and 4 were grid -related (Entergy 2012a). The ratio 19/24 32 then represents the fraction of LOSP frequency if severe weather causes are eliminated. 33 The ratio 9/24 then represents the fraction of LOSP frequency if the plant -centered causes 34 are eliminated. The staff concludes that this approach is valid for the assessment of 35 these SAMAs. 36 Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk 1 Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk 2 (OECR) 3 Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

% Risk Reduction Internal and External Benefit Internal and External Benefit with Uncertainty CDF PDR OECR Case 1. Direct Current Power Assumption:  Eliminates all cutsets for station blackout (Analysis Case for SAMA Nos. 1, 2, 11, 12, & 15) 1-Provide additional direct current battery capacity
$2,131,000 2-Replace lead

-acid batteries with fuel cells

$4,080,000 11-Portable generator for direct current power:  This SAMA involves the use of a portable generator to supply direct current power to the battery chargers during a station blackout.
$1,278,000 12-Portable generator for direct current power:  This SAMA involves the use of a portable generator to supply direct current power to the individual panels during a station blackout.
$1,278,000 15-Use direct current generators to provide power to operate the switchyard power control breakers while a 480

-V alternating current generator could supply the air compressors for breaker support

$1,428,000 37.1% 27.3% 21.3% $374,000 $1,121,000 Case 2. Improve Charger Reliability Assumption:  Failure of chargers contribution at zero (Analysis Case for SAMA Nos. 3 & 13) 3-Add battery charger to existing direct current system
$90,000  13-Proceduralize battery charger high

-voltage shutdown circuit inhibit $50,000 0.7% 2.0% 2.1% $1 2 , 100 $36 , 200 Case 3. Add Direct Current System Cross -Ties Assumption: Eliminates failure of direct current power gates (Analysis Case for SAMA No. 4) 4-Provide direct current bus cross -ties $300,000 3.6% 8.4% 9.0% $57,000 $171 ,000 F-24 Appendix F

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued) Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

% Risk Reduction CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 4. Increase Availability of Onsite Alternating Current Power Assumption:  Eliminates failure of diesel generators 11, 12, and 13 to their alternating current buses (Analysis Case for SAMA Nos. 5 & 8) 5-Provide an additional diesel generator
$20,000,000 8-Install a gas turbine generator with tornado protection
$2,000,000 42.1% 31.4% 25.6% $427 ,000 $1,282 ,000 Case 5. Improve Alternating Current Power Assumption:  Eliminates the loss of the most important 4.16-kV bus (Analysis Case for SAMA Nos. 6 & 17) 6-Improve 4.16

-kV bus cross-tie ability

$656,000  17-Provide alternate feeds to essential loads directly from an alternate emergency bus
$656,000  7.5% 29.5% 23.5% $145,000 $434,000 Case 6. Reduce Loss of Offsite Power During Severe Weather Assumption:  Eliminates the weather centered loss of offsite power initiating event (Analysis Case for SAMA No. 7) 7-Install an additional, buried offsite power source
$2,485,000 8.4% 6.0% 4.8% $84,200 $253,000 Case 7. Provide Backup Emergency Diesel Generator Cooling Assumption:  Eliminates failure of service water cooling to the emergency diesel generators (Analysis Case for SAMA Nos. 9 & 10) 9-Use fire water system as backup source for diesel cooling
$1,344,000 10-Add new backup source of diesel cooling
$2,000,000 7.6% 6.4% 4.6% $77,800 $234 ,000 Case 8. Increase Emergency Diesel Generator Reliability Assumption:  Eliminates failure of emergency diesel generators to run (Analysis Case for SAMA No. 14) 14-Provide a portable emergency diesel generator fuel oil transfer pump
$1,477,000 4.0% 4.3% 4.0% $45,500 $137 ,0 00   Appendix F F-25 Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued)

Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

 % Risk Reduction CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 9. Improve Diesel Generator Reliability Assumption:  Eliminates the common cause failure contribution of failure to start emergency diesel generators (Analysis Case for SAMA No. 16) 16-Provide a diverse swing diesel generator air start compressor
$100,000  0.8% 0.6% 0.4% $7, 8 50 $23 , 600 Case 10. Reduce Plant

-Centered Loss of Offsite Power Assumption: Removes contribution of plant- and switchyard -centered events (Analysis Case for SAMA No. 18) 18-Protect transformers from failure

$780,000  25.0% 17.6% 13.9% $250 ,000 $749,000 Case 11. Redundant Power to Torus Hard Pipe Vent Valves Assumption:  Eliminates failure of power to containment vents (Analysis Case for SAMA No. 19) 19-Provide redundant power to direct torus hard pipe vent valves to improve the reliability of the direct torus vent valves and enhance the containment heat removal capability.
$714,000  <0.1% 5.4% 6.0% $1 8 , 600 $55 , 700 Case 12. High Pressure Injection System Assumption:  Eliminates failure of the high pressure core spray (Analysis Case for SAMA Nos. 20 & 61) 20-Install an independent active or passive high

-pressure injection system

$8,800,000 61-Install a backup water supply and pumping capability that is independent of normal and emergency alternating current power $6,410,000 53.7% 6 2.2% 58.0% $622,000 $1,867,000   F-26 Appendix F

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued) Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

 % Risk Reduction CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 13. Extend Reactor Core Isolation Cooling Operation Assumption:  Eliminates failure of trip due to pressure (Analysis Case for SAMA No. 21) 21-Raise backpressure trip set points for high

-pressure coolant injection/reactor core isolation cooling [High -pressure coolant injection backpressure trip set point has already been raised. This SAMA evaluates raising the reactor core isolation cooling backpressure trip set point.]

$200,000  <0.1% <0.1% <0.1% <$1 <$1 Case 14. Improve Automatic Depressurization System Assumption:  Eliminates failure of automatic depressurization system valves (Analysis Case for SAMA No. 22) 22-Modify automatic depressurization system components to improve reliability [This SAMA will add larger accumulators thus increasing reliability during station blackouts].
$1,177,000 33.6% 12.7% 13.1% $310 ,000 $930 ,000 Case 15. Improve Automatic Depressurization System Signals Assumption:  Eliminates failure of the safety relief valve failing to open (Analysis Case for SAMA No. 23) 23-Add signals to open safety relief valves automatically in a main steam isolation valve closure transient.
$1,500,000 6.0% 4.5% 4.2% $61 , 900 $186 ,000 Case 16. Low Pressure Injection System Assumption:  Eliminates failure of the low pressure coolant injection and low pressure core spray (Analysis Case for SAMA No. 24) 24-Add a diverse low

-pressure injection system.

$8,800,000 11.4% 45.4% 40.5% $229,000 $687,000   F-27 Appendix F

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued) Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

 % Risk Reduction CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 17. Emergency Core Cooling System Low-Pressure Interlock Assumption:  Eliminates emergency core cooling system permissives and interlock failure (Analysis Case for SAMA No. 25) 25-Install a bypass switch to allow operators to bypass the low reactor pressure interlock circuitry that inhibits opening the low-pressure coolant injection or core spray injection valves following sensor or logic failures that prevent all low pressure injection valves from opening. $1,000,000 
 <0.1% <0.1% <0.1% $0 $0 Case 18. Residual Heat Removal Heat Exchangers Assumption:  Eliminates failure of standby service water to provide cooling to the residual heat removal heat exchangers (Analysis Case for SAMA No. 26) 26-Implement modifications to allow manual alignment of the fire water system to residual heat removal heat exchangers.
$1,950,000 12.5% 30.9% 34.1% $205,000 $616,000 Case 19. Emergency Service Water System Reliability Assumption:  Eliminates failure of service water pumps (Analysis Case for SAMA No. 27) 27-Add service water pump to increase availability of cooling water $5,900,000 3.5% 6.0% 6.3% $4 7, 200 $142,000 Case 20. Main Feedwater System Reliability Assumption:  Eliminates failure to inject from feedwater (Analysis Case for SAMA No. 28) 28-Add a motor-driven feed water pump
$1,650,000 7.5% 22.2% 23.7% $134 ,000 $402 ,000 Case 21. Increase Availability of Room Cooling Assumption:  Eliminates failure of room cooling to low

-pressure core spray, high -pressure core spray, standby service water and safeguard switchgear battery rooms (Analysis Case for SAMA No. 29) 29-Provide a redundant train or means of ventilation

$2,203,000 17.9% 15.1% 16.0% $1 93 ,000 $5 80 ,000 F-28 Appendix F

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued) Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

 % Risk Reduction CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 22. Increase Availability of the Diesel Generator System through HVAC Improvements Assumption:  Eliminates failure of HVAC  for diesel generator rooms (Analysis Case for SAMA Nos. 30, 32, & 33) 30-Add a diesel building high temperature alarm or redundant louver and thermostat
$1,305,000 32-Diverse emergency diesel generator HVAC logic $1,148,000 33-Install additional fan and louver pair for emergency diesel generator HVAC $6,000,000 23.9% 16.6% 12.3% $237,000 $711,000 Case 23. Increased Reliability of Room Cooling for High

-Pressure Coolant injection and Reactor Core Isolation Cooling Assumption: Eliminates failure of power to the high -pressure core spray pump room cooler (Reactor core isolation cooling pump continued operation is not dependent on room cooling.)

(Analysis Case for SAMA No. 31) 31-Create ability to switch high

-pressure coolant injection and reactor core isolation cooling room fan power supply to direct current in an station blackout event

$300,000  <0.1% <0.1% <0.1% $0 $0 Case 24. Increase Reliability of Instrument Air Assumption:  Eliminates failure of the instrument air (Analysis Case for SAMA Nos. 34 & 35) 34-Modify procedure/hardware to provide ability to align diesel power to more air compressors
$1,200,000 35-Replace service and instrument air compressors with more reliable compressors which have self

-contained air cooling by shaft-driven fans

$1,395,000 10.6% 17.1% 18.7% $143,000 $428,000  F-29 Appendix F

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued) Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

 % Risk Reduction CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 25. Backup Nitrogen to Safety Relief Valve   Assumption:  Eliminates operator failure to install air bottles (Analysis Case for SAMA No. 36) 36-Install nitrogen bottles as backup gas supply for safety relief valves
$1,723,000 5.9% 0.1% 0.0% $46, 900 $141,000 Case 26. Improve Availability of Safety Relief Valves and Main Steam Isolation Valves  Assumption:  Eliminates failure of non

-automatic-depressurization -system safety relief valves (Analysis Case for SAMA No. 37) 37-Improve safety relief valve and main steam isolation valve pneumatic components

$1,500,000 33.7% 12.9% 13.3% $312,000 $935,000 Case 27. Improve Suppression Pool Cooling Assumption:  Eliminates the failure of flow to the residual heat removal heat exchangers (Analysis Case for SAMA No. 38) 38-Install an independent method of suppression pool cooling
$5,800,000 1 2.5% 3 0.9% 3 4.1% $20 6 ,000 $617,000 Case 28. Increase Availability of Containment Heat Removal Assumption:  Eliminates failure of cooled flow from residual heat removal pump A and B (Analysis Case for SAMA Nos. 39 & 41) 39-Procedural change to cross

-tie open cycle cooling system to enhance containment spray system

$25,000 41-Use the fire water system as a backup source for the drywell spray system
$1,950,000 17.8% 45.6% 50.2% $297 ,000 $892 ,000 F-30 Appendix F

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued) Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

 % Risk Reduction CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 29. Decay Heat Removal Capability - Drywell Spray Assumption:  Eliminates failure of residual heat removal spray (Analysis Case for SAMA No. 40)  17.8% 45.6% 50.2% $297,000 $892,000 40-Install a passive drywell spray system to provide redundant drywell spray method
$5,800,000 Case 30. Increase Availability of the Condensate Storage Tank Assumption:  Eliminates failure of high

-pressure core spray and reactor core isolation cooling suction (Analysis Case for SAMA No. 42) 42 - Enhance procedures to refill condensate storage tank from demineralized water or service water system

$200,000  4.4% 12.6% 13.5% $77,000 $231,000 Case 31. Filtered Vent to Increase Heat Removal Capacity for Non-Anticipated Transient without Scram Events Assumption:  Reduces the baseline accident progression source terms by a factor of 2 (Analysis Case for SAMA No. 43) 43-Install a filtered containment vent to provide fission product scrubbing
$1,500,000 0.0% 31.6% 40.6% $118,000 $354,000 Case 32. Reduce Hydrogen Ignition Assumption:  Eliminates failure of hydrogen igniters (Analysis Case for SAMA Nos. 44 & 45) 44-Provide post

-accident containment inerting capability

$2,665,000 45-Install a passive hydrogen control system
$760,000  0.0% 18.8% 19.9% $6 2, 500 $188 ,000 F-31 Appendix F

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued) Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

 % Risk Reduction CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 33. Controlled Containment Venting Assumption:  Eliminates failure of air

-operated valves to open (Analysis Case for SAMA Nos. 46 & 47) 46-Provide passive overpressure relief by changing the containment vent valves to fail open and improving the strength of the rupture disk

$1,000,000 47-Enable manual operation of all containment vent valves via local controls
$150,000  1.3% 3.1% 3.5% $21,200 $63,600 Case 34. Interfacing Systems Loss of Coolant Accident Assumption:  Removes all interfacing systems LOCA initiators (Analysis Case for SAMA Nos. 48, 50, & 51) 48-Increase frequency of valve leak testing to reduce interfacing systems LOCA frequency $100,000 50-Revise emergency operating procedures to improve interfacing systems LOCA identification
$50,000 51-Improve operator training on interfacing systems LOCA coping $112,000  0.0% 0.1% 0.1% $128 $385 Case 35. Main Steam Isolation Valve Design Assumption:  Eliminates failure of the main steam isolation valves to close or remain closed (Analysis Case for SAMA No. 49) 49-Improve main steam isolation valve design to decrease the likelihood of containment bypass scenarios
$1,000,000 0.0% 0.1% 0.0% $5 $15    F-32 Appendix F

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued) Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

 % Risk Reduction   CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 36. Standby Liquid Control System Assumption:  Eliminates failure to initiate standby liquid control and failures of alternate boron injection (Analysis Case for SAMA No. 52) 52-Increase boron concentration in the standby liquid control system [Reduced time required to achieve shutdown provides increased margin in the accident timeline for successful initiation of standby liquid control]
$50,000  0.1% 0.1% 0.1% $590 $1,771 Case 37. Safety Relief Valve Reseat Assumption:  Eliminates the initiator for safety relief valves inadvertently being open and basic events for stuck open safety relief valves (Analysis Case for SAMA No. 53) 53-Increase safety relief valve reseat reliability to address the risk associated with dilution of boron caused by the failure of the safety relief valves to reseat after standby liquid control injection
$2,200,000 4.2% 3.9% 4.1% $46 , 500 $139 ,000 Case 38. Add Fire Suppression a  Assumption:  Eliminates fire CDF from the critical switchgear rooms (Analysis Case for SAMA No. 54) 54-Add automatic fire suppression systems to the dominant fire zones $375,000  n/a n/a n/a $32,600 $97 , 800 Case 39. Reduce Risk from Fires that Require Control Room Evacuation a Assumption:  Eliminates fire CDF from the main control room (Analysis Case for SAMA No. 55) 55-Upgrade the alternate shutdown system panel to include additional system controls for opposite division
$787,000  n/a n/a n/a $134 ,000 $4 0 2,000  F-33 Appendix F

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued) Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

 % Risk Reduction CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 40. Large Break Loss of Coolant Accident Assumption:  Eliminates large break LOCA (Analysis Case for SAMA No. 56) 56-Provide digital large break LOCA protection to identify symptoms and/or precursors of a large break LOCA (a leak before break) $2,000,000 3.3% 13.3% 14.5% $71 , 300 $214 ,000 Case 41. Trip/Shutdown Risk Assumption:  Reduces all initiating events except pipe breaks, floods,  and loss of offsite power by 10 percent (Analysis Case for SAMA No. 57) 57-Generation risk assessment implementation into plant activities (trip/shutdown risk modeling)
$500,000  5.7% 6.1% 6.5% $65 , 800 $19 7,000 Case 42. Increase Availability of Pump House Ventilation System for Standby Service Water Assumption:  Eliminates failure of standby service water pump house ventilation (Analysis Case for SAMA No. 58) 58-Increase the training emphasis and provide additional control room indication on the operational status of standby service water pump house ventilation system
$100,000  1.5% 1.6% 1.6% $16 , 800 $50,400  F-34 Appendix F

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued) Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

 % Risk Reduction CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 43. Increase Recovery Time of Emergency Core Cooling System Upon Loss of Standby Service Water Assumption:  Eliminates failure of standby service water to the low pressure core spray room cooler (Analysis Case for SAMA No. 59) 59-Increase operator training for alternating operation of the low-pressure emergency core cooling system pumps (low-pressure coolant injection and low

-pressure core spray) for loss of standby service water scenarios

$50,000  4.5% 5.2% 5.5% $53,300 $160 ,000 Case 44. Additional Containment Heat Removal Assumption:  Eliminates failure of suppression pool cooling and containment spray systems (Analysis Case for SAMA No. 60) 60-Install an additional method of heat removal from containment
$4,352,000 17.8% 47.1% 51.9% $302 ,000 $907 ,000 Case 45. Improve Heat Exchanger Availability for Residual Heat Removal Assumption:  Eliminates failure of residual heat removal heat exchanger cooler inlet and outlet valves (Analysis Case for SAMA No. 62) 62-Add a bypass around the residual heat removal heat exchanger inlet and outlet valves
$2,832,000 2.0% 6.4% 7.0% $37,800 $1 13 ,0 00 Case 46. Improve Lube Oil Cooling for Reactor Core Isolation Cooling Assumption:  Eliminates failure to cool lube oil for reactor core isolation cooling (Analysis Case for SAMA No. 63) 63-Add a redundant reactor core isolation cooling lube oil cooling path $1,803,000 7.4% 3.1% 2.5% $68,200 $205,000 a These analysis cases only affected external events and were evaluated differently.

b Clarified by the applicant to be reduced by 10 percent in response to a request for additional information. F-35 Appendix F

Appendix F F-36 Case 8, used to evaluate the benefit of SAMA No. 14 (provide a portable EDG fuel oil transfer 1 pump), assumed that the EDGs ' failure to run was eliminated. In its review, the staff noted that 2 the failure to run of the Division 3, HPCS diesel was not eliminated. In response to an RAI, 3 Entergy stated that the Division 3 diesel did not have a common fuel oil transfer pump with the 4 other two EDGs and i f the Division 3 diesel were included in the assessment, either two portable 5 fuel transfer pumps would be needed, or the pump would have to be moved to fill the additional 6 day tank. Entergy stated this would increase implementation costs and would not change the 7 results of the cost -benefit assessment (Entergy 2012a). While the staff disagrees that the 8 added cost of moving the portable transfer pump would be appreciable, in considering the 9 conservatism in the assumption that all failures to run would be eliminated by having a portable 10 pump, the staff concludes that the assessment of the benefit of SAMA No. 14 is acceptable. 11 Case 32, used to evaluate the benefit of SAMAs Nos. 44 and 45 (both changes to eliminate 12 hydrogen ignition containment failures), was evaluated by eliminating failures of the hydrogen 13 igniter system. A staff RAI on the original ER submittal (NRC 2012a) noted that Entergy results 14 indicated the assumption would lead to a 16 percent reduction in CDF, whereas it should have 15 no impact on CDF. In response, Entergy stated that the elimination of igniter failures in the 16 Level 2 analysis was done by setting a gate to TRUE, which eliminated all hydrogen igniter 17 failure cut sets from the Level 2 results, and therefore, led to the reduction in CDF in the original 18 analysis (Entergy 2012a). This inconsistency was resolved in the revised SAMA analysis. In 19 the revised analysis, there is no reduction in CDF for Case 32 (Entergy 2012c). The staff 20 concludes that the revised evaluation, as described, is appropriate for the SAMA analysis. 21 In the description of the updated analysis, Entergy stated that the assumptions for evaluating 22 the benefit for Case 5 used for SAMA No. 6 (Improve 4.16 -kV bus cross -tie ability) and SAMA 23 No. 17 (Provide alternate feeds to essential loads directly from an alternate emergency bus) 24 were revised to remove some of the excess conservatism in the prior evaluation 25 (Entergy 2012c). Because the applicant's additional information addressed the questions raised 26 by the staff and provided a sufficient basis for justifying the cost -benefit conclusions, the staff 27 concludes that the revised evaluation, as described, is appropriate for the SAMA analysis. 28 F.5 Cost Impacts of Candidate Plant Improvements 29 Entergy estimated the costs of implementing the 63 Phase II SAMAs through the use of other 30 licensees' estimates for similar improvements and the development of site -specific cost 31 estimates where appropriate. 32 Entergy stated that the following cost ranges were used based on the review of previous 33 SAMA applications. 34 Table F-6. Estimated Cost Ranges for SAMA Applications 35 Type of Change Estimated Cost Range Procedural only

$25K-$50K Procedural change with engineering or training required
$50K-$200K Procedural change with engineering and testing or training required $200K-$300K Hardware modification
$100K to > $1000K

Appendix F F-37 Entergy stated that the GGNS site -specific cost estimates were based on the engineering 1 judgment of project engineers experienced in performing design changes at the facility. 2 The detailed cost estimates considered engineering, labor, materials, and support functions, 3 such as planning, scheduling, health physics, quality assurance, security, safety, and fire watch. 4 The estimates included a 20 percent contingency on the design and installation costs but did not 5 account for inflation, replacement power during extended outages necessary for SAMA 6 implementation, or increased maintenance or operation costs following SAMA implementation. 7 In response to a staff RAI for more information concerning the applicability of cost estimates 8 taken directly from previous SAMA applications, Entergy stated that engineering judgment by 9 project engineers familiar with the costs of modifications at Entergy plants was used to 10 determine if the cited cost estimates from other SAMA analyses were valid for GGNS. If the 11 GGNS project engineers' rough conceptual cost estimate of the modification was larger than the 12 other plant's cost estimate, the other plant 's estimate was adopted without further detailed cost 13 analysis (Entergy 2012a). 14 The staff reviewed the applicant's cost estimates, presented in Table E.2-2 of Attachment E to 15 the ER in the original submittal (Entergy 2011) and in response s to staff RAIs 16 (Entergy 2012a, 2012c). For certain improvements, the staff also compared the cost estimates 17 to estimates developed elsewhere for similar improvements, including estimates developed as 18 part of other licensees' analyses of SAMAs for operating reactors. 19 The staff noted that the new plant -specific cost estimates incorporated into the revised 20 cost-benefit analysis for a number of SAMAs are considerably greater than those previously 21 given and appear large compared to that implied by the SAMA description. In response to an 22 RAI, Entergy provide d more details on what is specifically included in the new cost estimates for 23 SAMA Nos. 1, 9, 11, 14, and 63 to justify those estimates (Entergy 2012d). Based on the 24 additional information provided, comparison of the costs with those provided in other SAMA 25 submittals, conservatisms in the determination of the benefit, and consideration of the margins 26 between the cost and the benefit, the staff concludes that the applicant's cost estimates are 27 acceptable for determining the cost -benefit ratio of these SAMAs. 28 In the revised cost -benefit analysis, Entergy stated that the cost estimate for SAMA No. 6 29 (Improve 4.16 -kV bus cross-tie ability) and SAMA No. 17 (Provide alternate feeds to essential 30 loads directly from an alternate emergency bus) of $656,000 was taken from the Susquehanna 31 SAMA analysis. In response to a staff RAI that pointed out the value used from Susquehanna 32 was for two reactor units, Entergy described the basis for concluding that the cost for these 33 SAMAs at GGNS would exceed the $656,000 value and justified use of this value for the GGNS 34 SAMA analysis (Entergy 2012d) on the basis of extensive changes to the electrical bus control 35 scheme, supporting calculations, documentation changes, required hardware, installation, and 36 testing. Based on the information provided for implementing these SAMAs at GGNS, the staff 37 concludes that Entergy's cost estimates are acceptable for determining the cost -benefit ratio of 38 these SAMAs. 39 The staff concludes that, with the above clarifications, the cost estimates provided by Entergy 40 are sufficient and appropriate for use in the SAMA evaluation. 41 Appendix F F-38 F.6 Cost-Benefit Comparison 1 Entergy's cost-benefit analysis and the staff's review are described in the following sections. 2 F.6.1 Entergy's Evaluation 3 The methodology used by Entergy was based primarily on NRC's guidance for performing 4 cost-benefit analysis; i.e., NUREG/BR-0184 (NRC 1997a). As described in Section 4.21.5.4 of 5 the ER (Entergy 2011), the net value was determined for each SAMA according to the 6 following formula: 7 Net Value = (APE + AOC + AOE + AOSC) - COE 8 where 9 APE (averted public exposure) = present value of APE costs ($) 10 AOC (averted offsite property damage costs) = present value of AOC costs ($) 11 AOE (averted occupational exposure) = present value of AOE costs ($) 12 AOSC (averted onsite costs) = present value of AOSC ($) 13 COE = cost of enhancement ($) 14 If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the 15 benefit associated with the SAMA, and it is not considered to be cost beneficial. Entergy's 16 derivation of each of the associated costs is summarized next. 17 NEI guidance states that two sets of estimates should be developed for discount rates of 18 7 percent and 3 percent (NEI 2005). Entergy provided a base set of results using a discount 19 rate of 7 percent and a 20-year license renewal period. Two sensitivity cases were developed 20 by Entergy

one used a discount rate of 7 percent with a 33-year period for remaining plant life 21 and another used a more conservative discount rate of 3 percent with a 20-year license 22 renewal period. 23 F.6.1.1 Averted Public Exposure (APE) Costs 24 Entergy defined APE cost as the monetary value of accident risk avoided from population doses 25 after discounting (Entergy 2011). The APE costs were calculated using the following formula:

26 APE = -rem per year) 27 x monetary equivalent of unit dose

($2 ,000 per person

-rem) 28 x present value conversion corresponding to NRC (1997a, Equation on p. 5.27 29 for C when a facility is already operating) 30 The annual reduction in public exposure was calculated according to the following formula: 31 Annual reduction in public exposure = (Accident frequency without modification 32 accident population dose without modification) - (Accident frequency with 33 modification x accident population dose with modification) 34 As stated in NUREG/BR -0184 (NRC 1997a), it is important to note that the monetary value of 35 the public health risk after discounting does not represent the expected reduction in public 36 health risk due to a single accident. Rather, it is the present value of a stream of potential 37 losses extending over the remaining lifetime (in this case, the 20 -year renewal period) of the 38 facility. Thus, it reflects the expected annual loss due to a single accident, the possibility that 39 such an accident could occur at any time over the renewal period, and the effect of discounting 40 Appendix F F-39 these potential future losses to present value. As previously stated, Entergy also considered an 1 extended period of 33 years for the remaining facility lifetime as a sensitivity case. For a 2 discount rate of 7 percent and a 20 -year license renewal period in the revised analysis with a 3 CDF of 2.93 x 106 per year, the applicant calculated an APE cost of $13,116 for internal events 4 (Entergy 2012c). 5 F.6.1.2 Averted Offsite Property Damage Costs (AOC) 6 Entergy defined AOC as the monetary value of risk avoided from offsite property damage after 7 discounting (Entergy 2011). The AOC values were calculated using the following formula: 8 AOC = Annual reduction in offsite property damage x present value conversion 9 corresponding to NRC (1997a, Equation for C on p. 5.27 for an operational 10 facility). 11 The annual reduction in offsite property damage was calculated according to the 12 following formula: 13 Annual reduction in offsite property damage = (Accident frequency without 14 modification x accident property damage without modification) - (Accident frequency 15 with modification x accident property damage with modification) 16 For a discount rate of 7 percent and a 20-year license renewal period in the revised analysis 17 with a CDF of 2.93 x 106 per year, the applicant calculated an AOC of $16,264 for internal 18 events (Entergy 2012c). 19 F.6.1.3 Averted Occupational Exposure (AOE) Costs 20 Entergy defined AOE as the avoided onsite exposure (Entergy 2011). Similar to the APE 21 calculations, the applicant calculated costs for immediate onsite exposure. Long -term onsite 22 exposure costs were calculated consistent with guidance in NUREG/BR -0184 (NRC 1997a), 23 which included an additional term for accrual of long -term dose s. 24 Entergy derived the values for averted occupational exposure from information provided in 25 Section 5.7.3 of NUREG/BR -0184 (NRC 1997a). Best estimate values provided for immediate 26 occupational dose (3,300 person-rem) and long -term occupational dose (20,000 person-rem 27 over a 10-year clean -up period) were used. The present value of these doses was calculated 28 using the equations provided in the handbook in conjunction with a monetary equivalent of unit 29 dose of $2,000 per person -rem, a real discount rate of 7 percent, and a time period of 20 years 30 to represent the license renewal period. Entergy assumed an accident frequency with 31 modification of zero to overestimate and bound the long -term onsite exposure costs. Immediate 32 and long-term onsite exposure costs were summed to determine AOE cost. For a CDF of 33 2.93 x 106 per year in its revised analysis, the applicant calculated an AOE cost of $1,115 for 34 internal events (Entergy 2012c). 35 F.6.1.4 Averted Onsite Costs (AOSC) 36 AOSC include averted cleanup and decontamination costs and averted power replacement 37 costs. Repair and refurbishment costs are considered for recoverable accidents only and not 38 for severe accidents. The applicant derived the values for AOSC based on information provided 39 in Section 5.7.6 of NUREG/BR -0184 (NRC 1997a). This cost element was divided into two 40 parts: the onsite cleanup and decontamination cost, also commonly referred to as averted 41 cleanup and decontamination costs; and the replacement power cost (RPC). 42 Appendix F F-40 Averted cleanup and decontamination costs (ACC) were calculated using the following formula: 1 ACC = Annual CDF reduction 2 x present value of clean -up costs per core damage event 3 x present value conversion factor 4 The total cost of clean -up and decontamination subsequent to a severe accident is estimated in 5 NUREG/BR-0184 to be $1.5 x 10 9 (undiscounted). This value was converted to present costs 6 over a 10-year clean -up period and integrated over the term of the proposed license extension. 7 Long-term RPC s were calculated using the following formula: 8 RPC = Annual CDF reduction 9 x present value of replacement power for a single event 10 x factor to account for remaining service years for which replacement power 11 is required 12 x reactor power scaling factor 13 Accounting for the GGNS EPU, the applicant based its calculations on a net electric output of 14 1, 475 megawatt s-electric (MWe) and scaled up from the 910 MWe reference plant in 15 NUREG/BR-0184 (NRC 1997a). Therefore, the applicant applied a power -scaling factor of 16 1.62 (1475 / 910 = 1.62) to determine the RPCs. For a CDF of 2.93 x 106 per year in its 17 revised analysis, Entergy calculated an AOSC of $71,500 from internal events for the 20-year 18 license renewal period (Entergy 2012c). 19 Using the above equations, Entergy estimated the total present dollar value equivalent 20 associated with completely eliminating severe accidents due to internal events at GGNS to be 21 about $101,995 (Entergy 2012c, Table 4.21-1). The applicant multiplied the internal events 22 estimated benefit by 11 to account for the risk contributions from external events and yield the 23 internal and external benefit. Additionally, internal and external benefits were multiplied by a 24 factor of 3 to account for uncertainties in the CDF calculation (Entergy 2011). In total, a 25 multiplication factor of 33 was applied to the estimated benefit from internal events to obtain the 26 total estimated benefit for internal and external events with uncertainty, which was used in 27 Entergy's cost -benefit comparisons. 28 F.6.1.5 Entergy's Results 29 If the implementation costs for a candidate SAMA exceeded the calculated benefit, the SAMA 30 was determined to be not cost beneficial. If the benefit exceeded the estimated cost, the SAMA 31 candidate was considered to be cost beneficial. In Entergy's original submittal and revised 32 analysis, three SAMA candidates were found to be potentially cost beneficial (Entergy 2011, 33 Section 4.21.6; Entergy 2012c, Table 4.21-2). Results of the cost -benefit evaluation are 34 presented in Table F-5. 35 The potentially cost -beneficial SAMAs are: 36 SAMA No. 39-Change procedure to cross tie open cycle cooling system to 37 enhance containment spray system, 38 SAMA No. 42-Enhance procedures to refill condensate storage tank from 39 demineralized water or service water system), and 40 SAMA No. 59-Increase operator training for alternating operation of the 41 low-pressure emergency core cooling system pumps (low -pressure coolant 42 Appendix F F-41 injection and low -pressure core spray) for loss of standby service water 1 scenarios. 2 Entergy stated that a condition report to implement these potentially cost -beneficial SAMAs has 3 been initiated within the corrective action process. 4 A sensitivity analysis considered two cases: a discount rate of 7 percent with a 33 -year period 5 for remaining plant life and a more conservative discount rate of 3 percent with a 20 -year 6 license renewal period (Entergy 2011, Section 4.21.5 and Table E.2-3; Entergy 2012c, 2012d). 7 Based on its sensitivity analysis in the original submittal and revised analysis, Entergy did not 8 identify any additional cost -beneficial SAMAs. 9 F.6.2 Review of Entergy's Cost-Benefit Evaluation 10 Based primarily on NUREG/BR -0184 (NRC 1997a) and NEI guidelines on discount rate s 11 (NEI 200 5), the staff determined the cost-benefit analysis performed by Entergy was consistent 12 with the guidance. Three SAMA candidates were found to be potentially cost beneficial. 13 The applicant considered possible increases in benefits from analysis uncertainties on the 14 results of the SAMA assessment. In the ER (Entergy 2011), Entergy stated that the 15 95 th percentile value of the GGNS CDF was a factor of 2.38 greater than the mean CDF. 16 A multiplication factor of 3 was conservatively selected by the applicant to account for 17 uncertainty. This multiplication factor was applied in addition to a separate multiplication factor 18 of 11 for CDF increases due to external events. Entergy's assessment accounted for the 19 potential risk -reduction benefits associated with both internal and external events. The staff 20 considers the multipliers of 3 for uncertainty and 11 for external events provide adequate margin 21 and are acceptable for the SAMA analysis. 22 At the staff's request, Entergy provided further information on the uncertainty analysis that 23 indicated the 95 th percentile CDF was 7.14 x 106/yr for a cutset truncation of 1 x 1011/yr. The 24 point estimate and mean values for CDF were 2.82 x 106/yr and 3.00 x 106/yr 25 (Entergy 2012a). The ratio of the 95 th percentile to the point estimate, which should be used in 26 determining the uncertainty multiplier, is therefore 2.53 versus the 2.38 discussed above. 27 Because a multiplier of 3 was conservatively used in the assessment, the results of the SAMA 28 assessment are not affected by this correction. 29 Sensitivity to the discount rate and time period for remaining plant life was analyzed by the 30 applicant. Compared to Entergy's baseline benefits in the original submittal (Entergy 2011, 31 Table E.2-3), benefit increases for individual SAMAs ranged from 20 to 59 percent and from 32 20 to 40 percent for the first and second sensitivity cases, respectively. Additional sensitivity 33 analyses were performed on MACCS2 input parameters for an increased evacuation time delay 34 and for a slower evacuation speed. The applicant indicated consequence deviations of less 35 than 1 percent to the sensitivity case results for the MACCS2 parameters (Entergy 2011). 36 The staff requested additional information related to costs for a few SAMAs within $10,000 of 37 estimated benefits in the sensitivity analysis. Entergy provided additional information that the 38 margin between the cost benefit and actual implementation cost would be greater than $10,000 39 (Entergy 2012a, 2012c). For SAMA No. 13 on a procedure change to inhibit high -voltage circuit 40 shutdown for battery charging, Entergy explained that the cost -benefit ratio in the SAMA 41 analysis is an overestimate because other failure mechanisms, not precluded by the procedure 42 change, were included into the benefit calculation. The implementation cost selected by 43 Entergy was the minimum value from the typical range for procedure changes with engineering 44 or training required. For SAMA Nos. 14 and 63 (provide portable EDG fuel oil transfer pump 45 and adding a redundant path for reactor core isolation cooling lube oil cooling), Entergy 46 Appendix F F-42 provided refined, pl ant-specific cost estimates of $1,477,000 and $1,803,000, respectively, for 1 these modifications that involve piping changes to safety -related systems. Based on this 2 additional information, additional cost -beneficial SAMAs were not identified. 3 Sensitivity analysis results were recast in the SAMA reanalysis (Entergy 2012c). In response to 4 an NRC clarification question on the unexpected large increase in the sensitivity to the discount 5 rate shown in the revised results, Entergy described that the sensitivity calculation for the lower 6 discount rate of 3 percent inadvertently included the cumulative effect of both the longer time 7 period of remaining plant life of 33 years and the lower discount rate (Entergy 2012d). Without 8 the additional effect from a longer time period, increases in the benefit solely due to a lower 9 discount rate would be smaller than those results reported in Entergy (2012c). Individual (as 10 well as cumulative) increases in the estimated benefits from the sensitivity parameters were 11 smaller than the factor of 3 applied by the applicant to account for uncertainty. In the revised 12 analysis, neither individual nor cumulative sensitivity effects resulted in benefit estimates for 13 individual SAMAs that exceeded GGNS implementation costs beyond the three SAMAs 14 previously identified by Entergy to be potentially cost beneficial. 15 The staff asked the applicant to evaluate potentially lower cost alternatives to several 16 candidates SAMAs, as summarized below: 17 Revising procedures for operators to manually initiate EDG HVAC if the 18 existing automatic logic fails or procedures for the plant auxiliary operators to 19 check on any automatic start of the EDG that could allow HVAC failures to be 20 discovered and might eliminate the need for alarms. 21 Providing directions to use jumpers to bypass the low reactor pressure 22 interlock instead of installing a bypass switch to allow operators to bypass 23 interlock circuitry. 24 Using other air compressors (service air) that might be connected to the 25 instrument air system instead of providing new compressors. 26 Improving control room fire -detection system response for a limited number of 27 key cabinets. 28 Concerning the first alternative, Entergy agreed that a procedure revision to direct that the 29 operator monitoring a running diesel ensure the ventilation system is running, or take action to 30 open doors or use portable fans, would be potentially cost beneficial. Entergy stated that a 31 condition report to implement this potentially cost -beneficial SAMA has been initiated within the 32 corrective action process (Entergy 2012a). 33 Concerning the second alternative, Entergy concluded that because of system design and the 34 number of failures that would initiate the need for this action, the likelihood of performing this 35 action successfully would be low and the benefit small. Thus, this alternative was not 36 considered cost beneficial (Entergy 2012a). 37 Concerning the third alternative, Entergy stated that a modification to connect service air with 38 instrument air has already been implemented (Entergy 2012a). 39 Concerning the fourth alternative, Entergy stated that the control room is already protected by 40 smoke detectors in the underfloor area and in every cabinet except P680 (i.e., the console at 41 which the operator sits). Since the control room is continuously occupied and, thus, provides 42 the capability of prompt detection and suppression, the use of "very early warning" or "incipient" 43 detection is not expected to provide a significant improvement and would not be cost beneficial 44 (Entergy 2012a). 45 Appendix F F-43 The staff agrees with the Entergy disposition of the above lower -cost alternatives. 1 F.7 Conclusions 2 Entergy considered 249 candidate SAMAs based on risk -significant contributors at GGNS from 3 updated probabilistic safety assessment models, its review of SAMA analyses from other BWR 4 plants, NRC and industry documentation of potential plant improvements, and GGNS individual 5 plant examination of internal and external events including available updates. Phase I 6 screening reduced the list to 63 unique SAMA candidates by eliminating SAMAs that were not 7 applicable to GGNS, had already been implemented at GGNS, or were combined into a more 8 comprehensive or plant-specific SAMA. 9 For the remaining SAMA candidates, Entergy performed a cost -benefit analysis with results 10 shown in Table F-5. The cost -benefit analysis identified three potentially cost -beneficial SAMAs 11 (Phase II SAMA Nos. 39, 42, and 59). Sensitivity cases were analyzed for the present value 12 discount rate and time period for remaining plant life. No additional SAMAs were identified as 13 potentially cost beneficial from the sensitivity analysis. In response to a staff RAI concerning 14 potential low -cost alternatives, Entergy determined that a procedure revision to direct that the 15 operator monitoring a running diesel ensure the ventilation system is running, or take action to 16 open doors, or use portable fans would be potentially cost beneficial. 17 The staff reviewed the Entergy SAMA analysis and concludes that, subject to the discussion 18 in this appendix, the methods used and implementation of the methods were sound. On the 19 basis of the applicant's treatment of SAMA benefits and costs, the staff finds that the 20 SAMA evaluations performed by Entergy are reasonable and sufficient for the license 21 renewal submittal. 22 The staff agrees with Entergy's conclusion that the four candidate SAMAs discussed in this 23 section are potentially cost beneficial, which was based on generally conservative treatment of 24 costs, benefits, and uncertainties. This conclusion of a small number of potentially 25 cost-beneficial SAMAs is consistent with the low residual level of risk indicated in the GGNS 26 PRA and the fact that Entergy has already implemented the plant improvements identified from 27 the IPE and IPEEE. Because the potentially cost -beneficial SAMAs do not relate to aging 28 management during the period of extended operation, they do not need to be implemented as 29 part of license renewal in accordance with Title 10 of the Code of Federal Regulations, Part 54. 30 Nevertheless, Entergy issued a condition report under the corrective action process to consider 31 implementation of these potentially cost -beneficial SAMAs. The staff accepts this course of 32 action. 33 F.8 References 34 Electric Power Research Institute (EPRI). 1991. "A Methodology for Assessment of Nuclear 35 Power Plant Seismic Margin." NP-6041-SL, Rev. 1. Jack R. Benjamin and Associates, 36 Inc., et al. Palo Alto, CA. August 1991. 37 Electric Power Research Institute (EPRI). 1992. "Fire -Induced Vulnerability Evaluation (FIVE)," 38 TR-100370. Professional Loss Control, Inc. Palo Alto, CA. April 1992. 39 Electric Power Research Institute (EPRI). 1994. "EPRI Fire PRA Implementation Guide." 40 EPRI Report Project 3385 -01. Draft, Parkinson, W.J., et al. Palo Alto, CA. January 1994. 41 Enercon Services, Inc. (Enercon). 2011. Permanent, Transient, and Total Population Projection 42 in Sectors. Calc. No. ENTGGG084-CALC-001, Revision

1. Oklahoma City, OK. May 27, 2011. 43 Appendix F F-44 Entergy Operations, Inc. (Entergy). 1992. "Individual Plant Examination (IPE) for Grand Gulf 1 Nuclear Station Unit 1." December 1992. Accessible at Agencywide Documents Access 2 Management System (ADAMS) No.

ML080090496 (nonpublic document ). 3 Entergy Operations, Inc. (Entergy). 1995. Letter from M.J. Meisner, Entergy, to U.S. NRC 4 Document Control Desk.

Subject:

"Grand Gulf Nuclear Station Docket No.

50-416 License 5 No. NPF-29 Individual Plant Examination of External Events (IPEEE) Schedule Final 6 Submittal." November 15, 1995 (nonpublic document ). 7 Entergy Operations, Inc. (Entergy). 1998. Letter from W. K. Hughey, Entergy, to U.S. NRC 8 Document Control Desk.

Subject:

"Grand Gulf Nuclear Station Unit 1 Docket No.

50-416 9 License No. NPF-29 Response to Request for Additional Information Related to Individual Plant 10 Examination of External Events ." February 10, 1998 (nonpublic documen t). 11 Entergy Operations, Inc. (Entergy). 2011. "Applicant's Environmental Report Operating License 12 Renewal Stage Grand Gulf Nuclear Generating Station." Appendix E to Grand Gulf Nuclear 13 Station (GGNS) License Renewal Application (LRA). Port Gibson, MS. October 2011. 14 Accessible at ADAMS No. ML11308A234. 15 Entergy Operations, Inc. (Entergy). 2012a. Letter from Michael Perito, Entergy, to U.S. Nuclear 16 Regulatory Commission Document Control Desk.

Subject:

"Response to Request for Additional 17 Information (RAI) on Severe Accident Mitigation Alternatives dated May 21, 2012, Grand Gulf 18 Nuclear Station, Unit 1, Docket No. 50-416, License No. NPF -29." Port Gibson, MS. 19 July 19, 2012. Accessible at ADAMS No. ML12202A056. 20 Entergy Operations, Inc. (Entergy). 2012b. Letter from Michael Perito, Entergy, to U.S. Nuclear 21 Regulatory Commission Document Control Desk.

Subject:

 "Response to Request for Additional 22 Information (RAI) on Severe Accident Mitigation Alternatives dated August 23, 2012, Grand Gulf 23 Nuclear Station, Unit 1, Docket No. 50

-416, License No. NPF -29." Port Gibson, M S. 24 October 2, 2012. Accessible at ADAMS No. ML12277A082. 25 Entergy Operations, Inc. (Entergy). 2012c. Letter from Michael Perito, Entergy, to U.S. Nuclear 26 Regulatory Commission Document Control Desk.

Subject:

 "Reanalysis of Severe Accident 27 Mitigation Alternatives, Grand Gulf Nuclear Station, Unit 1, Docket No.

50-416, License 28 No. NPF-29." Port Gibson, MS. November 19, 2012. Accessible at ADAMS No. ML12325A174. 29 Entergy Operations, Inc. (Entergy). 2012d. Letter from Kevin J. Mulligan, Entergy, to 30 U.S. Nuclear Regulatory Commission Document Control Desk.

Subject:

"Response to 31 Clarification Questions on Reanalysis of Severe Accident Mitigation Alternatives (SAMA) Letter 32 dated November 19, 2012, Grand Gulf Nuclear Station, Unit 1, Docket No. 50-416, License 33 No. NPF-29." Port Gibson, MS. December 19, 2012. Accessible at ADAMS No. ML12359A038. 34 Nuclear Energy Institute (NEI). 2005. "Severe Accident Mitigation Alternative (SAMA) Analysis 35 Guidance Document." NEI 05-01, Rev. A. Washington, DC. November 2005. 36 Nuclear Energy Institute (NEI). 2010. "Roadmap for Attaining Realism in Fire PRA." 37 Washington, DC. December 2010. Accessible at ADAMS No. ML110210990. 38 U.S. Nuclear Regulatory Commission (NRC). 1988. "Individual Plant Examination for Severe 39 Accident Vulnerabilities." Generic Letter 88-20. November 23, 1988. Accessible at ADAMS 40 No. ML031470299. 41 U.S. Nuclear Regulatory Commission (NRC). 1990. Severe Accident Risks: An Assessment for 42 Five U.S. Nuclear Power Plants. NUREG-1150. Washington, DC. Accessible at ADAMS 43 Nos. ML040140729 and ML120960691. 44 Appendix F F-45 U.S. Nuclear Regulatory Commission (NRC). 1991a. "Individual Plant Examination of External 1 Events (IPEEE) for Severe Accident Vulnerabilities." Generic Letter 88-20, Supplement

4. 2 Washington, DC. June 28, 1991. Accessible at ADAMS No.

ML031150485. 3 U.S. Nuclear Regulatory Commission (NRC). 1991b. Procedural and Submittal Guidance for the 4 Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities. 5 NUREG-1407. Washington, DC. May 1991. Accessible at ADAMS No. ML063550238. 6 U.S. Nuclear Regulatory Commission (NRC). 1996. U.S. NRC to R. Hutchinson (GGNS). 7 "Individual Plant Examination (IPE) -Internal Events -Grand Gulf Nuclear Station (TAC 8 No. M74415)." Generic Letter 88-20. Correspondence No. GNRI-96/00067. March 7, 1996. 9 Available via the NRC Public Document Room by e-mail to pdr.resource@nrc.gov. 10 U.S. Nuclear Regulatory Commission (NRC). 1997a. Regulatory Analysis Technical Evaluation 11 Handbook. NUREG/BR -0184. Washington, DC. Accessible at ADAMS No. ML050190193. 12 U.S. Nuclear Regulatory Commission (NRC). 1997b. Individual Plant Examination Program: 13 Perspectives on Reactor Safety and Plant Performance Parts 2 -5, Final Report." 14 NUREG-1560, Vol.

2. Washington, DC. December 31, 1997. Accessible at ADAMS 15 No. ML0635550228 (nonpublic document

). 16 U.S. Nuclear Regulatory Commission (NRC). 2001. Letter from S.P. Sekerak, NRC, to William 17 A. Eaton, Entergy.

Subject:

 "Grand Gulf Nuclear Station, Unit 1 - Re:  Staff Evaluation of 18 Licensee Response to Generic Letter 88-20, Supplement 4, 'Individual Plant Examination for 19 Severe Accident Vulnerabilities,' (TAC No.

M83625)." March 16, 2001 (nonpublic document ). 20 U.S. Nuclear Regulatory Commission (NRC). 2005. EPRI/NRC-RES Fire PRA Methodology 21 for Nuclear Power Facilities. NUREG/CR -6850. Vols. 1 and 2. Washington, DC. 22 September 2005. Accessible at ADAMS Nos. ML052580075 and ML052580118. 23 U.S. Nuclear Regulatory Commission (NRC). 2009. "An Approach for Determining the Technical 24 Adequacy of Probabilistic Risk Assessment Results for Risk -Informed Activities." Regulatory 25 Guide 1.200, Revision

2. March 2009. Accessible at ADAMS No.

ML090410014. 26 U.S. Nuclear Regulatory Commission (NRC). 2010. "NRC Information Notice 2010 -18: Generic 27 Issue 199, Implications of Updated Probabilistic Seismic Hazard Estimates in Central and 28 Eastern United States on Existing Plants." Washington, DC. September 2, 2010. Accessible at 29 ADAMS No. ML101970221. 30 U.S. Nuclear Regulatory Commission (NRC). 2012a. Letter from David Drucker, NRC, to 31 Michael Perito, Entergy.

Subject:

 "Request for Additional Information on Severe Accident 32 Mitigation Alternatives for the Review of the Grand Gulf Nuclear Station, Unit 1, License 33 Renewal Application." May 21, 2012. Accessible at ADAMS No.

ML12115A101. 34 U.S. Nuclear Regulatory Commission (NRC). 2012b. Letter from David Drucker, NRC, to 35 Michael Perito, Entergy.

Subject:

 "Request for Additional Information on Severe Accident 36 Mitigation Alternatives for the Review of the Grand Gulf Nuclear Station, Unit 1, License 37 Renewal Application." August 23, 2012. Accessible at ADAMS No.

ML12227A735. 38 U.S. Nuclear Regulatory Commission (NRC). 2012c. Letter from Alan Wang, NRC, to Vice 39 President, Operations, Entergy.

Subject:

 "Grand Gulf Nuclear Station, Unit 1 - Issuance of 40 Amendment Re:  Extended Power Uprate (TAC No.

ME4679)." Enclosure 2, Safety Evaluation 41 by the Office of Nuclear Reactor Regulation Related to Amendment No. 191 to Facility 42 Operating License No. NPF -29, Entergy Operations, Inc., Grand Gulf Nuclear Station, Unit 1, 43 Docket No. 50-416. July 18, 2012. Accessible at ADAMS No. ML121210020. 44 Generic Environmental Impact Statement for License Renewal of Nuclear Plants

Supplement 50 Regarding Grand Gulf Nuclear Station, Unit 1 Draft Report for Comment Office of Nuclear Reactor Regulation NUREG-1437 Supplement 50

!NRC Reference Material As of November 1999, you may electronically access NUREG-series publications and other NRC records at NRCs Public Electronic Reading Room at http://www.nrc.gov/reading -rm.html. Publicly released records include, to name a few, NUREG -series publications; Federal Register notices; applicant, licensee, and vendor documents and correspondence; NRC correspondence and internal memoranda; bulletins and information notices; inspection and investigative reports; licensee event reports; and Commission papers and their attachments. NRC publications in the NUREG series, NRC regulations, and Title 10, Energy , in the Code of Federal Regulations may also be purchased from one of these two sources.

1. The Superintendent of Documents U.S. Government Printing Office Mail Stop SSOP Washington, DC 20402 0001 Internet: bookstore.gpo.gov Telephone: 202

-512-1800 Fax: 202-512-2250 2. The National Technical Information Service Springfield, VA 22161 0002 www.ntis.gov 18005536847 or, locally, 703 6056000 A single copy of each NRC draft report for comment is available free, to the extent of supply, upon written request as follows: Address: U.S. Nuclear Regulatory Commission Office of Administration

Publications Branch Washington, DC 20555 -0001 E-mail: DISTRIBUTION.RESOURCE@NRC.GOV Facsimile: 301 4152289 Some publications in the NUREG series that are posted at NRCs Web site address http://www.nrc.gov/reading -rm/doc-collections/nuregs are updated periodically and may differ from the last printed version. Although references to material found on a Web site bear the date the material was accessed, the material available on the date cited may subsequently be removed from the site. N on-NRC Reference Material Documents available from public and special technical libraries include all open literature items, such as books, journal articles, transactions, Federal Register notices, Federal and State legislation, and congressional reports. Such documents as theses, dissertations, foreign reports and translations, and non -NRC conference proceedings may be purchased from their sponsoring organization. Copies of industry codes and standards used in a substantive manner in the NRC regulatory process are maintained at Ñ The NRC Technical Library Two White Flint North 11545 Rockville Pike Rockville, MD 20852 2738 These standards are available in the library for reference use by the public. Codes and standards are usually copyrighted and may be purchased from the originating organization or, if they are American National Standards, fromÑ American National Standards Institute 11 West 42 nd Street New York, NY 10036 8002 www.ansi.org 2126424900 !AVAILABILITY OF REFERENCE MATERIALS IN NRC PUBLICATION S Legally binding regulatory requirements are stated only in laws; NRC regulations; licenses, including technical specifications; or orders, not in NUREG -series publications. The views expressed in contractor -prepared publications in this series are not necessarily those of the NRC. The NUREG series comprises (1) technical and administrative reports and books prepared by the staff (NUREGXXXX) or agency contractors (NUREG/CR XXXX), (2) proceedings of conferences (NUREG/CP XXXX), (3) reports resulting from international agreements (NUREG/IA XXXX), (4) brochures (NUREG/BRXXXX), and (5) compilations of legal decisions and orders of the Commission and Atomic and Safety Licensing Boards and of Directors decisions under Section 2.206 of NRCs regulations (NUREG 0750). DISCLAIMER: This report was prepared as an account of work sponsored by an agency of the U.S. Government. Neither the U.S. Government nor any agency thereof, nor any employee, makes any warranty, expressed or implied, or assumes any legal liability or responsibility for any third partys use, or the results of such use, of any information, apparatus, product, or process disclosed in this publication, or represents that its use by such third party would not infringe privately owned rights.

Generic Environmental Impact Statement for License Renewal of Nuclear Plants

Supplement 50 Regarding Grand Gulf Nuclear Station, Unit 1 Draft Report for Comment Manuscript Completed: October 2013 Date Published: November 2013

Office of Nuclear Reactor Regulation NUREG-1437 Supplement 50

COMMENTS ON DRAFT REPORT Any interested party may submit comments on this report for consideration by the NRC staff. Comments may be accompanied by additional relevant information or supporting data. Please specify the report number NUREG-1437, Supplement 50, in your comments, and send them by the end of the comment period specified in the Federal Register notice announcing the availability of this report. Addresses: You may submit comments by any one of the following methods. Please include Docket ID NRC-2011-0262 in the subject line of your comments. Comments submitted in writing or in electronic form will be posted on the NRC website and on the Federal rulemaking website http://www.regulations.gov. Federal Rulemaking Website

Go to http://www.regulations.gov and search for documents filed under Docket ID NRC-2011-0262. Address questions about NRC dockets to Carol Gallagher at 301

-287-3422 or by e-mail at Carol.Gallagher@nrc.gov. Mail comments to

Cindy Bladey, Chief , Rules, Announcements , and Directives Branch (RADB), Division of Administrative Services , Office of Administration , Mail Stop:

3WFN-06-A44MP , U.S. Nuclear Regulatory Commission , Washington, DC 20555 -0001. For any questions about the material in this report, please contact David Drucker, NRC Environmental Project Manager, at 1 -800-368-5642, extension 6223, or by e -mail at david.drucker@nrc.gov Please be aware that any comments that you submit to the NRC will be considered a public record and entered into the Agencywide Documents Access and Management System (ADAMS). Do not provide information you would not want to be publicly available.

iii ABSTRACT 1 This supplemental environmental impact statement (SEIS) has been prepared in response to an 2 application submitted by Entergy Operations, Inc. (Entergy) to renew the operating license for 3 Grand Gulf Nuclear Station, Unit 1 (GGN S), for an additional 20 years. 4 This SEIS includes the preliminary analysis that evaluates the environmental impacts of the 5 proposed action and alternatives to the proposed action. Alternatives considered include: new 6 nuclear generation, natural gas -fired combined -cycle generation, supercritical coal -fired 7 generation, combination alternative, and no renewal of the license (the no -action alternative ). 8 The U.S. Nuclear Regulatory Commission's (NRC's) preliminary recommendation is that the 9 adverse environmental impacts of license renewal for GGNS are not great enough to deny the 10 option of license renewal for energy -planning decisionmakers. This recommendation is based 11 on the following: 12 the analysis and findings in NUREG -1437, Volumes 1 and 2, Generic 13 Environmental Impact Statement for License Renewal of Nuclear Plants, 14 the Environmental Report submitted by Entergy, 15 consultation with Federal, State, local, and Tribal government agencies, 16 the NRC's environmental review, and 17 consideration of public comments received during the scoping process. 18

v TABLE OF CONTENTS 1 ABSTRACT .............................................................................................................................. iii 2 TABLE OF CONTENTS

............................................................................................................

v 3 FIGURES .................................................................................................................................. xi 4 TABLES ................................................................................................................................. xiii 5 EXECUTIVE

SUMMARY

.........................................................................................................

xv 6 ABBREVIATIONS AND ACRONYMS

....................................................................................

xxi 7 1.0 PURPOSE AND NEED FOR ACTION .......................................................................... 1-1 8 1.1 Proposed Federal Action

.....................................................................................

1-1 9 1.2 Purpose and Need for the Proposed Federal Action

...........................................

1-1 10 1.3 Major Environmental Review Milestones

.............................................................

1-2 11 1.4 Generic Environmental Impact Statement

...........................................................

1-3 12 1.5 Supplemental Environmental Impact Statement

..................................................

1-6 13 1.6 Cooperating Agencies

.........................................................................................

1-6 14 1.7 Consultations

......................................................................................................

1-6 15 1.8 Correspondence

................................................................................................. 1-7 16 1.9 Status of Compliance
..........................................................................................

1-7 17 1.10 References

.........................................................................................................

1-7 18 2.0 AFFECTED ENVIRONMENT

........................................................................................

2-1 19 2.1 Facility Description

..............................................................................................

2-1 20 2.1.1 Reactor and Containment Systems

........................................................

2-1 21 2.1.2 Radioactive Waste Management

............................................................

2-5 22 2.1.3 Nonradiological Waste Management

......................................................

2-6 23 2.1.4 Plant Operation and Maintenance

..........................................................

2-8 24 2.1.5 Power Transmission System

..................................................................

2-9 25 2.1.6 Cooling and Auxiliary Water Systems

.....................................................

2-9 26 2.1.7 Facility Water Use and Quality

.............................................................

2-10 27 2.2 Surrounding Environment

.................................................................................

2-14 28 2.2.1 Land Use .............................................................................................. 2-16 29 2.2.2 Air Quality and Meteorology

................................................................. 2-17 30 2.2.3 Geologic Environment
..........................................................................

2-25 31 2.2.4 Surface Water Resources

....................................................................

2-30 32 2.2.5 Groundwater Resources

......................................................................

2-32 33 2.2.6 Aquatic Resources

...............................................................................

2-37 34 2.2.7 Terrestrial Resources

...........................................................................

2-45 35 2.2.8 Protected Species and Habitats

...........................................................

2-52 36 2.2.9 Socioeconomics

...................................................................................

2-63 37 2.2.10 Historic and Archaeological Resources

................................................

2-76 38 Table of Contents vi 2.3 Related Federal and State Activities

................................................................. 2-80 1 2.4 References
.......................................................................................................

2-81 2 3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT

................................................

3-1 3 3.1 References

.........................................................................................................

3-2 4 4.0 ENVIRONMENTAL IMPACTS OF OPERATION

..........................................................

4-1 5 4.1 Land Use ............................................................................................................ 4-1 6 4.2 Air Quality

...........................................................................................................

4-2 7 4.3 Geologic Environment

.........................................................................................

4-2 8 4.3.1 Geology and Soils

..................................................................................

4-2 9 4.4 Surface Water Resources

...................................................................................

4-3 10 4.5 Groundwater Resources

.....................................................................................

4-3 11 4.5.1 Generic Groundwater Issues

..................................................................

4-3 12 4.5.2 Groundwater Use Conflicts (Ranney Wells)

...........................................

4-4 13 4.5.3 Radionuclides Released to Groundwater

...............................................

4-4 14 4.6 Aquatic Resources

..............................................................................................

4-5 15 4.6.1 Exposure of Aquatic Organisms to Radionuclides

..................................

4-6 16 4.7 Terrestrial Resources

..........................................................................................

4-6 17 4.7.1 Generic Terrestrial Resource Issues

......................................................

4-7 18 4.7.2 Exposure of Terrestrial Organisms to Radionuclides

..............................

4-7 19 4.7.3 Effects on Terrestrial Resources (Non -cooling System Impacts)

............

4-8 20 4.8 Protected Species and Habitats

..........................................................................

4-8 21 4.8.1 Correspondence with Federal and State Agencies

................................. 4-9 22 4.8.2 Species and Habitats Protected Under the Endangered Species 23 Act ..........................................................................................................

4-9 24 4.8.3 Species Protected by the State of Mississippi

......................................

4-12 25 4.8.4 Species Protected Under the Bald and Golden Eagle Protection 26 Act ........................................................................................................ 4-13 27 4.8.5 Species Protected Under the Migratory Bird Treaty Act

........................

4-13 28 4.9 Human Health

...................................................................................................

4-13 29 4.9.1 Generic Human Health Issues

..............................................................

4-13 30 4.9.2 Radiological Impacts of Normal Operations

..........................................

4-14 31 4.9.3 Electromagnetic Fields -Acute Effects

.................................................

4-17 32 4.9.4 Electromagnetic Field s-Chronic Effects

..............................................

4-18 33 4.10 Socioeconomics

................................................................................................

4-18 34 4.10.1 Generic Socioeconomic Issues

............................................................

4-19 35 4.10.2 Housing ................................................................................................ 4-19 36 4.10.3 Public Services -Public Utilities

...........................................................

4-20 37 4.10.4 Public Services -Transportation

..........................................................

4-20 38 4.10.5 Offsite Land Use

..................................................................................

4-21 39 4.10.6 Historic and Archaeological Resources

................................................

4-22 40 4.10.7 Environmental Justice

..........................................................................

4-23 41 Table of Contents vii 4.11 Evaluation of New and Potentially Significant Information

................................. 4-29 1 4.12 Cumulative Impacts
..........................................................................................

4-30 2 4.12.1 Air Quality

............................................................................................

4-31 3 4.12.2 Water Resources

.................................................................................

4-33 4 4.12.3 Aquatic Resources

...............................................................................

4-35 5 4.12.4 Terrestrial Resources

...........................................................................

4-38 6 4.12.5 Human Health

......................................................................................

4-40 7 4.12.6 Socioeconomics

...................................................................................

4-41 8 4.12.7 Historic and Archaeological Resources

................................................

4-42 9 4.12.8 Summary of Cumulative Impacts

..........................................................

4-42 10 4.13 References

.......................................................................................................

4-44 11 5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS .................................. 5-1 12 5.1 Design-Basis Accidents

......................................................................................

5-1 13 5.2 Severe Accidents

................................................................................................

5-2 14 5.3 Severe Accident Mitigation Alternatives

..............................................................

5-3 15 5.3.1 Overview of SAMA Process

...................................................................

5-3 16 5.3.2 Estimate of Risk

.....................................................................................

5-3 17 5.3.3 Potential Plant Improvements

................................................................. 5-5 18 5.3.4 Evaluation of Risk Reduction and Costs of Improvement s......................

5-7 19 5.3.5 Cost-Benefit Comparison

.....................................................................

5-10 20 5.3.6 Conclusions

.........................................................................................

5-11 21 5.4 References

.......................................................................................................

5-12 22 6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE, 23 SOLID WASTE MANAGEMENT, AND GREENHOUSE GAS EMISSIONS .................. 6-1 24 6.1 The Uranium Fuel Cycle

.....................................................................................

6-1 25 6.2 Greenhouse Gas Emissions

...............................................................................

6-3 26 6.2.1 Existing Studies

......................................................................................

6-3 27 6.2.2

Conclusions:

Relative Greenhouse Gas Emissions

...............................

6-8 28 6.3 References

.......................................................................................................

6-10 29 7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING

.............................................

7-1 30 7.1 Decommissioning

................................................................................................

7-1 31 7.2 References

.........................................................................................................

7-2 32 8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES

....................................................

8-1 33 8.1 New Nuclear Generation

.....................................................................................

8-4 34 8.1.1 Air Quality

..............................................................................................

8-5 35 8.1.2 Groundwater Resources

........................................................................

8-6 36 8.1.3 Surface Water Resources

......................................................................

8-7 37 8.1.4 Aquatic Ecology

.....................................................................................

8-7 38 8.1.5 Terrestrial Ecology

.................................................................................

8-8 39 8.1.6 Human Health

........................................................................................

8-8 40 Table of Contents viii 8.1.7 Land Use ................................................................................................ 8-8 1 8.1.8 Socioeconomics

.....................................................................................

8-9 2 8.1.9 Transportation

........................................................................................

8-9 3 8.1.10 Aesthetics

............................................................................................

8-10 4 8.1.11 Historic and Archaeological Resources

................................................

8-10 5 8.1.12 Environmental Justice

..........................................................................

8-11 6 8.1.13 Waste Management

.............................................................................

8-11 7 8.1.14 Summary of Impacts of New Nuclear Generation

................................. 8-12 8 8.2 Natural Gas

-Fired Combined -Cycle Generation

................................................

8-12 9 8.2.1 Air Quality ............................................................................................ 8-13 10 8.2.2 Groundwater Resources

......................................................................

8-15 11 8.2.3 Surface Water Resources .................................................................... 8-16 12 8.2.4 Aquatic Ecology

...................................................................................

8-16 13 8.2.5 Terrestrial Ecology

...............................................................................

8-17 14 8.2.6 Human Health

......................................................................................

8-17 15 8.2.7 Land Use .............................................................................................. 8-18 16 8.2.8 Socioeconomics

...................................................................................

8-18 17 8.2.9 Transportation

......................................................................................

8-19 18 8.2.10 Aesthetics

............................................................................................

8-19 19 8.2.11 Historic and Archaeological Resources

................................................

8-19 20 8.2.12 Environmental Justice

..........................................................................

8-20 21 8.2.13 Waste Management

.............................................................................

8-21 22 8.2.14 Summary of Impacts of NGCC Alternative

...........................................

8-21 23 8.3 Supercritical Pulverized Coal -Fired Generation

.................................................

8-21 24 8.3.1 Air Quality

............................................................................................

8-23 25 8.3.2 Groundwater Resources

......................................................................

8-25 26 8.3.3 Surface Water Resources

....................................................................

8-26 27 8.3.4 Aquatic Ecology

...................................................................................

8-26 28 8.3.5 Terrestrial Ecology

...............................................................................

8-27 29 8.3.6 Human Health

......................................................................................

8-28 30 8.3.7 Land Use .............................................................................................. 8-28 31 8.3.8 Socioeconomics

...................................................................................

8-29 32 8.3.9 Transportation

......................................................................................

8-29 33 8.3.10 Aesthetics

............................................................................................

8-30 34 8.3.11 Historic and Archaeological Resources

................................................

8-30 35 8.3.12 Environmental Justice

..........................................................................

8-31 36 8.3.13 Waste Management

.............................................................................

8-31 37 8.3.14 Summary of Impacts of SCPC Alternative

............................................

8-32 38 Table of Contents ix 8.4 Combination Alternative

....................................................................................

8-32 1 8.4.1 Air Quality

............................................................................................

8-34 2 8.4.2 Groundwater Resources

......................................................................

8-36 3 8.4.3 Surface Water Resources

....................................................................

8-37 4 8.4.4 Aquatic Ecology

...................................................................................

8-37 5 8.4.5 Terrestrial Ecology

...............................................................................

8-38 6 8.4.6 Human Health

......................................................................................

8-39 7 8.4.7 Land Use .............................................................................................. 8-40 8 8.4.8 Socioeconomics

...................................................................................

8-41 9 8.4.9 Transportation

......................................................................................

8-42 10 8.4.10 Aesthetics

............................................................................................

8-42 11 8.4.11 Historic and Archaeological Resources

................................................

8-43 12 8.4.12 Environmental Justice

..........................................................................

8-44 13 8.4.13 Waste Management

.............................................................................

8-45 14 8.4.14 Summary of Impacts of Combination Alternative

..................................

8-45 15 8.5 Alternatives Considered But Dismissed

............................................................

8-46 16 8.5.1 Demand-Side Management

..................................................................

8-46 17 8.5.2 Wind Power

..........................................................................................

8-47 18 8.5.3 Solar Power

.........................................................................................

8-48 19 8.5.4 Hydroelectric Power

.............................................................................

8-48 20 8.5.5 Wave and Ocean Energy

.....................................................................

8-49 21 8.5.6 Geothermal Power

...............................................................................

8-49 22 8.5.7 Municipal Solid Waste

..........................................................................

8-49 23 8.5.8 Biomass ............................................................................................... 8-50 24 8.5.9 Oil-Fired Power

....................................................................................

8-51 25 8.5.10 Fuel Cells

.............................................................................................

8-51 26 8.5.11 Purchased Power

.................................................................................

8-51 27 8.5.12 Delayed Retirement.............................................................................. 8-52 28 8.6 No-Action Alternative

........................................................................................

8-52 29 8.6.1 Air Quality

............................................................................................

8-52 30 8.6.2 Groundwater Resources

......................................................................

8-52 31 8.6.3 Surface Water Resources

....................................................................

8-53 32 8.6.4 Aquatic Ecology

...................................................................................

8-53 33 8.6.5 Terrestrial Ecology

...............................................................................

8-53 34 8.6.6 Human Health

......................................................................................

8-53 35 8.6.7 Land Use .............................................................................................. 8-53 36 8.6.8 Socioeconomics

...................................................................................

8-53 37 8.6.9 Transportation

......................................................................................

8-54 38 8.6.10 Aesthetics

............................................................................................

8-54 39 8.6.11 Historic and Archaeological Resources

................................................

8-54 40 Table of Contents x 8.6.12 Environmental Justice

..........................................................................

8-54 1 8.6.13 Waste Management

.............................................................................

8-54 2 8.6.14 Summary of Impacts of Combination Alternative

..................................

8-54 3 8.7 Alternatives Summary

.......................................................................................

8-55 4 8.8 References

.......................................................................................................

8-58 5

9.0 CONCLUSION

..............................................................................................................

9-1 6 9.1 Environmental Impacts of License Renewal

........................................................

9-1 7 9.2 Comparison of Alternatives

.................................................................................

9-1 8 9.3 Resource Commitments

......................................................................................

9-2 9 9.3.1 Unavoidable Adverse Environmental Impacts

........................................

9-2 10 9.3.2 Short-Term Versus Long -Term Productivity

...........................................

9-2 11 9.3.3 Irreversible and Irretrievable Commitments of Resources

......................

9-3 12 9.4 Recommendations

..............................................................................................

9-3 13 10.0 LIST OF PREPARERS

...............................................................................................

10-1 14 11.0 LIST OF AGENCI ES, ORGANIZATIONS, AND PERSONS TO WHOM 15 COPIES OF THIS SEIS ARE SENT

...........................................................................

11-1 16 12.0 INDEX ......................................................................................................................... 12-1 17 APPENDIX A COMMENTS RECEIVED ON THE GGNS ENVIRONMENTAL 18 REVIEW ......................................................................................................... A-1 19 APPENDIX B NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR 20 LICENSE RENEWAL OF NUCLEAR POWER PLANTS

................................ B-1 21 APPENDIX C APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS
...................... C-1 22 APPENDIX D CONSULTANT CORRESPONDENCE
........................................................... D-1 23 APPENDIX E CHRO NOLOGY OF ENVIRONMENTAL REVIEW 24 CORRESPONDENCE
.................................................................................... E-1 25 APPENDIX F U.S. NUCLEAR REGULATORY COMMISSION STAFF 26 EVALUATION OF SEVERE ACCIDENT MITIGATION 27 ALTERNATIVES FOR GRAND GULF NUCLEAR STATION IN 28 SUPPORT OF LICENSE RENEWAL APPLICATION REVIEW
..................... F-1 29 Table of Contents xi FIGURES 1 Figure 1-1. Environmental Review Process
........................................................................ 1-2 2 Figure 1-2. Environmental Issues Evaluated During License Renewal
............................... 1-5 3 Figure 2-1. Location of GGNS, 50

-mi (80-km) Vicinity

........................................................ 2-2 4 Figure 2-2. Location of GGNS, 6

-mi (10-km) Vicinity

.......................................................... 2-3 5 Figure 2-3. GGNS, General Site Layout
............................................................................. 2-4 6 Figure 2-4. Plan (Map) View and Cross Section View of Ranney Well at GGNS
.............. 2-12 7 Figure 2-5. GGNS Ranney Well Locations
....................................................................... 2-13 8 Figure 2-6. GGNS Upland Complex Aquifer Permitted Wells
............................................ 2-15 9 Figure 2-7. Topographic Map of GGNS Facility
................................................................ 2-16 10 Figure 2-8. GGNS Wind at 33

-ft (10-m) and 162 -ft (50-m), 2006-2011 ............................ 2-19 11 Figure 2-9. Location Map for Geologic Cross -Sections A-A' and B-B' ............................... 2-27 12 Figure 2-10. Geologic Cross Section A-A' .......................................................................... 2-28 13 Figure 2-11. Geologic Cross Section B-B' .......................................................................... 2-29 14 Figure 2-12. GGNS Surface Water Features ...................................................................... 2-31 15 Figure 2-13. Most Recent GGNS Tritium Contaminated Well Data from 16 February 2012 ................................................................................................ 2-36 17 Figure 2-14. GGNS Property Habitat Types ....................................................................... 2-47 18 Figure 4-1. 2010 Census Minority Block Groups Within a 50 -mi Radius of GGNS

............ 4-26 19 Figure 4-2. 2010 Census Low

-Income Block Groups Within a 50 -mi Radius of 20 GGN S ............................................................................................................ 4-27 21

Table of Contents xiii TABLES 1 Table ES-1. NRC Conclusions Relating to Site -Specific Impacts of License 2 Renewal ........................................................................................................... xvii 3 Table 2-1. Permitted Maximum Allowable Emission Limits for Criteria Air 4 Pollutants and Volatile Organic Compounds (VOCs) and Estimated 5 Annual CO 2e Emission Rate at GGNS

............................................................ 2-22 6 Table 2-2. National Ambient Air Quality Standards (NAAQS)
.......................................... 2-23 7 Table 2-3. Dominant Vegetation by Habitat Type
............................................................ 2-48 8 Table 2-4. Most Common or Abundant Wildlife Documented on GGNS
.......................... 2-50 9 Table 2-5. Transmission Line Corridor Land Use by Area

................................................ 2-52 10 Table 2-6. Federally and State -Listed Species

................................................................ 2-55 11 Table 2-7. 2009 GGNS Employee Residence by County
................................................. 2-64 12 Table 2-8. Housing in GGNS ROI
.................................................................................... 2-64 13 Table 2-9. Claiborne County Public Water Supply Systems
............................................. 2-65 14 Table 2-10. Major Commuting Routes Near GGNS 2011 Average Annual Daily 15 Traffic ............................................................................................................. 2-66 16 Table 2-11. Population and Percent Growth in GGNS ROI Counties  from 17 1970-2009 and Projected for 2010

-2050 ....................................................... 2-68 18 Table 2-12. Demographic Profile of the Population in the GGNS ROI in 2010

................... 2-69 19 Table 2-13. 2010 Seasonal Housing in Counties within 50 miles of GGNS
........................ 2-70 20 Table 2-14. Migrant Farm Workers and Temporary Farm Labor in Counties 21 Located within 50 Miles of GGNS
................................................................... 2-72 22 Table 2-15. Major Employers of the GGNS ROI in 2012
.................................................... 2-74 23 Table 2-16. Estimated Income Information for the GGNS ROI in 2010
.............................. 2-75 24 Table 2-17. 2007-2012 Unemployment Rates in the GGNS ROI
...................................... 2-75 25 Table 3-1. Category 1 Issues Related to Refurbishment
.................................................... 3-1 26 Table 3-2. Category 2 Issues Related to Refurbishment
.................................................... 3-2 27 Table 4-1. Land Use Issues
............................................................................................... 4-1 28 Table 4-2. Air Quality Issues
.............................................................................................. 4-2 29 Table 4-3. Surface Water Issues
....................................................................................... 4-3 30 Table 4-4. Groundwater Issues.......................................................................................... 4-3 31 Table 4-5. Aquatic Resource Issues
.................................................................................. 4-6 32 Table 4-6. Terrestrial Resource Issues
.............................................................................. 4-7 33 Table 4-7. Threatened or Endangered Species
................................................................. 4-8 34 Table 4-8. Human Health Issues
..................................................................................... 4-13 35 Table 4-9. Socioeconomics Issues
.................................................................................. 4-19 36 Table 4-10. Summary of Cumulative Impacts on Resource Areas
..................................... 4-43 37 Table 5-1. Issues Related to Postulated Accidents
............................................................ 5-2 38 Table 5-2. GGNS Core Damage Frequency (CDF) for Internal Events
.............................. 5-4 39 Table 5-3. Base Case Mean Population Dose Risk and Offsite Economic Cost 40 Risk for Internal Events ..................................................................................... 5-6 41 Table 5-4. Severe Accident Mitigation Alternatives Cost

-Benefit Analysis for 42 GGNS ............................................................................................................... 5-8 43 Table of Contents xiv Table 5-5. Estimated Cost Ranges for SAMA Applications

.............................................. 5-10 1 Table 6-1. Issues Related to the Uranium Fuel Cycle and Solid Waste 2 Management.
................................................................................................... 6-1 3 Table 6-2. Nuclear Greenhouse Gas Emissions Compared to Coal
.................................. 6-6 4 Table 6-3. Nuclear Greenhouse Gas Emissions Compared to Natural Gas
....................... 6-7 5 Table 6-4. Nuclear Greenhouse Gas Emissions Compared to Renewable Energy 6 Sources ............................................................................................................ 6-8 7 Table 7-1. Issues Related to Decommissioning
................................................................. 7-1 8 Table 8-1. Summary of Alternatives Considered In Depth
................................................. 8-4 9 Table 8-2. Summary of Environmental Impacts of the New Nuclear Alternative 10 Compared to Continued Operation of GGNS
.................................................. 8-12 11 Table 8-3. Summary of Environmental Impacts of the NGCC Alternative 12 Compared to Continued Operation of GGNS
.................................................. 8-21 13 Table 8-4. Summary of Environmental Impacts of the SCPC Alternative 14 Compared to Continued Operation of GGNS
.................................................. 8-32 15 Table 8-5. Summary of Environmental Impacts of the Combination Alternative 16 Compared to Continued Operation of GGNS
.................................................. 8-46 17 Table 8-6. Summary of Environmental Impacts of the No

-action Alternative 18 Compared to Continued Operation of GGNS

.................................................. 8-55 19 Table 8-7. Summary of Environmental Impacts of Proposed Action and 20 Alternatives
..................................................................................................... 8-57 21 Table 10-1. List of Preparers
.............................................................................................

10-1 22 Table A-1. Individuals Who Provided Comments During the Scoping Comment 23 Period .................................................................................................................. 1 24 Table B-1. Summary of Issues and Findings

......................................................................... 1 25 Table C-1. Federal and State Environmental Requirements
............................................... C-1 26 Table C-2. Licenses and Permits
....................................................................................... C-4 27 Table D-1. Consultation Correspondence
.......................................................................... D-1 28 Table E-1. Environmental Review Correspondence
.............................................................. 1 29 Tabl e F-1. Grand Gulf Nuclear Station Core Damage Frequency (CDF) for 30 Internal Events.................................................................................................. F-4 31 Table F-2. Base Case Mean Population Dose Risk and Offsite Economic Cost 32 Risk for Internal Events
..................................................................................... F-5 33 Table F-3. Major GGNS Probabilistic Safety Assessment (PSA) Models
........................... F-7 34 Table F-4. GGNS Fire IPEEE Core Damage Frequency (CDF) Results for 35 Unscreened Compartments
............................................................................ F-13 36 Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for 37 Grand Gulf Nuclear Stati on ............................................................................. F-24 38 Table F-6. Estimated Cost Ranges for SAMA Applications
.............................................. F-36 39 xv EXECUTIVE 

SUMMARY

1 BACKGROUND 2 By letter dated October 28, 2011, Entergy Operations, Inc. (Entergy) submitted an application to 3 the U.S. Nuclear Regulatory Commission (NRC) to issue a renewed operating license for Grand 4 Gulf Nuclear Station, Unit 1 (GGNS), for an additional 20 -year period. 5 Pursuant to Title 10, Part 51.20(b)(2) of the Code of Federal Regulations (10 CFR 51.20(b)(2)), 6 the renewal of a power reactor operating license requires preparation of an environmental 7 impact statement (EIS) or a supplement to an existing EIS. In addition, 10 CFR 51.95(c) states 8 that the NRC shall prepare an EIS, which is a supplement to the Commission's NUREG -1437, 9 Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants. 10 Upon acceptance of Entergy's application, the NRC staff began the environmental review 11 process described in 10 CFR Part 51 by publishing a notice of intent to prepare a supplemental 12 EIS (SEIS) and conduct scoping. In preparation of this SEIS for GGNS, the NRC staff 13 performed the following: 14 conducted public scoping meetings on January 31, 2012, in 15 Port Gibson, Mississippi; 16 conducted a site audit at the plant in March 2012; 17 reviewed Entergy 's environmental report (ER) and compared it to the GEIS; 18 consulted with other agencies; 19 conducted a review of the issues following the guidance set forth in 20 NUREG-1555, "Standard Review Plans for Environmental Reviews for 21 Nuclear Power Plants, Supplement 1: Operating License Renewal"; and 22 considered public comments received during the scoping process. 23 PROPOSED ACTION 24 Entergy initiated the proposed Federal action -issuing a renewed power reactor operating 25 license-by submitting an application for license renewal of GGNS, for which the existing 26 license (NPF-29) for GGNS, will expire on November 1, 2024. The NRC's Federal action is the 27 decision whether or not to renew the license for an additional 20 years. 28 PURPOSE AND NEED FOR ACTION 29 The purpose and need for the proposed action (issuance of a renewed license) is to provide an 30 option that allows for power generation capability beyond the term of the current nuclear power 31 plant operating license to meet future system generating needs. Such needs may be 32 determined by other energy -planning decisionmakers, such as state, utility, and -where 33 authorized, Federal (other than NRC). This definition of purpose and need reflects the NRC's 34 recognition that, unless there are findings in the safety review required by the Atomic Energy 35 Act or findings in the National Environmental Policy Act (NEPA) environmental analysis that 36 would lead the NRC to reject a license renewal application, the NRC does not have a role in the 37 energy planning decisions of whether a particular nuclear power plant should continue to 38 operate. 39 Executive Summary xvi If the renewed license is issued, the appropriate energy -planning decisionmakers, along with 1 Entergy, will ultimately decide if the reactor unit will continue to operate based on factors such 2 as the need for power. If the operating license is not renewed, then the facility must be shut 3 down on or before the expiration date of the current operating license -November 1, 2024. 4 ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL 5 The SEIS evaluates the potential environmental impacts of the proposed action. The 6 environmental impacts from the proposed action are designated as SMALL, MODERATE, or 7 LARGE. As set forth in the GEIS, Category 1 issues are those that meet all of the following 8 criteria: 9 The environmental impacts associated with the issue 10 is determined to apply either to all plants or, for some 11 issues, to plants having a specific type of cooling 12 system or other specified plant or site characteristics. 13 A single significance level (i.e., SMALL, MODERATE, 14 or LARGE) has been assigned to the impacts, except 15 for collective offsite radiological impacts from the fuel 16 cycle and from high -level waste and spent fuel 17 disposal. 18 Mitigation of adverse impacts associated with the 19 issue is considered in the analysis, and it has been 20 determined that additional plant -specific mitigation 21 measures are likely not to be sufficiently beneficial to 22 warrant implementation. 23 For Catego ry 1 issues, no additional site -specific analysis is required in this SEIS unless new 24 and significant information is identified. Chapter 4 of this report presents the process for 25 identifying new and significant information. Site -specific issues (Category

2) are those that do 26 not meet one or more of the criterion for Category 1 issues; therefore, an additional site

-specific 27 review for these non -generic issues is required, and the results are documented in the SEIS. 28 On June 20, 2013, the NRC published a final rule (78 FR 37282) revising its environmental 29 protection regulation, 10 CFR Part 51, "Environmental Protection Regulations for Domestic 30 Licensing and Related Regulatory Functions." The final rule updates the potential 31 environmental impacts associated with the renewal of an operating license for a nuclear power 32 reactor for an additional 20 years. A revised GEIS, which updates the 1996 GEIS, provides the 33 technical basis for the final rule. The revised GEIS specifically supports the revised list of NEPA 34 issues and associated environmental impact findings for license renewal contained in Table B-1 35 in Appendix B to Subpart A of the revised 10 CFR Part 51. The final rule consolidates similar 36 Category 1 and 2 issues, changes some Category 2 issues into Category 1 issues, and 37 consolidates some of those issues with existing Category 1 issues. The final rule also adds new 38 Category 1 and 2 issues. 39 The final rule became effective 30 days after publication in the Federal Register. Compliance 40 by license renewal applicants is not required until 1 year from the date of publication 41 (i.e., license renewal environmental reports submitted later than 1 year after publication must be 42 compliant with the new rule). Nevertheless, under NEPA, the NRC must now consider and 43 analyze, in its license renewal SEISs, the potential significant impacts described by the revised 44 SMALL: Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource. MODERATE: Environmental effects are sufficient to alter noticeably, but not to destabilize, important attributes of the resource. LARGE: Environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource.

Executive Summary xvii rule's new Category 2 issues, and to the extent there is any new and significant information, the 1 potential significant impacts described by the revised rule's new Category 1 issues. 2 The NRC staff has reviewed Entergy's established process for identifying and evaluating the 3 significance of any new and significant information (including the consideration and analysis of 4 new issues associated with the recently approved revision to 10 CFR Part 51) on the 5 environmental impacts of license renewal of GGNS. Neither Entergy nor NRC identified 6 information that is both new and significant related to Category 1 issues that would call into 7 question the conclusions in the GEIS. This conclusion is supported by NRC's review of the 8 applicant's ER, other documentation relevant to the applicant's activities, the public scoping 9 process and substantive comments raised, and the findings from the environmental site audit 10 conducted by NRC staff. Further, the NRC staff did not identify any new issues applicable to 11 GGNS that have a significant environmental impact. The NRC staff, therefore, relies upon the 12 conclusions of the GEIS for all Category 1 issues applicable to GGNS. 13 Table ES-1 summarizes the Category 2 issues applicable to GGNS, if any, as well as the NRC 14 staff's findings related to those issues. If the NRC staff determined that there were no 15 Category 2 issues applicable for a particular resource area, the findings of the GEIS, as 16 documented in Appendix B to Subpart A of 10 CFR Part 51, stand. 17 Table ES-1. NRC Conclusions Relating to Site -Specific Impacts of License Renewal 18 Resource Area Relevant Category 2 Issues Adverse Impacts Land Use None SMALL Air Quality None SMALL Geology and Soils None SMALL Surface Water Resources None SMALL Groundwater Resources Groundwater use conflicts Radionuclides released to groundwater SMALL SMALL Aquatic Resources None SMALL Terrestrial Resources Non-cooling system impacts SMALL Protected Species Threatened or endangered species No effect/ may affect, but is not likely to adversely affect(a) Human Health Issues Electromagnetic fields -acute effects SMALL Socioeconomics Housing Impacts Public services (public utilities) Offsite land use Public services (public transportation) Historic & archaeological resources SMALL Cumulative Impacts Aquatic Resources Terrestrial Resources Protected Species & Habitats All other evaluated resources MODERATE MODERATE May affect, but is not likely to adversely affect(a) SMALL (a): For Federally protected species, the GEIS and the final rule state that, in complying with the Endangered Species Act (ESA), the NRC will report the effects of continued operations and refurbishment in terms of its ESA findings, which varies by species for GGNS. With respect to environmental justice, the NRC staff has determined that there would be no 19 disproportionately high and adverse impacts to these populations from the continued operation 20 of GGNS during the license renewal period. Additionally, the NRC staff has determined that no 21 Executive Summary xviii disproportionately high and adverse human health impacts would be expected in special 1 pathway receptor populations in the region as a result of subsistence consumption of water, 2 local food, fish, and wildlife. 3 SEVERE ACCIDENT MITIGATION ALTERNATIVES 4 Since GGNS had not previously considered alternatives to reduce the likelihood or potential 5 consequences of a variety of highly uncommon, but potentially serious, accidents at GGNS, 6 10 CFR 51.53(c)(3)(ii)(L) requires that Entergy evaluate severe accident mitigation alternative s 7 (SAMAs) in the course of the license renewal review. SAMAs are potential ways to reduce the 8 risk or potential impacts of uncommon, but potentially severe accidents, and they may include 9 changes to plant components, systems, procedures, and training. 10 The NRC staff reviewed the ER's evaluation of potential SAMAs. Based on the staff's review, 11 the NRC staff concluded that none of the potentially cost beneficial SAMAs relate to adequately 12 managing the effects of aging during the period of extended operation. Therefore, they need 13 not be implemented as part of the license renewal, pursuant to 10 CFR Part 54. 14 ALTERNATIVES 15 The NRC staff considered the environmental impacts associated with alternatives to license 16 renewal. These alternatives include other methods of power generation and not renewing the 17 GGNS operating license (the no -action alternative). Replacement power options considered 18 were as follows: 19 new nuclear generation, 20 natural gas -fired combined -cycle generation, 21 supercritical pulverized coal -fired generation, and 22 combination alternative. 23 The NRC staff initially considered a number of additional alternatives for analysis as alternatives 24 to license renewal of GGNS; these were later dismissed due to technical, resource availability, 25 or commercial limitations that currently exist and that the NRC staff believes are likely to 26 continue to exist when the existing GGNS license expire. The no -action alternative by the NRC 27 staff, and the effects it would have, were also considered. Where possible, the NRC staff 28 evaluated potential environmental impacts for these alternatives located both at the GGNS site 29 and at some other unspecified alternate location. Alternatives considered, but dismissed, were 30 as follows: 31 energy conservation and energy efficiency, 32 wind power, 33 solar power, 34 hydroelectric power, 35 wave and ocean energy, 36 geothermal power, 37 municipal solid waste, 38 biomass, 39 oil-fired power, 40 fuel cells, 41 purchased power, and 42 delayed retirement. 43 Executive Summary xix The NRC staff evaluated each alternative using the same impact areas that were used in 1 evaluating impacts from license renewal. 2 RECOMMENDATION 3 The NRC's preliminary recommendation is that the adverse environmental impacts of license 4 renewal for GGNS are not great enough to deny the option of license renewal for 5 energy-planning decisionmakers. This recommendation is based on the followin g: 6 analysis and findings in the GEIS, 7 ER submitted by Entergy, 8 consultation with Federal, State, local, and Tribal government agencies, 9 NRC staff's own independent review, and 10 consideration of public comments received during the scoping process. 11

xxi ABBREVIATIONS AND ACRONYMS 1 °C degree(s) Celsius 2 °F degree(s) Fahrenheit 3 AADT average annual daily traffic 4 AAI American Aquatics, Inc. 5 ac acre(s) 6 ACAA American Coal Ash Association 7 ACC averted cleanup and decontamination costs 8 ACHP Advisory Council on Historic Preservation 9 ADAMS Agencywide Documents Access and Management System 10 AEA Atomic Energy Authority 11 AEC U.S. Atomic Energy Commission 12 ALARA as low as is reasonably achievable 13 ANL Argonne National Laboratory 14 ANS American Nuclear Society 15 AOC averted offsite property damage costs 16 AOE averted occupation exposure 17 AOSC averted onsite costs 18 APE averted public exposure 19 AQCR air quality control region 20 AQRV air quality related values 21 ARI Alternative Resources, Inc. 22 ASME American Society of Mechanical Engineering 23 BACT Best Available Control Technology 24 BEA U.S. Bureau of Economic Analysis 25 BLM Bureau of Land Management 26 BLS U.S. Bureau of Labor Statistics 27 BMPs best management practices 28 BP before present 29 B tu British thermal unit(s) 30 B tu/kWh British thermal units per kilowatt -hour 31 B tu/lb British thermal units per pound 32 BWR boiling water reactor 33 BWROG BWR Owners Group 34 Abbreviations and Acronyms xxii CAA Clean Air Act 1 CAES compressed air energy storage 2 CAPS Circular Area Profiling System 3 CCDPs conditional core damage probabilities 4 CCP coal combustion products 5 CDF core damage frequency 6 CDM Clean Development Mechanism 7 C eq/kWh carbon equivalent per kilowatt -hour 8 CEQ Council on Environmental Quality 9 CET containment event tree 10 CFR Code of Federal Regulations 11 cfs cubic feet per second 12 CH4 methane 13 cm centimeter(s) 14 CNWRA Center for Nuclear Waste Regulatory Analyses 15 CO carbon monoxide 16 CO2 carbon dioxide 17 CO 2e carbon dioxide equivalent 18 COE cost of enhancement 19 COL combined license 20 CP construction permit 21 CS&I Crossroads, Shiloh & Ingleside 22 CWA Clean Water Act 23 CZMA Coastal Zone Management Act 24 dBA decibels adjusted 25 DBA design-basis accident 26 DC direct current 27 DOE U.S. Department of Energy 28 DOT Department of Transportation 29 DSEIS draft Supplemental Environmental Impact Statement 30 DSM demand-side management 31 EA Environmental Assessment 32 EAC Electricity Advisory Committee 33 EDG emergency diesel generator 34 EHV Extra High Voltage 35 Abbreviations and Acronyms xxiii EIA Energy Information Administration 1 EIS environmental impact statement 2 ELF-EMF extremely low frequency -electromagnetic field 3 EMI Entergy Mississippi, Inc 4 EMS environmental management systems 5 Entergy Entergy Operations, Inc. 6 EO Executive Order 7 EPA U.S. Environmental Protection Agency 8 EPCRA Emergency Planning and Community Right -to-Know Act 9 EPRI Electric Power Research Institute 10 EPU extended power uprate 11 ER Environmental Report 12 ESA Endangered Species Act of 1973, as amended 13 ESBWR Economic Simplified Boiling Water Reactor 14 ESP early site permit 15 FEIS final environmental impact statement 16 FEMA U.S. Federal Emergency Management Agency 17 FERC Federal Energy Regulatory Commission 18 FES final environmental statement 19 FIVE Fire-Induced Vulnerability Evaluation 20 FLMs Federal Land Managers 21 FONSI Finding of No Significant Impact 22 FR Federal Register 23 ft foot (feet) 24 ft/s feet per second 25 ft3 cubic feet 26 FWS U.S. Fish and Wildlife Service 27 gal gallon(s) 28 gal/yr gallons per year 29 GE General Electric 30 GEA Geothermal Energy Association 31 GEIS Generic Environmental Impact Statement for License Renewal of 32 Nuclear Power Plants, NUREG-1437 33 GGNS Grand Gulf Nuclear Station 34 GHG greenhouse gas 35 Abbreviations and Acronyms xxiv GI Generic Issue 1 gpd gallons per day 2 gpm gallons per minute 3 GSI Generic Safety Issue 4 GW gigawatt(s) 5 GWh gigawatthour(s) 6 ha hectare(s) 7 HAPs hazardous air pollutan ts 8 H/E high early 9 HFCs hydrofluorocarbons 10 HMR Hydro Meteorological Reports 11 HPCS high-pressure core spray 12 HVAC heating, ventilation, and air conditioning 13 IAEA International Atomic Energy Agency 14 IEEE Institute of Electrical and Electronics Engineers 15 IGCC integrated gasification combined-cycle 16 in. inch(es) 17 INEEL Idaho National Engineering and Environmental Laboratory 18 IPCC Intergovernmental Panel on Climate Change 19 IPE individual plant examination 20 IPEEE individual plant examination of external events 21 ISFSI Independent Spent Fuel Storage Installation 22 kg kilogram(s) 23 km kilometer(s) 24 km 2 square kilometers 25 kV kilovolt(s) 26 kWh kilowatthour(s) 27 lb pound(s) 28 lb/MWh pounds per megawatthour 29 LERF large early release frequency 30 LOCA Loss of Coolant Accident 31 LOSP loss of offsite power 32 LRA license renewal application 33 m meter(s) 34 m/s meters per second 35 Abbreviations and Acronyms xxv m 2 square meters 1 m3 cubic meters 2 m 3/s cubic meters per second 3 m 3/yr cubic meters per year 4 mA milliampere(s) 5 MAAP Modular Accident Analysis Program 6 MACCS2 MELCOR Accident Consequence Code System 2 7 MBTA Migratory Bird Treaty Act of 1918, as amended 8 MCEQ Mississippi Commission on Environmental Quality 9 MCR model change request 10 MDAH Mississippi Department of Archives and History 11 MDEQ Mississippi Department of Environmental Quality 12 MDES Mississippi Department of Employment Security 13 MDH Mississippi Department of Health 14 MDEQ Mississippi Department of Environmental Quality 15 MDOT Mississippi Department of Transportation 16 MDWFP Mississippi Department of Wildlife, Fisheries, and Parks 17 mg/L milligrams per liter 18 mGy milligray 19 mi mile(s) 20 mi 2 square miles 21 MIHL Mississippi Institutions of Higher Learning 22 millirem milliroentgen equivalent man 23 mm millimeter(s) 24 MMB tu/MWh one million Btu per megawatthour 25 MMNS Mississippi Museum of Natural Science 26 MNHP Mississippi Natural Heritage Program 27 MMPA Ma rine Mammal Protection Act 28 MP&L Mississippi Power & Light Company 29 mph miles per hour 30 mrad milliradiation absorbed dose 31 mrem milliroentgen equivalent man 32 MSA Magnuson-Stevens Fishery Conservation and Management Act, 33 as amended through January 12, 2007 34 MSCEQ Mississippi Commission of Environmental Quality 35 Abbreviations and Acronyms xxvi MSL mean sea level 1 mSv millisievert 2 MT metric ton(s) 3 MTHM metric ton of heavy metal 4 MWd/MTU megawatt-days per metric ton of uranium 5 MWe megawatt(s) electrical 6 MWt megawatt(s) thermal 7 N 2 O nitrous oxide 8 NAAQS National Ambient Air Quality Standards 9 NAS National Academy of Sciences 10 NASS National Agricultural Statistics Service 11 NCDC National Climatic Data Center 12 NCES National Center for Education Statistics 13 NCF no containment failure 14 NEA Nuclear Energy Agency 15 NEI Nuclear Energy Institute 16 NEPA National Environmental Policy Act 17 NESC National Electrical Safety Code 18 NETL National Energy Technology Laboratory 19 NGCC natural-gas-fired combined-cycle 20 NHPA National Historic Preservation Act 21 NIEHS National Institute of Environmental Health Sciences 22 NMFS National Marine Fisheries Service 23 NOAA National Oceanic and Atmospheric Administration 24 NO x nitrogen oxide(s) 25 NPDES National Pollution Discharge Elimination System 26 NRC U.S. Nuclear Regulatory Commission 27 NRCS National Resources Conservation Service 28 NREL National Renewable Energy Laboratory 29 NRHP National Register of Historic Places 30 NRR Office of Nuclear Reactor Regulation 31 NS Nuclear Station 32 NUREG NRC technical report designation (Nuclear Regulatory 33 Commission) 34 O 3 ozone 35 Abbreviations and Acronyms xxvii ODCM Offsite Dose Calculation Manual 1 OECD Organization for Economic Co -operation and Development 2 OECR offsite economic cost risk 3 PAH polycyclic aromatic hydrocarbon 4 Pb lead 5 pCi/L picocuries per liter 6 PDR population dose risk 7 PDS plant damage state 8 PFCs perfluorocarbons 9 pH hydrogen-ion concentration 10 PM 10 11 PM2.5 12 PMP probably maximum precipitation 13 PNNL Pacific Northwest National Laboratory 14 POST Parliamentary Office of Science and Technology 15 p pb parts per billion 16 p pm parts per million 17 PRA probabilistic risk assessment 18 PSA probabilistic safety assessment 19 PSD Prevention of Significant Deterioration 20 RAI request for additional information 21 RC release category 22 RCRA Resource Conservation and Recovery Act of 1976 23 REMP radiological environmental monitoring program 24 RES Nuclear Regulatory Research, Office of 25 RLE review level earthquake 26 RM river mile(s) 27 ROI region of influence 28 ROW(s) right(s)-of-way 29 RPC replacement power cost 30 RPSEA Research Partnership to Secure Energy for America 31 RPV reactor pressure vessel 32 RRW risk reduction worth 33 SAAQS State Ambient Air Quality Standards 34 SAMA Severe Accident Mitigation Alternative 35 Abbreviations and Acronyms xxviii SAR safety analysis report 1 SCPC supercritical pulverized coal 2 SDWA Safe Drinking Water Act 3 SEIS supplemental environmental impact statement 4 SERI System Energy Resources, Inc. 5 SF 6 sulfur hexafluoride 6 SHPO State Historic Preservation Office 7 SMA seismic margins assessment 8 SNL Sandia National Laboratory 9 SO 2 sulfur dioxide 10 SO x sulfur oxide(s) 11 SRP Standard Review Plan 12 SSCs systems, structures, and components 13 SSE safe shutdown earthquake 14 SSW standby service water 15 State State of Mississippi 16 Sv sievert(s) 17 TCPA Texas Comptroller of Public Accounts 18 TEEIC Tribal Energy and Environmental Information Center 19 TPWD Texas Parks and Wildlife Department 20 TSS total suspended solids 21 U.S. United States 22 U.S.C. United States Code 23 USACE U.S. Army Corps of Engineers 24 USCB U.S. Census Bureau 25 USDA U.S. Department of Agriculture 26 USFS U.S. Forest Service 27 USFWS U.S. Fish & Wildlife Service 28 USGCRP U.S. Global Change Research Program 29 USGS U.S. Geological Survey 30 USOWC U.S. Offshore Wind Collaborative 31 VOCs volatile organic compounds 32 WCD Waste Confidence Decision Rule 33 1-1 1.0 PURPOSE AND NEED FOR ACTION 1 Under the U.S. Nuclear Regulatory Commission's (NRC's) environmental protection regulations 2 in Title 10 of the Code of Federal Regulations Part 51 (10 CFR Part 51) -which carry out the 3 National Environmental Policy Act (NEPA)-renewal of a nuclear power plant operating license 4 requires the preparation of an environmental impact statement (EIS). 5 The Atomic Energy Act of 1954 originally specified that licenses for commercial power reactors 6 be granted for up to 40 years. The 40 -year licensing period was based on economic and 7 antitrust considerations rather than on technical limitations of the nuclear facility. 8 The decision to seek a license renewal rests entirely with nuclear power facility owners and, 9 typically, is based on the facility's economic viability and the investment necessary to continue 10 to meet NRC safety and environmental requirements. The NRC makes the decision to grant or 11 deny license renewal based on whether the applicant has demonstrated that the environmental 12 and safety requirements in the agency's regulations can be met during the period of extended 13 operation. 14 1.1 Proposed Federal Action 15 Entergy Operations , Inc. (Entergy) initiated the proposed F ederal action by submitting an 16 application for license renewal of Grand Gulf Nuclear Station, Unit 1 (GGNS), for which the 17 existing license (NPF-29) expire s on November 1, 2024. The NRC's Federal action is the 18 decision whether to renew the license for an additional 20 years. 19 1.2 Purpose and Need for the Proposed Federal Action 20 The purpose and need for the proposed action (decision whether to renew the license) is to 21 provide an option that allows for power generation capability beyond the term of a current 22 nuclear power plant operating license to meet future system generating needs, as such needs 23 may be determined by other energy -planning decision -makers. This definition of purpose and 24 need reflects the Commission's recognition that, unless there are findings in the safety review 25 required by the Atomic Energy Act or findings in the NEPA environmental analysis that would 26 lead the NRC to reject a license renewal application, the NRC does not have a role in the 27 energy-planning decisions of State regulators and utility officials as to whether a particular 28 nuclear power plant should continue to operate. 29 If a renewed license is issued, State regulatory agencies and Entergy will ultimately decide 30 whether the plant will continue to operate based on factors such as the need for power or other 31 matters within the State's jurisdiction or the purview of the owners. If a renewed license is 32 denied, then the facility must be shut down on or before the expiration date of the current 33 operating license -November 1, 2024. 34 Purpose and Need for Action 1-2 Figure 1-1. Environmental Review Process 1 1.3 Major Environmental Review Milestones 2 Entergy submitted an Environmental Report (ER) (Entergy 2011a) as part of its License 3 Renewal Application (Entergy 2011b) on November 1, 2011. After reviewing the application and 4 ER for sufficiency, the staff published a Federal Register Notice of Acceptability and Opportunity 5 for Hearing (76 FR 80980) on December 27, 2011. Then, o n December 29, 2011 , the NRC 6 published another notice in the Federal Register (76 FR 81996) on the intent to conduct 7 scoping, thereby beginning the 60-day scoping period. 8 Two public scoping meetings were held on January 31, 2012, in Port Gibson, Mississippi 9 (NRC 2012a). The comments received during the scoping process are presented in 10 NRC staff reviews application Staff conduct s environmental site audit NRC issues draft SEIS Company submits an application to NRC *Scoping Process *Draft SEIS Process NRC issues final SEIS NRC decision on whether to renew license

• Opportunity for Public Involvement

Purpose and Need for Action 1-3 "Environmental Impact Statement, Scoping Process, Summary Report," published in April 2013 1 (NRC 2013 a). The scoping process summary report presents NRC responses to comments 2 that the NRC staff considered to be out -of-scope of the environmental license renewal review. 3 The comments considered within the scope of the environmental license renewal review and the 4 NRC responses are presented in Appendix A of this supplemental environmental impact 5 statement (SEIS). 6 In order to independently verify information provided in the ER, NRC staff conducted a site audit 7 at GGNS in March 2012. During the site audit, NRC staff met with plant personnel, reviewed 8 specific documentation, toured the facility, and met with interested Federal, State, and local 9 agencies. A summary of that site audit is contained in "Summary of Site Audit Related to the 10 Environmental Review of the License Renewal Application for Grand Gulf Nuclear Station, 11 Unit 1," published in May 2012 (NRC 2012b). 12 Upon completion of the scoping period and site audit, NRC staff compiled its findings in a draft 13 SEIS (Figure 1 -1). This document is made available for public comment for 45 days. During 14 this time, NRC staff will host public meetings and collect public comments. Based on the 15 information gathered, the NRC staff will amend the draft SEIS findings as necessary, and 16 publish the final SEIS. 17 The NRC has established a license renewal process that can be completed in a reasonable 18 period of time with clear requirements to assure safe plant operation for up to an additional 19 20 years of plant life. The safety review, which documents its finding in a Safety Evaluation 20 Report, is conducted simultaneously with the environmental review. The findings in both the 21 SEIS and the Safety Evaluation Report are factors in the Commission's decision to either grant 22 or deny the issuance of a renewed license. 23 1.4 Generic Environmental Impact Statement 24 The NRC performed a generic assessment of the environmental impacts associated with 25 license renewal to improve the efficiency of the license renewal process. The Generic 26 Environmental Impact Statement for License Renewal of Nuclear Power Plants, NUREG-1437 27 (GEIS) (NRC 1996, 1999) documented the results of the NRC staff's systematic approach to 28 evaluate the environmental consequences of renewing the licenses of individual nuclear power 29 plants and operating them for an additional 20 years. NRC staff analyzed in detail and resolved 30 those environmental issues that could be resolved generically in the GEIS. 31 The GEIS established 92 separate issues for NRC staff to independently verify. Of these 32 issues, NRC staff determined that 69 are generic to all plants (Category 1) while 21 issues do 33 not lend themselves to generic consideration (Category 2). Two other issues remained 34 uncategorized; environmental justice and chronic effects of electromagnetic fields, and must be 35 evaluated on a site -specific basis. A list of all 92 issues can be found in Appendix B. 36 For each potential environmental issue, the GEIS: 37 (1) describes the activity that affects the environment, 38 (2) identifies the population or resource that is affected, 39 (3) assesses the nature and magnitude of the impact on the affected population or 40 resource, 41 (4) characterizes the significance of the effect for both beneficial and adverse effects, 42 (5) determines whether the results of the analysis apply to all plants, and 43 Purpose and Need for Action 1-4 (6) considers whether additional mitigation measures would be warranted for impacts 1 that would have the same significance level for all plants. 2 The NRC's standard of significance for impacts was established using the Council on 3 Environmental Quality (CEQ) terminology for "significant." The NRC established three levels of 4 significance for potential impacts: SMALL, MODERATE, and LARGE, as defined below. 5 SMALL: Environmental effects are not detectable 6 or are so minor that they will neither destabilize nor 7 noticeably alter any important attribute of the 8 resource. 9 MODERATE: Environmental effects are sufficient 10 to alter noticeably, but not to destabilize, important 11 attributes of the resource. 12 LARGE: Environmental effects are clearly 13 noticeable and are sufficient to destabilize important 14 attributes of the resource. 15 The GEIS includes a determination of whether the analysis of the environmental issue could be 16 applied to all plants and whether additional mitigation measures would be warranted 17 (Figure 1-2). Issues are assigned a Category 1 or a Category 2 designation. As set forth in the 18 GEIS, Category 1 issues are those that meet the following criteria: 19 (1) The environmental impacts associated with the issue have been determined 20 to apply either to all plants or, for some issues, to plants having a specific 21 type of cooling system or other specified plant or site characteristics. 22 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been 23 assigned to the impacts (except for collective offsite radiological impacts from 24 the fuel cycle and from high -level waste and spent fuel disposal). 25 (3) Mitigation of adverse impacts associated with the issue has been considered 26 in the analysis, and it has been determined that additional plant -specific 27 mitigation measures are likely not to be sufficiently beneficial to warrant 28 implementation. 29 For generic issues (Category 1), no additional site -specific analysis is required in this SEIS 30 unless new and significant information is identified. The process for identifying new and 31 significant information is presented in Chapter 4. Site -specific issues (Category

2) are those 32 that do not meet one or more of the criteria of Category 1 issues, and therefore, additional 33 site-specific review for these issues is required. The results of that site-specific review are 34 documented in the SEIS. 35 Significance indicates the importance of likely environmental impacts and is determined by considering two variables:

context and intensity. Context is the geographic, biophysical, and social context in which the effects will occur. Intensity refers to the severity of the impact, in whatever context it occurs . Purpose and Need for Action 1-5 Figure 1-2. Environmental Issues Evaluated During License Renewal 1 The NRC staff initially evaluated 92 issues in the GEIS. Based on the findings of the GEIS, a 2 site-specific analysis is required for 23 of those 92 issues. 3 On June 20, 2013, the NRC published a final rule (78 FR 37282) revising its environmental 4 protection regulation, Title 10 of the Code of Federal Regulations (10 CFR) Part 51, 5 "Environmental Protection Regulations for Domestic Licensing and Related Regulatory 6 Functions." Specifically, the final rule update s the potential environmental impacts associated 7 with the renewal of an operating license for a nuclear power reactor for an additional 20 years. 8 A revised GEIS (NRC 2013b), which updates the 1996 GEIS, provides the technical basis for 9 the final rule. The revised GEIS specifically supports the revised list of NEPA issues and 10 associated environmental impact findings for license renewal contained in Table B-1 in 11 Appendix B to Subpart A of the revised 10 CFR Part 51. The revised GEIS and final rule reflect 12 lessons learned and knowledge gained during previous license renewal environmental reviews. 13 In addition, public comments received on the draft revised GEIS and rule and during previous 14 license renewal environmental reviews were re -examined to validate existing environmental 15 issues and identify new ones. 16 The final rule identifies 78 environmental impact issues, of which 17 will require plant-specific 17 analysis. The final rule consolidates similar Category 1 and 2 issues, changes some 18 Category 2 issues into Category 1 issues, and consolidates some of those issues with existing 19 Category 1 issues. The final rule also adds new Category 1 and 2 issues. The new Category 1 20 Purpose and Need for Action 1-6 New and significant information either: (1) identifies a significant environmental issue not covered in the GEIS, or (2) was not considered in the analysis in the GEIS and leads to an impact finding that is different from the finding presented in the GEIS. issues include geology and soils, exposure of terrestrial organisms to radionuclides, exposure of 1 aquatic organisms to radionuclides, human health impact from chemicals, and physical 2 occupational hazards. Radionuclides released to groundwate r, effects on terrestrial resources 3 (non-cooling system impacts), minority and low -income populations (i.e., environmental justice), 4 and cumulative impacts were added as new Category 2 issues. 5 The final rule became effective 30 days after publication in the Federal Register. Compliance 6 by license renewal applicants is not required until 1 year from the date of publication 7 (i.e., license renewal environmental reports submitted later than 1 year after publication must be 8 compliant with the new rule). Nevertheless, under NEPA, the NRC must now consider and 9 analyze, in its license renewal SEISs, the potential significant impacts described by the final 10 rule's new Category 2 issues and, to the extent there is any new and significant information, the 11 potential significant impacts described by the final rule's new Category 1 issues. 12 1.5 Supplemental Environmental Impact Statement 13 The SEIS presents an analysis that considers the environmental effects of the continued 14 operation of GGNS, alternatives to license renewal, and mitigation measures for minimizing 15 adverse environmental impacts. Chapter 8 contains analysis and comparison of the potential 16 environmental impacts from alternatives while Chapter 9 presents the staff's preliminary 17 recommendation to the Commission on whether or not the environmental impacts of license 18 renewal are so great that preserving the option of license renewal would be unreasonable. The 19 recommendation includes consideration of comments received during the public scoping period. 20 In the preparation of this SEIS for GGNS, the staff: 21 reviewed the information provided in Entergy's ER, 22 consulted with other Federal, State, and local agencies, 23 conducted an independent review of the issues during a site audit, and 24 considered the public comments received during the scoping process. 25 New information can be identified from a 26 number of sources, including the applicant, 27 NRC, other agencies, or public comments. If a 28 new issue is revealed, then it is first analyzed to 29 determine whether it is within the scope of the 30 license renewal evaluation. If it is not 31 addressed in the GEIS then the NRC 32 determines its significance and documents its 33 analysis in the SEIS. 34 1.6 Cooperating Agencies 35 During the scoping process, no Federal, State, or local agencies were identified as cooperating 36 agencies in the preparation of this SEIS. 37 1.7 Consultations 38 The Endangered Species Act of 1973, as amended; the Magnuson-Stevens Fisheries 39 Management Act of 1996, as amended; and the National Historic Preservation Act of 1966 40 require that Federal agencies consult with applicable State and Federal agencies and groups 41 Purpose and Need for Action 1-7 prior to taking action that may affect endangered species, fisheries, or historic and 1 archaeological resources, respectively. Below are the agencies and groups with whom the 2 NRC consulted; Appendix D to this report includes copies of consultation documents. 3 Advisory Council on Historic Preservation 4 National Marine Fisheries Service 5 U.S. Fish and Wildlife Service, Mississippi Field Office 6 U.S. Fish and Wildlife Service, Louisiana Field Office 7 Mississippi Band of Choctaw Indians 8 Jena Band of Choctaw Indians 9 Choctaw Nation of Oklahoma 10 Tunica-Biloxi Tribe of Louisiana 11 1.8 Correspondence 12 During the course of the environmental review, the NRC staff contacted the Federal, State, 13 regional, local, and tribal agencies listed in Section 1.7, as well as the following: 14 Mississippi Department of Archives and History 15 Louisiana Division of Historic Preservation 16 Mississippi Natural Heritage Program 17 Louisiana Natural Heritage Program 18 Appendix E contains a chronological list of all the documents sent and received during the 19 environmental review. 20 A list of persons who received a copy of this SEIS is provided in Chapter

11. 21 1.9 Status of Compliance 22 Entergy is responsible for complying with all NRC regulations and other applicable Federal, 23 State, and local requirements. A description of some of the major Federal statutes can be found 24 in Appendix H of the GEIS. Appendix C to this SEIS includes a list of the permits and licenses 25 issued by Federal, State, and local authorities for activities at GGNS.

26 1.10 References 27 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 28 Protection Regulations for Domestic Licensing and Related Regulator Activities." 29 76 FR 80980. U.S. Nuclear Regulatory Commission, Washington DC, "Notice of Acceptance for 30 Docketing of the Application and Notice of Opportunity for Hearing Regarding Renewal of 31 Facility Operating License No. NPF -29 for an Additional 20 -Year Period, Entergy Operations, 32 Inc., Grand Gulf Nuclear Station." Federal Register 76(248): 80980-80982, December 27, 2011. 33 76 FR 81996. U.S. Nuclear Regulatory Commission, Washington DC, "Entergy Operations, Inc.; 34 Notice of Intent To Prepare an Environmental Impact Statement and Conduct Scoping Process 35 for Grand Gulf Nuclear Station, Unit 1." Federal Register 76(250): 81996 -81998, December 29, 36 2011. 37 78 FR 37282. U.S. Nuclear Regulatory Commission. "Revisions to Environmental Review for 38 Renewal of Nuclear Power Plant Operating Licenses. " Federal Register 78(119): 37282 -37324. 39 June 20, 2013. 40 Atomic Energy Act of 1954. 42 U.S.C. §2011, et seq. 41 Purpose and Need for Action 1-8 Endangered Species Act of 1973, as amended. 16 U.S.C. §1531, et seq. 1 [Entergy] Entergy Operations, Inc. 2011

a. Grand Gulf Nuclear Station, Unit 1, License Renewal 2 Application , Appendix E, Applicant's Environmental Report, Operating License Renewal Stage. 3 Agencywide Documents Access and Management System (ADAMS) Accession 4 No. ML11308A234.

5 [Entergy] Entergy Operations, Inc. 2011b. Grand Gulf Nuclear Station, Unit 1 -License Renewal 6 Application. October 2011. ADAMS Accession No. ML11308A101. 7 Magnuson-Stevens Fishery Conservation and Management Act, as amended by the 8 Sustainable Fisheries Act of 1996. 16 U.S.C. §1855, et seq. 9 National Environmental Policy Act of 1969, as amended. 42 U.S.C. §4321, et seq. 10 National Historic Preservation Act of 1966. 16 U.S.C. §470, et seq. 11 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 12 for License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2. Washington DC. 13 May 1996. ADAMS Accession Nos. ML040690705 and ML040690738. 14 [NRC] U.S. Nuclear Regulatory Commission. 1999. Generic Environmental Impact Statement 15 for License Renewal of Nuclear Plants, Main Report, "Section 6.3 -Transportation, Table 9.1, 16 Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final 17 Report, NUREG -1437, Volume 1, Addendum 1. Washington DC. August 1999. ADAMS 18 Accession No. ML04069 0 720. 19 [NRC] U.S. Nuclear Regulatory Commission. 2012a. "Summary of Public Scoping Meetings 20 Conducted on January 31, 2012, Related to the Review of the Grand Gulf Nuclear Station, 21 Unit 1, License Renewal Application." February 2012. ADAMS Accession No. ML12044A151. 22 [NRC] U.S. Nuclear Regulatory Commission. 2012b. "Summary of Site Audit Related to the 23 Environmental Review of the License Renewal Application for Grand Gulf Nuclear Station, 24 Unit 1." May 21, 2012. ADAMS Accession No. ML12116A060. 25 [NRC] U.S. Nuclear Regulatory Commission. 2012c. Staff Requirements, SECY 0063 - Final 26 Rule: Revisions to Environmental Review for Renewal of Nuclear Power Plant Operating 27 Licenses (10 CFR Part 51; RIN 3150 -AI42). December 6, 2012. ADAMS Accession 28 No. ML12341A134. 29 [NRC] U.S. Nuclear Regulatory Commission. 2013a. "Environmental Impact Statement, Scoping 30 Process, Summary Report," April 2013. ADAMS Accession No. ML12201A623. 31 [NRC] U.S. Nuclear Regulatory Commission. 2013

b. Generic Environmental Impact Statement 32 for License Renewal of Nuclear Plants. Washington, DC: Office of Nuclear Reactor Regulation.

33 NUREG-1437, Revision 1, Volumes 1, 2, and 3. June 2013. ADAMS Accession Nos. 34 ML13106A241, ML13106A242, and ML13106A244. 35 2-1 2.0 AFFECTED ENVIRONMENT 1 Grand Gulf Nuclear Station (GGNS) is located in Claiborne County, Mississippi, on the east 2 bank of the Mississippi River, approximately 25 miles (mi) (39 kilometers (km)) south-southwest 3 of Vicksburg, Mississippi. Figure 2 -1 and Figure 2 -2 present the 50-mi (80-km) and 6-mi 4 (10-km) vicinity maps, respectively. In this supplemental environmental impact statement 5 (SEIS), the "affected environment" is the environment that currently exists at and around GGNS. 6 Because existing conditions are at least partially the result of past construction and operation at 7 the plant, the impacts of these past and ongoing actions, and how they have shaped the 8 environment, are presented here. Section 2.1 of this SEIS describes the facility and its 9 operation, and Section

2.2 discusses

the affected environment. 10 2.1 Facility Description 11 GGNS is a single -unit nuclear power plant that began commercial operation in July 1985. 12 The property boundary shown in Figure 2 -3 encloses approximately 2,100 acres (ac), or 13 850 hectares (ha). Currently, the property is approximately 2,015 ac (816 ha) because of the 14 loss of approximately 85 ac (34 ha) from erosion by the Mississippi River (Entergy 2011a ). The 15 original application submitted in 1972 for GGNS was for a two -unit nuclear power facility. 16 Construction on Unit 2 was halted before completion in 1979. The majority of the Unit 2 power 17 block buildings were completed, along with the outer cylindrical concrete wall of the reactor 18 containment building. The switchyard was designed and constructed for two units 19 (NRC 2006 a). 20 The most conspicuous structures on the GGNS site include the natural draft cooling tower, the 21 turbine building, the Unit 1 reactor containment building, the Unit 2 (cancelled) reactor 22 containment outer cylindrical concrete wall, the auxiliary cooling tower, and various other 23 buildings. 24 2.1.1 Reactor and Containment Systems 25 The GGNS nuclear reactor system is a single -cycle, forced -circulation, General Electric Mark III 26 boiling water reactor (BWR). The reactor core heats water to make steam that is dried by steam 27 separators and dryers located in the upper portion of the reactor vessel. The steam is then 28 directed to the main turbine through the main steam lines where it turns the turbine generator to 29 produce electricity. 30 Fuel for GGNS is made of low-enrichment (less than 5 percent by weight) high -density ceramic 31 uranium dioxide fuel pellets, with a maximum average burnup level of less than 32 62,000 megawatt-days/metric ton of uranium. GGNS operates on an 18 -month refueling cycle 33 and plans to switch to a 24 -month refueling cycle in the future. 34 The functional design basis of the containment, including its penetrations and isolation valves, is 35 to contain, with adequate design margin, the energy released from a design basis 36 loss-of-coolant accident. It also provide s a leak-tight barrier against the uncontrolled release of 37 radioactivity to the environment, even assuming a partial loss of engineered safety features. 38 The reactor and related systems are enclosed in containment and enclosure structures. The 39 containment structure encloses the reactor coolant system, drywell, suppression pool, upper 40 pool, and some of the engineered safety feature systems and supporting systems. The 41 enclosure building and auxiliary building are combined to form a secondary containment which 42 Affected Environment 2-2 Figure 2-1. Location of GGNS, 50 -mi (80-km) Vicinity 1 Source: Entergy 2011a 2 Affected Environment 2-3 Figure 2-2. Location of GGNS, 6 -mi (10-km) Vicinity 1 Source: Entergy 2011a 2 Affected Environment 2-4 Figure 2-3. GGNS, General Site Layout 1 Source: Modified from Entergy 2011a 2 Affected Environment 2-5 maintains a negative pressure in the volume between the containment and enclosure/auxiliary 1 building. These two containment systems and associated engineered safety features are 2 designed and maintained to minimize the release of airborne radioactive materials under 3 accident conditions. 4 2.1.2 Radioactive Waste Management 5 GGNS radioactive waste systems collect, treat, and dispose of radioactive wastes that are 6 byproducts of plant operations. These byproducts are activation products associated with 7 nuclear fission, reactor coolant activation, and non -coolant material activation. 8 Release of liquid and gaseous effluents are controlled to meet the limits specified in Title 9 10, Code of Federal Regulatio ns (CFR) Part 20 and 10 CFR Part 50, Appendix I, through the 10 Radioactive Effluent Controls Program defined in the GGN S technical specifications. Operation 11 procedures for the radioactive waste system s ensure that radioactive wastes are safely 12 processed and discharged from GGNS. The systems are designed and operated to ensure that 13 the quantities of radioactive materials released from GGNS are as low as is reasonably 14 achievable (ALARA) and within the dose standards set forth in 10 CFR Part 20, "Standards for 15 protection against radiation," and Appendix I to 10 CFR Part 50, "Domestic licensing of 16 production and utilization facilities." The GG NS Offsite Dose Calculation Manual (ODCM) 17 contains the methods and parameters used to calculate offsite doses resulting from radioactive 18 effluents. These methods are used to ensure that radioactive material discharges from GGN S 19 meet regulatory dose standards. 20 Radioactive wastes resulting from GGNS plant operations are classified as liquid, gaseous, or 21 solid. Liquid radioactive wastes are generated from liquids received directly from portions of the 22 reactor coolant system or were contaminated by contact with liquids from the reactor coolant 23 system. Gaseous radioactive wastes are generated from gases or airborne particulates vented 24 from reactor and turbine equipment containing radioactive material. Solid radioactive wastes 25 are solids from the reactor coolant system, solids that came into contact with reactor coolant 26 system liquids or gases, or solids used in the steam and power conversion system. 27 Reactor fuel that has exhausted a certain percentage of its fissile uranium content is referred to 28 as spent fuel. Spent fuel assemblies that are removed from the reactor core are replaced with 29 fresh fuel assemblies during routine refueling outages. Spent nuclear fuel from the GGNS 30 reactor is stored on site in a spent fuel pool and an independent spent fuel storage installation 31 (ISFSI) (Entergy 2011 a). 32 2.1.2.1 Radioactive Liquid Waste 33 The GGNS liquid radwaste system collects, processes, recycles, and disposes of potentially 34 radioactive wastes produced during operation of the plant. The liquid effluents from the liquid 35 radwaste system are monitored continuously, and the discharges are terminated if the effluents 36 exceed preset radioactivity levels, which are specified in the GGNS ODCM. The liquid radwaste 37 system is comp rised of a group of subsystems designed to collect and treat different types of 38 liquid waste, designated as the equipment drain processing subsystem (clean radwaste), floor 39 drain processing subsystem (dirty radwaste), chemical waste subsystem, and miscellaneous 40 supporting subsystems. 41 Liquid wastes that accumulate in radwaste drain tanks or in sumps are transferred to collection 42 and sample tanks in the radwaste building. The liquid wastes are processed through filters and 43 demineralizers and returned to the condensate system or released from the plant. 44 Control of discharges from the radwaste system includes a radiation monitor, an effluent flow 45 control valve, and dilution water flow rate monitoring equipment. Radioactive liquid wastes are 46 Affected Environment 2-6 subject to the sampling and analysis program described in the ODCM. This enables GGNS to 1 handle radioactive liquid releases in accordance with applicable regulations and impacts to 2 offsite areas will be consistent with ALARA concepts (Entergy 2011a ). 3 2.1.2.2 Radioactive Gaseous Waste 4 The gaseous radwaste system process es and control s the release of gaseous radioactive 5 effluents to the atmosphere. Gaseous effluents are released from the radwaste building vent, 6 the turbine building vent, the containment vent, the auxiliary vent, and standby gas treatment 7 system. 8 Radioactive gas is continuously removed from the main condenser by the air ejector during 9 plant operation. It is then filtered, cooled, and discharged to the environment. GGNS uses 10 continuous radiation monitors to ensure radioactive gaseous effluent discharges are within 11 specifications in the ODCM (Entergy 2011a). 12 2.1.2.3 Radioactive Solid Waste 13 The solid waste management system collects, processes, and packages solid radioactive 14 wastes for storage and offsite shipment and permanent disposal. GGNS has developed 15 long-term plans that would ensure radwaste generated during the license renewal term would 16 either be stored on site in existing structures or shipped to an offsite licensed facility for 17 processing and disposal. 18 Wet wastes are collected, dewatered, packaged in containers and stored before offsite 19 shipment. 20 Dry wastes usually consist of small tools, air filters, miscellaneous paper, rags, equipment parts 21 that cannot be effectively decontaminated, wood, and solid laboratory waste. Compressible 22 wastes can be shipped off site and compacted to reduce their volume. Noncompressible 23 wastes are packaged in appropriate containers. Because of its low radiation levels , this waste 24 can be stored until enough is accumulated to permit economic transportation off site for final 25 disposal or further processing. 26 GGNS currently transports radioactive waste to licensed processing facilities in Tennessee, 27 such as the Studsvik, Duratek (owned by EnergySolutions), or Race (owned by Studsvik) 28 facilities, where wastes are further processed before they are sent to a facility such as 29 EnergySolutions in Clive, Utah, for disposal. GGNS also may transport material from an offsite 30 processing facility to a disposal site or back to the plant site for reuse or storage. GGNS 31 radioactive waste shipments are packaged in accordance with both NRC and Department of 32 Transportation (DOT) requirements (Entergy 2011a). 33 2.1.2.4 Low-Level Mixed Wastes 34 Currently, no mixed waste s are generated or stored on the GGNS site. If they were, they would 35 be managed and transported to an offsite facility licensed to accept and manage the wastes in 36 accordance with appropriate GGNS and Entergy procedures (Entergy 2011a). 37 2.1.3 Nonradiological Waste Management 38 The Resource Conservation and Recovery Act of 1976 (RCRA) governs nonradioactive 39 hazardous and nonhazardous wastes produced at GGNS. The U.S. Environmental Protection 40 Agency (EPA) is ultimate ly responsib le for implementing RCRA and regulations governing the 41 disposal of solid and hazardous waste are contained in 40 CFR Parts 239-299. Specifically, 42 RCRA Subtitle D regulations for solid (nonhazardous) waste are contained in 43 40 CFR Parts 239-259. RCRA Subtitle C regulations for hazardous waste are contained in 44 Affected Environment 2-7 40 CFR Parts 260-279. RCRA Subtitle C establishes a system for controlling hazardous waste 1 from "cradle to grave ." RCRA Subtitle D encourages states to develop comprehensive plans to 2 manage nonhazardous solid waste and mandates minimum technological standards for 3 municipal solid waste landfills. EPA authorizes states to implement the RCRA hazardous wa ste 4 program through their rulemaking process. 5 EPA granted initial authorization to Mississippi to operate its hazardous waste program on 6 June 13, 1984. The Mississippi Department of Environmental Quality (MDEQ) administers the 7 State's hazardous waste regulations and address es the identification, generation, minimization, 8 transportation, and final treatment, storage, or disposal of hazardous and nonhazardous waste. 9 Mississippi's hazardous waste regulations can be found in MDEQ, Office of Pollution Control, 10 Hazardous Waste Management Regulations, HW -1. Mississippi's solid waste law is contained 11 in Chapter 17, "Solid Wastes Disposal Law of 1974 ," of Title 17, "Local Government; Provisions 12 Common to Counties and Municipalities. " As EPA amends its RCRA regulations, Mississippi 13 has amended its program to maintain consistency with the national standards. 14 2.1.3.1 Nonradioactive Waste Streams 15 GGNS generates nonradioactive waste as part of routine maintenance of equipment, cleaning 16 activities, and plant operations. Nonradioactive waste generated at GGNS include s batteries, 17 fluorescent lamps, scrap metals, used oil, used oil filters, used tires, electronics for 18 reconditioning, and equipment containing mercury. Nonhazardous waste generated at GGNS 19 consists of materials such as blasting media, oil contaminated wastes, wastewater, and 20 wastewater sludges. Hazardous waste generated at GGNS is usually a small percentage of the 21 total waste generated at the plant. Hazardous waste generated at GGNS include s aerosols, oils 22 and solvents, paint, and out-of-date or off -specification chemicals. 23 EPA recognizes the following main types of hazardous waste generators (40 CFR 260.10) 24 based on the quantity of the hazardous waste produced: 25 large quantity generators that generate 2,200 pounds (lb) (1,000 kilograms 26 (kg)) per month or more of hazardous waste, more than 2.2 lb (1 kg) per 27 month of acutely hazardous waste, or more than 220 lb (100 kg) per month of 28 acute spill residue or soil; 29 small quantity generators that generate more than 220 lb (100 kg) but less 30 than 2,200 lb (1,000 kg) of hazardous waste per month; and, 31 conditionally exempt small quantity generators that generate 220 lb (100 kg) 32 or less per month of hazardous waste, 2.2 lb (1 kg) or less per month of 33 acutely hazardous waste, or less than 220 lb (100 kg) per month of acute spill 34 residue or soil. 35 Mississippi has adopted EPA's regulations relating to RCRA Subpart C and Subpart D wastes 36 and MDEQ recognizes GGNS as a small quantity generator of hazardous wastes. The NRC 37 staff reviewed Waste Minimization Certified Reports that GGN S submitted to MDEQ , 38 Environmental Permits Division, for the years 2006 through 2010. These reports document the 39 types and quantities of nonradioactive waste generated at GGNS and verify the status of GGNS 40 as a small quantity generator of hazardous waste. 41 Conditions and limitations for wastewater discharge by GGNS are specified in National Pollution 42 Discharge Elimination System (NPDES) Permit No. MS0029521. Radioactive liquid waste is 43 addressed in Section 2.1.2 of this SEIS. Section

2.2.4 provides

more information about the 44 GGNS NPDES permit and permitted discharges. 45 Affected Environment 2-8 The Emergency Planning and Community Right -to-Know Act (EPCRA) requires applicable 1 facilities to supply information about hazardous and toxic chemicals to local emergency planning 2 authorities and the EPA (42 USC 11001). GGNS is subject to Federal EPCRA reporting 3 requirements. As such, GGNS submits an annual Section 312 (Tier II) report on hazardous 4 substances to the Claiborne County Emergency Planning Committee and to the Mississippi 5 Emergency Management Agency. 6 2.1.3.2 Pollution Prevention and Waste Minimization 7 EPA encourages the use of environmental management systems (EMS) for organizations to 8 assess and manage the environmental impacts associated with their activities, products, and 9 services in an efficient and cost -effective manner. The EPA defines an EMS as "a set of 10 processes and practices that enable an organization to reduce its environmental impacts and 11 increase its operating efficiency." EMSs help organizations fully integrate a wide range of 12 environmental initiatives, establish environmental goals, and create a continuous monitoring 13 process to help meet those goals. The EPA Office of Solid Waste especially advocates the use 14 of EMSs at RCRA -regulated facilities to improve environmental performance, compliance, and 15 pollution prevention (EPA 2010). 16 Related to the use of EMSs, Entergy, the parent company for GGNS, has established a Waste 17 Minimization Plan for its fleet of nuclear power plants. The plan describes the activities plant 18 personnel must take to reduce, to the extent feasible, the hazardous, hazardous/radioactive, 19 and nonhazardous wastes generated, treated, stored , or disposed. The Waste Minimization 20 Plan is used in conjunction with Entergy's fleet procedures and the individual plant's procedures 21 to minimize, to the maximum extent possible, the generation of all types of waste. 22 Pollution-prevention and waste -minimization efforts that GGNS uses are summarized in annual 23 Waste Minimization Certified Reports submitted to MDEQ. Entergy's Waste Minimization 24 procedure (EN -EV-104) lists the practices used to minimize waste generation. The hierarchy for 25 minimizing or managing waste is: 26 source reduction - reduce or eliminate potential waste material, 27 recycle - reuse or reclaim material instead of throwing it in the trash, 28 treatment - neutralize acids or bases, and 29 disposal - last resort when no other action can be taken. 30 2.1.4 Plant Operation and Maintenance 31 Maintenance activities conducted at GGNS include inspection, testing, and surveillance to 32 maintain the current licensing basis of the facility and to ensure compliance with environmental 33 and safety requirements. These maintenance activities include inspection requirements for 34 reactor vessel materials, boiler and pressure vessel inservice inspection and testing, the 35 monitoring program for maintaining structures, and maintenance of water chemistry. 36 Additional programs include those carried out to meet technical specification surveillance 37 requirements, those implemented in response to the NRC generic communications, and various 38 periodic maintenance, testing, and inspection procedures. Certain program activities are carried 39 out during the operation of the unit, while others are carried out during scheduled refueling 40 outages. Nuclear power plants must periodically discontinue the production of electricity for 41 refueling, periodic inservice inspection, and scheduled maintenance. GGNS operates on an 42 18-month refueling cycle. 43 Affected Environment 2-9 2.1.5 Power Transmission System 1 Three 500-kilovolt (kV) transmission lines were constructed to connect GGNS to the regional 2 power grid: the Baxter -Wilson line, the Franklin line, and a short, unnamed tie -in line that 3 connects the Unit 1 turbine building to the GGNS station switchyard. Entergy Mississippi, Inc. 4 (EMI) owns and operates these lines. This section summarizes each line and discusses 5 vegetative maintenance procedures. Figures 2-1 and 2-2 depict the transmission line 6 corridors. 7 The Baxter -Wilson line is a 22 -mi (35-km) single -circuit 500-kV line that extends north from the 8 GGNS switchyard to the Baxter -Wilson Steam Electric Station Extra High Voltage (EHV) 9 switchyard in Claiborne County, Mississippi. Its corridor is 200 f eet (ft) (60 meters (m)) wide 10 and traverses rural, sparsely populated agricultural and forested land. 11 The Franklin line is a 43.6 -mi (70.2-km) single -circuit 500 -kV line that extends southeast from 12 the GGNS switchyard to the Franklin EHV Switching Station in Franklin County, Mississippi. 13 Its corridor is 200 ft (60 m) wide and traverses four major highways, the Bayou Pierre and 14 Homochitto Rivers, and a portion of the Homochitto National Forest. 15 The third transmission line extends 300 ft (90 m) from the Unit 1 turbine building to the GGNS 16 switchyard. 17 EMI inspects each transmission line right-of-way 18 by air or ground at least three times per year to 19 identify encroaching vegetation or other required 20 maintenance. EMI follows an integrated 21 vegetative plan that includes mechanical and 22 manual clearing and herbicide application. The 23 degree and type of clearance varies by line 24 voltage and the type, growth rate, and branching 25 characteristics of trees and vegetation. Large 26 trees generally are trimmed or pruned to allow for 27 adequate line clearance

smaller trees and woody 28 vegetation may be mowed to prepare the area for followup herbicide treatments. In sensitive 29 areas, such as streams, ponds, or other water features, EMI chooses maintenance techniques 30 that minimize erosion. In wetlands and aquatic habitat, EMI personnel selectively apply 31 herbicides that are E PA-approved for aquatic environments. These herbicides are applied on 32 foot with backpack sprayers to minimize impacts. All EMI maintenance crew personnel have a 33 U.S. Department of Agriculture (USDA) state-approved herbicide license.

34 Along the Franklin line, 38.6 ac (15.6 ha) of the transmission line corridor pass through the Bude 35 Range District of the Homochitto National Forest. For this portion of the line, EMI holds a USDA 36 Forest Service Special Use Permit for construction, operation, and maintenance of the line. EMI 37 also uses a low-toxicity herbicide program for this portion of the transmission line corridor to 38 promote open, grassy habitat as part of a partnership established in 2003 with the National Wild 39 Turkey Federation (Entergy 2011a). 40 2.1.6 Cooling and Auxiliary Water Systems 41 A surface water structure to obtain cooling water from the Mississippi River does not exist at 42 GGNS. Instead, water is pumped from Ranney wells located in an aquifer along the Mississippi 43 River. The Ranney well system design and hydrogeology is discussed in greater detail in 44 Section 2.1.7. 45 A transmission line right-of-way (ROW) is a strip of land used to construct, operate, maintain, and repair transmission line facilities. The transmission line is usually centered in the ROW. The width of a ROW depends on the voltage of the line and the height of the structures. ROWs must typically be clear of tall -growing trees and structures that could interfere with a powerline.

Affected Environment 2-10 Entergy's Environmental Report (ER) (Entergy 2011a) provides information on the circulating 1 water system that removes excess heat from the reactor. The circulating water system cools 2 the main condenser. Heat is removed from the circulating water system by cooling towers, 3 which dissipate the heat to the atmosphere. The main cooling tower is a natural draft cooling 4 tower. It does not require the use of fans to operate. It may operate alone or it may operate in 5 tandem with a forced draft auxiliary cooling tower, which use fans. When both tower systems 6 are in service, the maximum temperature of the cooling water delivered to the main condenser 7 by the circulating water system is 32.2

°C (90 °F). 8 Five Ranney wells provide makeup water to replace water lost from the cooling towers by drift, 9 evaporation, and blowdown. During normal operation, as many wells and pumps as required 10 are operated to meet the plant demand. Blowdown (water intentionally removed from the 11 cooling water system to avoid concentration of impurities) is returned to the Mississippi River 12 through a 54-inch (in.) (137-centimeter (cm)) diameter pipeline (Entergy 2011a). 13 The temperature of the water exiting the 54

-in (137-cm) discharge pipeline is monitored 14 throughout the year as required by MDEQ NPDES Permit MS002952

1. GGNS has not violated 15 the thermal conditions of the permit. Therefore, water temperatures in the Mississippi River as 16 a result of this discharge have not exceeded a water temperature change of 2.8 °C (5.0 °F) 17 relative to the upriver temperature, outside a mixing zone not exceeding a maximum width of 18 60 ft (18.5 m) from the river edge and a maximum length of 6,000 ft (1,829 m) downstream from 19 the point of discharge, as measured at a depth of 5 ft (1.5 m). Further, the maximum water 20 temperatures outside the mixing zone have not exceeded 32.2

°C (90 °F), except when ambient 21 river temperatures approach or exceed this value (GGNS 2010a). 22 Should an emergency plant shutdown occur, a standby service water system would supply 23 auxiliary cooling to the reactor. Makeup water is provided automatically by the Ranney wells to 24 the standby service water system basins. However, if the Ranney wells were not operable, t he 25 plant service water basins contain enough water to ensure cooling for the shutdown reactor for 26 30 days (GGNS 2003 a). 27 2.1.7 Facility Water Use and Quality 28 Cooling water for GGNS is supplied from Ranney wells located next to the Mississippi River. 29 A Ranney well is a radial well used to extract water from an aquifer with direct connection to a 30 river or lake. It consists of a vertical caisson constructed into sand or gravel below the surface 31 level of an adjacent river or lake. Screened conduits are extended horizontally from ports in the 32 caisson. The radial arrangement of the screened conduits extending outward from the central 33 vertical caisson forms a large infiltration gallery (Figure 2-4). Groundwater flows into the 34 horizontal screened conduits that make up the infiltration gallery. From there, the water flows to 35 the central caisson, where it is pumped to the surface. One advantage of using a Ranney well 36 to extract water from a river or lake is that less water treatment may be required than if the 37 water is directly extracted from the river or lake.

38 At GGNS, Ranney wells supply water from the Mississippi River by pumping water from the 39 aquifer, which underlies the Mississippi River (NRC 2006 a). Pumping from the aquifer removes 40 suspended sediment from Mississippi River water. With the exception of suspended sediment, 41 the water quality obtained from these wells is nearly identical to that of the Mississippi River. 42 Fresh (potable) water for the plant is obtained from three wells located within the site boundary 43 and from the Crossroads, Shiloh & Ingleside (CS&I) Water Association #1 located 6 mi away 44 from GGNS (Entergy 2011a). 45 The following sections describe water use and relevant quality issues at GGNS. 46 Affected Environment 2-11 2.1.7.1 Surface Water Use 1 Mississippi River water quality is generally hard to very hard, requiring softening to avoid scale 2 formation when heated in a cooling system (NRC 2006). In March 2012, four Ranney well s 3 supplied water from the Mississippi River by pumping water from the Mississippi River Alluvial 4 Aquifer. Most of th is water cool ed the reactor, but some supplied makeup water to the standby 5 service water cooling towers, administration building, and fire protection system. Each of the 6 Ranney wells is permitted by MDEQ to operate at a maximum production rate of 10,000 gallons 7 per minute (gpm) (0.63 cubic meters per second (m 3/s)) (Entergy 2011a). This would produce a 8 total maximum production rate from the Mississippi River of 40,000 gpm (2.5 m 3/s). However, 9 from 2005 through 2010, the four Ranney wells generated a combined annual water production 10 rate that was much less than permitted amounts. This is because infiltration rates have 11 declined over time due to sediment buildup in the screened conduits. Over this time period, the 12 production rate from all four wells averaged approximately 22,396 gpm (1.4 m 3/s). 13 A new Ranney well (well number PSW -6 on Figure 2 -5) was installed and bec ame operational 14 in August 2012. Its purpose is to ensure that adequate plant cooling water is maintained. As 15 with the other Ranney wells, this well is located next to the Mississippi River. The estimated 16 average combined production rate of Mississippi River water is approximately 27,860 gpm 17 (1,758 m 3/s). Of this volume, 7,170 gpm (0.45 m 3/s) of blowdown is estimated to be returned to 18 the Mississippi River through a 54-in. (137-cm) diameter discharge pipeline. An estimated 19 20,690 gpm (1.31 m 3/s) of water is lost to the atmosphere, mainly through evaporation and drift 20 from the cooling towers (Entergy 2011a). 21 Affected Environment 2-12 Figure 2-4. Plan (Map) View and Cross Section View of Ranney Well at GGNS 1 Source: Modified from Entergy 2011a 2 Affected Environment 2-13 Figure 2-5. GGNS Ranney Well Locations 1 Source: Modified from Entergy 2011a 2 Affected Environment 2-14 2.1.7.2 Groundwater Use 1 As discussed in Section 2.1.7.1, the GGNS reactor cooling system relies on induced infiltration 2 from the Mississippi River obtained by a system of Ranney collector wells (Entergy 2012a). 3 The total annual pumping from these four wells amounts to 10,800 -13,100 million gallons (gal) 4 (40.9-49.6 million m 3) per year (Entergy 2006, 2010b, 2011 c). 5 Three wells (North Construction Well and the North and South Drinking Water Wells), located 6 within the site boundary and northeast of the main plant buildings, produce water used for 7 domestic purposes, once -through cooling for plant air conditioners, and for regenerating the 8 water softeners (Figure 2 -6). After it has been used, this water flows to the Mississippi River 9 through a 54-in. (137-cm) diameter pipeline, either after it has been processed by the onsite 10 sewage treatment facility or as other permitted surface water discharges. Total annual pumping 11 from these three wells amounts to 32 -39 million gal/yr (0.12 -0.15 million m 3/yr) 12 (Entergy 2006, 2010b, 2011 c). The average rate of water these wells produce from the 13 groundwater in the Upland Terrace Deposits is estimated to be 67 gpm (0.3 m 3/s). 14 GGNS also obtains potable water from the CS&I Water Association #1. This public water 15 system supplies potable water needs for the GGNS recreational vehicle trailer park, firing range, 16 health physics calibration laboratory, and environmental garden areas. The water association 17 obtains its water from three wells completed in the Catahoula Formation at a location 6 mi 18 (10 km) to the east -northeast of GGNS. The amount of water supplied to GGNS by the water 19 association is estimated to be 286,740 gal/yr (108.5 m 3/yr) (Entergy 2011a). 20 2.2 Surrounding Environment 21 GGNS is located in Claiborne County, Mississippi, on the east bank of the Mississippi River, 22 approximately 25 mi (39 km) south-southwest of Vicksburg, Mississippi. The site is bounded by 23 the Mississippi River on the west. The western half of the site lies in the Mississippi River 24 floodplain . This portion of GGNS has generally level topography, with elevations varying from 25 55 to 75 ft (16.7 to 22.8 m) above mean sea level (MSL) (Figure 2-7). This area also contains 26 Hamilton and Gin Lake

s. These oxbow lakes were once a channel of the Mississippi River.

27 They have an average depth of approximately 8 to 10 ft (2.4 to 3 m). The reactor building and 28 most of the associated facilities are located in the eastern half of the site. This portion of GGNS 29 is separated from the lowland plain by steep bluffs that trend north -south through the middle 30 portion of the site. The topography in the upland area rises from the floodplain as rough, 31 irregular bluffs, with steep slopes and deep -cut stream valleys and drainage courses. 32 The surface topography in the upland area ranges from 80 to 200 ft (24 to 61 m) above MSL. 33 A 6-mile radius from the center of the power block location (Figure 2-2) includes a portion of 34 Claiborne County, Mississippi, on the east side of the Mississippi River and Tensas Parish, 35 Louisiana, on the west side of the Mississippi River. The nearest incorporated community is the 36 City of Port Gibson, which has an estimated population of less than 1,600 people located about 37 6 mi (9 km) southeast of the site. The Grand Gulf Military Park, a Mississippi State park, 38 borders part of the north side of the property. The region surrounding GGNS consists mainly of 39 forest and agricultural lands (Entergy 2011a). 40 Affected Environment 2-15 Figure 2-6. GGNS Upland Complex Aquifer Permitted Wells 1 Source: Modified from Entergy 2011a 2 Affected Environment 2-16 Figure 2-7. Topographic Map of GGNS Facility 1 Source: Modified from GGNS 2003 2 2.2.1 Land Use 3 The GGNS site is comprised of 2,015 ac (815 ha). The western half of the site lies in the 4 Mississippi River floodplain and is mostly undeveloped. The eastern half of the site contains the 5 power block and support facilities (buildings, parking lots, and roads). A 2 ac (1 ha) 6 Affected Environment 2-17 privately-owned residential property is located in the southwest sector of the site and is totally 1 surrounded by the GGNS site property boundary. No other industrial, commercial, institutional, 2 or residential structures are on the site other than a private hunting lodge in the extreme 3 southwest corner. Public access is allowed to parts of the site for recreational purposes 4 (NRC 2006). 5 The immediate area surrounding GGNS is enclosed by a security fence shown in Figure 2-3. 6 Road access to GGNS is through a security gate by a two -lane road connecting to Grand Gulf 7 Road, north of the plant, and from Bald Hill Road on the east and south. The site also can be 8 accessed to the west from a barge slip on the Mississippi River. No active railways traverse the 9 site. Railways constructed for GGNS construction have been abandoned. One 10 county-maintained road runs through the GGNS site. Bald Hill Road cuts through the 11 south-southeast, south, south-southwest, and southwest sectors of the site. Another road 12 (unpaved) traverses the GGNS site property in the north, north -northwest, northwest, 13 west-northwest, and west sectors, providing access to the two lakes on the property. Two 14 transmission lines traverse the eastern edge of the site. 15 The immediate area of GGNS is rural and largely undeveloped or agricultural. Nearby land 16 across the Mississippi River in Louisiana is almost entirely agricultural land. Notable manmade 17 features within a 6 -mi (10-km) radius of GGNS (see Figure 2-2) include several Civil War 18 monuments and historic plantations around the town of Port Gibson. The Port of Claiborne is 19 located 2.2 mi (3.5 km) southwest of GGNS at river mile (RM) 404.8 of the Mississippi. 20 Nearby communities include the small community of Grand Gulf, about 1.6 mi (2.7 km) north, 21 the town of Port Gibson, approximately 6 mi (10 km) southeast; the city of Vicksburg, 25 mi 22 (40 km) north; and the city of Natchez, 37 mi (60 km) southwest. Several other small towns are 23 located in the surrounding area in Mississippi and Louisiana. Alcorn State University 24 (enrollment 3,252, fall 2011) is located 10.5 mi (17 km) southwest of GGNS. The nearest 25 occupied residence is 0.83 mi (1.3 km) east of GGNS. Prominent features of the surrounding 26 area, out to 50 mi (80 km), are shown in Figure 2-1 (Entergy 2011a). 27 2.2.2 Air Quality and Meteorology 28 GGNS is located on the east bank of the Mississippi River in Claiborne County in southwestern 29 Mississippi (NRC 2006a). The site is located approximately 150 mi (240 km) from the coast of 30 the Gulf of Mexico, which has a moderating effect on the climate. During most of the year, the 31 dominant air mass in the region is maritime tropical. As a result, the climate of the region is 32 significantly humid during most of the year, with long, warm summers and short, mild winters. 33 Occasional cold spells are associated with outbreaks of continental polar air but are usually of 34 short duration. In summer, temperatures above 100 F (38 C) are infrequent and extended 35 periods of very hot temperatures in the summers are rare. The location and seasonal intensity 36 of the Bermuda High, which is a semi -permanent area of high pressure, can dominate an entire 37 season in Mississippi (NCDC 2012a). 38 The nearby terrain consists mainly of forest and agricultural lands. The Louisiana side of the 39 Mississippi River is typically a flat alluvial plain, while the Mississippi side is typically upland and 40 rolling, forested hill country. These terrain features do not appreciably influence the local 41 climate around the GGNS site (NRC 2006a). 42 The area around the site is characterized by light winds. Based on 2006 -2011 wind 43 measurements taken at two levels at GGNS, average wind speeds are about 4.3 mph (1.9 m/s) 44 at the lower level (a height of 33 ft (10 m)) and 8.3 mph (3.7 m/s) at the higher level (a height of 45 162 ft [50 m]) (GGNS 2012a, GGNS 2012c), as shown in Figure 2-8. During the same period, 46 highest wind speeds of 22.7 mph (10.1 m/s) and 34 .1 mph (15.2 m/s) were recorded at the 47 Affected Environment 2-18 lower and higher levels, respectively. Seasonal average wind speeds at both levels are highest 1 in winter and about 50 percent higher than the lowest in summer. Although not prominent, 2 prevailing wind directions are from the northeast (about 9.2 percent of the time) at the lower 3 level and from the southeast (about 11.6 percent of the time) at the higher level. At the lower 4 level, winds from the northeast and southeast quadrants are far more frequent than winds from 5 the northwest and southwest quadrants. However, at the higher level, winds from the southeast 6 are far more frequent than winds from the three other quadrants, which are equally distributed. 7 By season, prevailing wind directions at the lower level are south in spring, northeast in summer 8 and fall, and north in winter. In contrast, prevailing wind directions at the higher level swing from 9 southeast to south -southwest throughout the year. The wind patterns at the higher level reflect 10 the regional wind patterns, while those at the lower level seem to be influenced by local 11 topography and nearby vegetation. 12 The long-term (48 years) annual average temperature at Jackson International Airport, which is 13 located about 60 mi (96.5 km) east-northeast of GGNS, was 64 .7 F (18.2 C) (NCDC 2012b). 14 During these years, monthly average temperatures ranged from 45.7 F (7.6 C) in January to 15 81.8 F (27.7 C) in July. From 1971 -2000, the average number of days with maximum 16 temperatures greater than or equal to 90 F (32.2 C) was about 84. In contrast, about 46 days 17 had minimum temperatures at or below freezing, and none of the days had minimum 18 temperatures below 0 F (-17.8 C). During the last 47 -year period, the highest temperature, 19 107 F (41.7 C), was reached in August 2000, and the lowest, 2 F (-16.7 C), in January 1985. 20 Based on 2006 -2011 measurements at GGNS, average temperature with an annual average of 21 64.9 F (18.3 C) and monthly averages ranging from 47.0 F (8.3 C) in January and 80.3 F 22 (26.8 C) in August are similar to those at the Jackson International Airport. For the 2006 -2011 23 period, the lowest and highest temperatures recorded at GGNS were 17.4 F (-8.1 C) and 99.7 24 F (37.6 C), respectively (GGNS 2012a, GGNS 2012c). 25 Mississippi, along with other coastal states along the Gulf of Mexico, is situated in one of the 26 wettest regions in the United States. Based on data from 1971 -2000, the annual average 27 precipitation at Jackson International Airport was about 55.95 in. (142 cm) (NCDC 2012b). 28 Annually, about one third of the days (about 110 days) experienced a measurable precipitation 29 (0.01 in. [0.025 cm] or higher). Precipitation is fairly well -distributed throughout the year, with 30 monthly precipitation ranging from 3.23-5.98 in. (8.20-15.19 cm). In general, monthly 31 precipitation is lower from May through October, and higher from November through April (with 32 the exception of February). At GGNS, the annual average precipitation for 2006 -2011 was 33 about 49.63 in. (126.1 cm) and ranged from 38.43 -58.50 in. (97.6-148.6 cm). For the same 34 period, the annual average precipitation and monthly precipitation patterns at the site are similar 35 to those in Jackson, Mississippi (GGNS 2012a, GGNS 2012c ). Snow in this area starts as early 36 as November and continues as late as April. Most of the snow falls from December through 37 March, with a peak in January that accounts for about 60 percent of snowfalls. The annual 38 average snowfall at the Jackson International Airport is about 0 .9 in. (2.3 cm) (NCDC 2012b). 39 Affected Environment 2-19 Figure 2-8. GGNS Wind at 33 -ft (10-m) and 162 -ft (50-m), 2006-2011 (GGNS 2012) 1 The 30-year (1971 -2000) relative humidity has an annual average of about 75 percent and 2 diurnal variation from 58 percent at 12 p.m. to 91 percent at 6:00 a.m. Hourly average relative 3 humidity ranges from 53 percent at 12 p.m. in April to 95 percent at 6:00 a.m. in August. For 4 each hour, monthly variations in relative humidity are relatively small. When the relative 5 humidity is near 100 percent, small water droplets (fog) form in the atmosphere and degrade 6 visibility. At Jackson, heavy fog, defined as visibility of 1/4 mile (0.4 km) or less, occurs about 7 Affected Environment 2-20 20 days per year based on the last 48 years of data. Heavy fog is more frequent in winter 1 months than in summer months, with the lowest of 0.8 days in June and the highest of about 2 2.9 days in December (NCDC 2012b). 3 Severe weather events, such as floods, hail, high winds and thunderstorm winds, snow and ice 4 storms, tornadoes, and hurricanes have been reported for Claiborne County (NCDC 2012c). 5 Other significant weather can be associated with these events. For example, lightning, hail, and 6 high winds frequently occur with thunderstorms, and tornadoes can occur with both 7 thunderstorms and hurricanes (NRC 2006a). 8 Based on the data for the last 48 -year period, thunderstorms occur about 67.3 days per year at 9 Jackson (NCDC 2012b). Thunderstorms are least frequent in winter (the lowest of 2.3 days in 10 December) and most frequent in summer (the highest of 12.7 days in July). In the warmer 11 season, prevailing southerly winds provide humid, semitropical conditions often conducive to 12 creating afternoon thunderstorms. Thunderstorms sometimes are accompanied by high winds, 13 mostly occurring from March through June. The highest recorded thunderstorm wind speed of 14 about 100 mph (45 m/s) occurred in April 1956 (NCDC 2012c). 15 Since 1999, 13 floods were reported in Claiborne County, 11 of which were classified as flash 16 floods (NCDC 2012c). In Mississippi, the flood season is from November through June 17 (coincident with the period of greatest rainfall), with peaks in March and April, but flooding is 18 also associated with persistent thunderstorms in summer and tropical cyclones in late summer 19 or early fall (NCDC 2012a). 20 Tornadoes occur frequently in Mississippi, many of which are violent. Based on 1991 -2010 21 data, Mississippi is in the higher range among the U.S. states in terms of average number of 22 tornadoes per unit area and average number of strong -violent (on the enhanced Fujita scale of 23 EF3 to EF5) tornadoes per unit area (NCDC 2012d). From 1957 to March 2012, a total of 24 29 tornadoes were reported in Claiborne County, mostly occurring in non -summer months with 25 a peak of 6 tornadoes in November (NCDC 2012c). Magnitudes of tornadoes for 26 pre-2006 years are not available but, since 2006, the worst tornado in Claiborne County was an 27 EF2 reported in March 2012. Historically, a tornado struck the GGNS site shortly after 28 11:00 p.m. on April 17, 1978, when two GGNS units were under construction (NRC 2006b). 29 The damage path at the plant site was approximately 1,500 -1,800 ft (457-549 m) wide, and the 30 highest onsite wind speeds were estimated to be in the 125 -150 mph (56-67 m/s) range. The 31 collapse of construction cranes caused major damage to the power plant facility; high winds 32 also extensively damaged the switchyard installation (NRC 2006a). 33 Tropical cyclones strike the Gulf Coast along the Louisiana and Mississippi coastlines with 34 expected return periods of 7 to 14 years for any hurricane and 20 to 34 years for a major 35 hurricane (Category 3 or higher) passing within 50 nautical miles (57.5 mi or 92.6 km) 36 (Blake et al. 2011). In general, impacts due to high winds from hurricanes include loss of life 37 and property damage but are limited mainly to the coastal areas. Most of these high winds are 38 weakened by passage over land and could cause rain damage to crops and considerable 39 flooding of inland areas (NCDC 2012a). Since 1851, 64 tropical cyclones have passed within 40 100 mi (161 km) of the GGNS site, 14 of which were classified as hurricanes (CSC 2012). 41 Among the 14 hurricanes, the strongest ever recorded were 3 Category 3 hurricanes: 1 not 42 named (1909), Camille (1969), and Elena (1985). 43 2.2.2.1 Air Quality 44 The Air Division of MDEQ is the regulatory agency whose primary responsibility is to ensure that 45 air quality within Mississippi is protective of public health and welfare. MDEQ is charged with 46 controlling, preventing, and abating air pollution to achieve compliance with air emission 47 Affected Environment 2-21 regulations pursuant to the Mississippi Air and Water Pollution Control Act, applicable 1 regulations promulgated by the EPA, and the Federal Clean Air Act (MDEQ 2012a). 2 A facility is defined as a "major" source if it has the potential to emit 100 tons (90.7 metric tons) 3 or more per year of one or more of the criteria pollutants, or 10 tons (9.07 metric tons) or more 4 per year of any of the listed hazardous air pollutants (HAPs), or 25 tons (22.7 metric tons) or 5 more per year of an aggregate total of HAPs. Major sources are subject to Title V of the Clean 6 Air Act (CAA) (42 U.S.C. 7401 et seq.), which standardizes air quality permits and the permitting 7 process across the United States. Permit stipulations include source -specific emission limits, 8 monitoring, operational requirements, recordkeeping, and reporting. A "synthetic minor" (or 9 "conditional major") source has the potential to exceed major source emission thresholds but 10 avoids major source requirements by accepting Federally enforceable permit conditions limiting 11 emissions below major source thresholds. The "small" (or "minor") source has no potential for 12 exceeding major source emission thresholds. 13 GGNS has the following sources of criteria pollutants and HAPs (Entergy 2011a; GGNS 2008): 14 (1) combustion sources: standby emergency diesel generators, fire water pump diesel engines, 15 the Energy Services Center diesel generator, the Operations Support Center diesel generator, 16 diesel start engines, water well diesel engine, outage equipment, and a telecommunications 17 emergency diesel generator; (2) bulk material storage tanks

diesel, gasoline, lube oil, hydraulic 18 oil, and used oil tanks; (3) other sources, such as: natural draft and auxiliary cooling towers, 19 standby service water cooling towers, and sand blasting/painting; and (4) miscellaneous 20 sources, such as: small diesel generators, welding, hand

-held equipment, and laboratory hoods. 21 GGNS is classified as a "synthetic minor" source (air permit number 0420 -00023) (GGNS 2008). 22 Although GGNS may periodically use a portable auxiliary boiler or generator(s) during power 23 outages, nonradioactive combustion-related gaseous effluents result primarily from testing and 24 preventive maintenance of emergency generators and diesel pumps operating on an 25 intermittent basis. To comply with the National Ambient Air Quality Standards (NAAQS) and to 26 ensure that potential air quality impacts are maintained at minimal levels, the MDEQ governs 27 the discharge of regulated pollutants by limiting operational run times and sulfur limits stipulated 28 in the operating permit. GGNS reports operating hours for selected equipment to show 29 compliance with permit limitations, but it has no requirements to report annual emissions 30 inventory data to the MDEQ. Continuous emission sources at the GGNS site include cooling 31 towers, which emit particulate matter as drift. The GGNS air permit does not require reporting 32 of cooling tower operating hours. 33 Air emission sources at GGNS emit criteria pollutants, volatile organic compounds (VOCs), and 34 HAPs into the atmosphere. Maximum allowable emissions from the entire facility, in 35 accordance with operating permit requirements, are presented in Table 2-1, which includes air 36 emissions from all stationary combustion and cooling tower sources at the site (GGNS 2008). 37 Because emission sources are operating well below the maximum operating hours specified in 38 the permit, actual emissions of criteria pollutants, VOCs, and HAPs are typically well below the 39 maximum allowable emissions for a "synthetic minor" source. From 2006-201 1 , there have 40 been no regulatory notices of violation issued to GGNS, based on a review of records 41 associated with the air permit (Entergy 2011a). 42 As shown in Table 2-1, annual emissions for greenhouse gases (GHGs), which include those 43 from stationary and mobile sources, are presented in terms of carbon dioxide equivalent (CO2e). 44 "Carbon dioxide equivalent" adjusts for different global warming potentials for different GHGs . 45 Total annual GHG emissions from GGNS were estimated to be about 5,980 tons CO2e 46 (5,425 metric tons CO2e) in 2011 (EPA 2011; GGNS 2012b), which is well below EPA's 47 mandatory reporting threshold of 25,000 metric tons CO2e per year (74 FR 56264). GGNS 48 Affected Environment 2-22 emits GHGs such as CO 2 , methane (CH 4), and nitrous oxide (N 2O) from combustion sources. 1 Additionally, GGNS uses GHGs such as hydrofluorocarbons (HFCs) in the two plant cooling 2 water chillers as refrigerants and sulfur hexafluoride (SF

6) in three electrical disconnect 3 switches. GGNS does not use perfluorocarbons (PFCs).

4 Table 2-1. Permitted Maximum Allowable Emission Limits for 5 Criteria Air Pollutants and Volatile Organic Compounds (VOCs)(a) 6 and Estimated Annual CO 2e Emission Rate at GGNS 7 Pollutant(b) Emission Limits and CO2e Emission Rate (lb/hr) (tons/yr) CO 225.03 25.17 NO x 850.41 98.18 PM10 42.07 68.73 SO 2 264.13 26.44 VOCs 24.80 12.94 CO2e -(c) 5,980 (5,425)(d) (a) Estimated based on maximum operating hours specified for permitted sources, including stationary combustion sources and cooling towers.

(b) CO = carbon monoxide; CO 2e = carbon dioxide equivalent; NO x = nitrogen oxides; PM 10 = particulate matter with an aerodynamic diameter of  10 m; SO 2 = sulfur dioxide; and VOCs = volatile organic compounds.
(c) A hyphen denotes that the data are not available.
(d) Values in parentheses are in metric tons carbon dioxide equivalent.

Source: EPA (2011); GGNS (2008); GGNS (2012b). Under the CAA, EPA has set NAAQS for pollutants considered harmful to public health and the 8 environment (40 CFR Part 50). NAAQS are established for criteria pollutants

carbon 9 monoxide (CO); lead (Pb); nitrogen oxides (NO x); particulate matter with an aerodynamic 10 diameter of 10 microns or less and 2.5 microns or less (PM 10 and PM2.5, respectively);

11 ozone (O 3); and sulfur dioxide (SO

2) (EPA 2012a). The CAA established two types of NAAQS:

12 primary standards to protect public health, including sensitive populations, such as asthmatics, 13 children, and the elderly; and secondary standards to protect public welfare, including protection 14 against decreased visibility and damage to animals, crops, vegetation, and buildings. Individual 15 states can have their own State Ambient Air Quality Standards (SAAQS), but SAAQS must be 16 at least as stringent as the NAAQS. If a state has no standard corresponding to one of the 17 NAAQS, or the SAAQS is not as stringent as the NAAQS, then the NAAQS apply. Except for 18 odor, Mississippi has adopted the NAAQS (MDEQ 2012b), as presented in Table 2-2. 19 Affected Environment 2-23 Table 2-2. National Ambient Air Quality Standards (NAAQS)(a),(b) 1 Pollutant (c) Averaging Tim e NAAQS Value Type(d) CO 1-hour 35 ppm P 8-hour 9 ppm P Pb Rolling 3-month average 0.15 µg/m 3 P, S NO 2 1-hour 100 ppb P Annual (arithmetic average) 53 ppb P, S O 3 8-hour 0.075 ppm P, S PM10 24-hour 150 µg/m 3 P, S PM2.5 24-hour 35 µg/m 3 P, S Annual (arithmetic average) 15 µg/m 3 P, S SO 2 1-hour 75 ppb P 3-hour 0.5 ppm S (a) Except for odor, the ambient air quality standards for Mississippi are the primary and secondary NAAQS as duly promulgated by EPA. (b) Refer to 40 CFR Part 50 for detailed information on attainment determination and reference method for monitoring.

(c) CO = carbon monoxide; NO 2 = nitrogen dioxide; O 3 = ozone; Pb = lead; PM2.5 = particulate matter with an aerodynamic diameter of 2.5 m; PM 10 = particulate matter with an aerodynamic diameter of  10 m; and SO 2 = sulfur dioxide.
(d) P = primary standards, which set limits to protect public health, including the health of "sensitive" populations such as asthmatics, children, and the elderly; S = secondary standards, which set limits to protect public welfare including protection against decreased visibility, damage to animals, crops, vegetation, and buildings.

Sources: EPA (2012c); MDEQ (2012b). EPA designates areas that meet NAAQS as "attainment areas." Areas that exceed NAAQS are 2 designated as "nonattainment areas." Areas that previously were nonattainment areas but 3 where air quality has improved to meet the NAAQS are redesignated "maintenance areas," 4 subject to an air quality maintenance plan. Claiborne County, Mississippi, where GGNS is 5 located, is part of the Mobile (Alabama) -Pensacola-Panama City (Florida) -Southern Mississippi 6 Interstate Air Quality Control Region (AQCR) (40 CFR 81.68), which includes 3 southwestern 7 counties in Alabama, 10 northwestern panhandle counties in Florida, and 37 southern counties 8 in Mississippi. The area across the Mississippi River from the site is in the Monroe 9 (Louisiana) -El Dorado (Arkansas) Interstate AQCR (40 CFR 81.92). The EPA has designated 10 all of the counties in these AQCRs adjacent to the GGNS site as in compliance with the NAAQS 11 (40 CFR 81.301, 81.304, 81.310, 81.319, and 81.325). Mississippi is in attainment with primary 12 and secondary NAAQS for all criteria pollutants, except De Soto County which is located about 13 200 miles (322 km) north-northeast of GGNS and part of which was recently designated as a 14 marginal nonattainment area for the 2008 8 -hour ozone standard. Outside of Mississippi, the 15 nearest nonattainment areas include the Birmingham area in Alabama for PM2.5 and the 16 Houston-Galveston-Brazoria area in Texas for 8 -hour ozone (O 3), both of which are located 17 about 240 mi (386 km) east-northeast and west -southwest, respectively, of GGNS. The nearest 18 maintenance area is the Baton Rouge area in Louisiana for 8 -hour O 3, which is located about 19 90 mi (145 km) south of GGNS. 20 Affected Environment 2-24 In recent years, three revisions to NAAQS have been announced. Effective January 12, 2009 , 1 EPA revised the Pb standard from a calendar -quarter average of 1.5 3 to a rolling 3-month 2 average of 0.15 3 (73 FR 66964). Effective April 12, 2010, EPA established a new 1 -hour 3 primary NAAQS for NO 2 at 100 ppb (75 FR 6474) and effective August 23, 2010, EPA 4 established a new 1 -hour primary NAAQS for SO 2 at 75 ppb (75 FR 35520). Notwithstandin g 5 these revisions to the NAAQS, the attainment status for Claiborne County will not be affected 6 because concentration levels at nearby monitoring stations are relatively low compared to the 7 NAAQS and generally are trending downward as discussed below. 8 Through operation of a network of air monitoring stations, MDEQ evaluates compliance with 9 NAAQS. The MDEQ monitors all criteria air pollutants, except CO and Pb. Monitoring for CO 10 and Pb was discontinued because the measured concentrations were much lower than the 11 NAAQS limits. Currently, no air monitoring data are available in Claiborne County 12 (MDEQ 2011c), but air monitoring stations exist in nearby Adams County where the city of 13 Natchez is located, and Hinds County where Jackson is located. Eight -hou r O 3 and PM2.5 data 14 collected in these counties indicated a general downward trend for these pollutants from 15 2001-2010. Only Jackson County, which is located in the southeastern corner of the State and 16 abuts the Gulf of Mexico, monitors NO 2 and SO 2 in Mississippi and also exhibits a general 17 downward trend during the same period. As a result, Mississippi meets all NAAQS based on air 18 monitoring data scattered around the State. 19 While the NAAQS place upper limits on the levels of air pollution, Prevention of Significant 20 Deterioration (PSD) regulations (40 CFR 52.21) place limits on the total increase in ambient 21 pollution levels above established baseline levels for SO 2, NO 2, PM 10, and PM2.5, thus 22 preventing "polluting up to the NAAQS." These allowable increments are smallest in Class I 23 areas, such as national parks and wilderness areas, and less limiting in other areas. A major 24 new source or modification of an existing major source located in an attainment or unclassified 25 area must meet stringent control technology requirements. As a matter of policy, EPA 26 recommends that the permitting authority notify the Federal Land Managers (FLMs) when a 27 proposed PSD source will be located within 62 mi (100 km) of a Clas s I area. If the source's 28 emissions are large, EPA recommends that sources beyond 62 mi (100 km) be brought to the 29 attention of the FLMs. The FLMs then become responsible for determin ing whether the 30 source's emissions could have an adverse effect on air quality related values (AQRVs), such as 31 scenic, cultural, biological, and recreational resources. There are no Class I areas in 32 Mississippi and none of the Class I areas in other nearby states are located within the 33 aforementioned 62 -mi (100-km) range. The nearest Class I area is Breton Wilderness Area in 34 Louisiana managed by the U.S. Fish and Wildlife Service (40 CFR 81.412), which is located 35 about 186 mi (300 km) southeast of GGNS. Considering the locations of and intervening terrain 36 features to any nearby Class I areas around GGNS, prevailing wind directions, distances from 37 GGNS, and the minor nature of air emissions from GGNS, there is little likelihood that activities 38 at GGNS would adversely impact air quality and AQRVs in this Class I area. 39 GGNS has a primary and backup tower for monitoring and collecting meteorological data. The 40 primary tower is 162 ft (50 m) high. It has instrumentation at heights of 162 ft (50 m) and 33 ft 41 (10 m). The backup tower is 33 ft (10 m) high. Along with an instrument shack , these towers 42 are located in an open area surrounded by tall vegetation about 0.9 mi (1.4 km) north-northwest 43 of the reactor control building. The backup tower and instrument shack are located about 300 44 and 430 ft (91 and 131 m), respectively, north -northeast of the primary tower. Onsite 45 meteorological monitoring began in March 1972. The original meteorological monitoring system 46 was replaced in December 2000. This current monitoring system will continue to serve for the 47 period of extended operation, with no major changes or upgrades anticipated (GGNS 2010b). 48 Affected Environment 2-25 The primary tower monitors wind speed, wind direction, and ambient temperature along with 1 differential temperature and data used to determine atmospheric stability collected at both 162 ft 2 (50 m) and 33 ft (10 m). Relative humidity data is collected only at 33 ft (10 m), while 3 precipitation data using a tipping bucket rain gauge is collected at the ground level. 4 Meteorological data from the primary tower is supplemented with those from the backup tower . 5 The backup tower monitors wind speed, wind direction, ambient temperature, and atmospheric 6 stability data. GGNS uses data processing procedures for analyzing meteorological data. 7 Observations are averaged to 15 -minute and hourly values and are made available to the 8 GGNS plant computer and then this information is transmitted to the control room. Information 9 from both towers is provided to the reactor control room (GGNS 2010b). 10 The data processing procedures for GGNS meteorological data involve three basic steps: 11 (1) data collection (recorded in digital form); (2) data editing and consolidation; and (3) data 12 analysis. For steps (2) and (3), computer software has been developed to process the collected 13 data. The plant data computer receives data measurements at least every 10 seconds. Data is 14 recorded each time a value varies by a preset amount. Each piece of data is checked to assure 15 it is between the minimum and maximum instrument limits. This quality indication and the time 16 are recorded with each value. An average is calculated every 15 minutes and each hour. The 17 quality of the samples is reflected in the quality of the average. This quality indication and the 18 time the average was calculated are recorded with each value. The meteorological data, for 19 which readings are available every 10 seconds or less, a 15-minute average, and an hourly 20 average, are relayed to the main control room by the plant computer (GGNS 2010b). 21 Based on the NRC's Regulatory Guide 1.23, "Meteorological Monitoring Programs for Nuclear 22 Power Plants," meteorological instruments should be inspected and serviced at a frequency that 23 will ensure data recovery of at least 90 percent annual ly. GGNS has established procedures for 24 the inspection and maintenance of the onsite meteorological system. Routine inspections are 25 made to ensure proper operation of equipment and that no damage to the towers, instrument 26 shack, or any other structure or equipment has occurred. Semi -annual visual inspections of the 27 tower and equipment are made to determine the conditions of sensors, cabinets, wiring, 28 structures, and individual components. Semi -annual checks for proper instrumentation readings 29 are performed. All calibrations at the site are performed in compliance with the 30 recommendations of Regulatory Guide 1.23. Based on the 2006 -2011 onsite meteorological 31 data, the data recovery rates for all meteorological parameters from the meteorological 32 monitoring system at GGNS were over 90 percent. 33 2.2.3 Geologic Environment 34 This section describes the current geologic environment of GGNS and vicinity, including 35 topography, geology, soils, and seismic conditions. 36 2.2.3.1 Topography and Geol ogy 37 GGNS is bounded by the Mississippi River on the west. The western half of the site is called 38 the lowland plain and lies in the floodplain of the Mississippi River. This portion of GGNS has a 39 generally level topography, with elevations that vary from 55 -75 ft (16.7-22.8 m) above MSL 40 (Figure 2-7). This area also contains Hamilton and Gin Lake s. These oxbow lakes were once 41 a channel of the Mississippi River. They have an average depth of approximately 8 -10 ft (2.4-42 3 m). 43 The reactor building and most of the associated facilities are located in the eastern half of the 44 site, which is called the upland area. The upland area is separated from the lowland plain by 45 steep bluffs that trend north -south through the middle portion of the site. The topography in the 46 upland area rises from the floodplain as rough, irregular bluffs, with steep slopes and deep -cut 47 Affected Environment 2-26 stream valleys and drainage courses. The surface topography in the upland area ranges from 1 80-200 ft (24-61 m) above MSL. Most of the facilities are located about 132.5 ft (40.3 m) 2 above MSL. The upland area has two drainage channels that trend east -west. One drainage 3 channel (Stream A) is north of the reactor and site facilities and the other (Stream B) is south of 4 the main plant complex. 5 The lowland plain is underlain by the Mississippi River Alluvium. At the land surface, it consists 6 of a layer of clay and silt that overlies interbedded layers of stream -deposited sand, gravel, silt, 7 and clay. The alluvium generally ranges from 95 -182 ft (29-55 m) thick. On GGNS , t he 8 lowland plain extends from the Mississippi River to the bluffs of the upland area. 9 The upland area is underlain by loess deposits. The loess deposits are made up of about 10 75 ft (23 m) of fine -grained silt deposited by wind and comprise the bluffs that rise above the 11 floodplain of the Mississippi River. The loess deposits are underlain by the Upland Complex , 12 which is comprised of two stream -deposited terraces, the Upland Complex Alluvium and the 13 Upland Complex Old Alluvium. These terrace deposits are thickest near the bluffs (up to 14 150 ft (46 m) thick) and thinnest near the power block area (about 40 ft (12 m) thick) 15 (GZA GeoEnvironmental Inc. 2009). The Upland Complex Alluvium is typically comprised of 16 sands and clayey, silty sands, while the Upland Complex Old Alluvium is comprised of clayey, 17 silty sands with coarse grained sands and gravels. Neither upland complex unit is found west of 18 the bluffs of the upland area, as they have been removed by the erosive activity of the 19 Mississippi River and replaced by Mississippi River Alluvium. 20 The Upland Complex Alluvium, the Upland Complex Old Alluvium, and the Mississippi Alluvium 21 are all underlain by the Catahoula Formation. The Catahoula Formation underlies the entire 22 GGNS property. It consists of lenticular deposits of sand, clayey silt, and sandy -silty clay. The 23 sand layers are predominantly fine -grained and range in thickness from a few inches to more 24 than 100 ft (30 m) thick. 25 At the site, the Catahoula Formation is underlain by the Bucatunna Formation (Entergy 2011a). 26 It is composed of clay and is about 100 -ft (30-m) thick at the site. Underneath the Bucatunna 27 Formation is the Glendon Formation, which is made up of beds of limestone. Figures 2-9 , 28 2-10, and 2-11 contain generalized geologic cross-sections that illustrate the stratigraphy 29 across the site from east to west. 30 2.2.3.2 Soils 31 U.S. Department of Agriculture (USDA 2012) soil unit mapping identifies the area of the site on 32 the Mississippi River alluvial valley (mostly Bowdre soil) as being made up of soils that are 33 somewhat poorly drained, frequently flooded, and in locations where the water table is near the 34 land surface. The soil is comprised of clayey alluvium over loamy alluvium. In areas that 35 underlie surface drainage areas (Adler silt loam), soils are moderately well drained and 36 occasionally flooded. These soils are made up of silt loam. The upland area of the site is 37 largely made up of soils that developed in loess (mostly Memphis and Natchez silt loams). The 38 depth to the water table for these soils generally is in excess of 6 ft (1.8 m). They are well 39 drained and not prone to flooding. Their typical texture is silty loam to silty clay loam. 40 2.2.3.3 Seismic Setting 41 The region is characterized by extremely low rates of earthquake activity. The rate of 42 earthquake activity in the Gulf Coastal Plain is among the lowest in the United States (Entergy 43 2011a). 44 The earliest recorded and strongest earthquake (magnitude 4.6) within Mississippi occurred at 45 Charleston, Mississippi, on December 16, 1931. In the area of maximum intensity, the walls 46 Affected Environment 2-27 and foundation of an agricultural high school cracked and several chimneys were thrown down. 1 The shock was perceptible over a 65,000 square mile area, including the northern two -thirds of 2 Mississippi and adjacent portions of Alabama, Arkansas, and Tennessee. Two earthquakes 3 greater than a magnitude 3.5 occurred within Mississi ppi (USGS 2012a, 2012 b) between 1976 4 and 2003. During that same time period, neighboring Louisiana had one earthquake greater 5 than a magnitude 3.5. 6 Figure 2-9. Location Map for Geologic Cross -Sections A-A' and B-B' 7 Source: Modified from Entergy 2011a 8 Affected Environment 2-28 Figure 2-10. Geologic Cross Section A-A' 1 Source: Modified from Entergy 2011a 2 Affected Environment 2-29 Figure 2-11. Geologic Cross Section B-B' 1 Source: Modified from Entergy 2011a 2 Affected Environment 2-30 Although the number of earthquakes reported within Mississippi's boundaries is small, the State 1 has been affected by numerous shocks located in neighboring states. In 1811 and 1812, a 2 series of earthquakes (maximum magnitude 7.7) occurred, near New Madrid, in southeast 3 Missouri and was felt as far south as the Gulf Coast. This series of earthquakes caused the 4 banks of the Mississippi River to cave in as far south as Vicksburg, more than 300 mi (483 km) 5 from the epicentral region. While earthquakes still occur in the New Madrid area, it is far 6 enough away that only a very small probability exists of experiencing damaging earthquake 7 effects in the area of GGNS (FEMA 2012). 8 The geologic setting and modern tectonic framework suggest that the earthquake hazard for the 9 region will remain low for the foreseeable future. There have been no active faults found within 10 a 5 mi (8 km) radius of the site (Entergy 2011a ). 11 2.2.4 Surface Water Resources 12 With an average discharge of 593,000 cfs (16,792 m 3/s), the Mississippi River is the largest river 13 in the United States. The western boundary of the site begins at the river's eastern bank. At 14 the site, the Mississippi River is about 0.5 mi (0.8 km) wide at low flow and about 1.4 mi 15 (2.3 km) wide during a typical annual high -flow period. The lowland plain between the river and 16 the upland area is subject to nearly annual flooding by the Mississippi River. The plain contains 17 Hamilton and Gin Lake s, which are two shallow oxbow lakes (created in a now abandoned 18 former river channel) and a small borrow pit (created during plant construction). Under 19 non-flooding conditions, watersheds that drain the upland area discharge water into Hamilton or 20 Gin Lake s. Gin Lake discharges water into Hamilton Lake through a culvert. Hamilton Lake 21 discharges into the Mississippi River (Entergy 2011a). 22 The upland area is drained by two watersheds. Watershed A is north of Watershed B. The 23 watersheds are drained by Stream A and Stream B, respectively. The estimated areas of 24 Watershed A and Watershed B are 2.94 mi 2 (7.6 km 2) and 0.68 mi 2 (1.7 km 2), respectively. 25 Water from each watershed flows through sedimentation basins before flowing into either 26 Hamilton or Gin Lakes (Figure 2-12). 27 Surface water discharges that flow to the Mississippi River from the site are permitted by the 28 MDEQ NPDES program. The current permit authorizes discharges at 11 outfalls (locations). 29 Three of the outfalls monitor discharges to surface water outside the site boundary (external 30 outfalls); eight of the outfall locations monitor discharges within the site boundary (internal 31 outfalls). 32 The three external outfalls (Outfalls 001, 013, and 014) monitor all releases to surface water 33 from GGNS. Outfall 001 is a 54 -in. (137-cm) diameter pipe that discharges in the barge slip 34 along the Mississippi River. It receives water from internal outfalls, including cooling tower 35 blowdown, standby service water leakage, the low volume waste basin, liquid radwaste, and 36 storm water. Outfall 013 is the discharge from the northwest end of Sedimentation Basin A to 37 Hamilton Lake; it includes sanitary wastewater effluent from the onsite wastewater treatment 38 plant and storm water. Outfall 014 is at the northwest end of Sedimentation Basin B. This basin 39 receives various effluents at Outfall 007 through a large concrete structure at its southeast end 40 with an approximately 20 -ft (6-m) diameter corrugated metal pipe discharging water from 41 Stream B (designed to convey storm water from the site from a 100 -year storm event). 42 Outfall 007 also receives miscellaneous wastewaters; such as heating, ventilation, and air 43 conditioning (HVAC) blowdown; air conditioner cooling water; oily waste sumps; ionic reject 44 water; and turbine building cooling water blowdown. 45 Affected Environment 2-31 Figure 2-12. GGNS Surface Water Features 1 Source: Modified from Entergy 2011a 2 Permit conditions require flow reporting at all outfalls and value reporting or monthly average 3 and/or maximum of various other parameters. Depending on the outfall, these parameters may 4 include water temperature, free available chlorine, zinc, oil and grease, total suspended solids, 5 Affected Environment 2-32 total residual chlorine, biochemical oxygen demand, and fecal coliform. Iron, arsenic, and 1 copper must be reported at some outfalls, and a range of pH (6.0 -9.0 standard units) is required 2 at several outfalls. Details are provided in GGNS's Certificate of Permit Coverage under 3 Mississippi's Baseline Storm Water General NPDES Permit (MDEQ 2010 a). The permit also 4 specifies a maximum Mississippi River water temperature increase of 5 F (2.8 C) beyond a 5 mixing zone. Thermal monitoring is required during certain low -flow river conditions. 6 The Ranney wells each have their own service water system for motor cooling. Permitted 7 discharge from each is back to the Mississippi River through an underground pipe 8 (MDEQ 2011 b). 9 In March 2011, GGNS had one EPA violation in its effluent monitoring at Outfall 007 for total 10 suspended solids (TSS) (EPA 2012 a). The violation was because of an average TSS of 11 31 mg/L, when the average limit is 30 mg/L. This was not considered a significant 12 noncompliance effluent violation. The ER (Entergy 2011a) lists several other noncompliances 13 from 2006-2010. These included three pH exceedances, a zinc exceedance, a free residual 14 chlorine exceedance, and an unauthorized discharge. 15 As described above, GGNS has an NPDES permit (MDEQ 2011a) to discharge wastewater in 16 accordance with effluent limits, monitoring requirements, and other permit conditions. Under 17 Section 401 of the Clean Water Act (CWA), an entity requiring a Federal permit for any activity 18 that may result in a discharge to navigable waters of the United States must obtain a 401 Water 19 Quality Certification from the state in which the discharge will occur to ensure that the discharge 20 complies with state water quality standards. Mississippi issued a water quality certification for 21 GGNS in 1974. In a letter dated October 17, 2011, MDEQ stated that the water quality 22 certification remains in effect as long as GGNS does not expand its footprint, increase its water 23 discharge, engage in any new activity that would trigger the need for a new certification from the 24 State, and remains in compliance with State and Federal regulations to refrain from violating the 25 State's water quality standards (MDEQ 2011 b). 26 A storm water pollution prevention plan (GGNS 2006) and a permit to discharge storm water 27 (MDEQ 2010 a) are also maintained for the site. The plan documents best management 28 practices (BMPs), potential pollutant sources, and other aspects related to storm water quality. 29 According to GGNS staff at the environmental site audit, no dredging takes place at the 30 Mississippi River barge slip or at the sedimentation basins. 31 2.2.5 Groundwater Resources 32 2.2.5.1 Mississippi River Alluvium 33 The Mississippi River Alluvium forms an aquifer underlying both the river and the lowland plain. 34 The water table in the lowland plain is at most a few feet beneath the ground surface 35 (NRC 2006 a). The Mississippi River Alluvial Aquifer is in close hydraulic connection with the 36 river. Increases or decreases in Mississippi River water levels cause changes in the direction of 37 flow in the Mississippi River Alluvial Aquifer and corresponding increases or decreases in 38 groundwater level. Usually, the alluvium discharges to the river. However, during floods, the 39 river may discharge to the aquifer. 40 This close hydraulic connection between the Mississippi River and the Mississippi River Alluvial 41 Aquifer means that the Mississippi River forms a large, effective hydraulic boundary along the 42 western boundary of the site. As a result, groundwater use, flow, and water quality west of the 43 Mississippi River are unlikely to be influenced by groundwater use, flow, and water quality east 44 of the Mississippi River (the plant side of the river). 45 Affected Environment 2-33 The GGNS cooling system uses Ranney wells to pump water from the Mississippi River Alluvial 1 Aquifer (see Section 2.1.7). Pumping from these wells induces river water to flow through the 2 alluvial aquifer to the wells. The connection between the alluvium and the river means that 3 GGNS is essentially using river water from which river water sediment has been removed 4 (filtered out by the pore spaces of the aquifer) (NRC 2006 a). 5 2.2.5.2 Perched Groundwater and the Upland Complex Aquifer 6 Some perched groundwater occurs in the loess deposits of the upland area (Entergy 2011a). 7 Because of their small area extent, size, and low production rates, the perched groundwater is 8 not considered a groundwater resource. 9 The water table occurs in the sand and gravel deposits of the Upland Complex Aquifer, which 10 underlies the loess deposits. The Upland Complex Alluvium and the Upland Complex Old 11 Alluvium form the Upland Complex Aquifer. West of the bluffs of the upland area, the Upland 12 Complex Aquifer has been removed by the erosive activity of the Mississippi River and replaced 13 by Mississippi River Alluvium. As a result, in the lowland plain, where the two aquifers are in 14 contact, the Upland Complex Aquifer is hydraulically connected to the Mississippi River Alluvial 15 Aquifer. 16 The Upland Complex Aquifer is recharged by local precipitation and the lateral movement of 17 groundwater within the Upland Complex Aquifer. Groundwater flows laterally into the southeast 18 corner of the plant property and moves in a northwest direction. From the west side of Unit 1 19 and Unit 2 power blocks, groundwater in the Upland Complex Aquifer flows west until it reaches 20 the bluffs. At that point, groundwater in the Upland Complex Aquifer flows into the Mississippi 21 River Alluvial Aquifer. From the east side of the power blocks, groundwater in the Upland 22 Complex Aquifer flows towards the northeast, until it exits the site boundary. Downward vertical 23 flow in the Upland Complex Aquifer is prevented by a thick clay layer at the top of the Catahoula 24 Formation. This clay layer has a very low permeability and is approximately 50 ft (15 m). 25 2.2.5.3 Catahoula Aquifer 26 The Catahoula Formation underlies the Mississippi River Alluvial Aquifer in the lowland plain 27 and underlies the Upland Complex Aquifer in the upland area. Sandstone layers, separated by 28 layers of siltstone or clay, transmit water in the Catahoula Formation and make up the 29 Catahoula Aquifer. The top of the Catahoula Formation contains approximately 50 ft (15 m) of 30 clay that forms an effective flow barrier, preventing the downward movement of water from the 31 Upland Complex Aquifer (NRC 2006 a) into the sands of the Catahoula Aquifer. Hydraulic 32 interconnection between the Upland Complex Aquifer and the Catahoula Aquifer has not been 33 identified in pumping well tests, monitor well water levels, or by the collection of drill -hole data. 34 The Catahoula Aquifer is fully saturated and a confined aquifer (water in a well would rise above 35 the top of the Catahoula Aquifer sands). Water in the Catahoula Aquifer is not of local origin. 36 Aquifer recharge occurs north of the site in Warren and Hinds Counties (Entergy 2011a). 37 The substructures (basements) of the plant power blocks penetrate through the loess deposits 38 and the Upland Complex Aquifer and rest on top of the Catahoula Formation. The top of the 39 Catahoula Formation is elevated in the area of the power block, forming a ridge beneath the 40 power block that is oriented northwest -southeast. The elevation of the top of the Catahoula 41 Formation generally decreases in elevation in all directions from the power block area 42 (GZA GeoEnvironmental, Inc. 2009). The thick vertical flow barrier and change in elevation of 43 the top of the Catahoula Formation and the excavation of the power block through the Upland 44 Complex Aquifer is interpreted as causing two directions of lateral groundwater flow in the 45 Upland Complex Aquifer in the power block area. 46 Affected Environment 2-34 At the site, the Catahoula Aquifer is underlain by the Bucatunna Formation (Entergy 2011a). It 1 is composed of clay and is about 100 ft (30 m) thick, forming a barrier to the downward 2 movement of water in the Catahoula Aquifer. Of the three aquifers at the site, the Catahoula 3 Aquifer is the least productive. Not only is it deeper, but the ability of the aquifer to transmit 4 water to a well is much less that the other two aquifers. No wells at the site produce water from 5 the Catahoula Aquifer or from any deeper aquifers. 6 On the lowland plain, the ancient Mississippi River eroded (cut into) the top of the Catahoula 7 Aquifer and then deposited the Mississippi River Alluvial Aquifer on top of that surface 8 (Entergy 2011a). Data from holes drilled on the lowland plain have not detected any hydraulic 9 interconnection between the Catahoula Aquifer and the Mississippi River Alluvial Aquifer. 10 However, it cannot be completely ruled out that some upper sands of the Catahoula Aquifer 11 may be hydraulically connected to the Mississippi River Alluvial Aquifer, either under the river 12 itself or under the lowland areas on either side of the river. This is because it is difficult to 13 determine how deep the Mississippi River has eroded into the top of the Catahoula in the 14 lowland plain or under the river. 15 Transmissivity is a measure of the ability of an aquifer to transmit water. It is more difficult to 16 extract water from aquifers with low transmissivity than from aquifers with high transmissivity. 17 At the site, the transmissivity of the Mississippi River Alluvium ranges from 21,500 to 18 163,500 gpd/ft (267 to 2,031 m 2/day), while the transmissivity of the Catahoula Aquifer sands 19 has an estimated transmissivity of 300 gpd/ft (3.7 m 2/day) (Entergy 2011a). The transmissivity 20 of the Catahoula Aquifer sands is so much less than the Mississippi River Alluvial Aquifer that if 21 an interconnection between the two aquifers exists, wells pumping water from the Mississippi 22 River Alluvial Aquifer would obtain their water as induced infiltration from the Mississippi River 23 rather than from upward discharge of groundwater from the Catahoula Aquifer. Furthermore, 24 should groundwater contamination enter the Mississippi River Alluvial Aquifer, it would be likely 25 to remain in the Mississippi River Alluvial Aquifer or discharge into the Mississippi River. 26 The groundwater quality in Claiborne County is generally good. Onsite groundwater quality is 27 adequate for a variety of uses. Except for less suspended sediment, the induced infiltration 28 from the operation of the GGNS Ranney wells produces water nearly identical to the water 29 quality of the Mississippi River (Entergy 2011a). Onsite Upland Complex Aquifer water quality 30 is suitable for use as potable water. Water from the GGNS Upland Complex Aquifer wells is 31 sampled as required by the Mississippi Department of Health (MDH), pursuant to the Safe 32 Drinking Water Act. County residents obtain their water from the Catahoula Aquifer. 33 Groundwater from the Catahoula Aquifer, although very hard, is suitable for potable uses. 34 Water quality generally decreases for aquifers underlying the Catahoula Formation 35 (NRC 2006 a; Entergy 2011a). 36 EPA designated the Southern Hills Aquifer, which includes the Catahoula Aquifer that underlies 37 GGNS, to be a sole -source aquifer (EPA 2012 c). The designation protects an area's 38 groundwater resource by requiring EPA to review all proposed projects within the designated 39 area that will receive Federal financial assistance. All proposed projects receiving Federal 40 funds are subject to review to ensure they do not endanger the groundwater source . As such, 41 the MDEQ's Wellhead Protection Program is working to identify and manage potential sources 42 of contamination located near public water supply wells. The Port Gibson and CS&I Water 43 Association #1 well fields are the only wellhead protection areas identified within a 6 -mi (10-km) 44 radius of the site (Entergy 2011a; MDEQ 2010 b). 45 2.2.5.4 Groundwater with elevated tritium 46 Groundwater with elevated tritium activities (above background levels) was recently found in 47 backfill material and in the Upland Complex Aquifer near the northeast side of the Unit 2 power 48 Affected Environment 2-35 block. This power block does not contain a nuclear reactor. No other radionuclides have been 1 detected above background levels in the Upland Complex Aquifer. Based on a review of 2 available data, tritium contaminated groundwater has not migrated off site (GGNS 2012 a). 3 Contamination appears to be restricted to the area near the power block. No radionuclides 4 above background levels have been detected in the Catahoula Aquifer or the Mississippi River 5 Alluvial Aquifer (Entergy 2011a). Elevated tritium levels have not been detected in the GGNS 6 potable water supply wells, or in any radiological environmental monitoring program monitoring 7 wells (GGNS 2012 a). 8 With the exception of dewatering well DW-01 and monitor well MW-07, all wells with tritium 9 activities above background levels have levels significantly below the EPA primary drinking 10 water standard for tritium (20,000 pCi/L) (40 CFR 141). Recent tritium values for DW -01 ranged 11 from 8,407 to 21,100 pCi/L and for MW -07 ranged from 7,135 to 17,404 pCi/L. DW -01 12 exceeded the EPA drinking water standard in September 2011. These wells are located close 13 together near the outer wall of the Unit 2 power block (Figure 2-13). These wells are located in 14 backfill material between the power block and the tie -back wall. The backfill material was used 15 to fill the excavation created to build the power blocks. The tie -back wall is a structure built to 16 hold up the sides of the open excavation during construction. After the power blocks were built, 17 this structure was left in place and the excavation was filled in. Outside of the tie -back wall, 18 groundwater near the Unit 2 power block is moving away from the power block toward the 19 northeast (GGNS 2012 a). 20 Elevated tritium values have not been detected in any wells located outside the site. The 21 nearest wells outside GGNS that provide water from the Upland Complex Aquifer are located 22 approximately 1 mi (1.6 km) south-southeast from the Unit 1 power block. One well provides 23 water to two residences; the other well is not being used for human consumption. These wells 24 are located in the opposite direction (i.e., upgradient), from the direction of contamination 25 migration in the Upland Complex Aquifer. CS&I Water Association

#1 provides water to the 26 majority of the rural population in the area. The closest area of concentrated groundwater 27 withdrawal is the Port Gibson municipal water system, which obtains water from the Catahoula 28 Aquifer about 5 mi (8 km) southeast of the site (Entergy 2011a

). Hydraulic interconnection 29 between the Upland Complex Aquifer and the Catahoula Aquifer has not been identified. 30 Elevated tritium levels above background have not been detected in the three onsite Upland 31 Complex Aquifer wells that supply potable water to GGNS. The wells, located near the bluffs 32 between the Mississippi River and the power blocks, are in the opposite direction from any 33 contamination moving northeast from the Unit 2 power block. These are the only drinking water 34 wells that could be affected if groundwater contamination moved westward from the power block 35 towards the Mississippi River Alluvial Aquifer. These wells are sampled annually for tritium and 36 the results are reported to the NRC. 37 In 2007, the nuclear power industry began implementing its "Industry Ground Water Protection 38 Initiative" (NEI 2007). Since 2008, the NRC has been monitoring implementation of this 39 initiative at licensed nuclear reactor sites. The initiative identifies actions to improve utilities' 40 management and response to instances in which the inadvertent release of radioactive 41 substances may result in low but detectible levels of plant -related materials in subsurface soils 42 and water. It also seeks to identify those actions necessary for implementation of a timely and 43 effective groundwater protection program. The areas of contamination were discovered as part 44 of GGNS participation in this initiative. At this time, monitoring wells have been drilled on all 45 sides of the power blocks and GGNS is monitoring them. Monitoring results from these wells 46 are reported annually to the NRC. 47 Affected Environment 2-36 Figure 2-13. Most Recent GGNS Tritium Contaminated Well Data from February 2012* 1 (*Most recent data for MW -07 is August 2011) 2 Source: Modified from GGNS 2012a 3 Affected Environment 2-37 2.2.6 Aquatic Resources 1 GGNS is located adjacent to the Mississippi River, which is part of the largest river basin in 2 North America and the third largest river basin in the world (Brown et al. 2005). GGNS lies 3 within the Lower Mississippi River, which is defined as the portion of the Mississippi River that 4 extends from the confluence with the Ohio River in Illinois to the Gulf of Mexico in Louisiana 5 (Brown et al. 2005). The site occurs within the Gulf Coastal Plain physiographic province. 6 The Lower Mississippi River has relatively high number of species, especially for fish. The high 7 species richness is in part due to the variety of habitats within the Mississippi River, as well as 8 nearby floodplain habitats hydraulically connected to the Mississippi River during flooding 9 events. Other factors that contribute to the high species diversity include the length of the river, 10 the unique habitats that the river's tributaries provide, and the connection with the Gulf of 11 Mexico, which brings marine and anadromous species into the lower reaches of the Mississippi 12 River (Brown et al. 2005). 13 2.2.6.1 Environmental Changes in the Lower Mississippi River 14 Human activities have had a large influence on the relative abundance of many species and 15 their habitat within the Mississippi River. The major activities that altered aquatic resources 16 near GGNS include: (1) efforts to control flooding and increase navigation; (2) chemical 17 contamination from runoff as a result of industrial, urban, and agricultural activities; and 18 (3) introduction of nonnative species (Brown et al. 2005). 19 To allow for ship traffic along the Mississippi River, several projects have changed the relative 20 abundance and types of habitats within the river. Beginning in 1824, the U.S. government has 21 removed snags, such as trees or tree roots, from the river. Snags provide natural habitat for 22 invertebrates that require a firm attachment site. On the other hand, revetments, which are built 23 to prevent erosion and river meandering, have increased availability of hard -surface habitats, 24 but decreased the availability of soft -surface river bank habitats. Revetments such as timber, 25 wooden or wire fences, rocks, and tires cover approximately 50 percent of the banks of the 26 Lower Mississippi River (Baker et al. 1991; Brown et al. 2005). At GGNS, articulated concrete 27 was installed on the river bank downstream of the discharge structure and barge slip to stabilize 28 the river bank (NRC 1981). 29 In addition, the U.S. Army Corps of Engineers (USACE) has artificially created cutoffs that 30 shortened the length of the river by cutting across a point bar or neck of a meander. 31 Baker et al. (1991) estimate that artificially created cutoffs have shortened the length of the 32 Lower Mississippi River by 25 to 30 percent, or approximately 500 km (310 mi). Cutoffs also 33 can increase the river speed and erosion of river banks (Baker et al. 1991). 34 Levees have been built along the Mississippi River for more than 300 years to control flooding. 35 By 1973, 29 km (18 mi) of levees lined the river near New Orleans. By 1844, levees were 36 nearly continuous up to the confluence with the Arkansas River (Baker et al. 1991). As of 2005, 37 nearly 3,000 km (1,864 mi) of levees lined the Lower Mississippi River and an additional 38 1,000 km (621 mi) of levees lined its tributaries (Brown et al. 2005). The levees decrease the 39 frequency of flooding events, during which aquatic biota can move between the Mississippi and 40 floodplain habitats. The movement of aquatic resources from floodplain habitats into the river is 41 one reason that the Lower Mississippi is so rich in species diversity. USACE continues to 42 dredge, install river bank revetments and levees, and regulate upstream reservoirs to minimize 43 the historical movements of the river and create a relatively stable channel. 44 In addition to physical changes, runoff from over 40 percent of the conterminous 48 states 45 drains into the Mississippi River. Land use changes over time have increased the concentration 46 of industrial, chemical, and sediment inputs into the river. For example, forests have been 47 Affected Environment 2-38 cleared to farm cotton, soybeans, rice, and corn near GGNS. Farming practices currently 1 include the use of fertilizers, pesticides, and herbicides, which wash into the Mississippi River, 2 especially after large rain events (Brown et al. 2005). Plowed fields, as compared to forested 3 areas, increase the amount of sediments entering the Mississippi River. 4 From 1963 through 1965, a catastrophic fish kill occurred from Memphis to the Mississippi River 5 mouth as a result of industrial releases of endrin, a pesticide made from a chlorinated 6 hydrocarbon. Mississippi Power & Light Company (MP&L) suggests that the endrin release 7 may have reduced species diversity near GGNS by extirpating some species that were highly 8 sensitive to the chlorinated hydrocarbon pesticide (MP&L 1981). As of 2002, testing has 9 indicated that several of the older "first generation" chlorinated insecticides can be detected in 10 low concentrations in bed sediments, although none of the chemical were detected in the water 11 column. 12 2.2.6.2 Description of the Aquatic Resources Associated With GGNS 13 Aquatic resources in the vicinity of GGNS include the following: 14 the Mississippi River, 15 Hamilton and Gin Lakes, 16 a flooded borrow pit, 17 three small upland ponds, 18 Stream "A" and Stream "B," and 19 ephemeral drainages. 20 In 1972, MP&L conducted aquatic studies on the GGNS site to determine baseline conditions of 21 the aquatic environment before construction. MP&L conducted aquatic ecology surveys from 22 June 1972 to August 1973 and documented 86 fish species, more than 100 plankton taxa, and 23 more than 50 macroinvertebrate taxa (MP&L 1981). System Energy Resources, Inc. (SERI) 24 conducted reconnaissance -level surveys from August 19 to 24, 2002, and October 29 to 25 November 1, 2002, in support of the early site permit (ESP) for GGNS (SERI 2005). These 26 surveys primarily resulted in qualitative data and general observations. In November 2006, 27 Entergy hired a consultant to conduct a mussel survey along the Mississippi River in support of 28 the COL application. Entergy is not aware of any other aquatic studies that have been 29 conducted at GGNS (GGNS 2012 a). 30 SERI (2005) concluded that similar aquatic resources were present in 2002 as in 1972 and 31 1973 at GGNS. SERI (2005) based this finding primarily upon the results of the 2002 32 reconnaissance -level surveys. SERI (2005) also noted that the only major change that coul d 33 have substantial impacts on aquatic biota was the installation of the articulated concrete mats 34 along the river bank in 1979. The staff notes the operation of GGNS and its discharge of 35 effluent into the Mississippi River is another change that has occurred since 1973. 36 The staff notes that the current aquatic resources may vary from that recorded in 1972 and 37 1973. As described above, the relative abundance of human -made habitats in the 38 Mississippi River, such as deep channels and hard substrates, have increased, while 39 meandering portions of the river and soft substrates have decreased. Therefore, species that 40 prefer human -made habitats have likely increased in relative abundance. Similarly, the relative 41 abundance of pollution-sensitive species has likely increased because of the improved water 42 quality in the Mississippi River since the implementation of the CWA and other environmental 43 regulations (Caffey et al. 2002). 44 The staff compared aquatic surveys from 1972 through 1974 with more recent surveys from 45 2006 through 2008. The surveys were recorded on FishNet (2012), which is a collaborative 46 effort by the Mississippi Natural History Museum and other natural history museums and 47 Affected Environment 2-39 biodiversity institutions to compile a database of fish survey data. Aquatic surveys from the 1 Mississippi River near GGNS from 1972 through 1974 captured a total of 215 fish, representing 2 25 different species belonging to 12 families. Aquatic surveys from the Mississippi River near 3 GGNS from 2006 through 2008 captured a total of 205 fish, representing 20 different species 4 belonging to 9 families. Of the 25 species recorded from 1972 through 1974 , 8 species 5 (32 percent) were collected and 17 species (68 percent) were not collected in the more recent 6 surveys. In addition, 12 species were collected from 2006 through 2008 that were not collected 7 during the earlier surveys. Of the 12 families recorded from 1972 through 1974 , 8 families 8 (67 percent) were collected and 4 families (37 percent) were not collected in the more recent 9 surveys. In addition, one family was collected from 2006 through 2008 that was not collected 10 during the earlier surveys. These results suggest that the aquatic resources from 1972 through 11 1974 have changed, although some of the same species and many of the same families likely 12 still inhabit the aquatic environments near GGNS. In addition, some new species have likely 13 been introduced into the Mississippi River near GGNS. The staff also notes that degree of 14 species overlap reported above is likely lower than what occurs in nature given that the studies 15 likely used different capture methods, occurred at different seasons, and sampled in different 16 areas or habitats in the river. 17 Mississippi River 18 The Mississippi River's eastern bank defines the western boundary of the GGNS site. The 19 width of the river ranges from approximately 0.5 mi (0.8 km) at low flow to 1.4 mi (2.3 km) at 20 high flow. The deepest part of the channel is about 16 ft (4.9 m). Three predominate habitat 21 types occur within the Mississippi River near GGNS: backwater habitat, river bank habitat, and 22 the main channel (Entergy 2011a). GGNS-related aquatic surveys within these habitats are 23 described below. 24 Sampling Methods for Preconstruction Studies 25 MP&L (1981) sampled aquatic biota in the Mississippi River from September 1972 through 26 August 1973. MP&L sampled areas within each of the three main habitats between RM 400 27 and RM 410. 28 For fish, MP&L (1981) collected monthly samples for 3 to 15 consecutive days using various 29 mesh sizes of gill, trammel, and hoop nets in backwater and river bank habitats. MP&L set nets 30 for 24 hours, or for as long as conditions permitted. Along the channel, MP&L sampled fish 31 once in September 1972 and monthly from June through September 1973, using an otter trawl 32 and fish-locating echo sounder. MP&L collected larval fish monthly or semi -monthly from 33 January through July 1973. 34 For macroinvertebrates, which are invertebrates that are visible without a microscope, MP&L 35 sampled monthly using a Shipek sediment sampler from September 1972 through August 1973. 36 Starting in January 1973, drifting benthic macroinvertebrate samples were collected near the 37 water surface at two stations in the Mississippi River using a 1 -m (3-ft) diameter plankton net 38 (505-micron mesh). MP&L collected shrimp monthly using 4 x 2 x 1 ft (1.2 x 0.6 x 0.3 m) box 39 traps (MP&L 1981). 40 MP&L sampled plankton monthly to semi -monthly from September 1972 through August 1973. 41 Sample stations were similar to that described for fish. 42 The results of this sampling are discussed in the following sections. 43 Biological Communities in Backwater Habitat 44 Backwater habitat occurs in the slow, relatively shallow waters created by the large bend in the 45 Mississippi River near the site. The substrate is generally loosely consolidated, silty clay 46 Affected Environment 2-40 sediment of low plasticity. MP&L documented an abundant assemblage of fish, 1 macroinvertebrates, and plankton in this habitat. The relatively high number of 2 macroinvertebrates provides food and shelter for spawning fish, eggs, and larvae. 3 Fish. MP&L collected 35 fish species within the backwater habitat. Ten fish species comprised 4 85 percent of the fish captured. The most common species included gizzard shad (Dorosoma 5 cepedianum ), blue catfish (Ictalurus furcatus), river carpsucker (Carpiodes carpio), freshwater 6 drum (Aplodinotus grunniens), and shovelnose sturgeon (Scaphirhynchus platorynchus ). 7 Catch-per-unit-effort (CPUE) was highest in the fall (MP&L 1981). 8 Invertebrates. Benthic invertebrates, which inhabit the bottom of the river, were the most 9 abundant and dense within backwater habitats as compared to river bank and river channel 10 habitats. The most common taxa included tubificid worms, chironomid larvae (dipteran), 11 burrowing mayfly (Hexagenia) larvae, leeches, and bivalves (mussels and clams) 12 (MP&L 1981; NRC 2006 a). The abundance of benthic invertebrates in backwaters increased 13 from September 1972 through June 1973 and then decreased through August. MP&L 14 determined that backwaters provide an important feeding ground for fish based on the dry 15 weight standing stock of benthic macroinvertebrates (MP&L 1981). 16 Biological Communities in River Bank Habitat 17 The river bank provides habitat with moderate to swift currents passing by steep banks. The 18 substrate is generally consolidated, high -plastic clay (SERI 2005). In 1979, the river bank 19 downstream of the discharge structure and barge slip was stabilized with articulated concrete 20 mats (NRC 1981). 21 Juvenile and Adult Fish. MP&L collected 34 fish species within river bank habitat. The most 22 commonly collected fish were gizzard shad, freshwater drum, silver chub (Macrhybopsis 23 storeriana), flathead catfish (Pylodictis olivaris), and blue catfish. Gizzard shad comprised 24 52 percent of the relative abundance of fish. CPUE was highest in late winter, right before larval 25 fish were observed. Therefore, MP&L conjectured that these fish were likely moving toward 26 spawning habitat in late winter (MP&L 1981). 27 Ichthyoplankton. MP&L first observed larval fish in March 1973 and observed seven species 28 during this time. The most abundant early -spawning species included shad, Mississippi 29 silverside (Menidia audens), and mosquitofish (Gambusia affinis) larvae. The density of larval 30 fish increased throughout the spring with peak spawning activity occurring in April and May. 31 MP&L observed lower densities of larvae through July, although spawning activity likely occurs 32 through the fall (MP&L 1981). 33 The spawning periods and number of spawning peaks varied for different species. For 34 example, shad spawning began in early April, peaked in May and June, and extended through 35 July. Drum, on the other hand, spawned during a shorter period of time with two spawning 36 peaks: once in June and again in mid -July. MP&L observed a relatively long spawning period 37 for minnow as larvae were collected throughout the entire sampling period. While MP&L 38 commonly observed adult catfish and suckers, their larvae were not collected near the river 39 bank probably because adults spawn in backwaters where larvae mature until they enter the 40 riverine environment as juveniles (MP&L 1981). 41 Most fish eggs near GGNS are demersal (sinking), adhesive, and small (between 0.02 and 42 0.03 in. (0.5 mm) diameter. As such, eggs spawned in backwaters typically adhere to 43 vegetation or logs and eggs spawned over gravelbars and sandbars typically adhere to the 44 bottom substrate during development. Therefore, MP&L caught relatively few fish eggs in its 45 0.02 in. (0.5 mm)-mesh plankton net. Specifically, MP&L caught 20 fish eggs compared to 46 16,596 larvae (MP&L 1981). 47 Affected Environment 2-41 Invertebrates. MP&L collected benthic invertebrates on stable river banks, but did not observe 1 benthic invertebrates on unstable river banks because these river banks likely eroded before 2 invertebrates could establish in sufficient numbers. Highly erosive clay and sand river banks 3 make for a highly dynamic benthic invertebrate community. In some locations, MP&L observed 4 benthic invertebrates during one sampling period, but not during the following month, because 5 of recently eroded clay river banks. The most common taxa included tubificids, the midges 6 Cryptochironomus and Chaoborus, the mayflies Pentagenia and Tortopus, chironomids, and 7 amphipods (MP&L 1981). 8 MP&L also collected river shrimp (Macrobrachium ohione) in the nearshore habitat along the 9 river bank. River shrimp abundance was highest from August through October and close to 10 zero from November 1972 through April 1973. MP&L attributed the decline in river shrimp to the 11 river temperature dropping below 7.5 C (46 F) in November 1972 and not rising above 20 C 12 (68 F) until April 1973 (MP&L 1981). 13 In November 2006, American Aquatics, Inc. (AAI) conducted a mussel survey in support of 14 Entergy's COL application. The purpose of the survey was to determine whether any mussels 15 occurred along the east Mississippi River bank near RM 406 (Entergy 2008c). Survey methods 16 included visual surveys of dead mussel shells along four shoreline sites and visual underwater 17 surveys for live mussels along six transects. One of the four shoreline sampling sites was in the 18 area of the discharge structure. AAI did not observe any live mussels. AAI found dead mussel 19 shells of two non -native species, zebra mussels (Dresissena polymorpha ) and Asiatic Clam 20 (Corbicula fluminea). River currents likely transported the dead shells from upriver locations. 21 As a result of these surveys, AAI concluded that mussel colonization near GGNS was not likely 22 (Entergy 2008b ). 23 Biological Communities in Main Channel Habitat 24 The most prominent aquatic habitat in the vicinity of GGNS is the main channel. This area 25 provides deep water habitat with strong and turbulent currents. The coarse grained river bottom 26 typically consists of gravelly sand sediments (MP&L 1981; SERI 2005). MP&L documented 27 relatively low productivity within the main channel as few benthic invertebrates inhabited the 28 river bottom and the water column contained less fish compared to other river habitats. 29 However, difficult conditions during sampling techniques, such as rapid currents, irregular bed 30 configurations, and bottom associated debris, also may have contributed to the relatively low 31 numbers of fish captured (MP&L 1981). 32 Fish. Commonly observed species included gizzard shad and drum. During June and July 33 trawls, all captured fish were young -of-the-year. Commonly collected species during trawl 34 sampling in August and September included blue and channel catfish (Ictalurus punctatus), 35 shovelnose sturgeon, and four chub species, most of which were juveniles. Adult fish also were 36 likely present in the main channel, but they may have avoided capture more easily because of 37 faster swim speeds (MP&L 1981). 38 Invertebrates. MP&L collected 36 benthic samples from the bottom of the main channel in 39 September and October 1972, and March, June, July, and August 1973. MP&L did not observe 40 any macroinvertebrates. 41 Overall Biological Community in Mississippi River 42 Fish. MP&L captured a total of 69 fish species (MP&L 1981). A similar study conducted at the 43 same time period captured the same number of species at the River Bend Nuclear Station, 44 232 km (144 mi) downstream from GGNS (MP&L 1981; NRC 2006). Gizzard shad was the 45 most abundant species, and the relative numerical abundance varied from 3 to 76 percent 46 (MP&L 1981). The relative abundances of other dominant species captured were freshwater 47 Affected Environment 2-42 drum (10 percent), blue catfish (8 percent), flathead catfish, and river carpsucker (5 percent) 1 (MP&L 1981). 2 Plankton. MP&L (1981) characterized plankton in the Mississippi River as either zooplankton 3 or phytoplankton. Zooplankton are small animals that float, drift, or weakly swim in the water 4 column of any body of water, whereas phytoplankton are plants. Zooplankton density ranged 5 over two orders of magnitude during the study period. MP&L identified 46 taxa and dominant 6 zooplankton that included a stalked protozoan (Carchesium sp.), various cladocerans, and a 7 colonial rotifer. Carchesium sp. can be an indicator of pollution, especially where sewage is not 8 treated properly. MP&L identified a total of 49 phytoplankton genera and the most dominant 9 were centric diatoms (MP&L 1981). 10 Hamilton and Gin Lakes 11 Hamilton and Gin Lakes are remnants of a former Mississippi River channel after the river 12 moved west. The lakes are relatively shallow, approximately 2 to 3 m (8 to 10 ft deep 13 (Energy 2011a). SERI (2005) examined aerial photography from 2001 and estimated the 14 surface area of Hamilton Lake to be 26 ha (64 ac) and Gin Lake to be 22 ha (55 ac). The lakes 15 have decreased in size since 1973. 16 Water enters and leaves Hamilton and Gin Lakes when the Mississippi River floods. Hamilton 17 Lake also receives water from Streams "A" and "B," which transport storm water from GGNS. 18 Gin Lake is connected to Hamilton Lake through a culvert beneath the Heavy Haul Road 19 (MP&L 1981; SERI 2005). 20 MP&L characterized the oxbow lakes as similar to backwater habitat in physical characteristics. 21 The lakes are relatively shallow with no current and the bottom habitat is loosely consolidated, 22 highly plastic clay sediments. Relatively productive biotic assemblages inhabit the lakes 23 (MP&L 1981). 24 Biological Communities in Hamilton and Gin Lakes 25 Fish. MP&L sampled for fish in Hamilton and Gin Lakes bimonthly from June 1972 through 26 August 1973 using electrofishing gear or gill and trammel nets (MP&L 1981). MP&L set nets for 27 24 hours, or for as long as conditions permitted. 28 Although both lakes have similar habitats, MP&L collected 46 fish species in Hamilton Lake and 29 36 species from Gin Lake. The greater number of species in Hamilton Lake likely is due to the 30 more frequent connection with the Mississippi River (MP&L 1981). For example, eight of the 31 species observed in Hamilton Lake, but not in Gin Lake, were species that typically inhabit the 32 Mississippi River. 33 Despite the difference in species diversity, the most common species in both lakes were the 34 same: Eighty percent of the fish were gizzard shad, bluegill (Lepomis macrochirus), threadfin 35 shad (Dorosoma petenense), or largemouth bass (Micropterus salmoides). In both lakes, 36 gizzard shad was the most common species within open -water habitats, whereas bluegill was 37 the most common species within shoreline -covered habitats. 38 Fish communities within oxbow lakes are relatively dynamic. When the Mississippi River floods, 39 aquatic biota can enter and leave the lakes. For example, in April and May 1973, the 40 Mississippi River flooded to Hamilton Lake and the silvery minnow (a river species) comprised 41 17 and 2 percent of the lake, respectively. In June, after the flood subsided, MP&L did not 42 observe silvery minnow in the lakes. Therefore, MP&L's one -year study provides a basic 43 characterization of the lakes that may vary considerably both on a short-term and long -term 44 basis. 45 Affected Environment 2-43 Invertebrates. MP&L sampled benthic invertebrates in Hamilton and Gin Lakes using a Ponar 1 bottom grab starting in October 1972 through August 1973. Benthic macroinvertebrates in 2 Hamilton and Gin Lakes resembled the macroinvertebrate community MP&L observed in 3 backwater habitats of the Mississippi River. Grab samples during the fall and winter indicated 4 that the most common taxa included larvae of the phantom midge Chaoborus and various 5 genera of chironomid midges (e.g., Coelotanypus , Procladius, Cryptochironomus, Pentaneura 6 and Tanypus). During the spring, common taxa included tubificid worms and bivalves 7 (MP&L 1981). MP&L also observed several species not included in grab samples, such as 8 large unionid mussels (Carunculinus , Anodonta, and Lampsilus), large snails (Campeloma and 9 Viviparus), whirligig beetles (Gyrinus), water striders (Notonectidae), crayfish (Procambarus), 10 and the grass shrimp Palaemonetes kadiakensis. 11 Benthic invertebrate density in Hamilton Lake was relatively stable, whereas MP&L observed 12 several peaks of benthic invertebrate density in Gin Lake (MP&L 1981). 13 Plankton. During the 1972 and 1973 studies, MP&L observed that the frequency and duration 14 of Mississippi River flooding, which allowed the plankton to enter or leave the lakes, had a 15 strong influence on the plankton composition and abundance. When the lakes were not 16 flooded, plankton developed into distinct populations that differed from the river communities. 17 However, during flood events, the plankton community more closely resembled plankton 18 communities within the Mississippi River (MP&L 1981). 19 Flooded B orrow Pit 20 MP&L created a borrow pit north of the barge slip in the 1970s to obtain fill for use in GGNS 21 construction. Water enters and leaves the borrow pit when the Mississippi River floods. The 22 depth of the pit is not known. SERI (2005) examined aerial photography from 2001 and 23 estimated the surface area to be 6.5 ha (16 ac) in size. The pit does not appear to be 24 hydrologically connected to the lakes, except when the Mississippi River floods and the flood 25 water flows between the lakes and burrow pit. The bottom habitat within the burrow pit is likely 26 similar to that of the oxbow lakes (SERI 2005). 27 Three Small Upland Ponds 28 Three small upland ponds exist on the GGNS site. Each pond is approximately 0.25 -0.50 ac 29 (0.1-0.2 ha). MP&L (1981) concluded that previous land owners stocked the ponds with bluegill 30 and channel catfish. 31 Biological Communities in Upland Ponds 32 MP&L sampled the upland ponds using electrofishing and mark -recapture methods 33 (MP&L 1981). The most common species include bluegill and mosquitofish. One pond also 34 contained a few channel catfish. 35 Streams A and B 36 Streams A and B are perennial streams that run through the GGNS site. Stream A flows west 37 from the GGNS sanitary waste water treatment facility. Stream A receives continual flow from 38 facility storm water and processed dischar ge from the waste water treatment facility 39 (NRC 2006 a). Stream B flows west from the cooling towers on the south side of Heavy Haul 40 Road. Flow in Stream B is intermittent, consisting mostly of storm runoff, and runs into Hamilton 41 Lake. MP&L constructed sedimentation basins on both Stream A and B, referred to as 42 Outfall 13 and 14, respectively (MP&L 1981; SERI 2005). 43 Affected Environment 2-44 Biological Communities in Stream A and B 1 MP&L sampled Stream A twice between 1972 and 1973 (MP&L 1981). MP&L observed a total 2 of 21 fish species, including bluntnose minnow, green sunfish (Lepomis cyanellus), longear 3 sunfish (Lepomis megalotis), silvery minnow (Hybognathus nuchalis, a river species), and 4 blackspotted top minnow (Fundulus olivaceus). Aquatic biota likely entered the stream during 5 spring floods (SERI 2005). For example, several species, such as largemouth bass, river shiner 6 (Notropus blennius), and warmouth (Lepomis gulosus), also inhabit Hamilton and Gin Lakes 7 and the Mississippi River (MP&L 1981). In addition to the small number of fish, MP&L observed 8 unidentified bivalves and snails in Stream A. As a result of the preconstruction studies, 9 SERI (2005) concluded that Stream A is relatively unproductive. For example, species diversity 10 in Stream A was lower than similar streams near Vicksburg, Mississippi (MP&L 1981). 11 NRC is not aware of any aquatic surveys in Stream B. Stream A and B likely provide similar 12 habitat for aquatic resources (SERI 2005), and therefore contain similar species. However, the 13 aquatic community within Stream B may be smaller than the community in Stream A due to the 14 intermittent flow of water. In addition, the species in Stream B would need to be able to survive 15 in a wide-range of environmenta l conditions due to the intermittent flow of water. 16 Ephemeral Drainages 17 SERI (2005) calculated 24,140 linear ft (7.4 km) of ephemeral drainage channels throughout the 18 GGNS site. These ephemeral drainage channels occur on the upland bluffs primarily on the 19 eastern portion of the GGNS site. Several drainages support small wetlands (SERI 2005). 20 Commercially and Recreationally Important Fish 21 Limited commercial fishing occurs in the area. Most commercial fishing occurs on the 22 Mississippi River near GGNS and on the Big Black and Bayou Pierre Rivers (NRC 2006 a). 23 Predominate harvest species include bigmouth (Ictiobus cyprinellus) and smallmouth buffalo 24 (Ictiobus bubalus) (SERI 2005). 25 In 1973, MP&L estimated that there may have been 10 -15 full-time and 30 -40 part-time 26 commercial fishermen operating between Grand Gulf and Natchez. Commonly collected 27 species from a creel study in January through February 1973 included bigmouth and 28 smallmouth buffalo (MP&L 1981). 29 Recreational fishing occurs on the Mississippi River and Hamilton and Gin Lakes (SERI 2005; 30 NRC 2006a). Recreational fisherman generally fish from boats and the bank as well as use 31 trotlines in the lakes. The most common fish caught include catfish, bluegill, and bass 32 (MP&L 1981; SERI 2005). 33 Nuisance Speci es 34 The ERs associated with the Operating Permit (MP&L 1981), ESP (SERI 2005), COL 35 (Entergy 2008c), and LRA (Entergy 2011a) did not identify aquatic nuisance species in the 36 waters associated with GGNS. As described above, in November 2006, AAI observed dead 37 mussel shells of two exotic species, zebra mussels (Dresissena polymorpha ) and Asiatic Clam 38 (Corbicula fluminea), while conducting mussel surveys in support of the COL application 39 (Entergy 2008 c). River currents likely transported the dead shells from an unknown upriver 40 location. Zebra mussels also have been observed 35 river miles upriver of GGNS, near 41 Vicksburg and throughout the Lower Mississippi River (Benson 2011). The Asiatic clam has 42 been observed in the Big Black River north of GGNS and throughout the Lower Mississippi 43 River (USGS 2012 c). 44 Affected Environment 2-45 Aquatic Resources Associated with Transmission Line Rights -of-Way 1 Transmission line rights -of-way for GGNS cross waterways in Claiborne County. The 2 Baxter-Wilson right -of-way crosses the Big Black River approximately 12 km (7.5 mi) to the 3 northeast of the GGNS site. In addition, the Baxter -Wilson substation in Warren County is less 4 than 0.75 km (0.47 mi) from the shores of the Mississippi River. The Franklin right -of-way 5 crosses the Bayou Pierre approximately 5.5 km (3.4 mi) to the south of GGNS (NRC 2006 a). 6 The Franklin right -of-way also crosses the Homochitto River (Entergy 2011a). 7 Neither the ER for the ESP (SERI 2005), the ER for the COL (Entergy 2008 c), nor the ER for 8 license renewal (Entergy 2011a) provide a description of the aquatic resources along the 9 transmission lines. NRC (2006 a) determined that information on aquatic resources was not 10 available from the transmission and distribution system owner and operator, EMI. 11 2.2.7 Terrestrial Resources 12 2.2.7.1 GGNS Ecoregion 13 GGNS lies where the Mississippi Valley Alluvial Plain and Mississippi Valley Loess Plain meet. 14 The Mississippi Valley Alluvial Plain ecoregion consists of a broad, flat alluvial plain. River 15 terraces, swales, and levees provide the main elements of relief. Soils are typically 16 finer-textured and poorly drained compared to the upland soils of the adjacent Mississippi Valley 17 Loess Plains ecoregion. The Mississippi Valley Loess Plains consist of a thin strip of land that 18 extends from western Kentucky southward to Louisiana. It is about 750 km (470 mi) long, 19 110 k m (70 mi) wide, and covers about 43,775 km 2 (16,901 mi

2) of land (USGS 2011). This 20 ecoregion consists of irregular plains with a thick layer of highly erodible loess deposits, 21 oak-hickory and oak

-hickory-pine forests, and streams with low gradients and silty substrates. 22 2.2.7.2 Summary of Past GGNS Site Surveys and Reports 23 In 1972 , MP&L conducted vegetation and wildlife studies on the GGNS site to determine 24 baseline conditions of the terrestrial environment before construction. As part of these studies, 25 MP&L mapped overstory and understory vegetation and conducted wildlife surveys to determine 26 the occurrence and relative abundance of mammals, birds, reptiles, and amphibians on the site. 27 The U.S. Atomic Energy Commission (NRC's predecessor agency) summarized the results of 28 these studies and described the terrestrial environment in its Final Environmental Statement 29 Related to Construction of Grand Gulf Nuclear Station, Units 1 and 2 (FES) (AEC 1973). 30 In 2003, SERI submitted an application to the NRC for an ESP on the GGNS site. As part of its 31 ESP application, SERI prepared an ER (SERI 2005). In its preparation of the ESP ER, SERI 32 conducted qualitative reconnaissance site visits to compare the ecological conditions with those 33 described in the 1973 FES. The ESP ER identified little change in undeveloped portions of the 34 site; the report largely summarized the findings in AEC's 1973 FES. The NRC developed an 35 environmental impact statement (EIS) (NRC 2006 a) during its review of the ESP application, 36 which it published in 2006. 37 In 2008, Entergy submitted an application for a combined license (COL) to the NRC for the 38 proposed Grand Gulf, Unit 3. Entergy requested that the NRC suspend its review of this 39 application in January 2009 until further notice. Nevertheless, the application contained an ER 40 (Entergy 2008 c) that include d an assessment of the terrestrial environment. Entergy conducted 41 several new surveys during the preparation of its ER for the COL specific to protected species. 42 Section 2.2.8 discusses these surveys in more detail. In 2011, Entergy submitted an application 43 for license renewal to the NRC. The associated ER (Entergy 2011a) also described the 44 terrestrial environment. Entergy did not conduct any new surveys for the license renewal 45 application. Entergy does not conduct any ongoing terrestrial monitoring on the site beyond that 46 Affected Environment 2-46 associated with the site's radiological environmental monitoring program (REMP) 1 (Entergy 2011a). Section 4.8 of this SEIS describes the REMP. 2 Since multiple, previously published reports describe the GGNS site in detail, the following 3 section provides a brief overview of the site habitats and wildlife. Refer to the reports 4 referenced above for a more detailed description of the GGNS site. 5 Affected Environment 2-47 Figure 2-14. GGNS Property Habitat Types (Source: Entergy 2011a) 1 2.2.7.3 GGNS Site 2 The GGNS site lies along the east bank of the Mississippi River. North -south bluffs run parallel 3 to the river and divide seasonally inundated bottomlands from upland habitat atop the bluffs. 4 Affected Environment 2-48 Roughly half of the site consists of upland habitats and half the site consists of bottomland 1 habitats. Two small lakes -Hamilton and Gin Lakes -lie within the bottomlands. During 2 construction, about 270 ac (109 ha) of upland habitat was cleared for GGNS buildings and 3 related infrastructure. Upland areas are more diverse than bottomland areas because they do 4 not experience prolonged periods of river inundation as do the bottomland habitats 5 (Entergy 2011a). The South Woods, which lies to the south and west of the cooling tower, is an 6 especially diverse area because of its complex topography of narrow ridges with steep slopes, 7 ravines, and bluffs. Figure 2-14 shows the GGNS property by habitat type. This figure outlines 8 the historical property boundary, which encompasses 2,100 ac (850 ha), although the actual 9 property size today is 2,015 ac (815 ha) because of erosional loss from the Mississippi River. 10 Table 2-3 summarizes the GGNS site habitats. Since the only terrestrial site surveys were 11 conducted before construction, the table primarily relies on information from these surveys as 12 they were presented in the AEC's 1973 FES. However, the table includes updated or more 13 specific habitat information, as available in the ESP ER (SERI 2005), the COL ER 14 (Entergy 2008 c), and the license renewal ER (Entergy 2011a). Two primary habitat changes 15 between preconstruction and present day are in the bottomland scrub -shrub wetlands (east of 16 Gin Lake) and the upland open fields and clearings, in which Entergy has planted American 17 sycamore (Platanus occidentali) and loblolly pine (Pinus taeda), respectively. 18 Table 2-3. Dominant Vegetation by Habitat Type 19 Bottomland Hardwood Forest Community types: bottomland deciduous forest Area: 985 ac (398 ha)(a) Dominant vegetation: Overstory box elder (Acer negundo) pecan (Carya illinoiensis) sugarberry (Celtis laevigata) swamp privet (Forestiera acuminate) green ash (Fraxinus pennsylvanica) black willow (Salix nigra) Understory aster (Aster spp.) buckvine [or ambervine] (Ampelopsis arborea) false nettle (Boehmeria cylindrica) trumpet creeper (Campsis radicans) sugarberry (Celtis laevigata) ladies'-eardrops (Fuchsia megellanica) dewberry (Rubus spp.) Johnson grass (Sorghum halepense) poison ivy (Toxicodendron radicans ) Bottomland Emergent Wetlands Community types: palustrine, emergent seasonally flooded Area: 30 ac (12 ha) Dominant vegetation: redtop panicgrass (Panicum rigidulum ) sedges (Carex spp.) Bottomland Scrub -Shrub Wetlands (east of Gin Lake) Community types: palustrine, seasonally flooded Area: 70 ac (28 ha) Dominant vegetation: American sycamore (Platanus occidentali ) Affected Environment 2-49 Bottomland Scrub -Shrub Wetlands (north, northwest, and south of Gin Lake) Community types: palustrine, seasonally flooded Area: 10 ac (4 ha) Dominant vegetation: black willow (Salix nigra) swamp privet (Forestiera acuminate) common button bush (Cephalanthus occidentalis ) Upland Loessial Bluff Hardwood Forest Community types: oak forests American elm forests oak-sweetgum forests Area: 400 ac (162 ha) Dominant vegetation: Overstory bitternut hickory (Carya cordiformis) pecan (C. illinoiensis) sweetgum (Liquidambar styraciflua) cherrybark oak (Quercus pagoda) southern red oak (Q. falcata) Texas oak (Q. texana) water oak (Q. nigra) American elm (Ulmus americana) Understory aster (Aste r spp.) switchcane (Arundinaria gigantean) sedges (Carex spp.) Japanese honeysuckle (Lonicera japonica) poison ivy (Toxicodendron radicans) oaks (Quercus spp.) greenbriers (Similax spp.) winged elm (Ulmus alata) grasses Upland Open Fields and Clearings Community types: upland early successional field Area: 155 ac (63 ha) Dominant vegetation: loblolly pine (Pinus taeda) goldenrod (family Asteraceae) sida (Sida spp.) goatweed (Ageratum conyzoides) mare's-tail (Hippuris spp.) common ragweed (Ambrosia artemisiifolia) dog fennel (Anthemis spp.) (a) Habitat acreage in each of the references varies because of the loss of riparian habitat along the Mississippi River to erosion over time. This table uses those areas that appear in the most recent reference, the license renewal ER (Entergy 2011a). However, the FES (AEC 1973) is the only reference that specifies acreage for the bottomland hardwood forest area. Therefore, for this habitat type, the staff used the acreage estimate from the FES. Sources: AEC 1973; Entergy 2008c; Entergy 2011a; SERI 2005 The 1972 pre -operational wildlife surveys documented 96 species of birds on the site out of an 1 estimated 141 species likely to occur in the area (AEC 1973). Additionally, the AEC (1973) 2 notes that 45 mammalian species, 67 reptiles, and 25 amphibians are likely to occupy the 3 GGNS site. Tables D -1 through D -5 in the AEC's 1973 FES list these species. Table 2 -4 4 below lists the most common or abundant species on the site. Common or abundant birds and 5 mammals are those identified in the ESP EIS (NRC 2006 a). The ESP EIS, however, does not 6 Affected Environment 2-50 include information on reptiles or amphibians. Thus, reptile and amphibian species listed in 1 Table 2-4 are those identified as being abundant in the license renewal ER (Entergy 2011a) or 2 in the FES (AEC 1973). 3 Table 2-4. Most Common or Abundant Wildlife Documented on GGNS 4 Birds(a) Passerines and Near Passerines Acadian flycatcher S (Empidonax virescens) mourning dove Y (Zenaida macroura ) American robin W (Turdus migratorius) northern cardinal Y (Cardinalis cardinalis ) belted kingfisher Y (Ceryle alcyon ) northern rough -winged swallow S (Stelgidopteryx serripennis) blue jay Y (Cyanocitta cristata ) orchard oriole S (Icterus spurius) field sparrow W (Spizella pusilla) red-winged blackbird Y (Agelaius phoeniceus ) lark sparrow W (Chondestes grammacus) ruby-crowned kinglet W (Regulus calendula) Herons, Egrets, and Storks American coot W (Fulica americana ) tricolored heron S (Egretta tricolor ) cattle egret S (Bubulcus ibis ) white ibis S (Eudocimus albus ) great blue heron Y (Ardea Herodias ) wood stork S (Mycteria americana ) great egret S (Ardea alba ) yellow-billed cuckoo S (Coccyzus americanus ) Waterfowl and Grebes pied-billed grebe W (Podilymbus podiceps) northern pintail S (Anas acuta) mallard S (Anas platyrhynchos) wood duck Y (Aix sponsa ) Birds of Prey black vulture Y (Coragyps atratus) American kestrel M (Falco sparverius ) turkey vulture Y (Cathartes aura ) Mississippi kite S (Ictinia mississippiensis ) broad-winged hawk S (Buteo lineatus ) great horned owl Y (Bubo virginianus ) red-tailed hawk Y (Buteo jamaicensis ) northern harrier M (Circus cyaneus ) red-shouldered hawk Y (Buteo lineatus ) eastern screech owl Y (Otus asio) sharp-shinned hawk M (Accipiter striatus ) Affected Environment 2-51 Mammals beaver (Castor canadensis ) least shrew (Cryptotis parva ) bobcat (Lynx rufus ) marsh rice rat (Oryzomys palustris ) cotton mouse (Peromyscus gossypinus ) nine-banded armadillo (Dasypus novemcinctus ) eastern chipmunk (Tamias striatus ) opossum (Didelphis marsupialis ) eastern cottontail (Sylvilagus floridanus ) raccoon (Procyon lotor ) eastern fox squirrel (Sciurus niger ) shorttail shrew (Blarina brevicauda ) eastern gray squirrel (Sciurus carolinensis ) striped skunk (Mephitis mephitis ) fulvous harvest mouse (Reithrodontomys fulvescens ) swamp rabbit (Sylvilagus aquaticus ) golden mouse (Ochrotomys nuttalli ) white-footed mouse (Peromyscus leucopus ) gray fox (Urocyon cinereoargenteus ) whitetail deer (Odocoileus virginianus ) hispid cotton rat (Sigmodon hispidus ) woodland vole (Microtus pinetorum ) house mouse (Mus musculus ) Reptiles(b) American alligator AQ, TR (Alligator mississippiensis ) ground skink TR (Lygosoma laterale ) American toad TR (Bufo americanus ) red-eared turtle AQ (Pseudemys scripta ) black racer TR (Coluber constrictor ) southern black racer TR (Coluber constrictor priapus ) broad-banded water snake AQ, TR (Natrix sipedon ) southern copperhead TR (Agkistrodon contortrix contortrix ) diamond-backed water snake AQ, TR (Natrix rhombifera ) spade foot toad LB (Scaphiopus holbrookii ) eastern hognose TR (Heterodon platyrhinos ) speckled kingsnake TR (Lampropeltis getulus ) Fowler's toad TR (Bufo woodhousel fowleri ) stinkpot AQ (Sternotherus odoratus ) gray rat snake TR (Elaphe obsolete ) three-toed box turtle TR (Terrapene carolina triunguis ) green anole TR (Anolis carolinensis carolinensis ) western cottonmouth AQ, TR (Agkistrodon piscivorus leucostoma ) Affected Environment 2-52 Amphibians(b) amphiuma salamander BL (Amphiuma spp.) lesser siren BL (Siren intermedia ) bronze frog AQ, TR (Rana clamitans ) mole salamander LB (Ambystoma talpoideum ) bullfrog AQ, TR (Rana catesbeiana ) slimy salamander LB (Plethodon glutinosus ) (a)Codes following bird names signify seasonal use of the GGNS site; S = summer; M = migratory stopover; W = fall and winter; Y = year -round. (b)Codes following amphibian names signify habitat use; AQ = aquatic habitat; BL = bottomlands; LB = loessial bluffs; TR = terrestrial habitat (general). Sources: AEC 1973; Entergy 2011a; NRC 2006 a 2.2.7.4 Transmission Line Corridors 1 Section 2.1.5 of this SEIS describes the three transmission lines (two full-length lines and one 2 short tie that terminates on the site) associated with GGNS construction. The majority of the 3 land (77.7 percent) that the transmission lines traverse is undeveloped. About 15 percent of the 4 transmission line corridors is agricultural lands. Table 2-5 provides the land use by acreage 5 and percent along the transmission line corridors. 6 Table 2-5. Transmission Line Corridor Land Use by Area 7 Land Use Acres (Hectares) Percent Agricultural 246 (100) 14.7 Developed (Residential) 28 (11) 1.6 Developed (Non -residential) 3 (1) 0.2 Undeveloped 1,296 (525) 77.7 Water or Wetlands 96 (39) 5.8 Source: Entergy 2011a; NRC 2006a The Baxter -Wilson line runs through hardwood forest, loessial bluffs, hardwood -forested Big 8 Black River bottomland, farmland, and sparsely populated rural areas. The Franklin line runs 9 through loessial bluff hardwood forest and fields, pine and hardwood forest, and farmland 10 (Entergy 2011a). The Franklin line also runs through Homochitto National Forest to the 11 southeast of the GGNS site. Homochitto National Forest is an 189,000 ac (76,500 ha) National 12 Forest that spans seven Mississippi counties. 13 2.2.8 Protected Species and Habitats 14 The U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS) 15 jointly administer the Endangered Species Act (ESA) of 1973, as amended. The FWS manages 16 the protection of and recovery effort for listed terrestrial and freshwater species, while the NMFS 17 manages the protection of and recovery effort for listed marine and anadromous species. 18 Within Mississippi, the Mississippi Department of Wildlife, Fisheries, and Parks (MDWFP) lists 19 species as State endangered under the Mississippi Nongame and Endangered Species 20 Conservation Act of 1974 (MNHP 20 11). 21 The NMFS has not designated any essential fish habitat under the Magnuson -Stevens Fishery 22 Conservation and Management Act, as amended, within affected waterbodies within the vicinity 23 Affected Environment 2-53 of GGNS (NMFS 2012 a); therefore, this section does not discuss species with essential fish 1 habitat. 2 This section also discusses those species protected under the Bald and Golden Eagl e 3 Protection Act of 1940, as amended, and the Migratory Bird Treaty Act of 1918, as amended. 4 The FWS and NMFS have not designated any critical habitat under the ESA within the action 5 area, nor has either agency proposed the listing or designation of any new species or critical 6 habitat within the action area. 7 2.2.8.1 Action Area 8 For purposes of its protected species and habitat discussion and analysis, the NRC considers 9 the action area, as defined by the ESA regulations at 50 CFR 402.02, to include the lands and 10 waterbodies described below. The following sections only consider terrestrial and aquatic 11 species that occur or have the potential to occur within this action area. 12 Terrestrial, wetland, and riparian habitat on the GGNS site and surrounding area within a 13 2-mi (10-km) radius. The 2,015-ac (815-ha) GGNS site lies within Claiborne County, 14 Mississippi. The site includes hardwood forest, open fields and clearings, and several areas of 15 emergent wetlands and riparian habitat bordering the Mississippi River. Section 2.2.7 describes 16 the site terrestrial ecology. 17 Mississippi River 6 river miles (10 river kilometers) upstream and downstream of GGNS 18 and site aquatic features. This area includes the extent of the maximum thermal plume from 19 GGNS discharge into the Mississippi River. The action area also includes the aquatic features 20 at GGNS, including Hamilton and Gin Lakes, the borrow pit, streams "A" and "B ," three small 21 upland ponds, and ephemeral drainages. Section 2.2.6 describes the site aquatic ecology. 22 Transmission line corridors and 1 -mi (1.6-km) buffer on either side of the lines. The 23 transmission lines associated with GGNS travel through Claiborne, Franklin, Jefferson, and 24 Warren Counties. The transmission line corridors traverse pine and hardwood forest, loessial 25 bluffs, farmland, and sparsely populated rural areas and cross several rivers, including the 26 Mississippi, Bayou Pierre, and Big Black Rivers. One of the lines (the Franklin line) also runs 27 through Homochitto National Forest to the southeast of the GGNS site. 28 2.2.8.2 Overview of Protected Aquatic and Terrestrial Species 29 Sections 2.2.6 and 2.2.7 summarize past aquatic and terrestrial surveys that have been 30 conducted on the GGNS site. MP&L captured pallid sturgeon (Scaphirhynchus albus), chestnut 31 lamprey (Ichthyomyzon castaneus), black buffalo (Ictiobus niger), blue sucker (Cycleptus 32 elongates), and paddlefish (Polyodon spathula) during the 1972 through 1973 preconstruction 33 surveys (AEC 1973). However, neither the preconstruction surveys, the recent reconnaissance 34 surveys associated with the ESP application, nor the surveys associated with the COL 35 application identified any other Federally or State-listed species on the GGNS site. Several of 36 these Federally listed species (see Table 2-6) have the potential to occur in the action area. 37 Table 2-6 identifies Federally and State-listed species that occur in Claiborne County, in which 38 GGNS is located, or within one of the four counties through which the transmission line corridors 39 traverse. The NRC compiled this table from FWS's online search by county (F WS 2012 b); the 40 Mississippi Natural Heritage Program's online database (MNHP 201 1); and correspondence 41 from the FWS (2012 c, 2012 d), MDWFP (2012), and NMFS (2012 b). The MNHP online 42 database lists about 30 additional State-listed animal species and about 30 additional plant 43 species that do not appear in Table 2 -6; however, the MDWFP (2012) did not identify any of 44 these additional species as occurring within 2 mi (3.2 km) of the GGNS site or transmission line 45 corridors. Therefore, this section does not include these species in its discussion. 46 Affected Environment 2-54 In response to the NRC's request for endangered and threatened species that could be affected 1 by the proposed license renewal, NMFS (2012 b) stated that no species under its jurisdiction 2 occur within the action area, but that gulf sturgeon (Acipenser oxyrinchus desotoi) are known to 3 occur in the Mississippi River and have been collected upstream of the project site in the region 4 of Vicksburg, Mississippi. NMFS (2012 b) suggested that the NRC contact the FWS Panama 5 City Office about the gulf sturgeon. In response to the NRC's inquiry, the FWS Panama City 6 Office stated that it defer s to the letters written by the Louisiana FWS Office (FWS 2012 c) and 7 Mississippi FWS Office (FWS 2012 d) regarding Section 7 consultation. FWS (2012c, 2012d) 8 did not identify any concerns related to the proposed project on gulf sturgeon. Furthermore, 9 FWS, which has jurisdiction over the gulf sturgeon in the Mississippi River, did not identify the 10 species as occurring within the action area or within Claiborne, Franklin, Jefferson, or Warren 11 Counties (FWS 2012b, 2012c, 2012 d). Therefore, the NRC will not consider this species in any 12 further detail in this SEIS. 13 Affected Environment 2-55 Table 2-6. Federally and State -Listed Species 1 County(ies) of Occurrence(c) Scientific Name Common Name Federal Status(a) State Status(a) State Rank(b) Claiborne Franklin Jefferson Warren Amphibians Plethodon websteri Webster's salamander

- - S3 x  x  Birds         Eudocimus albus white ibis
- - S2B, S3N x x x x Haliaeetus leucocephalus bald eagle
- E S1B, S2N x x x x Mycteria americana wood stork E E S2N x x x x Picoides borealis red-cockaded woodpecker E E S1  x x  Sterna antillarum least tern (interior pop.) E E S3B x  x x Fish         Crystallaria asprella crystal darter 
- E S1 x x   Cycleptus elongatus blue sucker
- - S3 x    Etheostoma rubrum bayou darter T T S1 x    Ichthyomyzon castaneus chestnut lamprey
- - S3 x    Ictiobus niger black buffalo
- - S3 x   x Macrhybopsis meeki sicklefin chub
- - SA    x Polyodon spathula paddlefish
- - S3 x   x Scaphirhynchus albus pallid sturgeon E E S1 x  x x Mammals         Ursus americanus luteolus Louisiana black bear T E S1 x x x x Ursus americanus American black bear T(SA) E S1 x x x x Mussels         Potamilus capax fat pocketbook E E S1 x  x x Quadrula cylindrica ssp. cylindrica rabbitsfoot PT - - x   x (a) E = endangered; T = threatened; T(SA) - threatened due to similarity of appearance to another listed species; PT = proposed threatened.
(b) S1 = critically imperiled in MS because of extreme rarity; S2 = imperiled in MS because of rarity; S3 = rare or uncommon in MS; SA = accidental or casual in MS (i.e., infrequent and far outside usual range); B = applies to breeding populations; N = applies to migratory or non

-breeding populations.

(c) GGNS is located in Claiborne County, Mississippi. The transmission lines associated with GGNS traverse Claiborne, Franklin, Jefferson, and Warren Counties.

Sources: FWS 2012b, 2012c, 2012d; Mann et al. 2011; MDWFP 2012

Affected Environment 2-56 2.2.8.3 Species and Habitats Protected Under the Endangered Species Act 1 Wood Stork (U. S. Breeding Population) 2 The U.S. Fish and Wildlife Service (FWS) listed the U.S. breeding population of wood stork 3 (Mycteria americana) as endangered in 1984 (49 FR 7332). The wood stork is a large, white 4 wading bird with black flight and tail feathers. Its head is not feathered, and both the head and 5 bill are grey to brownish -grey in color. Wood storks' historic breeding range extends from South 6 Carolina to Florida, west to Texas, and throughout most of South America. Today, the species 7 breeds in South Carolina, Florida, and Georgia, though it still migrates west and south. Within 8 Mississippi, the wood stork occurs along the western edge of the State along the Mississippi 9 River in late summer and fall near freshwater wetlands, ponds, bayheads, oxbow lakes, a nd 10 ditches (MMNS 2001). 11 The AEC's 1973 FES notes that pre -construction surveys recorded the wood stork as occurring 12 in the summer on or near Hamilton and Gin Lakes. The license renewal ER (Entergy 2011a) 13 does not provide any updated information on the species' occurrence but notes that the wood 14 stork is a possible non -breeding transient to the GGNS site and surrounding area. Thus, the 15 staff assumes that the wood stork occurs in the action area. However, individuals in Mississippi 16 represent migrants from Mexican breeding colonies (49 FR 7332), and thus, would not be part 17 of the U.S. breeding population. Therefore, the NRC will not analyze this species in any further 18 detail in this SEIS. 19 The FWS has not designated critical habitat for this species. 20 Red-cockaded Woodpecker 21 I n 1970, under the Endangered Species Preservation Act of 1966, the predecessor regulation to 22 the Endangered Species Act (ESA) (35 FR 16047), the FWS listed the red -cockaded 23 woodpecker (Picoides borealis) as endangered wherever found. The red -cockaded 24 woodpecker is a medium -sized woodpecker that is distinguishable by barred black and whit e 25 horizontal stripes on its back and black cap and nape encircling white cheek patches. Males 26 have a small red streak along the back portion of their heads. 27 Red-cockaded woodpeckers live in family groups with one breeding pair and several 28 non-breeding birds that help raise young (FWS 2003). Males more often are helpers, but 29 females also may take on the helper role. If a breeder dies, a helper can replace the breeder. 30 Helpers also may increase fledgling success and reduce the workload of breeders, which 31 increases breeder survivorship (Khan and Walters 2002). Therefore, the effective population 32 size depends more on the number of breeding groups instead of the number of young 33 successfully raised in a given year. This cooperative breeding system makes the red -cockaded 34 woodpecker resistant to many environmental and demographic changes, but highly sensitive to 35 habitat spatial characteristics (FWS 2003). 36 Red-cockaded woodpeckers inhabit open pine woodlands and savannahs with large old pines 37 that serve as cavity trees for nesting and roosting. The species uses mature pine stands with 38 open canopies, little to no midstory, and native bunchgrass and forbs for foraging. Cavity tree 39 availability is often the limiting factor for growth in most populations (FWS 2003). 40 The red-cockaded woodpecker does not occur in Claiborne County; therefore, it does not occur 41 on the GGNS site. The Homochitto National Forest, which spans seven Mississippi counties, 42 including Franklin and Jefferson Counties, contains a secondary core population of the species 43 (FWS 2003). As of 2000, this national forest contained 51 active breeding clusters (FWS 2003). 44 The recovery plan sets forth a goal of 254 active breeding clusters for this population. The 45 Franklin transmission line (discussed in Section 2.1.5) travels through the northern section of 46 Affected Environment 2-57 Homochitto National Forest in Jefferson and Franklin Counties before its termination point at the 1 Franklin EHV Switching Station in Franklin County. Thus, the species is likely to occur within 2 the action area in the vicinity of the Franklin transmission line corridor within the Homochitto 3 National Forest. 4 The FWS has not designated critical habitat for this species. 5 Least Tern (Interior Population) 6 The FWS listed the interior population of the least tern (Sterna antillarum) as endangered in 7 1985 (50 CFR 21784). The least tern is an 8- to 9-in. bird that has a white body, gray back and 8 wings, a black crown on its head, orange legs, and a yellow bill. 9 Least terns arrive in the United States from early April to early June and spend 3 to 5 months in 10 breeding grounds (TPWD 2012). The species inhabits barren to sparsely vegetated sandbars 11 along the Missouri, Mississippi, Ohio, Red, and Rio Grande Rivers; sand and gravel pits; an d 12 lake and reservoir shorelines (Sidle and Harrison 1990). Least terns nest in small colonies in 13 such areas, and females create nests by scraping shallow holes in sandy areas or exposed 14 flats. Females lay two to three eggs over a period of several days in late May. Chicks hatch 15 within 20 to 22 days and are capable of flight within 3 weeks. Because least terns nest on 16 sandbars and shorelines, annual nesting success in a given location varies greatly due to water 17 level fluctuations. Least terns generally stay close to their breeding colony and limit their activity 18 to that portion of the river near the colony. The species is territorial and individuals communally 19 will defend the colony against invaders. Least terns are opportunistic feeders and prey on a 20 variety of small fish, crustaceans, and insects. Least terns migrate south to fall and winter 21 habitats beginning in late August.

(TPWD 2012) 22 Since 1986, biologists from the U.S. Army Corps of Engineers and Dyersburg State Community 23 College have conducted least tern surveys along the Mississippi River from Cape Girardeau, 24 Missouri, to Baton Rouge, Louisiana. The least tern occurs along this entire stretch of the 25 Mississippi River. During the most recent survey conducted in July 2011, Jones (2011) 26 recorded a total of 12,247 least terns and 45 nesting colonies. Two nesting colonies occur 27 within the action area:  the Yukatan Dikes (RM 410; 4 RM upriver of GGNS) colony and the 28 Bondurant Towhead Dikes (RM 393; 13 RM downriver of GGNS) colony. The Baxter

-Wilson 29 transmission line lies 0.46 mi (0.74 km) from the Mississippi River at its closest point, and the 30 nearest least tern colonies are at least 2 mi (3.2 km) away from the transmission line corridor; 31 thus, these colonies are outside the action area. 32 The FWS has not designated critical habitat for this species. 33 Bayou Darter 34 The FWS listed the bayou darter (Etheostoma rubrum) as threatened in 1975 (40 FR 17590). 35 Bayou darter are small fish; adults range from 1.0-1.8 in. (2.5 -4.6 cm) in length. These fish are 36 the smallest representative of the subgenus Nothonotus. Bayou darters are endemic to the 37 Bayou Pierre and also occur in the lower reaches of its tributaries, including White Oak Creek, 38 Foster Creek, and Turkey Creek. Bayou darter habitat includes meandering stream with stable 39 gravel riffles or sandstone exposures (FWS 2012d). Such habitat is often found downstream of 40 a headcutting area. In these areas, the stream becomes shallow (less than 6 -in. (15-mm) 41 depth), the flow is moderate to swift, and riffles become numerous. Primary prey includes 42 midges, blackflies, water mites, caddisflies, and mayflies (FWS 2012d). Bayou darter spawn 43 when water temperatures rise to between 72 and 84 F (22 and 29 C), which generally occurs 44 from April to early June (FWS 2012d). Past and current threats to the Bayou darter include 45 human-induced habitat alteration, such as floodplain or channel modification, petroleum 46 exploration and transportation, and farming and forestry (FWS 2012d). 47 Affected Environment 2-58 At GGNS, MP&L did not observe bayou darter during preconstruction studies from 1972 through 1 1973 (Entergy 2011a). However, bayou darter is endemic to Bayou Pierre, which flows within 2 2 mi (3.2 km) of the GGNS site and is crossed by the Franklin transmission line. Therefore, the 3 bayou darter is likely to occur within the action area. 4 The FWS has not designated critical habitat for this species. 5 Pallid Sturgeon 6 In 1990, the FWS listed the pallid sturgeon (Scaphirhynchus albus) as endangered wherever 7 found (55 FR 36641). Pallid sturgeon have a long, uniformly grayish-white body and a flattened, 8 shovel-shaped snout. Pallid sturgeon inhabit the Mississippi and Missouri Rivers from Montana 9 to Louisiana. Within the Mississippi River, primary habitat includes the main channel, especially 10 near the river bottom. Primary prey include fish and aquatic insects (FWS 2007 a). Although 11 information on reproduction is limited, pallid sturgeon likely spawn between June and August 12 (FWS 2007a). Larval fish drift downstream from the hatching site (Kynard et al. 2002). Eleven 13 to 17 days after hatching, larvae settle from the lower portion of the water column (FWS 2007a). 14 Current threats include commercial and recreational harvest because of misidentification by 15 fishermen, habitat modification (e.g., channelization of the Mississippi River), and curtailment of 16 the species' habitat range due to the operation of dams along the Missouri River (FWS 2009). 17 During the 1972 -1973 preconstruction studies , a specimen was collected offshore of the future 18 GGNS site (Entergy 201 1a). Spawning habitat may exist within 10 mi (16 km) of the site. 19 In 2001, FWS, the Mississippi Museum of Natural Science, and the Lower Mississippi River 20 Conservation Committee conducted trawl surveys for pallid sturgeon approximately 21 38 mi (61 km) upstream of GGNS (Hartfield et al. 2001 in SERI 2005). The team observed nine 22 adult pallid sturgeon and seven intermediates (sub -adults) within a variety of channel habitats 23 that included moderate to strong currents, sand or gravel substrates, 20 -40 ft (6.1 -12.2 m) 24 depths, and usually some type of habitat structure. From 2000 -2005, USACE sampled the 25 lower Mississippi River from river miles (RMs)145 to 954. USACE collected 162 pallid sturgeon 26 from more than 130 locations (FWS 2005). FWS (2012c) stated that pallid sturgeon may occur 27 within 50 mi (80 km) of GGNS. Similarly , MDFWP (2012) stated that pallid sturgeon may occur 28 within 2 mi (3.2 km) of GGNS. Therefore, the pallid sturgeon may occur within the action area. 29 The FWS has not designated critical habitat for this species. 30 Louisiana and American Black Bears 31 The Louisiana black bear (Ursus americanus luteolus) is one of 16 recognized subspecies of 32 American black bear (U. americanus). I n 1992, the FWS published a final rule listing the 33 Louisiana black bear as threatened (57 FR 588). This final rule also listed the American black 34 bear as threatened because of its similarity in appearance to the Louisiana black bear. The 35 American black bear is listed as threatened within all Louisiana counties and those Mississippi 36 and Texas counties within the historic range of the Louisiana black bear. 37 The Louisiana black bear is distinguished from the American black bear by its longer and 38 narrower skull and larger molar teeth. The species has a brown muzzle and generally uniformly 39 black fur, although its fur can range from shades of brown to red. Adult males weigh between 40 200 and 400 lbs (90 to 180 kg), and females weigh between 120 and 200 lbs (55 to 90 kg) 41 (FWS undated a). 42 The Louisiana black bear is an opportunistic omnivore whose diet varies with food availability 43 and season. From 2002 through 2004, Benson and Chamberlain (2006) studied the diets of two 44 subpopulations in the Tensas River Basin, which lies west of the GGNS site and runs parallel to 45 the Mississippi River. The study identified corn; pokeberry (Phytolacca americana), muscadine 46 Affected Environment 2-59 (Vitis rotundifolia), and other shrubs or vine fruit; and invertebrates as the primary sources of 1 food in spring. In the fall, acorns made up a significant portion of the Louisiana black bear's 2 diet. In the winter, the species relied on acorns, grasses, sedges, and invertebrates. Louisiana 3 black bears also consume small mammals and carrion opportunistically. In areas where bears 4 are in close proximity to agricultural fields, they often consume large amounts of wheat, oats, 5 and other cereal grains (Benson 2005). 6 Louisiana black bears prefer bottomland hardwood forest habitat with relatively inaccessible 7 terrain, thick understory vegetation, and abundant hard (acorns and nuts) and soft (leaf buds, 8 berries, drupes) mast (74 FR 10350). Studies indicate that individual home ranges of Louisiana 9 black bears are rather large and habitat use varies widely by gender, season, food availability, 10 and reproductive status. In a movement ecology study, Marchinton (1995) found that males 11 have a mean home range of about 52 km 2 (20 mi 2), while females have a mean home range of 12 about 13 km 2 (5 mi 2), and that ranges for both sexes were largest in fall. The Louisiana Black 13 Bear Recovery Plan (FWS 1995) indicates that in the Tensas River Basin, males and females 14 may have a home range of up to 162 km 2 (63 mi 2) and 73 km 2 (28 mi 2), respectively. The 15 smaller mean range of females could correlate with reproduction. Females may restrict their 16 ranges while rearing cubs because of the limited mobility of young in the first few months of life 17 (Lindzey and Meslow 1977). Availability of covered corridors between fragmented forest 18 habitats also affects individual ranges. 19 Females breed at three to four years of age and give birth to one to three cubs in late January to 20 early February while hibernating. Females and their cubs emerge from dens in late March to 21 late May, and females continue to care for cubs until their second summer. Thus, females 22 reproduce at most every other year. 23 Historically, the species occurred across North America as far north as Alaska and south to 24 Mexico. The species now occurs in two core populations within the Tensas and Atchafalaya 25 River Basins in Louisiana and in small, scattered populations in Mississippi. Continued habitat 26 fragmentation from transportation development, agricultural activities, and urban sprawl as well 27 as human-induced mortality from poaching and vehicle strikes threaten the continued existence 28 of the Louisiana black bear (74 FR 10350). 29 The FES for construction of GGNS (AEC 1973) did not identify either the Louisiana or American 30 black bears as likely to occur on the GGNS site. However, the Final ER for operation of GGNS 31 (MP&L 1981) indicates that black bears (subspecies unidentified) were observed on the GGNS 32 site four times in 1977, and several bear tracks and other signs of inhabitance were observed in 33 the bottomlands south of the GGNS property line. MP&L (1981) did not indicate that these 34 observations were part of any formal surveys; they appear to have been causal sightings 35 recorded by construction or site staff. 36 Entergy commissioned a field survey for suitable Louisiana black bear habitat on GGNS in 37 December 2006 (Wenstrom 2007a). The survey identified 30 trees that met the FWS's criteria 38 of candidate trees for black bear den habitat. The trees included water oak (Quercus nigra), 39 chinquapin oak (Quercus muehlembergii), and other oaks, pecans (Carya spp.), and elms 40 (Ulmus spp.) of 36 in. (91 cm) diameter at breast height or larger. Only one tree had a cavity, 41 which was open and exposed. None of the trees had enclosed cavities, claw marks, or other 42 evidence of black bear use. The survey also identified one potential ground den about 400 ft 43 (121 m) north of the heavy haul road and 3,800 ft (1,200 m) east of the Mississippi River. The 44 survey noted numerous foraging areas containing blackberry (Rubus trivialis) thickets or shallow 45 water in bottomlands scattered throughout the GGNS site. Wenstrom (2007a) concluded that 46 the site contains suitable habitat for black bear foraging and denning, but the survey did not 47 reveal any evidence of current use by bears. 48 Affected Environment 2-60 Based on historic occurrence and recent habitat surveys of the GGNS site, the NRC assumes 1 that the Louisiana and American black bears occur in the action area. 2 Designated critical habitat for the Louisiana black bear is discussed below. The FWS has not 3 designated critical habitat for the American black bear. 4 Louisiana Black Bear Critical Habitat 5 The FWS published a final rule to designate Louisiana black bear critical habitat in 2009 6 (74 FR 10350). The FWS did not designate any land within Mississippi as critical habitat; the 7 closest critical habitat lies along the Tensas River Basin about 16 mi (26 km) west of the GGNS 8 site at its closest point (Entergy 2011a; NRC 2006 a). The FWS has designated a total of 9 628,505 ac (254,347 ha) of habitat as critical within this basin, of which about a third is owned 10 by the Federal or State government (74 FR 10350). However, because no critical habitat 11 occurs within the action area, the NRC will not analyze designated Louisiana black bear habitat 12 in any further detail in this SEIS. 13 Fat Pocketbook Mussel 14 In 1976, the FWS listed the fat pocketbook mussel (Potamilus capax) as endangered wherever 15 found (41 FR 24062). Fat pocketbook mussels are large freshwater mussels that grow up to 16 130 mm (5.1 in) in length (FWS 2012e). The shells are shiny and tan or light brown without 17 rays. Fat pocketbook mussels inhabit sand, mud, and silt substrates (FWS 2007b). Similar to 18 other freshwater mussels, fat pocketbook mussels filter feed by siphoning phytoplankton, 19 zooplankton, detritus, and diatoms from the water. 20 During the reproductive cycle, males release sperm into the water column that are sucked in by 21 females through their siphons during feeding and respiration. Fertilized eggs develop into 22 larvae (glochidia) within the gills of females. After releasing the mussel glochidia into the water, 23 the glochidia must attach to the appropriate species of fish, which they parasitize until they 24 develop into juvenile mussels (FWS 2012e). 25 Historically, fat pocketbook mussels inhabited a significant portion of the Mississippi River, from 26 the confluence of the Minnesota and St. Croix rivers, in Minnesota, downstream to the White 27 River system in Arkansas (FWS 2007b). While most historical records are from the upper 28 Mississippi River, FWS (2007b) was not aware of any records of occurrence within the upper 29 Mississippi River within the past two decades. Within the Lower Mississippi River, these 30 mussels currently inhabit some secondary channels and side channels along a 300 -mi (480-km) 31 stretch of the Mississippi River that includes the GGNS area (FWS 2007b). In 2003, Mississippi 32 Museum of Natural Science biologists collected 16 dead shells and 1 live fat pocketbook in the 33 Ben Lomond Dike Field near Vicksburg in the Mississippi River channel (FWS 2004). These 34 mussels also occur downstream of GGNS in St. Catherine Creek Wildlife Refuge on the 35 Mississippi River near Natchez (FWS 2006). 36 At GGNS, MP&L did not observe fat pocketbook mussels during preconstruction studies fro m 37 1972-1973 (Entergy 2011a). In November 2006, AAI conducted a mussel survey in support of 38 Entergy's COL application. The purpose of the survey was to determine whether any mussels 39 occurred along the east Mississippi River bank near RM 406, which is near the discharge 40 structure (Entergy 2008 b). Survey methods included visual surveys of dead mussel shells 41 along four shoreline sites and visual underwater surveys for live mussels along six transects. 42 AAI did not observe any dead or live fat pocketbook mussels. As a result of these surveys, AAI 43 concluded that mussel colonization near GGNS was not likely (Entergy 2008 b). 44 In correspondence with the NRC, FWS Louisiana Ecological Services Office stated that the fat 45 pocketbook occurs within 50 mi (80 km) of GGNS (FWS 2012 c). However, MDWFP (2012) did 46 Affected Environment 2-61 not identify the fat pocketbook as occurring within 2 mi (3.2 km) of GGNS. Given that MP&L 1 and AAI did not observe any dead or live fat pocketbook mussels at GGNS and MDFWP (2012) 2 did not identify fat pocketbook mussels within 2 mi (3.2 km) of GGNS, the NRC staff concludes 3 that this species is not likely to occur within the action area. The FWS has not designated 4 critical habitat for this species. 5 Rabbitsfoot Mussel 6 The FWS issued a proposed rule to list the rabbitsfoot mussel (Quadrula cylindrica ssp. 7 cylindrica) as threatened under the ESA in October 2012 (77 FR 63439). The ESA allows the 8 FWS one year from the publication of its proposed rule to make a final determination as to 9 whether to list the rabbitsfoot mussel as threatened. 10 Rabbitsfoot mussels are freshwater, medium to large -sized mussels that grow to about 11 6 in. (15 cm) in length (FWS 2010). Rabbitsfoot mussels filter feed by siphoning phytoplankton, 12 zooplankton, detritus, and diatoms from the water. Similar to fat pocketbook and other 13 freshwater mussels, male rabbitsfoot mussels release sperm into the water column that are 14 sucked in by females and develop into glochidia (FWS 2010). 15 At GGNS, MP&L did not observe rabbitsfoot mussels during preconstruction studies from 16 1972-1973 (Entergy 201 1a). As described above, in November 2006, AAI conducted a mussel 17 survey in support of Entergy's COL application (Entergy 2008 b). AAI did not observe any dead 18 or live rabbitsfoot mussels. As a result of these surveys, AAI concluded that mussel 19 colonization near GGNS was not likely (Entergy 2008 b). 20 In correspondence with natural resource agencies, FWS Louisiana Ecological Services Office, 21 FWS Mississippi Field Office, and MDWFP did not include rabbitsfoot mussel as a species that 22 occurs within the action area (FWS 2012 d, 2012 c; MDWFP 2012). Therefore, the NRC staff 23 concludes that this species is not likely to occur within the action area. 24 Rabbitsfoot Mussel Proposed Critical Habitat 25 The FWS proposed critical habitat for the rabbitsfoot mussel with its October 2012 Federal 26 Register notice issuing a proposed rule to list the species as threatened under the ESA 27 (77 FR 63439). The rule proposes critical habitat within 10 states in the midwest and 28 southeastern U.S. Within Mississippi, proposed critical habitat occurs within Hinds, Sunflower, 29 Tishomingo, and Warren Counties. The only county applicable to the proposed GGNS license 30 renewal action area is Warren County, in which one proposed critical habitat unit occurs: RF17 31 (Big Black River). RF17 includes 43.3 river kilometers (26.9 river miles) of the Big Black River 32 from the Porter Creek confluence west of Lynchburg, Hinds County, Mississippi, downstream to 33 Mississippi Highway 27 west of Newman, Warren County, Mississippi (77 FR 63439). 34 Within the action area, the Baxter -Franklin transmission line corridor traverses the Big Black 35 River in Claiborne County. However, the corridor does not traverse this river within Warren 36 County where the proposed critical habitat unit RF17 is located. The portion of the 37 Baxter-Franklin transmission line in Warren County is a 2.2 -mi (3.5-km) stretch in the western 38 portion of the county. RF17 occurs in the eastern portion of the county. Thus, the NRC will not 39 analyze proposed rabbitsfoot mussel critical habitat in any further detail in this SEIS. 40 2.2.8.4 Species Protected by the State of Mississippi 41 Aquatic Species 42 Crystal Darter The State of Mississippi considers crystal darters (Crystallaria asprella) 43 endangered . These fish are elongated, cigar -shaped fish that grow to a maximum length of 44 approximately 150 mm (6 in.). The body is light -olive with dark lateral bands and dark blotches 45 along each side (MDWFP 2001). Crystal darters inhabit larger creeks and rivers with sand and 46 Affected Environment 2-62 gravel bottoms and a depth of 60 cm (2 ft) or more. These fish prefer moderate to strong 1 currents. The historical range of crystal darters included Wisconsin east to Ohio and south to 2 Oklahoma, Louisiana and Florida, although they currently are absent from all of Ohio, Indiana, 3 and Illinois (MDWFP 2001). Crystal darters inhabit the Bayou Pierre River and tributaries, 4 which flow as close as 2 mi (3.2 km) east of GGNS (MDWFP 2001; Entergy 2011a). The FES 5 for construction of GGNS (AEC 1973) and the ESP EIS (NRC 2006 a) did not identify crystal 6 darter as occurring on the GGNS site. 7 Crystal darters may occur in suitable habitat along the transmission line corridors. For example, 8 crystal darters inhabit the Bayou Pierre, which is crossed by the Franklin transmission line. 9 However, no GGNS-related aquatic surveys have been conducted along the transmission lines. 10 Species of Special Concern In the State of Mississippi, a species of special concern includes 11 "any species that is uncommon in Mississippi, or has unique or highly specific habitat 12 requirements or scientific value and therefore requires careful monitoring of its status" 13 (MDWFP 2011). In its correspondence with the NRC, the MDWFP (2012) identified five fish 14 species considered species of special concern by the State of Mississippi: blue sucker 15 (Cycleptus elongates), chestnut lamprey (Ichthyomyzon castaneus), black buffalo 16 (Ictiobus niger), sicklefin chub (Macrhybopsis meeki), and paddlefish (Polyodon spathula). 17 These species inhabit portions of the Mississippi River (NatureServe 2010). MP&L observed 18 paddlefish, black buffalo, blue sucker, and chestnut lamprey during preconstruction surveys in 19 1972 and 1973 (AEC 1973). The FES for construction of GGNS (AEC 1973) and the ESP EIS 20 (NRC 2006 a) did not identify sicklefin chub as occurring on the GGNS site. 21 Chestnut lamprey, blue sucker, black buffalo sicklefin chub, and paddlefish may occur in 22 suitable habitat along the transmission line corridors. For example, crystal darter, chestnut 23 lamprey, blue sucker, and chestnut lamprey inhabit the Bayou Pierre, which is crossed by the 24 Franklin transmission line. However, no GGNS-related aquatic surveys have been conducted 25 along the transmission lines. 26 Terrestrial Species 27 In its correspondence with the NRC, the MDWFP (2012) identified two State -listed species that 28 may occur in the action area: Webster's salamander (Plethodon websteri) and the white ibis 29 (Eudocimus albus). Webster's salamander is a small salamander with several color morphs 30 that occurs in mesophytic forest bordering rocky streams. It generally seeks shelter under logs, 31 bark, or leaf litter on the forest floor or on rocky stream beds. The white ibis is a large white bird 32 that nests in large groups in coastal marshes along the Atlantic and Gulf coasts. The FES for 33 construction of GGNS (AEC 1973) and the ESP EIS (NRC 2006 a) identify the white ibis as 34 occurring on the GGNS site. The species is also likely to occur in suitable habitat along the 35 transmission line corridors. Because the MDWFP (2012) did not identify any impacts of the 36 proposed license renewal that would affect these species, neither the Webster's salamander nor 37 the white ibis will be considered in further detail in this SEIS. 38 2.2.8.5 Species Protected Under the Bald and Golden Eagle Protection Act 39 The Bald and Golden Eagle Protection Act prohibits anyone from taking bald eagles 40 (Haliaeetus leucocephalus) or golden eagles (Aquila chrysaetos), including their nests or eggs, 41 without an FWS -issued permit. The term "take" in the Act is defined as to "pursue, shoot, shoot 42 at, poison, wound, kill, capture, trap, collect, molest, or disturb" (50 CFR 22.3). "Disturb" means 43 to take action that (1) causes injury to an eagle, (2) decreases its productivity by interfering with 44 breeding, feeding, or sheltering behavior, or (3) results in nest abandonment (50 CFR 22.3). 45 Bald eagles live and nest along the Mississippi River, but no studies are available on nesting 46 or population status in the action area. However, Entergy commissioned a one -day 47 Affected Environment 2-63 reconnaissance field survey to identify bald eagle nests along the Mississippi River in the 1 vicinity of GGNS in December 2006 (Wenstrom 2007b). The survey did not identify any bald 2 eagle nests or any eagles scavenging or perched in the survey area that would indicate bald 3 eagles may nest along this portion of the river (Wenstrom 2007b). 4 2.2.8.6 Species Protected Under the Migratory Bird Treaty Act 5 The FWS administers the Migratory Bird Treaty Act (MBTA), which prohibits anyone from taking 6 native migratory birds or their eggs, feathers, or nests. The MBTA definition of a "take" differs 7 from that of the ESA and is defined as "to pursue, hunt, shoot, wound, kill, trap, capture, or 8 collect, or any attempt to carry out these activities" (50 CFR 10.12). Unlike a take under the 9 ESA, a take under the MBTA does not include habitat alteration or destruction. The MBTA 10 protects a total of 1,007 migratory bird species (75 FR 9282). Of these 1,007, the FWS allows 11 for the legal hunting of 58 species as game birds (FWS undated b). Within Mississippi, the 12 MDWFP manages migratory bird hunting seasons and associated licenses for turkeys, 13 waterfowl, quail, and doves. The Federally and State -listed bird species that appear in 14 Table 2-6 are protected under the MBTA. Table 2 -4 lists other bird species that commonly 15 occur on or near the GGNS site, all of which are protected by the MBTA. Additionally, all U.S. 16 native bird species that belong to the families, groups, or species listed at 10 CFR 10.13 are 17 protected under the MBTA. 18 Entergy holds a depredation permit from the FWS that authorizes Entergy to take 200 cliff 19 swallows (Petrochelidon spp.), 200 cliff swallow nests (including eggs), 200 barn swallows 20 (Hirundo rustica), and 200 barn swallow nests (including eggs) per year to mitigate the 21 safety-related concern that the birds pose when nesting on certain plant structures 22 (FWS 2012 a). The permit directs Entergy to favor the use of hazing, harassment, or other 23 non-lethal techniques over lethal techniques. From 2006 through 2010, Entergy took 13 cliff 24 swallows and 7 eggs in 2006 and 4 barn swallows in 2009 (Entergy 2007, 2008a, 2009, 2010a, 25 2011b). 26 2.2.9 Socioeconomics 27 This section describes current socioeconomic factors that have the potential to be directly o r 28 indirectly affected by changes in operations at GGNS. GGNS, and the communities that 29 support it, can be described as a dynamic socioeconomic system. The communities supply the 30 people, goods, and services required to operate the nuclear power plant. Power plant 31 operations, in turn, supply wages and benefits for people and dollar expenditures for goods and 32 services. The measure of a community's ability to support GGNS operations depends on its 33 ability to respond to changing environmental, social, economic, and demographic conditions. 34 The socioeconomics region of influence (ROI) is defined by the areas where GGNS employees 35 and their families reside, spend their income, and use their benefits, thus affecting the economic 36 conditions of the region. GGNS employs a permanent workforce of approximately 37 690 employees (Entergy 2011a). Approximately 81 percent live in Claiborne, Hinds, Jefferson, 38 and Warren counties (see Table 2-7). Most of the remaining 19 percent of the workforce are 39 spread among 13 counties in Mississippi, with numbers ranging from one to 31 employees per 40 county. Given the residential locations of GGNS employees, the most significant effects of plant 41 operations are likely to occur in Claiborne, Hinds, Jefferson, and Warren counties; therefore , 42 these four counties are the GGNS ROI. The focus of the socioeconomic impact analysis in this 43 document is, therefore, on the impacts of continued GGNS operation on these four counties. 44 Affected Environment 2-64 Table 2-7. 2009 GGNS Employee Residence by County 1 County Number of Employees Percentage of Total Mississippi Warren 240 35 Claiborne 142 21 Hinds 94 14 Jefferson 82 12 Copiah 31 4 Adams 30 4 Lincoln 23 3 Other 37 5 Other states 11 2 Total 690 100 Source: Entergy 2011a Refueling outages at the GGNS typically have occurred at 18 -month intervals. During refueling 2 outages, site employment increases by as many as 700 -900 temporary workers for 3 approximately 25 -30 days (Entergy 2011a). Outage workers are drawn from all regions of the 4 country; however, the majority would be expected to come from Mississippi, Louisiana, and 5 other southeastern states. The following sections describe the housing, public services, offsite 6 land use, visual aesthetics and noise, population demography, and the economy in the ROI 7 surrounding GGNS. 8 2.2.9.1 Housing 9 The socioeconomic ROI is dominated by Hinds County, which is part of the Jackson 10 metropolitan area. The size of the Jackson area weighs heavily on the housing statistics, as the 11 rural counties of Claiborne and Jefferson are considerably different than the ROI averages 12 would indicate. Table 2-8 lists the total number of occupied and vacant housing units, vacancy 13 rates, and median home value in the four -county ROI. According to the 2010 Census, there 14 were approximately 133,096 housing units in the socioeconomic region, of which approximately 15 113,607 were occupied. The median values of owner -occupied housing units in the ROI range 16 from $53,500 in Claiborne County to $105,000 in Hinds County. The vacancy rate also ranged 17 considerably, from 11.5 percent in Warren County to 23.8 percent in Jefferson County 18 (USCB 2012). 19 Table 2-8. Housing in GGNS ROI 20 2006-20 10 , 5-year Estimate Claiborne Hinds Jefferson Warren ROI Total 4,255 103,351 3,717 21,773 133,096 Occupied housing units 3,308 88,201 2,831 19,267 113,607 Vacant units 947 15,150 886 2,506 19,489 Vacancy rate (percent) 22.3 14.7 23.8 11.5 14.6 Median value (dollars) 53,500 105,000 67,000 99,700 101,400 Source: USCB 2012

Affected Environment 2-65 2.2.9.2 Public Services 1 This section presents information on public services that include water supply, education, and 2 transportation. 3 Water Supply 4 Information about municipal water suppliers in close proximity to GGNS and maximum design 5 yields, reported annual peak usage, and population served are presented in Table 2 -9. The 6 source of potable water at GGNS is Entergy's private water system accessing groundwater. 7 Table 2-9. Claiborne County Public Water Supply Systems 8 Water System Capacity (GPM) Usage (GPM) Population Served Alcorn State University 1,136 646 3,824 CS&I Water Association #1 288 185 1,100 Hermanville Water Association 552 160 1,230 Pattison Water Association -West 982 389 2,994 Reedtown Water Association 243 35 504 Romola Water Association 556 155 650 Town of Port Gibson 850 587 4,308 Entergy Operations Inc. (private) 1,335 223 1,000 Sources: Entergy 2011a; EPA 2012e Beyond the water systems near GGNS, larger systems supply water to Vicksburg, Clinton, and 9 Jackson, Mississippi. These systems use groundwater wells with the exception of the City of 10 Jackson, which relies on Lake Jackson to provide water to a population of approximately 11 176,000 (EPA 2012e). 12 Education 13 The Claiborne County School District has one elementary school, one middle school, and one 14 high school. During the 2009 -2010 school year, enrollment was 1,723 students (NCES 2012a). 15 Hinds County has four public school districts and 42 elementary schools, 17 middle schools, 16 11 high schools, and 16 alternative or special needs schools. The enrollment in 2009 was over 17 42,200 students (NCES 2012a). 18 The Jefferson County School District has two elementary schools, one middle school, one high 19 school, and two alternative or vocational schools. The enrollment during the 2009 -2010 school 20 year was 1,465 students (NCES 2012a). 21 The Vicksburg -Warren School District serves all of Warren County and includes eight 22 elementary schools, four middle schools, two high schools, and two alternative or vocational 23 schools. During the 2009 -2010 school year, enrollment was 8,871 students (NCES 2012a). 24 Transportation 25 The area surrounding GGNS is largely rural. Highway access to Claiborne County and GGNS 26 from population centers is via US -61, a principal arterial paralleling the Mississippi River along 27 much of its course. Interstate 20 is a four -lane divided highway that runs east and west, 28 Affected Environment 2-66 connecting Dallas, TX with Jackson, MS, and passes through 1 Vicksburg-about 25 mi north of GGNS. US -84 is also a four -lane divided highway that lies 2 about 30 mi south of GGNS, and runs east -west, connecting Interstate 49 in Louisiana with 3 Interstate 55 in central Mississippi. The Natchez Trace Parkway, administered by the National 4 Park Service, preserves a transportation route of Civil War historical significance and provides 5 tourist access to Jefferson and Claiborne counties as it traverses a route between Natchez and 6 Clinton. 7 Table 2-10 lists commuting routes to GGNS and average annual daily traffic (AADT) volume 8 values. The AADT values represent traffic volume during the average 24 -hour period 9 during 2011. 10 Table 2-10. Major Commuting Routes Near GGNS 2011 Average Annual Daily Traffic 11 Roadway and Location Average Annual Daily Traffic Grand Gulf R oad at GGNS main gate 1,600 Old Mill R oad between Grand Gulf R oad and Bald Hill R oad 860 Grand Gulf R oad between Lake Claiborne R oad and Old Mill R oad 980 Grand Gulf R oad between US Hwy 61 and Lake Claiborne R oad 1,200 US Hwy 61 between Shiloh R oad and Willow R oad 7,500 US Hwy 61 between Natchez Trace Pkwy and McComb Avenue 6,600 Source: MDOT 2012 2.2.9.3 Offsite Land Use 12 Land use in the GGNS ROI primarily consists of agricultural lands, with small urban areas and 13 undeveloped forested land. 14 Claiborne County occupies approximately 487 mi 2 (1,247 square kilometers (km 2)) 15 (USCB 2012). Agricultural and forested lands make up the majority of the land used, with urban 16 lands making up about 4 percent of the total county land area (USDA NASS 2012). The 17 principal agriculture land use is pasture and hay crops and livestock products, with the market 18 value of crops (mostly cotton and soybeans) being about double that of livestock, poultry, and 19 their products. The number of farms in Claiborne County decreased about 12 percent from 20 2002-2007. Farmland acreage in the county decreased 7 percent during the same period, and 21 the average size of a farm increased 6 percent to 360 ac (146 ha) (USDA NASS 2009). 22 Hinds County occupies approximately 869 mi 2 (2,251 km 2) (USCB 2012). Hinds County is 23 home to part of Jackson, the State capital and largest city in Mississippi, along with Clinton, a 24 principal suburb of Jackson. Nearly 14 percent of the county is urbanized (USDA NASS 2012). 25 The majority of the county land area is either forested (40 percent) or agricultural land 26 (30 percent). The principal crop is livestock forage (i.e., hay and grass silage), followed by 27 cotton and nursery and greenhouse products. Livestock (mostly cattle and calves) is about 28 23 percent the market value for all agriculture products. The number of farms in Hinds County 29 decreased from 2002 -2007 by 14 percent. Farmland acreage in the county decreased 30 seven percent during the same period, and the average size of a farm increased 9 percent to 31 24 ac (98 ha) (USDA NASS 2009). 32 Jefferson County covers approximately 519 mi 2 (1,344 km 2) (USCB 2012). Jefferson County is 33 mainly rural, with just 4 percent of the county urbanized (USDA NASS 2012). Undeveloped 34 forest, grassland, and wetlands make up over 87 percent of the county's land area. The 35 Affected Environment 2-67 principal crop is livestock forage (i.e., hay and grass silage), followed by cotton and nursery and 1 greenhouse products. Livestock (mostly poultry and cattle) is about 70 percent the market 2 value for all agriculture products. The number of farms in Jefferson County increased from 3 2002-2007 by 13 percent. Farmland acreage in the county also increased 10 percent during 4 the same period, and the average size of a farm increased 2 percent to 282 ac (114 ha) 5 (USDA NASS 2009). 6 Warren County occupies approximately 587 mi 2 (1,520 km 2) (USCB 2012). Nearly 7 seven percent of the county is urbanized (USDA NASS 2012), with Vicksburg being the 8 principal city. The majority of the county land area is either forested (about 40 percent) or 9 wetlands (about 30 percent). The principal crops are soybeans and cotton, making up over 10 85 percent of the value of all agricultural products. The number of farms in Warren County 11 remained stable over the 2002 -2007 period, as has farmland acreage. The average size of a 12 farm is 403 ac (163 ha) (USDA NASS 2009). 13 2.2.9.4 Visual Aesthetics and Noise 14 GGNS is situated on a relatively flat bluff above the shore of the Mississippi River. Predominant 15 features include the containment structure, turbine building, auxiliary building, control building, 16 diesel generator building, standby service water cooling towers and basins, enclosure building, 17 radwaste building, independent spent fuel storage installation (ISFSI), auxiliary cooling tower, 18 and the natural draft cooling tower (Entergy 2011a). 19 There is often a visible plume of condensation rising up from the cooling towers. Its height and 20 visibility depend on weather conditions such as temperature, humidity, and wind speed. It is 21 typically several hundred feet tall and can be seen from several miles away. Because of the 22 open and flat terrain on the Louisiana side of the Mississippi River, the plume and the cooling 23 tower are clearly seen from US -65 in Louisiana for many miles in all directions. The rolling and 24 forested terrain of Claiborne County provides significant visual screening in the immediate 25 vicinity of GGNS. 26 Noise from nuclear plant operations can be detected off site. There are no local noise 27 ordinances that limit allowable sound levels at GGNS. The staff determined background noise 28 levels at GGNS are expected to range from 45 to 55 dBA at the nearest site boundary 29 (NRC 2006a). Noise levels may sometimes exceed the 55 -decibel adjusted level that the EPA 30 uses as a threshold level to protect against excess noise during outdoor activities. However, 31 according to the EPA this threshold does "not constitute a standard, specification, or regulation," 32 but was intended to give a basis for state and local governments establishing noise standards 33 (EPA 1974). 34 2.2.9.5 Demography 35 According to the 2010 Census, an estimated 23,406 people live within 20 mi (32 km) of GGNS, 36 which equates to a population density of 19 persons per mi 2 (Entergy 2011a). This translates to 37 a Category 1, "most sparse" population density using the GEIS measure of sparseness (less 38 than 40 persons per mi 2 and no community with 25,000 or more persons within 20 mi). An 39 estimated 329,043 people live within 50 mi (80 km) of GGNS with a population density of 40 42 persons per mi 2 (Entergy 2011a). Since Jackson is located beyond 50 mi from GGNS, this 41 translates to a Category 1 density, using the GEIS measure of proximity (no cities with 42 100,000 or more persons and less than 50 persons per mi 2 within 50 mi). Therefore, GGNS is 43 located in a low population area based on the GEIS sparseness and proximity matrix. 44 Table 2-11 shows population projections and growth rates from 1970 -2050 in the four -county 45 GGNS ROI. The net population growth rate in the ROI has been negative over the last two 46 decades. Based on State forecasts, rural counties are expected to continue to decline in 47 Affected Environment 2-68 population through 2025, while more developed urban counties are expected to continue 1 modest growth through 2025 (MIHL 2012). Beyond 2025, the staff applied the 50 -year trend in 2 population, observed between 1970 and 2020 projections, to approximate long -term trends. 3 Table 2-11. Population and Percent Growth in GGNS ROI Counties 4 from 1970-2009 and Projected for 2010 -2050 5 Year Claiborne Hinds Jefferson Warren Popu- lation Percent growth(a) Popu- lation Percent growth(a) Popu- lation Percent growth(a) Popu- lation Percent growth(a) 1970 10,086 - 214,973 - 9,295 - 44,981 - 1980 12,279 21.7% 250,998 16.8% 9,181 -1.2% 51,627 14.8% 1990 11,370 -7.4% 254,441 1.4% 8,653 -5.8% 47,880 -7.3% 2000 11,831 4.1% 250,800 -1.4% 9,740 12.6% 49,644 3.7% 2010 9,604 -18.8% 245,285 -2.2% 7,726 -20.7% 48,773 -1.8% 2020 8,700 -9.4% 250,264 2.0% 7,074 -8.4% 48,030 -1.5% 2030 8,676 -0.3% 251,086 0.3% 7,040 -0.5% 48,095 0.1% 2040 8,652 -0.3% 251,910 0.3% 7,006 -0.5% 48,160 0.1% 2050 8,628 -0.3% 252,737 0.3% 6,973 -0.5% 48,225 0.1% - = No data available.

(a) Percent growth rate is calculated over the previous decade.

Sources: Population data for 1970 through estimated population data for 2009 (USCB 2012); population projections for 2020 by Mississippi Institutions of Higher Learning (MIHL2012); 2030 -2050 calculated. Demographic Profile 6 According to the 2010 Census, minority populations were estimated to have increased by over 7 17,100 persons and comprised 69.4 percent of the ROI population (see Table 2 -12). Most of 8 this increase was due to an estimated influx of African Americans to urban centers such as 9 Jackson and Vicksburg, while minority populations in rural counties declined over the same 10 period. 11 Affected Environment 2-69 Table 2-12. Demographic Profile of the Population in the GGNS ROI in 2010 1 Claiborne Hinds Jefferson Warren ROI Total Population 9,604 245,285 7,726 48,773 311,388 Race (percent of total population, Not -Hispanic or Latino) White 14.1 28.0 13.7 49.5 30.6 Black or African American 84.0 68.8 85.4 46.8 66.3 American Indian and Alaska Native 0.1 0.1 0.2 0.2 0.2 Asian 0.4 0.8 0.0 0.8 0.7 Native Hawaiian Other Pacific Islander 0.0 0.0 0.0 0.0 0.0 Some other race 0.1 0.1 0.0 0.0 0.1 Two or more races 0.5 0.7 0.3 0.7 0.7 Ethnicity Hispanic or Latino 74 3,630 28 896 4,628 Percent of total population 0.8 1.5 0.4 1.8 1.5 Minority population (including Hispanic or Latino ethnicity) Total minority population 8,251 176,676 6,670 24,630 216,227 Percent minority 85.9 72.0 86.3 50.5 69.4 Source: USCB 2012. Transient Population 2 Within 50 mi (80 km) of GGNS, colleges and recreational opportunities attract daily and 3 seasonal visitors who create demand for temporary housing and services. In 2010, there were 4 approximately 21,859 students attending colleges and universities within 50 mi (80 km) of 5 GGNS (NCES 2012b). 6 Based on the 2010 Census, approximately 10,471 seasonal housing units are located within 7 50 mi of GGNS. Of those, 1,536 are located in the GGNS four-county ROI. Table-13 supplies 8 information on seasonal housing for the counties located all or partly within 50 mi of GGNS. 9 Affected Environment 2-70 Table 2-13. 2010 Seasonal Housing in Counties within 50 miles of GGNS 1 County(a) Housing Units Vacant Housing Units: for Seasonal, Recreational, or Occasional Use Percent Mississippi Adams 14,771 649 4.4 Amite 6,638 553 8.3 Claiborne 4,255 388 9.1 Copiah 12,056 323 2.7 Franklin 4,170 482 11.6 Hinds 103,351 458 0.4 Issaquena 712 46 0.4 Jefferson 3,717 350 6.5 Lincoln 15,101 411 9.4 Madison 37,349 375 2.7 Rankin 55,200 544 1.0 Sharkey 2,065 167 1.0 Simpson 11,837 94 8.1 Warren 21,773 340 0.8 Wilkinson 5,085 928 1.6 Yazoo 10,094 374 18.2 County Subtotal 308,174 6,482 2.1 Louisiana Caldwell 5,014 622 12.4 Catahoula 4,987 779 15.6 Concordia 9,369 931 9.9 East Carroll 2,813 65 2.3 Franklin 8,987 295 3.3 Madison 4,827 235 4.9 Richland 8,557 442 5.2 Tensas 3,357 620 18.5 County Subtotal 47,911 3,989 8.3 Total 356,085 10,471 2.9 (a) Counties within 50 mi (80 km) of GGNS with at least one block group located within the 50 -mi (80-km) radius. Source: USCB 2012. Migrant Farm Workers 2 Migrant farm workers are individuals whose employment requires travel to harvest agricultural 3 crops. These workers may or may not have a permanent residence. Some migrant workers 4 follow the harvesting of crops, particularly fruit, throughout rural areas of the United States. 5 Others may be permanent residents near GGNS and travel from farm to farm harvesting crops. 6 Affected Environment 2-71 Migrant workers may be members of minority or low -income populations. Because they travel 1 and can spend a significant amount of time in an area without being actual residents, migrant 2 workers may be unavailable for counting by census takers. If uncounted, these workers would 3 be "underrepresented" in U.S. Census Bureau (USCB) minority and low -income population 4 counts. 5 Information on migrant farm and temporary labor was collected in the 2007 Census of 6 Agriculture. Table 2-14 supplies information on migrant farm workers and temporary farm labor 7 (less than 150 days) within 50 mi of GGNS. According to the 2007 Census of Agriculture, 8 approximately 6,440 farm workers were hired to work for less than 150 days and were 9 employed on 1,419 farms within 50 mi of GGNS. The county with the largest number of 10 temporary farm workers (1,152) on 185 farms was Franklin County, Louisiana 11 (USDA NASS 2009). 12 Affected Environment 2-72 Table 2-14. Migrant Farm Workers and Temporary Farm Labor in Counties Located 1 within 50 Miles of GGNS 2 County(a) Number of Farms with Hired Farm Labor Number of Farms Hiring Workers for Less than 150 days Number of Farm Workers Working for Less than 150 days Number of Farms Reporting Migrant Farm Labor Mississippi Adams 30 24 (b) 3 Amite 91 72 339 7 Claiborne 49 47 176 3 Copiah 108 86 438 2 Franklin 22 20 64 2 Hinds 142 108 344 9 Issaquena 28 15 76 3 Jefferson 56 38 143 0 Lincoln 125 100 401 6 Madison 134 95 280 9 Rankin 138 108 364 5 Sharkey 38 7 171 4 Simpson 114 95 300 5 Warren 50 40 157 2 Wilkinson 49 38 155 0 Yazoo 121 77 508 7 Subtotal 1,295 970 3,916 67 Louisiana Caldwell 65 58 139 4 Catahoula 61 36 218 4 Concordia 61 33 198 1 East Carroll 75 25 178 2 Franklin 250 185 1152 6 Madison 67 28 156 4 Richland 112 74 250 13 Tensas 59 10 233 5 Subtotal 750 449 2,524 39 Total 2,045 1,419 6,440 106 (a) Counties within 50 miles of GGNS with at least one block group located within the 50 -mi radius. (b) Data not disclosed by USDA. Source: 2007 Census of Agriculture -County Data (USDA NASS 2009). In the 2002 Census of Agriculture, farm operators were asked for the first time whether or not 3 they hired migrant workers -defined as a farm worker whose employment required travel -to 4 do work that prevented the migrant worker from returning to their permanent place of residence 5 the same day. A total of 106 farms, in the 50 -mi radius of GGNS, reported hiring migrant 6 Affected Environment 2-73 workers in the 2007 Census of Agriculture. Richland County, Louisiana, reports the most farms 1 with migrant farm labor (13 farms) (USDA NASS 2009). 2 2.2.9.6 Economy 3 This section contains a discussion of the economy, including employment and income, 4 unemployment, and taxes. 5 Employment and Income 6 From 2000 to 2012, the civilian labor force in the GGNS ROI declined by about 5 percent to just 7 over 147,000. The number of employed persons declined by about 7 percent over the same 8 period, to about 135,000. Consequently, the number of unemployed people in the ROI has 9 increased over 36 percent in the same period, to over 12,200, or about 8.3 percent of the 10 current workforce (BLS 2012). 11 In 2010, state and local government made up the largest sector of the economy in terms of 12 employment (19.6 percent), followed by health care and social assistance (13.9 percent), retail 13 trade (8.2 percent), administrative services (6.4 percent) and accommodations and food 14 services (6.2 percent) (BEA 2012). A list of selected major employers in the ROI is given in 15 Table 2-15. As shown in the table, GGNS is the 22nd largest employer in the ROI and the 16 second largest in Claiborne County. 17 Affected Environment 2-74 Table 2-15. Major Employers of the GGNS ROI in 2012 1 Employer Number of Employees County State of Mississippi 31,556 Hinds University Medical Center 8,000 Hinds U.S. Government 5,500 Hinds Jackson Public Schools 4,814 Hinds Baptist Health Systems 2,875 Hinds St. Dominic Health Services 2,600 Hinds City of Jackson 2,323 Hinds Jackson State University 1,667 Hinds USACE Engineer Research & Development Center 1,600 Warren River Region Health Systems 1,500 Warren AT&T Mississippi 1,300 Hinds Vicksburg-Warren School District 1,300 Warren Central MS Medical Center 1,200 Hinds USACE, Division/District 1,100 Warren Trustmark National Bank 1,075 Hinds Delphi Mississippi 1,075 Hinds Ameristar Casino 900 Warren Saks Incorporated 800 Hinds Entergy Mississippi 765 Hinds Alcorn State University 750 Claiborne LeTourneau Technologies 750 Warren Grand Gulf Nuclear Station 691 Claiborne Tyson Foods 680 Warren Eaton Aerospace 625 Hinds DiamondJacks Casino Hotel 588 Warren City of Vicksburg 586 Warren Walmart Supercenter 550 Warren Jefferson Co School District 100 Jefferson Southern Lumber Co., Inc. 80 Claiborne MMC Materials, Inc. 32 Claiborne Source: Port Gibson Chamber (2012), Warren Co. Port Commission (2012), Hinds Co. Economic Development Authority (2008). Smaller Jefferson and Claiborne County employers are shown to be representative. Estimated income information for the GGNS ROI is presented in Table 2 -16. According to the 2 USCB's 2006 -2010 American Community Survey 5 -Year Estimates, people living in Claiborne 3 and Jefferson Counties had median household and per capita incomes below the State 4 average, while Hinds and Warren counties had median incomes higher than the State average. 5 The same trend is evident for families and individuals living below the official poverty level. The 6 relative lack of economic development in Claiborne and Jefferson counties contributes to higher 7 Affected Environment 2-75 than average poverty and lower than average median incomes compared to the more 1 economically developed counties of Hinds and Warren. The State of Mississippi, as a whole, is 2 positioned between the economically developed and the economically undeveloped county 3 groupings of the GGNS ROI for both median income and living below poverty level. 4 Table 2-16. Estimated Income Information for the GGNS ROI in 2010 5 Claiborne Hinds Jefferson Warren Mississippi Median household income (dollars)(a) 24,150 39,215 24,304 40,404 37,881 Per capita income (dollars)(a) 12,571 20,676 12,534 22,079 19,977 Individuals living below the poverty level (percent) 35.0 22.5 39.0 21.4 16.7 Families living below the poverty level (percent) 27.6 17.7 29.3 16.5 21.2 (a) In 2010 inflation adjusted dollars. Source: USCB 2012. Unemployment 6 Unemployment rates in the GGNS ROI have mirrored State and national trends from 2007 to 7 2012. Table 2 -17 illustrates the not -seasonally -adjusted unemployment rates for the GGNS 8 ROI counties compared to State and national rates. 9 The effects of the recent economic recession on employment are visible in all counties. 10 Claiborne and Jefferson Counties have had consistently higher unemployment rates than their 11 urban neighboring counties through this period. 12 Table 2-17. 2007-2012 Unemployment Rates in the GGNS ROI 13 ROI Counties 2007 2008 2009 2010 2011 2012 Claiborne 9.8 9.1 14.3 12.8 14.3 11.8 Hinds 5.4 5.0 7.1 8.9 8.8 7.6 Jefferson 11.2 10.7 14.7 14.4 14.5 13.0 Warren 6.0 5.3 8.7 10.5 11.3 9.3 Mississippi 5.9 5.5 8.3 9.9 10.0 8.3 United States 4.3 4.8 8.6 9.5 8.7 7.7 Source: MDES (2012); for consistency all values not seasonally adjusted. Taxes 14 Mississippi Code Title 27 addresses taxation of nuclear generating plants and the distribution of 15 tax revenues from nuclear plants. This code states that any nuclear generating plant located in 16 the State, which is owned or operated by a public utility, is exempt from county, municipal, and 17 district ad valorem taxes. In lieu of the payment of county, municipal, and district ad valorem 18 taxes, the nuclear power plant pays the Mississippi State Tax Commission a sum based on the 19 assessed value of the nuclear generating plant. 20 GGNS is taxed by the State for a sum equal to 2 percent of the assessed value but not less 21 than $20 million annually, $7.8 million of which is provided to Claiborne County. Of this amount, 22 $3 million is contingent upon Claiborne County upholding its commitment to the GGNS offsite 23 Affected Environment 2-76 emergency plan. The $7.8 million provided by the State represents roughly 83 percent of all 1 Claiborne County revenues. 2 The Mississippi State Tax Commission transfers $160,000 annually to the city of Port Gibson, 3 provided the city maintains its commitment to the GGNS offsite emergency plan. Ten percent of 4 the remainder of the payments are transferred from the Mississippi Tax Commission to the 5 General Fund of the State. The balance of the tax revenue from the GGNS site is transferred to 6 the counties and municipalities in the State of Mississippi where electric service is provided. 7 The tax revenues are distributed in proportion to the amount of electric energy consumed by the 8 retail customers in each county, with no county receiving an excess of 20 percent of the funds. 9 This distribution, based on energy consumed, also includes Claiborne County. 10 (Mississippi Code Title 27) 11 2.2.10 Historic and Archaeological Resources 12 This section discusses the cultural background and known historic and archaeological 13 resources in and around GGNS. 14 2.2.10.1 Cultural Background 15 The area in and around GGNS has a high potential for significant prehistoric and historic 16 resources. Human occupation in the Mississippi Valley area is generally characterized based 17 on the following chronological sequence (Peacock 2005): 18 Paleoindian Period (14,000+ to 9,000 years before present (BP)) 19 Archaic Period (9,000 to 3,000 BP) 20 Woodland Period (3,000 to 1,000 BP) 21 Mississippian Period (1,000 to 300 BP) 22 Protohistoric/Historic Period (300 BP to present) 23 Paleoindian Period (14,000 to 9,000 BP) 24 The Paleoindian Period is generally characterized by highly mobile bands of hunters and 25 gatherers. Little information is known about Paleoindian methods of subsistence, but it is 26 assumed that they would have hunted now -extinct megafauna (e.g., mammoth, ground sloth, 27 and saber-tooth tiger), in addition to hunting smaller game and gathering wild plants. No 28 Paleoindian sites are currently known in the GGNS vicinity; however, Paleoindian sites in the 29 Southeastern U.S. generally consist of isolated projectile points or other tools such as flaked 30 stone end scrapers or bone tools (Peacock 2005). 31 Archaic Period (9,000 to 3,000 BP) 32 The Archaic Period is generally distinguished from the preceding Paleoindian Period by 33 changes in the environment, technology, and population. The warmer and dryer part of the 34 Early Archaic Period facilitated groups' ability to exploit more diverse resources, and 35 consequently their tool kit also became more diversified. Technological changes are evidenced 36 by the manufacture of notched projectile points, which were smaller than Paleoindian points, 37 likely reflecting a reliance on smaller game (Neusius and Gross 2007). Groups became 38 sedentary as the climate became wetter and warmer as the Archaic Period progressed, and 39 ceremonialism (e.g., mounds, effigies) is evident in the archaeological record during this time. 40 Archaic sites have been documented on GGNS property (Entergy 2011a; MDAH 2012). 41 Affected Environment 2-77 Woodland Period (3,000 to 1,000 BP) 1 The Woodland Period is often divided into early, middle, and late periods. One of the most 2 notable aspects in the archaeological record of the Woodland Period is widespread pottery use; 3 the period is sometimes referred to as the Early Ceramic Period. Groups living permanently in 4 one place dominated the settlement pattern during the Woodland Period, an aspect that may 5 have facilitated the widespread development of pottery (Peacock 2005). Mounds were 6 frequently built in the Middle Woodland Period, but this practice dissipated by the end of the 7 period. Sites dating to the Late Woodland Period are the most common sites found in 8 Mississippi. These sites are found in various types of landforms; valleys, hills, deltas, and 9 prairies (Peacock 2005). Another important development during the latter portion of the 10 Woodland Period is the bow -and-arrow, which is evidenced by smaller projectile points and 11 likely involved significant changes in the way warfare and hunting were conducted (Lee 2010). 12 The GGNS property contains an example of a Middle Woodland mound. The Grand Gulf 13 Mound Site (22Cb522) is located on a loess bluff 220 ft above sea level, overlooking the 14 Mississippi River. Clarence Moore identified the mound in 1911. Members of Harvard's 15 Peabody Museum visited the site in the 1940s, and it was excavated in 1973 by the Mississippi 16 Department of Archives and History (MDAH) (Brookes 1976). Unfortunately, two -thirds of the 17 mound was bulldozed before its excavation and the portion that was not destroyed was 18 vandalized by looters. Human remains (mandible with teeth, several ribs, and a humerus) were 19 found in the dirt from the bulldozed section of the mound (Stone 1972). Artifacts found during 20 excavation of the mound include copper pieces (of non -local origin), ceramics, and a platform 21 pipe (found by a collector) (Brookes 1976). These artifacts suggest that those living at the 22 Grand Gulf Mound Site likely participated in an extensive trading network, the Hopewell 23 Interaction Sphere, with groups throughout the Eastern Woodlands. Potentially significant 24 deposits in the vicinity of the mound are still possible. 25 Two other mounds were documented at GGNS. They were located close to each other and 26 likely were farther back on the bluff than the Grand Gulf Mound Site; however, they have since 27 been destroyed (Brookes 1976). Additionally, Brookes (1976) noted that the area just north of 28 the Grand Gulf Mound Site had many surface finds and suggested that the area may have been 29 an Archaic Site or Woodland work area. Woodland sites also have been documented on the 30 western side of the Mississippi River across from the town of Grand Gulf located just north of 31 GGNS (Brookes 1976). 32 Mississippian Period (1,000 to 300 BP) 33 The Mississippian Period is arguably the most intensely studied period in the American 34 Southeast. With sites as far north as Wisconsin and extending to the Gulf Coast, Mississippian 35 peoples maintained a vast cultural and trading network. In the vicinity of GGNS, the 36 Mississippian Period was preceded by an Emergent Mississippian Period, referred to as the 37 Coles Creek Culture, beginning around A.D. 700 and lasting until about A.D. 1200 (Roe and 38 Schilling 2010). This period is characterized by changes in settlement patterns, mortuary 39 practices, and ceramic technology and decoration, as well as distinctive ceremonial centers 40 (Roe and Schilling 2010). Subsistence during the Emergent Mississippian Period in this area 41 continued to rely on hunting and gathering, with small amounts of maize and domesticated 42 crops beginning to appear (Roe and Schilling 2010). Around A.D. 1200, the Mississippian 43 Culture took hold in the region and is expressed locally as the Plaquemine Culture. The type 44 site of the culture is the Medora Site in West Baton Rouge Parish, Louisiana (Rees 2010). 45 Characterized by ceremonial mound centers, shell -tempered pottery, ceramic and stone 46 smoking pipes, stone axes, game stones and small stemmed projectile points, it is commonly 47 Affected Environment 2-78 accepted that the Mississippian Period saw more social stratification than previous periods, and 1 these high -status individuals likely lived on top of the platform mounds constructed (Rees 2010). 2 In other parts of the Southeast, the Mississippian Period is seen to decline around A.D. 1500, 3 but in the Lower Mississippi Valley the Mississippian Period appears to have continued into th e 4 Protohistoric Period, with historically known groups such as the Natchez and Chitimacha 5 persisting in the Mississippian culture until contact with Europeans changed their way of life. 6 Protohistoric/Historic Period (300 BP to Present) 7 Hernando de Soto undertook the earliest European expedition into the Southeast United States 8 that passed by the GGNS study area. While he did not stop near GGNS, the impact of this 9 expedition was felt by Native American tribes throughout the Southeast United States, which 10 were decimated by the diseases that the Europeans brought. Until fall 1543, de Soto and his 11 expedition attacked and enslaved the Native populations throughout the Southeast United 12 States, often exhausting Native food supplies (Neusius and Gross 2007). 13 An early historic reference to Grand Gulf comes from French explorer René Robert Cavelier, 14 Sieur de La Salle's 1862 voyage down the Mississippi River to find water passages into Spanish 15 territory. He traveled passed the GGNS vicinity and his subsequent maps referred to the locale 16 as "Grand Gouffre ," designating a large whirlpool (Wright 1982). The whirlpool was formed by 17 the Black River entering the Mississippi River, and the eddy was made more treacherous with a 18 large rock outcropping known as "Point of Rock," which is located within the Grand Gulf Military 19 Monument Park near GGNS. 20 Significant political and social reorganization took place among most of the Southeastern tribes 21 after European contact. Many of the historically known tribes were formed from refugee 22 populations or around the remnants of once great chiefdoms (Saunt 2004); however, in the 23 vicinity of GGNS little is known about the period between the end of the Mississippian Period 24 and European settlement. It has been suggested that early historic period groups moved 25 frequently based on the location of Europeans on the landscape (Kidder 2004). There are no 26 historical records of the tribal affiliation of groups in the GGNS vicinity; however, the Natchez 27 had significant settlements south of the property and the Taensa were located on the other side 28 of the Mississippi River in Louisiana. 29 An established European presence in the region came in 1699, when the French formed a 30 colony at Biloxi Bay near D'Iberville, Mississippi, about 170 mi southeast of GGNS. At this time, 31 the Mississippi River was one of the most important transportation and trade routes in the 32 country, and Europeans set up temporary camps along the river to float their cargo downriver to 33 the commercial center of New Orleans. The location of Grand Gulf on the Mississippi River, 34 along with the construction of a railroad connecting Grand Gulf and Port Gibson in 1830, 35 provided the opportunity for Grand Gulf's citizens to flourish as cotton shippers (Wright 1982). 36 Unfortunately, the prosperity would not last, when, after several floods, a tornado hit the town in 37 1853 and the town was unable to recover. 38 During the Civil War, Union General William Sherman's "total war" campaign decimated several 39 parts of the State of Mississippi. Union forces destroyed homes, factories, and infrastructure as 40 they battled throughout the State. After the fall of New Orleans in April 1862, Grand Gulf began 41 to play an increasingly important role in the Confederate defense of Vicksburg. Leading up to 42 the eventual 1863 Union victory at Vicksburg, Confederate installations at Grand Gulf 43 successfully defended Vicksburg and surrounding towns against several Union maneuvers 44 (Wright 1982). However, in April 1863, Union forces made the largest amphibious landing in 45 American History (before World War II) at Grand Gulf. The outnumbered Confederates held 46 onto their positions for 18 hours before abandoning the fortifications and retreating to Bayou 47 Affected Environment 2-79 Pierre. The Union forces moved into the town and used Grand Gulf as a base until early June. 1 This was by far the largest battle fought at Grand Gulf, but a n additional skirmish occurred 2 between a Union patrol and Confederate partisans on July 16, 1864, and a Union boat was 3 destroyed by Confederate forces in December 1864 (Wright 1982). The 1863 Union capture of 4 Vicksburg is viewed as one of the critical turning points in the war that helped to ensure a Union 5 victory (Smith 2010). 6 At the end of the war, a main feature of Reconstruction was the introduction of the sharecropper 7 system to the area surrounding GGNS. In this system, land owners rent ed parcels of their land 8 to those who farm ed it in exchange for a percentage of the crop. Many newly freed slaves 9 participated in this system and potential sharecropper sites were documented at GGNS during a 10 survey in 2006 (22Cb824 and 22Cb827). Most of the African -American sharecroppers began 11 resettling at the end of the 19 th century in nearby towns, and the area around GGNS remained 12 rural farmland until GGNS acquired it in the 1970s (Entergy 2011a). GGNS began commercial 13 operations in July 1985, as the first and only nuclear power plant in Mississippi. 14 2.2.10.2 Historic and Archaeological Resources 15 Before the construction of the approximately 2,0 15-ac (816-ha) GGNS site, the area was used 16 as farmland. The Mississippi River bounds the property on the west, with other land owners to 17 the north, south, and east. Both historic and prehistoric resources have been documented on 18 the GGNS property; however, any extant cultural resources are most likely subsurface remains 19 and would not be discovered unless land -disturbing operation s took place. 20 The GGNS property has been subject to several archaeological surveys and consultations with 21 the Mississippi State Historic Preservation Office. In June 1972 , Mississippi Power & Light 22 Company (MP&L), a precursor of Entergy, contracted the MDAH to perform archaeological, 23 architectural, and historical surveys of the property and transmission routes in Claiborne 24 County. Eight sites were recorded as a result of this survey, only one of which (the Grand Gulf 25 Mound) was considered potentially eligible for inclusion in the National Register of Historic 26 Places (NRHP). 27 The architectural survey of Claiborne County identified one additional resource, the Callendar 28 house. This was a mid -19 th century Greek Revival style house, located on the eastern portion 29 of the GGNS property. The house was in poor condition during the 1970s and is no longer 30 extant. The 164 acres of land GGNS donated to the Grand Gulf Military Monument Park 31 contained vestiges of the town of Grand Gulf that has been preserved with the protection the 32 park provides (Entergy 2011a). 33 Two transmission lines , which leave GGNS property, were constructed to connect GGNS to the 34 regional power grid: the Baxter -Wilson line and the Franklin line. Neither of these transmission 35 lines are documented as having been formally surveyed before construction. Other surveys 36 conducted in the vicinity of the transmission lines have identified at least seven cultural resource 37 sites that are present either in the path of the Baxter -Wilson and Franklin transmission lines or 38 in very close proximity to them. One of the sites along the Baxter -Wilson right -of-way is the 39 Loosa Yokena site (22Wr691), which is a Middle- to Late-Archaic stone and gem working 40 workshop and occupation site that is listed on the NRHP. The Yokena Mound Group 41 (Site 22Wr500/544) consists of three pyramid mounds damaged by a railroad cut, an d 42 Site 22Wr530 is a small occupational area on the Mississippi River floodplain. The current 43 eligibility status of these two sites is undetermined and would require further investigation to 44 assess their eligibility. Site 22Li558 is a Woodland site very near to the Franklin right -of-way 45 with lithics (stone tools and other chipped stone artifacts) and ceramics that requires further 46 testing before an NRHP eligibility determination can be made. Site 22Cb642 is also a 47 Affected Environment 2-80 Woodland period site with undetermined eligibility status. Sites 22Je581 and 22Je584 are not 1 eligible for listing in the NRHP (MDAH 2012). 2 The Archaeological Research Laboratory of the University of Tennessee conducted a Phase I 3 survey of areas of potential construction for a proposed new reactor at GGNS. The survey 4 identified two previously recorded sites (22Cb524 and 22Cb528), as well as nine newly 5 discovered sites (22Cb820, 22Cb821, 22Cb822, 22Cb823, 22Cb824, 22Cb825, 22Cb826, 6 22Cb827, and 22Cb828). Site 22Cb528 is an Archaic Period village consisting of ceramics and 7 lithics at various stages of production. It was determined that the site should be avoided or 8 tested further to determine eligibility (Entergy 2011a; MDAH 2012). A portion of the Grand Gulf 9 to Port Gibson railroad passes through the site boundary and was inspected by NRC staff on 10 April 13, 2004. It was determined that because the only extant remnants of the railroad are the 11 bed and berm , this section of the railroad does not retain enough integrity to warrant 12 preservation (Stapp 2004). 13 Overall, 17 archaeological sites have been documented on GGNS property; only one (22Cb528) 14 is considered potentially eligible for listing in the NRHP. Fifteen of these sites are prehistoric, 15 and two of them have both prehistoric and historic components. Even though the Grand Gulf 16 Mound (22Cb522) has been excavated, mound sites were typically part of larger village sites, 17 and it is possible that significant subsurface deposits exist in the vicinity of the mound complex. 18 Within 10 mi of GGNS, 219 archaeological sites have been documented, 9 of which are listed 19 on the NRHP, 2 are eligible, 40 are potentially eligible, 138 are of unknown potential, and 30 are 20 not eligible. Claiborne County maintains 38 properties in the NRHP; the closest listed properties 21 to GGNS are the Grand Gulf Military Park and historic sites in the town of Port Gibson 22 (Entergy 2011a; MDAH 2012). 23 2.3 Related Federal and State Activities 24 The staff reviewed the possibility that activities of other Federal agencies might affect the 25 renewal of the operating license for GGNS. Any such activity could result in cumulative 26 environmental impacts and the possible need for a Federal agency to become a cooperating 27 agency in the preparation of NRC's SEIS for GGNS. 28 There are no Federal projects that would make it necessary for another Federal agency to 29 become a cooperating agency in the preparation of this document. There are no known 30 American Indian lands within 50 mi (80 km) of GGNS. Federally owned facilities within 50 mi 31 (80 km) of GGNS are listed below: 32 Tensas River National Wildlife Refuge 33 Bayou Cocodrie National Wildlife Refuge 34 Poverty Point National Monument 35 Natchez Trace Parkway and National Scenic Trail 36 Vicksburg National Military Park 37 Natchez National Historical Park 38 Homochitto National Forest 39 Saint Catherine Creek National Wildlife Refuge 40 Delta National Forest 41 The NRC is required, under Section 102(2)(c) of the National Environmental Policy Act, to 42 consult with and obtain the comments of any Federal agency that has jurisdiction by law or 43 special expertise with respect to any environmental impact involved. For example, during the 44 course of preparing this DSEIS, the NRC consulted with the FWS and the NMFS. Federal 45 agency consultation correspondence is presented in Appendix D. 46 Affected Environment 2-81 2.4 References 1 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for 2 protection against radiation." 3 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic licensing of 4 production and utilization facilities." 5 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 6 protection regulations for domestic licensing and related regulatory functions." 7 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for 8 renewal of operating licenses for nuclear power plants." 9 10 CFR Part 61. Code of Federal Regulations, Title 10, Energy, Part 61, "Licensing 10 requirements for land disposal of radioactive waste." 11 10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, "Packaging and 12 transportation of radioactive material." 13 40 CFR Part 50. Code of Federal Regulations, Title 40, Protection of Environment, Part 50, 14 "National primary and secondary ambient air quality standards." 15 40 CFR Part 52. Code of Federal Regulations, Title 40, Protection of Environment, Part 52, 16 "Approval and promulgation of implementation plans." 17 40 CFR Part 81. Code of Federal Regulations, Title 40, Protection of Environment, Part 81, 18 "Designation of areas for air quality planning purposes." 19 40 CFR Part 141. Code of Federal Regulations, Title 40, Protection of Environment, Part 141, 20 "National primary drinking water regulations." 21 40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 22 "Environmental radiation protection standards for nuclear power operations." 23 50 CFR Part 10. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 10, "General 24 provisions." 25 50 CFR Part 22. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 22, "Eagle 26 permits." 27 35 FR 16047. U.S. Fish and Wildlife Service. "Conservation of endangered species and other 28 fish or wildlife; Appendix D -United States list of endangered native fish and wildlife." Federal 29 Register 35(199):16047 -16048. October 13, 1970. 30 49 FR 7332. U.S. Fish and Wildlife Service. "Endangered and threatened wildlife and plants; 31 U.S. breeding population of the wood stork determined to be endangered." Federal Register 32 49(40):7332 -7335. February 28, 1984. Available at 33 <http://ecos.fws.gov/docs/federal_register/fr800.pdf > (accessed 11 June 2012). 34 50 FR 21784. U.S. Fish and Wildlife Service. "Endangered and threatened wildlife and plants; 35 interior population of the least tern determined to be endangered." Federal Register 36 50(102):21784 -21792. May 28, 1985. Available at 37 <http://ecos.fws.gov/docs/federal_register/fr957.pdf > (accessed 12 June 2012). 38 57 FR 588. U.S. Fish and Wildlife Service. "Endangered and threatened wildlife and plants; 39 threatened status for the Louisiana black bear and related rules." Federal Register 40 57(4):588-595. January 7, 1992. Available at 41 <http://ecos.fws.gov/docs/federal_register/fr2000.pdf > (accessed 11 June 2012). 42 Affected Environment 2-82 73 FR 66964. U.S. Environmental Protection Agency. "National ambient air quality standards for 1 lead; final rule." Federal Register 73(219):66964 -67062. November 12, 2008. 2 74 FR 10350. U.S. Fish and Wildlife Service." Endangered and threatened wildlife and plants; 3 designation of critical habitat for the Louisiana black bear (Ursus americanus luteolus): final 4 rule." Federal Register 74(45):10350 -10409. March 10, 2009. Available at 5 <http://www.gpo.gov/fdsys/pkg/FR -2009-03-10/pdf/E9-4536.pdf#page=1 > (accessed 6 11 June 2012). 7 74 FR 56264. U.S. Environmental Protection Agency. "Mandatory reporting of greenhouse 8 gases; final rule." Federal Register 74(209):56260 -56519. October 30, 2009. 9 75 FR 6474. U.S. Environmental Protection Agency. "Primary national ambient air quality 10 standards for nitrogen dioxide; final rule." Federal Register 75(26):6474 -6537. February 9, 2010. 11 75 FR 9282. U.S. Fish and Wildlife Service. "General provisions; revised list of migratory birds." 12 Federal Register 75(39):9282 -9314. March 1, 2010. 13 75 FR 35520. U.S. Environmental Protection Agency. "Primary national ambient air quality 14 standard for sulfur dioxide; final rule." Federal Register 75(119):35520 -35603. June 22, 2010. 15 77 FR 63439. U.S. Fish and Wildlife Service. Endangered and threatened wildlife and plants; 16 Proposed endangered status for the Neosho mucket, threatened status for the rabbitsfoot, and 17 designation of critical habitat for both species; proposed rule." Federal Register 18 77 (200): 63439-63536. October 16, 2012. 19 [AEC] U.S. Atomic Energy Commission. 1973. Final Environmental Statement Related to the 20 Construction of Grand Gulf Nuclear Station, Units 1 and 2. Washington, DC: AEC. August 1973. 21 393 p. Agencywide Documents Access and Management System (ADAMS) No. ML021370576. 22 Baker, J.A., K.J. Killgore, and R.L. Kasul. 1991. Aquatic habitats and fish communities 23 in the lower Mississippi River. Rev. Aquatic. Sci. 3: 313 -356. 24 [BEA] U.S. Bureau of Economic Analysis. 2012. Total full -time and part -time employment by 25 industry (Series CA25, CA25N). Available at 26 http://www.bea.gov/iTable/iTable.cfm?ReqID=70&step=1&isuri=1&acrdn=5# (accessed 27 May 2012). 28 Benson JF. 2005. "Ecology and Conservation of Louisiana Black Bears in the Tensas River 29 Basin and Reintroduced Populations." M.S. thesis. Louisiana State University, Baton Rouge, 30 LA. May 2005. 126 p. Available at <http://etd.lsu.edu/docs/available/etd -04112005-125206/ 31 unrestricted/Benson_thesis.pdf > (accessed 11 June 2012). 32 Benson JF, Chamberlain MJ. 2006. Food habitats of Louisiana black bears (Ursus americanus 33 luteolus) in two subpopulations of the Tensas River Basin. The American Midland Naturalist, 34 156(1):118 -127. 35 Benson, A. J. 2011. Zebra mussel sightings distribution. Available at: 36 http://nas.er.usgs.gov/taxgroup/mollusks/zebramussel/zebramusseldistribution.aspx (accessed 37 20 June 2012). 38 Blake ES, Landsea CW, Gibney EJ. 2011. The Deadliest, Costliest, and Most Intense United 39 States Tropical Cyclones from 1851 to 2010 (and Other Frequently Requested Hurricane 40 Facts). NOAA Technical Memorandum NWS NHC -6. August. Available at 41 http://www.nhc.noaa.gov/pdf/nws -nhc-6.pdf (accessed 21 June 2012). 42 [BLS] U.S. Bureau of Labor Statistics. 2012. Local Area Unemployment Statistics. Available at 43 http://www.bls.gov/data/

(accessed June 2012).

44 Affected Environment 2-83 Brookes SO. 1976. The Grand Gulf Mound Salvage Excavation of an Early Marksville Burial 1 Mound in Claiborne County, Mississippi. Mississippi Department of Archives and History , 2 Jackson, Mississippi. 3 Brown A.V., Brown K.B., Jackson D.C. & Pierson W.K. 2005. The lower Mississippi River and its 4 tributaries. In A.C. Benke & C.E. Cushing eds. Rivers of North America. New York, Academic 5 Press. 6 Caffey, R. H. , P. Coreil, and D. Demcheck. 2002. Mississippi River Water Quality: Implications 7 for Coastal Restoration, Interpretive Topic Series on Coastal Wetland Restoration in Louisiana , 8 Coastal Wetland Planning, Protection, and Restoration Act (eds.), National Sea Grant Library 9 No. LSU-G 002. 10 [CSC] Coastal Services Center. 2012. Historical Hurricane Tracks. National Oceanic and 11 Atmospheric Administration (NOAA). Available at <http://www.csc.noaa.gov/hurricanes/ > 12 (accessed 21 June 2012). 13 Clean Air Act of 1963, as amended. 42 U.S.C. §7401 et seq. 14 Endangered Species Act of 1973, as amended. 16 U.S.C. §1531 et seq. 15 [Entergy] Entergy Operations, Inc. 200

4. Telephone call to M. Snow (Entergy Services, Inc.) 16 from J. Becker (P NNL), "Occurrences of Habitats and Species of Concern along Transmission 17 Corridors,"

December 2, 2004. Available at http://www.nrc.gov/reading -rm/adams.html, 18 Accessi on No. ML050350147. 19 [Entergy] Entergy Operations, Inc. 2006. Letter from W.R. Brian, General Manager, Plant 20 Operations, to J. Warner, Mississippi Department of Environmental Quality, regarding Grand 21 Gulf Nuclear Station Water Use Program, August 17, 2006. ADAMS N o. ML12157A178. 22 [Entergy] Entergy Nuclear Operations, Inc. 2007. Depredation Annual Report for 2006. 23 January 31, 2007. ADAMS No. ML12157A495. 24 [Entergy] Entergy Nuclear Operations, Inc. 2008a. Depredation Annual Report for 2007. 25 January 31, 2008. ADAMS No. ML12157A442. 26 [Entergy] Entergy Nuclear Operations, Inc. 2008b. Grand Gulf Nuclear Station, Unit 3 Combined 27 Operating License Application Responses to Environmental Site Audit Follow -up Items. 28 August 27, 2008. ADAMS No. ML082470608. 29 [Entergy] Entergy Operations, Inc. 2008c. Grand Gulf Nuclear Station, Unit 3, Combined 30 License Application. Part 3, Environmental Report. February 2008. ADAMS No. ML080640404. 31 [Entergy] Entergy Nuclear Operations, Inc. 2009. Depredation Annual Report for 2008. 32 January 31, 2009. ADAMS No. ML12157A443. 33 [Entergy] Entergy Nuclear Operations, Inc. 2010

a. Depredation Annual Report for 2009.

34 January 31, 2010. ADAMS N o. ML12157A445. 35 [Entergy] Entergy Operations, Inc. 2010

b. Letter from C.K. Shepphard, GGNS Site 36 Environmental Lead, to J.L. Crawford, Mississippi Department of Environmental Quality, 37 regarding Grand Gulf Nuclear Station Water Use Program. July 28, 2010. ADAMS 38 No. ML12157A178.

39 [Entergy] Entergy Operations, Inc. 2011

a. Grand Gulf Nuclear Station, Unit 1, License Renewal 40 Application. Appendix E, Applicant's Environmental Report.

Port Gibson, MS: Entergy. 41 October 2011. 425 p. ADAMS No. ML11308A234 42 Affected Environment 2-84 [Entergy] Entergy Nuclear Operations, Inc. 2011

b. Depredation Annual Report for 2010. 1 January 31, 2011. ADAMS No.

ML12157A446. 2 [Entergy] Entergy Operations, Inc. 2011

c. Letter from C.K. Shepphard, GGNS Site 3 Environmental Lead, to J.L. Crawford, Mississippi Department of Environmental Quality, 4 regarding Grand Gulf Nuclear Station 2010 Water Use Program Survey. June 7, 2011 ADAMS 5 No. ML12157A178.

6 [Entergy] Entergy Operations, Inc. 2012

a. Entergy Nuclear Grand Gulf Nuclear Station License 7 Renewal Environmental Audit - Hydrology Patton

- Attachment A labeled Radial Collector Well 8 Data. ADAMS No. ML12157A175. 9 [Entergy] Entergy Operations, Inc. 2012

b. Entergy Nuclear Grand Gulf Nuclear Station License 10 Renewal Environmental Audit - Hydrology Patton

- Attachment D labeled Well Permits. 11 ADAMS No. ML12157A177. 12 [EPA] U.S. Environmental Protection Agency. 1974. Information on Levels of Environmental 13 Noise Requisite to Protect Health and Welfare with an Adequate Margin of Safety. 14 Washington, D.C., Report 550/9 004.. Available at 15 <http://www.nonoise.org.library/levels74/levels74.htm > (accessed June 2012). 16 [EPA] U.S. Environmental Protection Agency. 2010. Waste Environmental Management 17 Systems. Available at <http://www.epa.gov/osw/inforesources/ems/index.htm > (accessed 18 June 2012). 19 [EPA] U.S. Environmental Protection Agency. 2011. Emission Factors for Greenhouse Gas 20 Inventories, last modified November 7, 2011. Available at <http://www.epa.gov/climateleaders/ 21 documents/emission -factors.pdf> (accessed 18 December 2012). 22 [EPA] U.S. Environmental Protection Agency. 2012

a. Enforcement & Compliance History Online 23 (ECHO), Detailed Facility Report.

Available at <http://www.epa -echo.gov/cgi -bin/ 24 get1cReport.cgi?tool=echo&IDNumber=MS0029521 > (accessed 22 March 2012). 25 [EPA] U.S. Environmental Protection Agency. 2012b. National Ambient Air Quality Standards 26 (NAAQS), Updated on May 1, 2012. Available at <http://www.epa.gov/air/criteria.html> 27 (accessed 16 May 2012). 28 [EPA] U.S. Environmental Protection Agency. 2012c. Sole Source Aquifers in the Southeast , 29 Available at <http://www.epa.gov/region4/water/groundwater/r4ssa.html > (accessed 30 14 May 2012). 31 [EPA] U.S. Environmental Protection Agency. 2012d. The Green Book Nonattainment Areas for 32 Criteria Pollutants. Available at <http://www.epa.gov/oaqps001/greenbk/ > (accessed 33 23 March 2012). 34 [EPA] U.S. Environmental Protection Agency. 2012e. USEPA Envirofacts, Safe Drinking Water 35 Information System, List of Water Systems in SDWIS, Claiborne County, Mississippi. Available 36 at <http://oaspub.epa.gov/enviro/sdw_query_v2 > (accessed 14 May 2012). 37 [FEMA] U.S. Federal Emergency Management Agency. 2012. Earthquake Hazard Maps. 38 available at <http://www.fema.gov/hazard/earthquake/hazards.shtm > (accessed 21 June 2012). 39 FishNet. 2012. FishNet2, Search FishNet. Available at <http://www.fishnet2.net > (accessed 40 6 June 2012). 41 [FWS] U.S. Fish and Wildlife Service. 1995. "Louisiana Black Bear (Ursus americanus luteolus) 42 Recovery Plan." Atlanta, GA: FWS Southeast Region. 59 p. Available a t <http://www.fws.gov/ 43 ecos/ajax/docs/recovery_plan/950927.pdf > (accessed 11 June 2012). 44 Affected Environment 2-85 [FWS] U.S. Fish and Wildlife Service. 2003. "Recovery Plan for the Red -cockaded Woodpecker 1 (Picoides borealis)." Second Revision. January 27, 2003. Atlanta, GA: FWS Southeast Region. 2 316 p. Available at <http://ecos.fws.gov/docs/recovery_plan/030320_2.pdf > (accessed 3 11 June 2012). 4 [FWS]. U.S. Fish and Wildlife Service. 2004. Letter dated April 14, 2004 from C. James, FWS, 5 Assistant Field Supervisor, Jackson, Mississippi Field Office, to M. Masnik, NRC, "Adding the 6 Fat Pocketbook Mussel (Potamilus capax) to the List of Endangered and Threatened Species." 7 ML041310449. 8 [FWS] U.S. Fish and Wildlife Service. 2005. 5 -Year Review: Summary and Evaluation of Pallid 9 Sturgeon (Scaphirhynchus albus). Endangered Species Bulletins and Technical Reports 10 (USFWS). Paper 33. Available at

<http://digitalcommons.unl.edu/endangeredspeciesbull/33

> 11 (accessed 11 June 2012). 12 [FWS]. U.S. Fish and Wildlife Service. 2006. St. Catherine Creek National Wildlife Refuge 13 Comprehensive Conservation Plan. Atlanta, Georgia. August, 2006. 14 [FWS] U.S. Fish and Wildlife Service. 2007

a. Pallid Sturgeon (Scaphirhynchus albus) 5-Year 15 Review Summary and Evaluation.

Available at 16 http://ecos.fws.gov/docs/five_year_review/doc1059.pdf (accessed 20 June 2012). 17 [FWS] U.S. Fish and Wildlife Service. 2007

b. Fat Pocketbook (Potamilus capax) 5-Year Review 18 Summary and Evaluation.

Available at 19 <http://www.fws.gov/southeast/5yearReviews/5yearreviews/fatpocketbookmussel.pdf> 20 (accessed 20 June 2012). 21 [FWS] U.S. Fish and Wildlife Service. 2009. U.S. Fish and Wildlife Service Spotlight Species 22 Action Plan, Pallid Sturgeon. Available at http://ecos.fws.gov/docs/action_plans/doc3026.pdf. 23 (accessed 20 June 2012). 24 [FWS] U.S. Fish and Wildlife Service. 2010. Species Assessment and Listing Priority 25 Assignment Form. Rabbitsfoot (Quadrula cylindrica cylindrical). Available at 26 <http://ecos.fws.gov/docs/candidate/assessments/2010/r4/F03X_I01.pdf>. 27 (accessed 20 June 2012). 28 [FWS] U.S. Fish and Wildlife Service. 2012

a. Federal Fish and Wildlife Permit for Depredation 29 No. MB798276

-0. February 4, 2012. ADAMS No. ML12157A492. 30 [FWS] U.S. Fish and Wildlife Service. 2012

b. "Find Endangered Species" Database for 31 Claiborne, Franklin, Jefferson, and Warren Counties. Available at 32 <http://www.fws.gov/endangered/> (accessed 12 June 2012).

33 [FWS] U.S. Fish and Wildlife Service. 2012

c. Letter from J.D. Weller, Louisiana Field Office 34 Supervisor, FWS, to D. Wrona, RPB2 Branch Chief, NRC. Reply to request for concurrence with 35 list of protected species and habitats for Grand Gulf license renewal review. February 29, 2012. 36 ADAMS No. ML12082A141.

37 [FWS] U.S. Fish and Wildlife Service. 2012

d. Letter from S. Ricks, Mississippi Field Office 38 Supervisor, FWS, to D. Drucker, Project Manager, NRC. Reply to request for concurrence with 39 list of protected species and habitats for Grand Gulf license renewal review. February 3, 2012. 40 ADAMS No. ML12047A113.

41 [FWS] U.S. Fish and Wildlife Service. 2012e. Fat Pocketbook (Potamilus capax). Available at 42 http://ecos.fws.gov/docs/life_histories/F00T.html (accessed 20 June 2012). 43 [FWS] U.S. Fish and Wildlife Service. Undated a. "Louisiana Black Bear." Available at 44 <http://www.fws.gov/southeast/pubs/LA_blackbear -fs.pdf> (accessed 11 June 2012). 45 Affected Environment 2-86 [FWS] U.S. Fish and Wildlife Service. Undated b. "Birds Protected by the Migratory Bird Treaty 1 Act: Game Birds and Hunted Species." Available at

<http://www.fws.gov/

2 migratorybirds/RegulationsPolicies/mbta/gmebrd.html > (accessed 30 August 2012). 3 [GGNS] Grand Gulf Nuclear Station. 2003

a. Lesson Plan Number GLP*GPST*P4100, General 4 Plant Systems Training, Standby Service Water (SSW) P41. May 2. ADAMS 5 No. ML12157A185.

6 [GGNS] Grand Gulf Nuclear Station. 2003

b. Grand Gulf Early Site Permit Application, 7 Revision 2, Part 3 - Environmental Report. Section 2.0, Site Characteristics, Figure 2.1

-1 8 through Figure 2.2-8. ADAMS No. ML052790325. 9 [GGNS] Grand Gulf Nuclear Station. 2006. Storm Water Pollution Prevention Plan. Revision

13. 10 July. ADAMS No. ML12157A249.

11 [GGNS] Grand Gulf Nuclear Station. 2007. (Water Withdrawal Mod), Groundwater Withdrawal 12 Permit Modification Grand Gulf Nuclear Station, Port Gibson, MS. ADAMS No. ML12157A250. 13 [GGNS] Grand Gulf Nuclear Station. 2008. Grand Gulf Nuclear Station (GGNS), Facility 14 No. 0420-00023, Renewal of Existing Synthetic Minor Operating Permit No. 0420 -00023, 15 Correspondence GEXO -2008/00086. November 25, 2008. ADAMS No. ML12157A448. 16 [GGNS] Grand Gulf Nuclear Station. 2010

a. License Amendment Request, Extended Power 17 Uprate. Attachment 4. ADAMS No. ML102660405.

18 [GGNS] Grand Gulf Nuclear Station. 2010

b. Grand Gulf Nuclear Unit 1 Updated Final Safety 19 Analysis Report. April 5, 2010. 20 [GGNS] Grand Gulf Nuclear Station. 2012

a. Response to Request for Additional Information 21 (RAI) Dated April 23, 2012 Grand Gulf Nuclear Station, Unit 1.

ADAMS No. ML12157A173. 22 [GGNS] Grand Gulf Nuclear Station. 2012

b. Response to Request for Additional Information 23 (RAI) Dated May 8, 2012 Grand Gulf Nuclear Station, Unit 1.

ADAMS No. ML12158A445. 24 [GGNS] Grand Gulf Nuclear Station. 2012

c. GGNS 2006

-2011 Meteorological Data. RAI 25 response dated May 23, 2012. ADAMS Nos. ML12157A218, ML12157A219, ML12157A220, 26 ML12157A221, ML12157A224, and ML12157A225. 27 GZA GeoEnvironmental, Inc. 2009. GPI Data Review Grand Gulf Nuclear Station Port Gibson, 28 Mississippi. ADAMS No. ML102350525. 29 Hinds County Economic Development Authority (2008). Largest Employers -Hinds County 30 Economic Development Authority. Available at 31 http://www.selecthinds.com/largestemployers.asp x (accessed May 2012). 32 Jones KH. 2011. Population survey of the interior least tern on the Mississippi River from Cape 33 Girardeau, Missouri, to Baton Rouge, Louisiana. July, August 2011. Dyersburg, TN: Dyersburg 34 State Community College. 130 p. Available at <http://www.mvm.usace.army.mil/river/ 35 Environmental/FINAL_Srvy_Rprt_2011.pdf > (accessed 12 June 2012). 36 Khan MZ, Walters JR. 2002. Effects of helpers on breeder survival in the red -cockaded 37 woodpecker (Picoides borealis). Behavioral Ecology and Sociobiology 51:336 -344. 38 Kidder TR. 2004. "Prehistory of the Lower Mississippi Valley After 800 B.C." In Handbook of 39 North American Indians: Southeast, edited by Raymond D. Fogelson. Washington, DC: 40 Smithsonian Institution. 41 Affected Environment 2-87 Kynard B, Henyey E, Horgan M. 2002. Ontogenetic behavior, migration, and social behavior of 1 pallid sturgeon, Scaphirhynchus albus, and shovelnose sturgeon, S. platorynchus, with notes on 2 the adaptive significance of body color. Environmental Biology of Fishes, Volume 63:389-403. 3 Lee AL. 2010. "Troyville and the Baytown Period." In Archaeology of Louisiana, edited by 4 Mark A. Rees. Louisiana State University Press. Baton Rouge, Louisiana. 5 Lindzey FG, Meslow EC. 1977. Home range and habitat use by black bears in southwestern 6 Washington. Journal of Wildlife Management 41:413 -425. 7 Mann DL, Mann TM, Thomas ML, Jourdan MB, Foss KL. 2011. The distribution of Webster's 8 salamander, Plethodon websteri, in Mississippi in relation to local geology. 96th ESA Annual 9 Meeting, August 7 -12, 2011. Available at <http://eco.confex.com/eco/ 10 2011/webprogram/Paper31670.html > (accessed 7 March 2012). 11 Marchinton FB. 1995. Movement ecology of black bears in a fragmented bottomland hardwood 12 habitat in Louisiana. M.S. thesis, University of Tennessee, Knoxville, TN.

p. 107. 13 Mississippi Code of 1972, as amended. Title 27: Taxation and Finance. Available at 14 http://www.mscode.com/free/statutes/27/index.htm (accessed June 2012). 15 [MDAH] Mississippi Department of Archives and History. 2012. Site file search conducted by 16 K. Wescott, Argonne National Laboratory, and E. Larson, Nuclear Regulatory Commission, at 17 the MDAH, Jackson, Mississippi on March 29 and 30. 18 [MDEQ] Mississippi Department of Environmental Quality. 2007. Correspondence from 19 J. Crawford, Groundwater Withdrawal, to R. Shaw, Entergy Operations, Grand Gulf Nuclear 20 Station. October 8, 2007. ADAMS No. ML12157A255.

21 [MDEQ] Mississippi Department of Environmental Quality. 2009. Records of Public -Supply 22 Wells in Mississippi. ADAMS No. ML12157A256. 23 [MDEQ] Mississippi Department of Environmental Quality. 2010 a. Certificate of Permit 24 Coverage under Mississippi's Baseline Storm Water General NPDES Permit. Coverage Number 25 MSR000883. December 1, 2010. ADAMS N o. ML12157A180. 26 [MDEQ] Mississippi Department of Environmental Quality. 2010

b. Well Head Protection Areas. 27 ADAMS No. ML12157A412.

28 [MDEQ] Mississippi Department of Environmental Quality. 2011a. Permit to discharge 29 wastewater in accordance with National Pollutant Discharge Elimination System, permit 30 no. MS0029521. ADAMS No. ML12157A413. 31 [MDEQ] Mississippi Department of Environmental Quality. 2011 b. (401 WQC Letter), Mississippi 32 Department of Environmental Quality, Re: Grand Gulf Nuclear Station License Renewal. 33 ADAMS No. ML11350A190. 34 [MDEQ] Mississippi Department of Environmental Quality. 2011

c. 2010 Air Quality Data 35 Summary. Available at

<http://www.deq.state.ms.us/ 36 mdeq.nsf/pdf/Air_2010AirQualityDataSummary/$File/2010%20Air%20Quality%20Data%20 37 Summary.pdf?OpenElement > (accessed 25 June 2012). 38 [MDEQ] Mississippi Department of Environmental Quality. 2012a. Home - Air Division. 39 Available at <http://www.deq.state.ms.us/mdeq.nsf/page/air_homepage?

(accessed 40 24 May 2012). 41 [MDEQ] Mississippi Department of Environmental Quality. 2012b. Mississippi Commission on 42 Environmental Quality Regulation APC-S-4: Ambient Air Quality Standards , Last Amended 43 Affected Environment 2-88 June 27, 2002. Available at 

<http://www.deq.state.ms.us/ 1 mdeq.nsf/page/Air_AirQualityPlanningandEmissionStandards? > (accessed 23 March 2012). 2 [MDES] Mississippi Department of Employment Security. 2012. Labor Market Data for 3 April 2012. Available at http://mdes.ms.gov/Home/docs/LMI/ 4 Publications/Labor%20Market%20Data/labormarketdata.pdf (accessed May 2012). 5 [MDOT] Mississippi Department of Transportation. 2012. MDOT Traffic Counts Web application. 6 Available at 7 http://sp.gomdot.com/Intermodal%20Planning/planning/Maps/Pages/Traffic -Volume-Maps.aspx 8 (accessed May 2012). 9 [MDWFP] Mississippi Department of Wildlife, Fisheries, and Parks. 2001. "Endangered Species 10 of Mississippi." Crystal Darter. Available at 11 http://www.mdwfp.com/media/127063/endangered_species_packet.pdf (accessed Apr 201 3). 12 [MDWFP] Mississippi Department of Wildlife, Fisheries, and Parks. 2011. Available at 13 http://museum.mdwfp.com/downloads/science/listed_ms_species_status_rank_definition.pdf 14 (accessed May 2012). 15 [MDWFP] Mississippi Department of Wildlife, Fisheries, and Parks. 2012. Letter from 16 A. Sanderson, Ecologist, Mississippi Natural Heritage Program, MDWFP, to D. Wrona, RPB2 17 Branch Chief, NRC.

Subject:

Reply to request for protected species and habitat information for 18 Grand Gulf license renewal review. February 13, 2012. ADAMS No. ML12055A312. 19 [MIHL] Mississippi Institutions of Higher Learning. 2012. Mississippi Population Projections 20 2015, 2020, 2025. Available at http://www.ihl.state.ms.us/urc/downloads 21 /PopulationProjections.pdf (accessed May 2012). 22 [MMNS] Mississippi Museum of Natural Science. 2001. "Endangered Species of Mississippi." 23 97 p. Available at <http://museum.mdwfp.com/downloads/ 24 science/endangered_species_packet.pdf > (accessed 6 March 2012). 25 [MNHP] Mississippi Natural Heritage Program. 201 1. "Listed Species of Mississippi." Available 26 at <http://www.mdwfp.com/media/127066/endangered_species_list.pdf

> 27 (accessed 11 June 2012). 28 [MP&L] Mississippi Power & Light Company. 1981. Grand Gulf Nuclear Station, Units 1 and 2, 29 Final Environmental Report. December 1981. ADAMS No.

ML12157A492. 30 National Environmental Policy Act of 1969, as amended. 42 U.S.C. §4321 et seq. 31 National Historic Preservation Act of 1966. 16 U.S.C. §470 et seq. 32 NatureServe. 2012. NatureServe Explorer: An online encyclopedia of life [web application]. 33 NatureServe, Arlington, Virginia. Available at http://www.natureserve.org/explorer. (accessed 34 June 25, 2012). 35 [NCDC] National Climatic Data Center. 1990. 1989 Local Climatological Data Annual Summary 36 with Comparative Data, Jackson, Mississippi. National Oceanic and Atmospheric 37 Administration, National Environmental Satellite, Data, and Information Service. Available at 38 <http://www7.ncdc.noaa.gov/IPS/lcd/lcd.html > (accessed 22 June 2012). 39 [NCDC] National Climatic Data Center. 2012a. Climates of the States (CLIM60): Climate of 40 Mississippi. National Oceanic and Atmospheric Administration, Satellite and Information 41 Service. Available at <http://cdo.ncdc.noaa.gov/cgi -bin/climatenormals/climatenormals.pl > 42 (accessed 23 March 2012). 43 Affected Environment 2-89 [NCDC] National Climatic Data Center. 2012b. 2011 Local Climatological Data Annual Summary 1 with Comparative Data, Jackson, Mississippi (KJAN). National Oceanic and Atmospheric 2 Administration, Satellite and Information Service. Available at <http://www7.ncdc.noaa.gov/ 3 IPS/lcd/lcd.html > (accessed 19 June 2012). 4 [NCDC] National Climatic Data Center. 2012c. Storm Events Database. National Oceanic and 5 Atmospheric Administration. Available at

<http://www.ncdc.noaa.gov/stormevents/

> (accessed 6 21 June 2012). 7 [NCDC] National Climatic Data Center. 2012d. U.S. Tornado Climatology. National Oceanic and 8 Atmospheric Administration, Satellite and Information Service. Available at 9 <http://www.ncdc.noaa.gov/oa/climate/severeweather/tornadoes.html > (accessed 10 21 June 2012). 11 [NCES] U.S. Department of Education, National Center for Education Statistics. 2012a. U.S. 12 Department of Education, National Center for Education Statistics, Common Core of Data 13 (CCD), "Public Elementary/Secondary School Universe Survey ," 2010-11 School Y ear." 14 Available at http://nces.ed.gov/ccd/districtsearch/

(accessed April 2012). 15 [NCES] U.S. Department of Education, National Center for Education Statistics. 2012b. College 16 Navigator Web Application. Available at http://nces.ed.gov/collegenavigator/default.aspx 17 (accessed May 2012). 18 [NEI] Nuclear Energy Institute. 2007. Industry Ground Water Protection Initiative - Final 19 Guidance Document. Washington, DC: Nuclear Energy Institute. NEI 07

-07 (Final). 20 August 2007. ADAMS No. ML091170588. 21 Neusius SW, Gross GT. 2007. Seeking Our Past: An Introduction to North American 22 Archaeology. New York, NY: Oxford University Press. 23 [NMFS] National Marine Fisheries Service. 2012

a. Essential Fish Habitat Mapper v2.0.

24 Available at http://sharpfin.nmfs.noaa.gov/website/EFH_Mapper/map.aspx (Accessed on 25 Ju ne 13, 2012). 26 [NMFS] National Marine Fisheries Service. 2012

b. Letter from D. Bernhart, Southeast Assistant 27 Regional Administrator for Protected Resources, to D. Wrona, RPB2 Branch Chief, NRC.

28

Subject:

Reply to request for list of species at Grand Gulf Nuclear Station, Unit 1. 29 March 1, 2012. ADAMS Accession No. ML12065A167. 30 [NRC] U.S. Nuclear Regulatory Commission. 19

81. Final Environmental Statement Related to 31 the Operation of Grand Gulf Nuclear Station, Units 1 and 2, Docket Nos. 50

-416 and 50 -417. 32 NUREG-0777. September 1981 . ADAMS Legacy Library No. 8110220161. 33 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 34 for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG -1437. May 1996. 35 ADAMS Nos. ML040690705 and ML040690738. 36 [NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3 -Transportation, Table 9.1, 37 Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic 38 Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: 39 NRC. NUREG -1437, Volume 1, Addendum 1. August 1999. ADAMS N o. ML04069720. 40 [NRC] U.S. Nuclear Regulatory Commission. 2006

a. Environmental Impact Statement for an 41 Early Site Permit (ESP) at the Grand Gulf ESP Site , Final Report. NUREG-1817. April 2006.

42 876 p. ADAMS No. ML060900037. 43 [NRC] U.S. Nuclear Regulatory Commission. 2006b. Safety Evaluation Report for an Early Site 44 Permit (ESP) at the Grand Gulf Site. NUREG-1840. April 2006. 45 Affected Environment 2-90 [NRC] U.S. Nuclear Regulatory Commission. 2007. Regulatory Guide 1.23, "Meteorological 1 Monitoring Programs for Nuclear Power Plant," Rev.1. March 2007. Available at 2 <http://pbadupws.nrc.gov/docs/ML0703/ML070350028.pdf > (accessed 5 July 2012). 3 Peacock E. 2005. Mississippi Archaeology: Q & A. Jackson, MI: University Press of Mississippi. 4 Port Gibson Chamber of Commerce. 2012. Port Gibson on the Mississippi.com: Employers. 5 Available at http://port gibsononthemississippi.com/Employers.html (accessed May 2012). 6 Rees MA. 2010. "Plaquemine and Mississippian." In Archaeology of Louisiana, edited by 7 Mark A. Rees. Baton Rouge, LA: Louisiana State University Press. 8 Roe LM, Schilling TM. 2010. "Coles Creek." In Archaeology of Louisiana, edited by 9 Mark A. Rees. Baton Rouge, LA: Louisiana State University Press. 10 Saunt C. 2004. "History until 1776." In Handbook of North American Indians: Southeast, edited 11 by Raymond D. Fogelson. Washington, DC: Smithsonian Institution. 12 [SERI] System Energy Resources, Inc. 2005. Grand Gulf Site Early Site Permit Application. 13 Revision 2 . Available at <http://www.nrc.gov/reading -rm/adams.html >. ADAMS No. 14 ML052780449. 15 Sidle JG, Harrison WF. 1990. Interior population of the least tern (Sterna antillarum) recovery 16 plan. Bloomington, MN: U.S. Fish and Wildlife Service, Midwest Region. 95 p. Available at 17 <http://ecos.fws.gov/docs/recovery_plan/900919a.pdf> (accessed 11 April 2013). 18 Smith TB. 2010. Mississippi in the Civil War. Jackson, MI: University Press of Mississippi. 19 Stapp DC. 2004. "Historic and Cultural Resources Contribution to Grand Gulf Trip 20 Report 4-13-04 to 4-15-04." ADAMS No. ML050350472. 21 Stone JH. 1972. "Grand Gulf Mound Statement of Significance and National Register of Historic 22 Places Nomination Form." U.S. Department of the Interior, National Park Service. Available at 23 the Mississippi SHPO. 24 [TPWD] Texas Parks and Wildlife Department. 2012. "Interior Least Tern (Sterna antillarum 25 athalassos)." Available at <http://www.tpwd.state.tx.us/huntwild/wild/species/leasttern/ > 26 (accessed 14 June 2012). 27 [USCB] U.S. Census Bureau (USCB), 2012. "American FactFinder, Census 2000 and 2006 -28 2010, 5-Year Estimate, American Community Survey, State and County QuickFacts on 29 Claiborne, Hinds, Jefferson, and Warren Counties," 2010, Available URLs: 30 http://factfinder.census.gov and http://quickfacts.census.gov (accessed May 2012). 31 [USDA] U.S. Department of Agriculture. 2012. Custom Soil Resource Report for Claiborne 32 County, Mississippi. National Resources Conservation Service, Available at 33 <http://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx > (accessed 3 April 2012). 34 [USDA NASS] U.S. Department of Agriculture. National Agricultural Statistics Service. 2009. 35 "2007 Census of Agriculture," Volume 1 Chapter 2, "County Level Data for Mississippi and 36 Louisiana," Table 1: "County Summary Highlights: 2007" and Table 7: "Hired Farm Labor -37 Workers and Payroll: 2007 ." Released February 4, 2009, and updated December 2009. 38 Available at http://www.agcensus.usda.gov/Publications/2007/ 39 Full_Report/Volume_1,_Chapter_2_County_Level/Mississippi/index.asp

40 http://www.agcensus.usda.gov/Publications/2007/Full_Report/Volume_1,_Chapter_2_County_L 41 evel/Louisiana/index.asp (accessed April 2012).

42 Affected Environment 2-91 [USDA NASS] U.S. Department of Agriculture. National Agricultural Statistics Service. 2012. 1 CropScape W eb Application of the 2011 Crop Data Layer Spatial Dataset. Available at 2 http://nassgeodata.gmu.edu/CropScape/

(accessed June 2012).

3 [USGS] U.S. Geological Survey. 2011. "Mississippi Valley Loess Plains." Updated 19 May 2011. 4 Available at <http://landcovertrends.usgs.gov/east/eco74Report.html> (accessed 5 2 March 2012). 6 [USGS] U.S. Geological Survey. 2012

a. Earthquake Hazards Program, Mississippi Earthquake 7 History. Available at

<www.earthquake.usgs.gov/earthquakes/states/mississippi/history.php > 8 (accessed 20 June 2012). 9 [USGS] U.S. Geological Survey. 2012 b. Earthquake Hazards Program, Top Earthquake States. 10 Available at

<www.earthquake.usgs.gov/earthquakes/states/top_states.php

> (accessed 11 21 June 2012). 12 [USGS] U.S. Geological Survey. 2012

c. Nonindigenous Aquatic Species Database. Gainesville, 13 Florida.(accessed 20 June 2012).

14 Warren County Port Commission. 2012. Vicksburg -Warren County Port Commission and EDF: 15 Top 10 Employers. Available at www.vicksburgedf.org/top10industry.htm (accessed May 2012). 16 Wenstrom, B. 2007a. Black Bear Habitat Survey, Grand Gulf Nuclear Station. Conducted 17 December 13-14, 2006. p. 7. ADAMS No. ML12157A493. 18 Wenstrom, B. 2007b. Memo from B. Wenstrom to GGNS COL Application File. January 2, 2007. 19 p. 7. ADAMS No. ML12157A493. 20 Wright, W.C. 1982. The Confederate Magazine at Fort Wade Grand Gulf, Mississippi: 21 Excavations, 1980 -1981. Mississippi Department of Archives and History and Grand Gulf 22 Military Monument. Archaeological Report No. 8. 23

3-1 3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT 1 Facility owners or operators may need to undertake or, for economic or safety reasons, may 2 choose to perform refurbishment activities in anticipation of license renewal or during the license 3 renewal term. The major refurbishment class of activities characterized in the Generic 4 Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants (NRC 1996) is 5 intended to encompass actions that typically take place only once in the life of a nuclear plant, if 6 at all. Examples of these activities include, but are not limited to, replacement of boiling water 7 reactor recirculation piping and pressurized water reactor steam generators. These actions may 8 have an impact on the environment beyond those that occur during normal operations and that 9 require evaluation, depending on the type of action and the plant -specific design. Table 3-1 10 lists the environmental issues associated with refurbishment that the U.S. Nuclear Regulatory 11 Commission (NRC) staff (the staff) determined to be Category 1 issues in the GEIS. 12 Table 3-1. Category 1 Issues Related to Refurbishment 13 Issue GEIS section(s) Surface water quality, hydrology, and use (for all plants) Impacts of refurbishment on surface water quality 3.4.1 Impacts of refurbishment on surface water use 3.4.1 Aquatic ecology (for all plants) Refurbishment

3.5 Groundwater

use and quality Impacts of refurbishment on groundwater use and quality 3.4.2 Land use Onsite land use 3.2 Human health Radiation exposures to the public during refurbishment

3.8.1 Occupational

radiation exposures during refurbishment

3.8.2 Socioeconomics

Public services: public safety, social services, and tourism and recreation 3.7.4; 3.7.4.3; 3.7.4.4; 3.7.4.6 Aesthetic impacts (refurbishment)

3.7.8 Table

source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51 Table 3-2 lists environmental issues related to refurbishment that the NRC staff determined to 14 be plant-specific or inconclusive in the GEIS. These issues are Category 2 issues. The 15 definitions of Category 1 and 2 issues can be found in Section 1.4. 16 Environmental Impacts of Refurbishment 3-2 Table 3-2. Category 2 Issues Related to Refurbishment 1 Issue GEIS section(s) 10 CFR 51.53 (c)(3)(ii) Subparagraph Terrestrial resources Refurbishment impacts 3.6 E Threatened or endangered species (for all plants) Threatened or endangered species 3.9 E Air quality Air quality during refurbishment (nonattainment and maintenance areas) 3.3 F Socioeconomics Housing impacts 3.7.2 I Public services: public utilities 3.7.4.5 I Public services: education (refurbishment) 3.7.4.1 I Offsite land use (refurbishment) 3.7.5 I Public services, transportation 3.7.4.2 J Historic and archaeological resources 3.7.7 K Environmental justice Environmental justice(a) Not addressed Not addressed (a) Guidance related to environmental justice was not in place at the time the U.S. Nuclear Regulatory Commission (NRC) prepared the GEIS and the associated revision to 10 CFR Part 51. If an applicant plans to undertake refurbishment activities for license renewal, the applicant's environmental report (ER) and the staff's environmental impact statement must address environmental justice. Table source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51 Table B.2 of the GEIS identifies systems, structures, and components (SSCs) that are subject to 2 aging and might require refurbishment to support continued operation during the license 3 renewal period of a nuclear facility. In preparation for its license renewal application, Entergy 4 Operations, Inc. (Entergy) performed an evaluation of these SSCs pursuant to Section 54.21 of 5 Title 10 of the Code of Federal Regulation (10 CFR 54.21) in order to identify the need to 6 undertake any major refurbishment activities that would be necessary to support the continued 7 operation of Grand Gulf Nuclear Station (GGNS) during the proposed 20 -year period of 8 extended operation. 9 In its SSC evaluation, Entergy did not identify the need to undertake any major refurbishment or 10 replacement actions associated with license renewal to support the continued operation of 11 GGNS beyond the end of the existing operating license (Entergy 2011). Therefore, the staff will 12 not assess refurbishment activities in this SEIS. 13 3.1 References 14 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy , Part 51, "Environmental 15 protection regulations for domestic licensing and related regulatory functions." 16 Environmental Impacts of Refurbishment 3-3 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for 1 renewal of operating licenses for nuclear power plants." 2 [Entergy] Entergy Operations, Inc. 2011. Grand Gulf Nuclear Station, Unit 1, License Renewal 3 Application. Port Gibson, MS: Entergy. Appendix E, Applicant's Environmental Report. 4 October 2011. 425 p. Agencywide Documents Access and Management System (ADAMS) 5 Accession No. ML11308A234. 6 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 7 for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG -1437. May 1996. 8 ADAMS Accession Nos. ML040690705 and ML040690 738. 9 [NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3 - Transportation, Table 9.1, 10 Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic 11 Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: 12 NRC. NUREG -1437, Volume 1, Addendum 1. August 1999. ADAMS Accession 13 No. ML04069720. 14

4-1 4.0 ENVIRONMENTAL IMPACTS OF OPERATION 1 This chapter addresses potential environmental impacts related to the license renewal term of 2 Grand Gulf Nuclear Station (GGNS). These impacts are grouped and presented according to 3 resource. Generic issues (Category

1) rely on the analysis presented in the Generic 4 Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants 5 (NRC 1996, 1999a, 2013a

), unless otherwise noted. Most site-specific issues (Category

2) 6 have been analyzed for GGNS and assigned a significance level of SMALL, MODERATE, or 7 LARGE. For Protected Species and Habitats and Historic and Archaeological Resources the 8 impact significance determination language is specific to the authorizing legislation (e.g., 9 Endangered Species Act, National Historic Preservation Act).

Also, environmental justice and 10 chronic effects of electromagnetic fields were considered. Some issues are not applicable to 11 GGNS because of site characteristics or plant features. Section 1.4 of this supplemental 12 environmental impact statement (SEIS) provides an explanation of the criteria for Category 1 13 and Category 2 issues, as well as the definitions of SMALL, MODERATE, and LARGE. As also 14 described in Section 1.4, the U.S. Nuclear Regulatory Commission (NRC) has published a final 15 rule (78 FR 37282, June 20, 2013) revising its environmental protection regulation, Title 10 of 16 the Code of Federal Regulations (10 CFR) Part 51, "Environmental Protection Regulations for 17 Domestic Licensing and Related Regulatory Functions." The final rule consolidates similar 18 Category 1 and 2 issues, changes some issues from Category 2 to Category 1 issues, and 19 consolidates some of those issues with existing Category 1 issues. The final rule also adds new 20 Category 1 and 2 issues. 21 The NRC staff also considers new and significant information on environmental issues related to 22 operation during the renewal term. New and significant information is information that identifies 23 a significant environmental issue not covered in the GEIS and codified in Table B -1 of 24 Appendix B to Subpart A of 10 CFR Part 51 or information that was not considered in the 25 analyses summarized in the GEIS and that leads to an impact finding that is different from the 26 finding presented in the GEIS and codified in 10 CFR Part 51. Section 4.11 of this SEIS 27 describes the process used to identify and evaluate new and significant information. 28 4.1 Land Use 29 Table 4-1 identifies the two land use issues applicable to GGNS during the renewal term. 30 Section 2.2.1 of this SEIS describes the land use conditions near GGNS. 31 Table 4-1. Land Use Issues 32 Issue GE IS section Category Onsite land use 4.5.3 1 Power line right-of-way (ROW) 4.5.3 1 Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 The NRC staff did not find any new and significant information during the review of the 33 applicant's Environmental Report (ER) (Entergy 201 1a), the site audit, the scoping process, or 34 the evaluation of other available information. Therefore, the staff concludes that there are no 35 impacts related to these issues beyond those discussed in the GEIS. Consistent with the GEIS, 36 the staff concludes that the impacts are SMALL. 37 Environmental Impacts of Operation 4-2 4.2 Air Quality 1 Table 4-2 identifies the air quality issue applicable to GGNS during the renewal term. Section 2 2.2.2 of this SEIS describes the meteorology and air quality in the vicinity of GGNS. 3 Table 4-2. Air Quality Issues 4 Issue GEIS Section Category Air quality effects of transmission lines 4.5.2 1 Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 The NRC staff did not find any new and significant information during the review of the 5 applicant's ER (Entergy 201 1a), the site audit, the scoping process, or the evaluation of other 6 available information. Therefore, the staff concludes that there are no impacts related to this 7 issue beyond those discussed in the GEIS. Consistent with the GEIS, the staff concludes that 8 the impacts are SMALL. 9 4.3 Geologic Environment 10 4.3.1 Geology and Soils 11 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmenta l 12 protection regulation, 10 CFR Part 51, "Environmental protection regulations for domestic 13 licensing and related regulatory functions." With respect to the geologic environment of a plant 14 site, the final rule amend s Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 , by adding a 15 new Category 1 issue, "Geology and soils." This new issue has an impact level of SMALL. This 16 new Category 1 issue considers geology and soils from the perspective of those resource 17 conditions or attributes that can be affected by continued operations during the renewal term. 18 An understanding of geologic and soil conditions has been well established at all nuclear power 19 plants and associated transmission lines during the current licensing term, and these conditions 20 are expected to remain unchanged during the 20 -year license renewal term for each plant. The 21 impact of these conditions on plant operations and the impact of continued power plant 22 operations and refurbishment activities on geology and soils are SMALL for all nuclear power 23 plants and not expected to change appreciably during the license renewal term. Operating 24 experience shows that any impacts to geologic and soil strata would be limited to soil 25 disturbance from construction activities associated with routine infrastructure renovation and 26 maintenance projects during continued plant operations. Implementing best management 27 practices would reduce soil erosion and subsequent impacts on surface water quality. 28 Information in plant -specific SEISs prepared to date and reference documents has not identified 29 these impacts as being significant. 30 Section 2.2.3 of this SEIS describes the local and regional geologic environment relevant to 31 GGNS. The NRC staff did not identify any new and significant information with regard to th is 32 Category 1 (generic) issue based on review of the ER (Entergy 2011a), the public scoping 33 process, or as a result of the environmental site audit. As discussed in Chapter 3 of this SEIS 34 and as identified in the ER (Entergy 2011a), Entergy has no plans to conduct refurbishment or 35 replacement actions associated with license renewal to support the continued operation of 36 GGNS. Further, Entergy anticipates no new construction or other ground -disturbing activities or 37 changes in operations and that operation and maintenance activities would be confined to 38 previously disturbed areas or existing ROWs. Based on this information, it is expected that any 39 incremental impacts on geology and soils during the license renewal term would be SMALL. 40 Environmental Impacts of Operation 4-3 4.4 Surface Water Resources 1 Table 4-3 identifies the surface water issues applicable to GGNS during the renewal term. 2 Section 2.2.4 of this SEIS describes surface water at GGNS. 3 Table 4-3. Surface Water Issues 4 Issue GEIS Section Category Impact of refurbishment on surface water quality 3.4.1 1 Impacts of refurbishment on surface water use 3.4.1 1 Altered salinity gradients 4.2.1.2.1 1 Temperature effects on sediment transport capacity 4.2.1.2.3 1 Scouring caused by discharged cooling water 4.2.1.2.3 1 Eutrophication 4.2.1.2.3 1 Discharge of chlorine or other biocides 4.2.1.2.4 1 Discharge of sanitary wastes and minor chemical spills 4.2.1.2.4 1 Discharge of other metals in wastewater 4.2.1.2.4 1 Table source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51 The NRC staff did not find any new and significant information during the review of the 5 applicant's ER (Entergy 201 1a), the site audit, the scoping process, or the evaluation of other 6 available information. Therefore, the staff concludes that there are no impacts related to these 7 issues beyond those discussed in the GEIS. For these issues, the GEIS concludes that the 8 impacts are SMALL. 9 4.5 Groundwater Resources 10 Table 4-4 identifies the issues related to groundwater that are applicable to GGNS during the 11 renewal term. Section 2.2.5 of this SEIS describes groundwater at GGNS. 12 Table 4-4. Groundwater Issues 13 Issue GEIS Section Category Groundwater use conflicts (potable and service water; plants that use <100 gpm) 4.8.1.1 1 Groundwater use conflicts (Ranney wells) 4.8.1.4 2 Groundwater quality degradation (Ranney wells) 4.8.2.2 1 Radionuclides released to groundwater 4.5.1.2(a) 2 Table source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51; (a) NRC 2013a 4.5.1 Generic Groundwater Issues 14 The NRC staff did not identify any new and significant information associated with the 15 Category 1 groundwater issues during the review of the applicant's ER (Entergy 201 1a), the site 16 audit, the scoping process, or the evaluation of other available information. Therefore, the staff 17 concludes that there are no impacts related to these issues beyond those discussed in the 18 GEIS. Consistent with the GEIS, the staff concludes that the impacts are SMALL. 19 Environmental Impacts of Operation 4-4 4.5.2 Groundwater Use Conflicts (Ranney Wells) 1 For nuclear power plants using Ranney wells or pumping more than 100 gpm (0.006 m 3/s) of 2 groundwater (total on site), the potential impact on groundwater is considered a Category 2 3 issue, therefore requiring a plant -specific assessment. The requirement for this assessment is 4 specified by 10 CFR 51.53(c)(3)(ii)(C). This groundwater aspect was classified as a site-5 specific (Category

2) issue because groundwater levels might be lowered beyond the site 6 boundary. The staff previously concluded in the GEIS that "[t]he impact of cooling water intake 7 on groundwater at the Grand Gulf plant (the only plant employing Ranney wells) does not 8 conflict with other groundwater uses in the area" (NRC 1996). In evaluating the potential 9 impacts resulting from groundwater use conflicts associated with license renewal, the NRC staff 10 uses as its baseline the existing groundwater resource conditions described in Sections 2.1.7 11 and 2.2.5 of this SEIS. These baseline conditions encompass the existing hydrogeologic 12 framework and conditions (including aquifers) potentially affected by continued operations as 13 well as the nature and magnitude of groundwater withdrawals for cooling and other purposes 14 (as compared to relevant appropriation and permitting standards). The baseline also considers 15 other downgradient or in

-aquifer uses and users of groundwater. 16 Future activities at the GGNS site are not expected to lower groundwater levels beyond the 17 plant boundary. The original evaluation of groundwater withdrawal impacts in the GGNS final 18 environmental statemen t (FES) was for an estimated 42,636 gpm (2.69 m 3/s) for makeup 19 cooling water needs. This evaluation was for two nuclear reactors (NRC 1973). However, only 20 one reactor was constructed. Groundwater withdrawals during the license renewal term are 21 expected to be approximately 27,860 gpm (1.76 m 3/s), which is about 65 percent of the 22 withdrawal rate previously evaluated and found to be acceptable (Entergy 2011 a). Groundwater 23 level changes are not detected far from the Ranney well s (Entergy 2011 a) because water from 24 the Mississippi River continuously flows into the Mississippi River Alluvial Aquifer, which 25 supplies the Ranney wells, and the aquifer is a thick water table aquifer. Consistent with the 26 GEIS, the staff concludes that the impact for this issue is SMALL. 27 4.5.3 Radionuclides Released to Groundwater 28 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 29 protection regulation, 10 CFR Part 51. With respect to groundwater quality, the final rule 30 amend s Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new 31 Category 2 issue, "Radionuclides released to groundwater," with an impact level range of 32 SMALL to MODERATE, to evaluate the potential impact of discharges of radionuclides from 33 plant systems into groundwater. This new Category 2 issue has been added to evaluate the 34 potential impact to groundwater quality from the discharge of radionuclides from plant systems, 35 piping, and tanks. This issue was added because, within the past several years, there have 36 been events at nuclear power reactor sites that involved unknown, uncontrolled, and 37 unmonitored releases of radioactive liquids into the groundwater. In evaluating the potential 38 impacts on groundwater quality associated with license renewal, the NRC staff uses as its 39 baseline the existing groundwater conditions described in Section 2.2.5 of this SEIS. These 40 baseline conditions encompass the existing quality of groundwater potentially affected by 41 continued operations (as compared to relevant state or EPA primary drinking water standards) 42 as well as the current and potential onsite and offsite uses and users of groundwater for drinking 43 and other purposes. The baseline also considers other downgradient or in -aquifer uses and 44 users of groundwater. 45 Section 2.2.5.4 of this SEIS contains a description of tritium contamination on the northeast side 46 of the Unit 2 power block. The groundwater contamination appears to be restricted to the 47 Environmental Impacts of Operation 4-5 backfill material and the Upland Complex Aquifer near the power block. This power block does 1 not contain a nuclear reactor. No other radionuclides have been detected above background 2 levels in the Upland Complex Aquifer. Tritium -contaminated groundwater has not migrated off 3 site. No radionuclide concentrations above background levels have been detected in the 4 Catahoula Aquifer or the Mississippi River Alluvial Aquifer or in any other areas in the Upland 5 Complex Aquifer. 6 GGNS is actively involved in defining the extent of contamination and determining its cause 7 (Entergy 2011 a). Should the contamination continue unchecked, it is very unlikely to move 8 downward into the Catahoula Aquifer because of the thick clay bed on top of the aquifer. 9 Rather, the areas of contamination should move laterally with the direction of groundwater flow 10 (northeast) within the Upland Complex Aquifer. 11 At this time, it is unknown if the plume will continue in that direction or if it will eventually flow 12 into the Mississippi River Alluvial Aquifer and from there to the Mississippi River. In any case, 13 dispersion, radioactive decay, and dilution would decrease the tritium activity concentration in 14 the plume. 15 In 2007, the nuclear power industry began implementing its "Industry Ground Water Protection 16 Initiative" (NEI 2007). Since 2008, the staff has been monitoring implementation of this initiative 17 at licensed nuclear reactor sites. The initiative identifies actions to improve utilities' 18 management and response to instances in which the inadvertent release of radioactive 19 substances may result in low but detectible levels of plant -related materials in subsurface soils 20 and water. It also seeks to identify those actions necessary for implementation of a timely and 21 effective groundwater protection program. The area s of contamination were discovered as part 22 of GGNS participation in this initiative. At this time, monitoring wells have been drilled on all 23 sides of the power blocks and GGNS is monitoring them. Monitoring results from these wells 24 are reported annually to the NRC. 25 The NRC staff's analysis of groundwater monitoring results and the site's hydrogeologic regime 26 indicates there is no immediate threat to groundwater resources. Water use in the area should 27 not be affected even if tritium -contaminated groundwater were ever to move off site. Therefore, 28 the NRC staff concludes that inadvertent releases of tritium have not substantially impaired site 29 groundwater quality or affected groundwater use. With continued NRC attention and GGNS 30 action, the NRC staff further concludes that groundwater quality impacts would remain SMALL 31 during the license renewal term. 32 4.6 Aquatic Resources 33 Sections 2.1.6 and 2.2.6 of this SEIS describe the GGNS cooling system and aquatic 34 environment, respectively. Table 4 -5 identifies the Category 1 issues related to aquatic 35 resources that are applicable to GGNS during the renewal term. There are no Category 2 36 issues that apply to aquatic resources at GGNS. The staff did not find any new and significant 37 information during the review of the applicant's ER (Entergy 201 1a), the site audit, the scoping 38 process, or the evaluation of other available information; therefore, the staff concludes that there 39 are no impacts related to aquatic resource issues beyond those discussed in the GEIS. For 40 these issues, the GEIS concludes that the impacts are SMALL. 41 Environmental Impacts of Operation 4-6 Table 4-5. Aquatic Resource Issues 1 Issues GEIS Section Category For All Plants Accumulation of contaminants in sediments or biota 4.1.1.2.4 1 Entrainment of phytoplankton & zooplankton 4.2.2.1.1 1 Cold shock 4.2.2.1.5 1 Thermal plume barrier to migrating fish 4.2.2.1.6 1 Distribution of aquatic organisms 4.2.2.1.6 1 Premature emergence of aquatic insects 4.2.2.1.7 1 Gas supersaturation (gas bubble disease) 4.2.2.1.8 1 Low dissolved oxygen in the discharge 4.2.2.1.9 1 Losses from predation, parasitism, and disease among organisms exposed to sublethal stresses 4.2.2.1.10 1 Stimulation of nuisance organisms 4.2.2.1.11 1 Exposure of aquatic organisms to radionuclides 4.6.1.2(a) 1 For Plants with Cooling Tower -Based Heat Dissipation Systems Entrainment of fish and shellfish in early life stages 4.3.3 1 Impingement of fish and shellfish 4.3.3 1 Heat shock 4.3.3 1 Table source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51; (a) NRC 2013a 4.6.1 Exposure of Aquatic Organisms to Radionuclides 2 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 3 protection regulation, 10 CFR Part 51. With respect to the aquatic organisms, the revision 4 amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new Category 1 5 issue, "Exposure of aquatic organisms to radionuclides," among other changes. This new 6 Category 1 issue considers the impacts to aquatic organisms from exposure to radioactive 7 effluents discharged from a nuclear power plant during the license renewal term. An 8 understanding of the radiological conditions in the aquatic environment from the discharge of 9 radioactive effluents within NRC regulations has been well established at nuclear power plants 10 during their current licensing term. Based on this information, the NRC concluded that the 11 doses to aquatic organisms are expected to be well below exposure guidelines developed to 12 protect these organisms and assigned an impact level of SMALL. 13 The NRC staff has not identified any new and significant information related to the exposure of 14 aquatic organisms to radionuclides during its independent review of the applicant's ER, the site 15 audit, and the scoping process. Section 2.1.2 of this SEIS describes the applicant's radioactive 16 waste management program to control radioactive effluent discharges to ensure that they 17 comply with NRC regulations in 10 CFR Part 20. Section 4.9.2 of this SEIS contains the NRC 18 staff's evaluation of GGNS's radioactive effluent and radiological environmental monitoring 19 programs. GGNS's radioactive effluent and radiological environmental monitoring programs 20 provide further support for the conclusion that the impacts to aquatic organisms from 21 radionuclides are SMALL. The NRC staff concludes that there would be no impacts to aquatic 22 organisms from radionuclides beyond those impacts contained in the GEIS (NRC 2013a) and 23 therefore, the impacts to aquatic organisms from radionuclides are SMALL. 24 4.7 Terrestrial Resources 25 The Category 1 (generic) and Category 2 (site -specific) terrestrial resources issues applicable t o 26 GGNS are discussed in the following sections and listed in Table 4-6. Terrestrial resources 27 issues that apply to GGNS are described in Sections 2.2.7 and 2.2.8. 28 Environmental Impacts of Operation 4-7 Table 4-6. Terrestrial Resource Issues 1 Issue GEIS Section Category Cooling tower impacts on crops and ornamental vegetation 4.3.4 1 Cooling tower impacts on native plants 4.3.5.1 1 Bird collisions with cooling towers 4.3.5.2 1 Power line right -of-way management (cutting, herbicide application) 4.5.6.1 1 Bird collisions with power lines 4.5.6.1 1 Impacts of electromagnetic fields on flora and fauna (plants, agricultural crops, honeybees, wildlife, livestock) 4.5.6.3 1 Floodplains and wetland on power line right -of-way 4.5.7 1 Exposure of terrestrial organisms to radionuclides 4.6.1.1(a) 1 Effects on terrestrial resources (non -cooling system impacts) 4.6.1.1(a) 2 Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51; (a) NRC 2013a 4.7.1 Generic Terrestrial Resource Issues 2 For the Category 1 terrestrial resources issues listed in Table 4 -6, the NRC staff did not identify 3 any new and significant information during the review of the ER (Entergy 2011a), the NRC 4 staff's site audit, the scoping process, or the evaluation of other available information. 5 Therefore, there are no impacts related to these issues beyond those discussed in the GEIS. 6 For these issues, the GEIS concludes that the impacts are SMALL. 7 4.7.2 Exposure of Terrestrial Organisms to Radionuclides 8 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 9 protection regulation, 10 CFR Part 51. With respect to the terrestrial organisms, the revision 10 amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new Category 1 11 issue, "Exposure of terrestrial organisms to radionuclides," among other changes. This new 12 issue has an impact level of SMALL. This new Category 1 issue considers the impacts to 13 terrestrial organisms from exposure to radioactive effluents discharged from a nuclear power 14 plant during the license renewal term. An understanding of the radiological conditions in the 15 terrestrial environment from the discharge of radioactive effluents within NRC regulations has 16 been well established at nuclear power plants during the ir current licensing term. Based on this 17 information, the NRC concluded that the doses to terrestrial organisms are expected to be well 18 below exposure guidelines developed to protect these organisms and assigned an impact level 19 of SMALL. 20 The NRC staff has not identified any new and significant information related to the exposure of 21 terrestrial organisms to radionuclides during its independent review of the applicant's ER, the 22 site audit, and the scoping process. Section 2.1.2 of this SEIS describes the applicant's 23 radioactive waste management program to control radioactive effluent discharges to ensure that 24 they comply with NRC regulations in 10 CFR Part 20. Section 4.9.2 of this SEIS contains t he 25 NRC staff's evaluation of GGNS's radioactive effluent and radiological environmental monitoring 26 programs. GGNS's radioactive effluent and radiological environmental monitoring programs 27 provide further support for the conclusion that the impacts from radioactive effluents are SMAL L. 28 Environmental Impacts of Operation 4-8 Therefore, the NRC staff concludes that there would be no impact to terrestrial organisms from 1 radionuclides beyond those impacts contained in the GEIS (NRC 2013a). For this issue, the 2 GEIS concl udes that the impacts are SMALL. 3 4.7.3 Effects on Terrestrial Resources (Non -cooling System Impacts) 4 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 5 protection regulation, 10 CFR Part 51. With respect to the terrestrial organisms, the revision 6 amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by expanding the Category 2 7 issue, "Refurbishment impacts," among others, to include normal operations, refurbishment, and 8 other supporting activities during the license renewal term. This issue remains a Category 2 9 issue with an impact level range of SMALL to LARGE; however, the GEIS (NRC 2013a) 10 renames this issue "Effects on terrestrial resources (non-cooling system impacts)." 11 The geographic scope for the assessment of this issue is the GGNS site and area near the site, 12 and the baseline is the condition of the terrestrial resources under the no -action alternative. 13 Section 2.2.7 describes the terrestrial resources on and in the vicinity of the GGNS site, and 14 Section 2.2.8 describes protected species and habitats. During construction of GGNS, 15 approximately 14 percent of the plant site (270 ac [109 ha]) was cleared for buildings, parking 16 lots, roads, and other infrastructure. The remaining terrestrial and associated wetland habitats 17 have not changed significantly since construction , except for reforestation activities performed 18 by Entergy (see Section 2.2.7). As discussed in Chapter 3 of this SEIS and according to the 19 applicant's ER (Entergy 2011a), Entergy has no plans to conduct refurbishment or replacement 20 actions associated with license renewal to support the continued operation of GGNS. Further, 21 Entergy (2011a) anticipates no new construction or other ground-disturbing activities, changes 22 in operations, or changes in existing land use conditions due to license renewal. Entergy 23 (2011a) reports that operation and maintenance activities would be confined to previously 24 disturbed areas or existing ROWs. As a result, Entergy (2011a) anticipates no new impacts on 25 the terrestrial environment on the GGNS site or along the in-scope transmission line corridors 26 during the license renewal term. Based on the staff's independent review, the staff concludes 27 that operation and maintenance activities that Entergy might undertake during the renewal term, 28 such as maintenance and repair of plant infrastructure (e.g., roadways, piping installations, 29 onsite transmission lines, fencing and other security infrastructure), would likely be confined to 30 previously -disturbed areas of the GGNS site. Therefore, the staff expects non -cooling system 31 impacts on terrestrial resources during the license renewal term to be SMALL. 32 4.8 Protected Species and Habitats 33 Section 2.2.8 of this SEIS describes the action area, as defined by the Endangered Species Act 34 of 1973, as amended (ESA), regulations at 50 CFR 402.02, and describes the protected species 35 and habitats within the action area associated with the GGNS license renewal. 36 Table 4-7 identifies the one Category 2 issue related to protected species and habitats that is 37 applicable to GGNS. 38 Table 4-7. Threatened or Endangered Species 39 Issue GEIS Section Category Threatened or endangered species 4.1 2 Table source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51 Environmental Impacts of Operation 4-9 4.8.1 Correspondence with Federal and State Agencies 1 As part of its National Environmental Policy Act (NEPA) and ESA reviews, the NRC staff 2 contacted the Louisiana and Mississippi Field Offices of the U.S. Fish and Wildlife Service 3 (FWS), the National Marine Fisheries Service (NMFS), the Louisiana Department of Wildlife and 4 Fisheries (LDWF) and the Mississippi Department of Wildlife, Fisheries, and Parks (MDWFP) to 5 gather information on protected species and habitats that may occur in the action area. 6 The NRC staff sent letters to the Louisiana and Mississippi FWS Field Offices and the NMFS on 7 January 19, 2012 (NRC 2012a, 2012b, 2012c), requesting concurrence with the NRC's list of 8 Federally protected species in the vicinity of GGNS. The Mississippi FWS Field Office replied in 9 a letter dated February 3, 2012 (FWS 2012a). In that letter, the FWS did not address the list of 10 Federally protected species, but it stated that no Federally listed species or their habitats are 11 likely to be affected from the proposed GGNS license renewal and that no further consultation 12 under the ESA would be necessary with that office. The Louisiana FWS Field Office concurred 13 with the NRC's list of Federally protected species in the vicinity of GGNS in a letter dated 14 February 29, 2012 (FWS 2012b). The NMFS replied to the NRC on March 1, 2012, as 15 described in Section 2.2.8 (NMFS 2012). 16 The NRC sent a letter to the MDWFP on January 20, 2012 (NRC 2012d), requesting information 17 on both Federally and State -listed species. The MDWFP replied in a letter dated 18 February 13, 2012 (MDWFP 2012), that provided the NRC with a list of species that occur within 19 2 mi (3.2 km) of the GGNS site and transmission line corridors. 20 The NRC (2012e) sent a letter to the LDWF on February 6, 2012, requesting information on 21 both Federally and State -listed species. The LDWF (2012) replied in a letter dated 22 February 16, 2012, that stated, "After careful review of our database, no impacts to rare, 23 threatened or endangered species or critical habitats are anticipated from the proposed project." 24 Pursuant to the ESA, the NRC intends to submit this draft SEIS to the FWS with a request for 25 concurrence on the NRC's effect determinations for Federally listed species and designated 26 critical habitat. The results of this consultation will be documented in the final SEIS. 27 4.8.2 Species and Habitats Protected Under the Endangered Species Act 28 4.8.2.1 Wood Stork 29 Section 2.2.8 concludes that the wood stork (Mycteria americana) occurs in the action area, but 30 that the individuals within Mississippi do not represent members of the endanger ed 31 U.S. breeding populations. Thus, the staff concludes that the proposed GGNS license renewal 32 would have no effect on the wood stork. 33 4.8.2.2 Red-cockaded Woodpecker 34 Section 2.2.8 concludes that the red -cockaded woodpecker occurs in the action area along the 35 portion of the Franklin transmission line corridor that travels through the Homochitto National 36 Forest and the corresponding 1 -mi (0.6-km) buffer. 37 Because the red -cockaded woodpecker does not occur on the GGNS site, ongoing operations 38 and maintenance activities associated with the proposed license renewal would have no effect 39 on the species. 40 In 2003, the U.S. Forest Service (USFS) completed an environmental assessment that 41 considered the environmental effects of managing utility corridors with practices intended to 42 enhance wildlife habitat within the Homochitto National Forest (USFS 2003). The environmental 43 assessment included a biological evaluation of the effects of transmission line maintenance on 44 Environmental Impacts of Operation 4-10 the red-cockaded woodpecker. The biological evaluation concluded that herbicide application 1 and other activities associated with transmission line maintenance would have no direct or 2 indirect effects on the species (USFS 2003). Since EMI's transmission line maintenance 3 procedures have not changed since 2003, the NRC adopts the USFS's conclusion of "no effect." 4 Additionally, in correspondence with the NRC, the FWS (2012a) indicated that no Federally 5 listed species would be affected by the proposed license renewal. 6 The staff concludes that the proposed license renewal would have no effect on the 7 red-cockaded woodpecker. 8 4.8.2.3 Least Tern (Interior Population) 9 Section 2.2.8 concludes that the least tern occurs within the action area along the Mississippi 10 River upstream and downstream of the GGNS site. The proposed GGNS license renewal 11 would not include new construction, refurbishment, ground-disturbing activities, or changes to 12 existing land use conditions that would affect any of the natural habitats on the site or any offsite 13 areas. Additionally, in its correspondence with the NRC, the FWS (2012 b) indicated that no 14 Federally listed species would be affected by the proposed license renewal. 15 The staff concludes that the proposed action would have no effect on the least tern. 16 4.8.2.4 Bayou Darter 17 Section 2.2.8 concludes that bayou darters occur in the action area along the portion of the 18 Franklin transmission line corridor that crosses Bayou Pierre. Although highly unlikely, 19 transmission line and vegetation maintenance requiring in -stream work could adversely affect 20 bayou darters directly or indirectly. Potential indirect effects could include a temporary decline 21 in habitat quality from increased sedimentation and turbidity during maintenance activities. 22 Entergy Mississippi, Inc. (EMI), takes a number of precautions to avoid impacts to bayou darters 23 and their habitat when performing maintenance in or near water bodies. As described in 24 Section 2.1.5, EMI chooses maintenance techniques that minimize impacts in streams and 25 other water features. In wetlands and aquatic habitats, EMI personnel selectively apply 26 Environmental Prote ction Agency (EPA) approved herbicides for wetlands and aquatic area 27 applications. Personnel spray areas on foot with backpack sprayers to minimize impacts. All 28 EMI maintenance crew personnel hold U.S. Department of Agriculture (USDA) State-approved 29 herbicide licenses. Therefore, the continued operation and maintenance of the Franklin 30 transmission line would have discountable or insignificant effects on bayou darters. 31 Bayou darters do not occur on the GGNS site because the species is endemic to the Bayou 32 Pierre, which does not flow through GGNS, as described in Section 2.2.8. Because bayou 33 darters do not occur on the GGNS site, ongoing operations and maintenance activities 34 associated with the proposed license renewal would have no effect on the species. 35 In correspondence with the NRC, the FWS Mississippi Field Office concluded that neither bayou 36 darters nor their habitat would likely be affected from the proposed GGNS operating license 37 renewal (FWS 2012 a). Similarly, MDFWP (2012) stated that the proposed project likely poses 38 no threat to listed species or their habitat if best management practices are properly 39 implemented. Based on FWS (2012a), MDWFP (2012), and the NRC staff's assessment that 40 the continued operation and maintenance of the Franklin transmission line would have 41 discountable or insignificant effects on bayou darters, the NRC staff concludes that the 42 proposed GGNS license renewal may affect, but is not likely to adversely affect bayou darters. 43 4.8.2.5 Pallid Sturgeon 44 Section 2.2.8 concludes that pallid sturgeon could occur in the action area in the Mississippi 45 River. Increased water temperature and other conditions near GGNS's discharge could affect 46 Environmental Impacts of Operation 4-11 pallid sturgeon. Direct effects to pallid sturgeon from heat shock would be highly unlikely 1 because the thermal plume does not create a barrier across the Mississippi River; therefore, the 2 fish could avoid the warmer temperature water (NRC 1972). Indirect effects could include a 3 decrease in habitat quality from thermal discharge in the Mississippi River. GGNS's NPDES 4 permit limits the flow, temperature, and other conditions of GGNS's discharge into the 5 Mississippi River. Therefore, the continued discharge from GGNS would have discountable or 6 insignificant effects on pallid sturgeon. 7 In correspondence with the NRC, the FWS Mississippi Field Office concluded that neither pallid 8 sturgeon nor their habitat would likely be affected from the proposed GGNS operating license 9 renewal (FWS 2012 a). Similarly, MDFWP (2012) stated that the proposed project likely poses 10 no threat to listed species or their habitat if best management practices are implemented 11 properly. Based on FWS (2012a), MDWFP (2012), and the staff's assessment that the 12 continued discharge from GGNS would have discountable or insignificant effects on pallid 13 sturgeon, the NRC staff concludes that the proposed GGNS license renewal may affect, but is 14 not likely to adversely affect the pallid sturgeon. 15 4.8.2.6 Louisiana and American Black Bears 16 Section 2.2.8 concludes that the Louisiana (Ursus americanus luteolus) and American 17 (U. americanus) black bears occur in the action area in bottomland hardwood forest habitat or 18 other suitable habitat. Black bears would be expected to avoid areas of human activity and 19 would be unlikely to occur on the developed portion of the GGNS site. Within the GGNS site, 20 the proposed license renewal would include maintenance and operation activities within 21 developed or previously disturbed areas and would not involve new construction, refurbishment , 22 ground-disturbing activities, or changes to existing land use conditions in either natural or 23 developed areas. The continued operation of GGNS during the license renewal term would 24 preserve the existing natural habitats on the site. The large tracts of bottomland and upland 25 hardwood forests on the site are relatively remote, restricted from public access, and provide 26 contiguous habitat with offsite areas of hardwood forest. Therefore, continued operation of the 27 GGNS site could result in beneficial effects to the species. 28 The continued operation and maintenance of the Baxter -Wilson and Franklin transmission lines 29 would have discountable or insignificant effects on black bears. Within the transmission line 30 corridors, black bears could take in herbicides that have been sprayed on berries or shrubs. 31 Noise from machinery and human activity could temporarily alter the behavior of black bears 32 during transmission line maintenance activities. However, none of these effects would be 33 measurable or detectable or reach the scale in which a take would occur. Transmission line 34 maintenance could require removal of mature trees if they pose a threat to the transmission 35 lines; however, black bears are unlikely to den at the edge of forest habitat, so tree removal 36 should not affect denning habitat. 37 Based on the staff's assessment that the continued operation and maintenance of the 38 Baxter-Wilson and Franklin transmission lines would have discountable or insignificant effects 39 on bears, the NRC staff concludes that the proposed GGNS license renewal may affect, but is 40 not likely to adversely affect the Louisiana and American black bears. 41 4.8.2.7 Louisiana Black Bear Critical Habitat 42 Secti on 2.2.8 concludes that no designated Louisiana black bear critical habitat occurs within 43 the action area, but notes that the closest designated critical habitat lies about 16 mi (26 km) 44 west of the GGNS site at its closest point. Because no designated critical habitat lies within the 45 action area, the staff conclude s that the proposed GGNS license renewal would have no effect 46 on designated Louisiana black bear critical habitat. 47 Environmental Impacts of Operation 4-12 4.8.2.8 Fat Pocketbook Mussel 1 Section 2.2.8 concluded that fat pocketbook mussels are not likely to occur within the action 2 area. In correspondence with the NRC, the FWS Mississippi Field Office concluded that neither 3 fat pocketbook mussels nor their habitat would likely be affected from the proposed license 4 renewal (FWS 2012 a). Similarly, MDFWP (2012) stated that the proposed project likely poses 5 no threat to listed species or their habitat if best management practices are implemented 6 properly. Therefore, the staff concludes that the proposed GGNS license renewal would have 7 no effect on fat pocketbook mussels. 8 4.8.2.9 Rabbitsfoot Mussel 9 Section 2.2.8 concluded that rabbitsfoot mussels are not likely to occur within the action area. 10 In correspondence with natural resource agencies, FWS Mississippi Field Office, FWS 11 Louisiana Field Office, and MDW FP did not include rabbitsfoot mussel as a species that would 12 be affected by the proposed license renewal (FWS 2012 a, 2012 b; MDFWP 2012). Therefore, 13 the staff concludes that the proposed GGNS license renewal would have no effect on 14 rabbitsfoot mussels. 15 4.8.2.10 Rabbitsfoot Mussel Proposed Critical Habitat 16 Section 2.2.8 concludes that no proposed rabbitsfoot mussel critical habitat occurs within the 17 action area. Thus, the staff conclude s that the proposed GGNS license renewal would have no 18 effect on proposed rabbitsfoot mussel critical habitat. 19 4.8.3 Species Protected by the State of Mississippi 20 4.8.3.1 Aquatic Species 21 Section 2.2.8 concluded that the chestnut lamprey, black buffalo, paddlefish, blue sucker, and 22 sicklefin chub inhabit portions of the Mississippi River (NatureServe 2010). Section 2.2.8 also 23 concluded that crystal darter, chestnut lamprey, blue sucker, black buffalo sicklefin chub, and 24 paddlefish may occur in suitable habitat along the transmission line corridors, such as the 25 transmission line crossings along the Mississippi, Big Black, and Bayou Pierre rivers. No 26 GGNS-related aquatic surveys have been conducted along the transmission lines. 27 In the Mississippi River, increased water temperature and other conditions near GGNS's 28 discharge could affect State-protected fish. As described above, GGNS's NPDES permit limits 29 the flow, temperature, and other conditions of GGNS's discharge into the Mississippi River. In 30 addition, the thermal plume would not extend the width of the Mississippi River; therefore, fish 31 could swim away to avoid the plume (NRC 1972). 32 The continued operation and maintenance of the transmission lines would have discountable or 33 insignificant effects on State-protected fish. Although highly unlikely, line and vegetation 34 maintenance requiring in -stream work could adversely affect fish directly and indirectly. 35 Potential adverse effects include a temporary decline in habitat quality from increased 36 sedimentation and turbidity during maintenance activities. As described in Section 2.1.5, EMI 37 takes a number of precautions to avoid impacts to State-protected fish and their habitat when 38 performing transmission line maintenance in or near water bodies. As described in Section 39 2.1.5, EMI chooses maintenance techniques that minimize erosion in streams and other water 40 features. In wetlands and aquatic habitats, EMI personnel selectively apply EPA -approved 41 herbicides on foot with backpack sprayers to minimize impacts. All EMI maintenance crew 42 personnel hold USDA state -approved herbicide licenses. 43 Environmental Impacts of Operation 4-13 In correspondence with the NRC, MDWFP (2012) did not identify any impacts of the proposed 1 license renewal that would affect State-protected species, assuming that best management 2 practices are implemented properly 3 4.8.3.2 Terrestrial Species 4 Section 2.2.8 discusses two species protected under the Mississippi Nongame and Endangered 5 Species Conservation Act of 1974: Webster's salamander (Plethodon websteri) and the white 6 ibis (Eudocimus albus). In its correspondence with the NRC, the MDWFP (2012) concluded 7 that "the proposed project likely poses no threat to listed species or their habitats." 8 4.8.4 Species Protected Under the Bald and Golden Eagle Protection Act 9 Though bald eagles occur throughout the action area, no known nests are in close proximity to 10 the GGNS site or along the transmission line corridors that could be disturbed by operations or 11 maintenance activities associated with the proposed license renewal. Since the proposed 12 license renewal does not involve construction or land disturbances, the proposed license 13 renewal would not affect any bald eagle habitat. 14 4.8.5 Species Protected Under the Migratory Bird Treaty Act 15 Section 2.2.7 discusses a variety of migratory birds that inhabit the GGNS site and surrounding 16 region. Section

2.2.8 describes

Entergy's depredation permit for cliff swallows 17 (Petrochelidon spp.) and barn swallows (Hirundo rustica). In the past 5 years of available 18 depredation reports, Entergy has taken a small number of birds to ensure the safety and 19 integrity of plant structures. This small number of takes would not be expected to destabilize or 20 noticeably alter either species' populations. Also, the FWS reviews Entergy's depredation 21 reports and renews the depredation permit annually to ensure that impacts to migratory birds 22 are minimal. The proposed license renewal does not involve construction or other land 23 disturbances that might adversely affect migratory birds. 24 4.9 Human Health 25 Table 4-8 lists the issues related to human health that are applicable to GGNS. 26 Table 4-8. Human Health Issues 27 Issue GEIS Section Category Microbiological organisms (occupational health) 4.3.6 1 Noise 4.3.7 1 Radiation exposures to public (license renewal term) 4.6.2 1 Occupational radiation exposures (license renewal term) 4.6.3 1 Electromagnetic fields -acute effects (electric shock) 4.5.4.1 2 Electromagnetic fields -chronic effects 4.5.4.2 Uncategorized Human health impact from chemicals 4.9.1.1.2 (a) 1 Physical occupational hazards 4.9.1.1.5 (a) 1 Table source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51; (a) NRC 2013 a 4.9.1 Generic Human Health Issues 28 Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B -1, applicable to GGNS in 29 regard to human health are listed in Table 4 -9. Entergy stated in its ER (Entergy 2011a) that it 30 Environmental Impacts of Operation 4-14 was not aware of any new and significant human health issues associated with the renewal of 1 the GGNS operating license. The NRC staff did not identify any new and significant information 2 during its independent review of the applicant's ER, the staff's site audit, the scoping process, or 3 the evaluation of other available information. Therefore, there are no impacts related to 4 Category 1 human health issues beyond those discussed in the GEIS . For these issues, the 5 GEIS concluded that the impacts are SMALL, and additional site -specific mitigation measures 6 are not likely to be sufficiently beneficial to warrant implementation. These impacts are 7 expected to remain SMALL through the license renewal term. 8 4.9.1.1 New Category 1 Human Health issues 9 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 10 protection regulation, 10 CFR Part 51. With respect to the human health, the revision amend s 11 Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding two new Category 1 issues, 12 "Human health impact from chemicals" and "Physical occupational hazards." The first issue 13 considers the impacts from chemicals to plant workers and members of the public. The second 14 issue only considers the non -radiological occupational hazards of working at a nuclear power 15 plant. An understanding of these non -radiological hazards to nuclear power plant workers and 16 members of the public have been well established at nuclear power plants during those plants' 17 current licensing terms. The impacts from chemical hazards are expected to be minimized 18 through the licensee's use of good industrial hygiene practices as required by permits and 19 Federal and State regulations. Also, the impacts from physical hazards to plant workers will be 20 of small significance if workers adhere to safety standards and use protective equipment as 21 required by Federal and State regulations. The impacts to human health for each of these new 22 issues from continued plant operations are SMALL. 23 The NRC staff has not identified any new and significant information related to these non -24 radiological issues during its independent review of the applicant's ER, the site audit, and the 25 scoping process. Therefore, the NRC staff concludes that there would be no impact to human 26 health from chemicals or physical hazards beyond those impacts described in the GEIS 27 (NRC 2013a) and, therefore, the impacts are SMALL. 28 4.9.2 Radiological Impacts of Normal Operations 29 Entergy stated in its ER that it was not aware of any new and significant radiological impacts 30 related to human health issues associated with the renewal of the GGNS operating license. 31 The NRC staff has not identified any new and significant information radiological impacts related 32 to human health issues during its independent review of the applicant's ER, the site audit, the 33 scoping process, or its evaluation of other available information. Therefore, the NRC staff 34 concludes that there would be no impact from radiation exposures to the public or to workers 35 during the renewal term beyond those discussed in the GEIS. 36 The findings in the GEIS are as follows: 37 Radiation exposures to public (license renewal term) -Based on information 38 in the GEIS, the NRC found that radiation doses to the public will continue at 39 current levels associated with normal operations. 40 Occupational exposures (license renewal term) -Based on information in the 41 GEIS, the NRC found that project ed maximum occupational doses during the 42 license renewal term are within the range of doses experienced during 43 normal operations and normal maintenance outages, and would be well 44 below regulatory limits. 45 There are no Category 2 issues related to radiological impacts of routine operations. 46 Environmental Impacts of Operation 4-15 The information presented below is a discussion of selected radiological programs conducted at 1 GGNS. 2 4.9.2.1 GGNS Radiological Environmental Monitoring Program 3 GGNS conducts a radiological environmental monitoring program (REMP) to assess the 4 radiological impact, if any, to its employees, the public, and the environment from operations. 5 The REMP measures aquatic, terrestrial, and atmospheric radioactivity, as well as ambient 6 radiation. 7 The REMP also measures background radiation (i.e., cosmic sources, global fallout, and 8 naturally occurring radioactive material, including radon). The REMP supplements the 9 radioactive effluent monitoring program, discussed later in this section, by verifying that any 10 measurable concentrations of radioactive materials and levels of radiation in the environment 11 are not higher than those calculated using the radioactive effluent release measurements and 12 transport model

s. 13 An annual radiological environmental operating report is issued, which contains a discussion of 14 the results of the monitoring program performed for the previous year. The REMP collects 15 samples of environmental media to measure the radioactivity levels that may be present. The 16 media samples are representative of the radiation exposure pathways that may have an impact 17 on the public.

18 The GGNS radiological environmental monitoring program consists of four categories based on 19 exposure pathways to the public. These categories are: airborne, waterborne, ingestion, and 20 direct radiation. The airborne samples taken around GGNS are airborne particulate and 21 airborne iodine. The waterborne pathway samples are taken from surface water and 22 groundwater sources. Sediment samples also are included in this pathway. The ingestion 23 pathway samples include fish and broadleaf vegetation. GGNS will also sample milk for this 24 pathway if it is available commercially within 8 km (5 mi) of the site. For 201 2, there was no 25 commercial milk available to sample. The direct radiation pathway measures direct exposure 26 from environmental radiation doses using thermoluminescent dosimeters. 27 In addition to the REMP, GGNS has an onsite groundwater protection program designed to 28 monitor the onsite environment for detection of leaks from plant systems and pipes containing 29 radioactive liquid (Entergy 2011 a). Additional information on the groundwater protection 30 program is contained later in this section and in the groundwater quality section in Chapter 2 of 31 this document. 32 The NRC staff reviewed the GGNS annual radiological environmental operating reports for 2008 33 through 201 2 for significant impacts to the environment or unusual trends in the data 34 (Entergy 2009a, 2010a, 2011 b, 2012a, 2013a ). Five year s provides a data set that covers a 35 broad range of activities that occur at a nuclear power plant, including refueling outages, 36 non-refueling outage years, routine operation, and years where there may be significant 37 maintenance activities. Based on the staff's review, no adverse trends (i.e., steadily increasing 38 build-up of radioactivity levels) were observed and the data showed no measurable impact to 39 the environment from operations at GGNS. 40 4.9.2.2 Ground Water Protection Program 41 In 2007, the Nuclear Energy Institute (NEI) established a standard for monitoring and reporting 42 radioactive isotopes in groundwat er: NEI 07-07, "Industry Ground Water Protection Initiative - 43 Final Guidance Document" (NEI 2007). GGNS implemented the recommendations of this 44 industry standard after initial sampling efforts in 2007. Results of Entergy's groundwate r 45 Environmental Impacts of Operation 4-16 protection program are contained in the annual radioactive effluent release report submitted 1 annually to the NRC . 2 Information on the GGNS groundwater protection program is located in Sections 2.2.5 and 4. 5.3 3 in this SEIS. 4 4.9.2.3 GGNS Radioactive Effluent Release Program 5 All nuclear plants were licensed with the expectation that they would release radioactive 6 material to both the air and water during normal operation. However, NRC regulations require 7 that radioactive gaseous and liquid releases from nuclear power plants must meet radiation 8 dose-based limits specified in 10 CFR Part 20, and the as low as is reasonably achievable 9 (ALARA) criteria in Appendix I to 10 CFR Part 50. Regulatory limits are placed on the radiation 10 dose that members of the public can receive from radioactive effluents that a nuclear power 11 plant releases. In addition, 10 CFR 50.36(a) requires nuclear power plants to submit an annual 12 report to the NRC that lists the types and quantities of radioactive effluents released into the 13 environment. 14 The NRC staff reviewed the annual radioactive effluent release reports for 2008 through 2012 15 (Entergy 2009b, 2010b, 2011c, 2012b, 2013b ). The review focused on the calculated doses to 16 a member of the public from radioactive effluents released from GGNS. The doses were 17 compared to the radiation protection standards in 10 CFR 20.1301 and the ALARA dose design 18 objectives in Appendix I to 10 CFR Part 50 and EPA's 40 CFR Part 190. 19 Dose estimates for members of the public are calculated based on radioactive gaseous and 20 liquid effluent release data and atmospheric and aquatic transport models. The 2012 annual 21 radioactive effluent release report (Entergy 2013b) contains a detailed presentation of the 22 radioactive discharges and the resultant calculated doses. The following summarizes the 23 calculated dose to a member of the public located outside the GGNS site boundary from 24 radioactive gaseous and liquid effluents released during 2012: 25 The total-body dose to an offsite member of the public from GGNS 26 radioactive liquid effluents was 3.02x10-01 mrem (3.02x10-03 mSv), which is 27 well below the 3 mrem (0.03 mSv) dose criterion in Appendix I to 28 10 CFR Part 50. 29 The organ (liver) dose to an offsite member of the public from GGNS 30 radioactive liquid effluents was 5.64x10-01 mrem (5.64x10-03 mSv), which is 31 well below the 10 mrem (0.10 mSv) dose criterion in Appendix I to 32 10 CFR Part 50. 33 The air dose at the site boundary from gamma radiation in gaseous effluents 34 from GGNS was 4.23x10-01 mrad (4.23x10-03 mGy), which is well below the 35 10 mrad (0.1 mGy) dose criterion in Appendix I to 10 CFR Part 50. 36 The air dose at the site boundary from beta radiation in gaseous effluents 37 from GGNS was 2.16x10-01 mrad (2.16x10-03 mGy), which is well below the 38 20 mrad (0.2 mGy) dose criterion in Appendix I to 10 CFR Part 50. 39 The dose to an organ (bone) from radioactive iodine, radioactive particulates, 40 and carbon -14 from GGNS was 7.06 mrem (7.06x10-02 mSv), which is below 41 the 15 mrem (0.15 mSv) dose criterion in Appendix I to 10 CFR Part 50. 42 4.9.2.4 Summary 43 The NRC staff's review of the GGNS radioactive effluent control program showed that radiation 44 doses to members of the public for the years 2008 -2012 comply with Federal radiation 45 Environmental Impacts of Operation 4-17 protection standards contained in Appendix I to 10 CFR Part 50, 10 CFR Part 20, and 1 40 CFR Part 190. 2 The applicant has no plans to conduct refurbishment activities during the license renewal term; 3 however, routine plant refueling and maintenance activities currently performed will continue 4 during the license renewal term. Based on the past performance of the radioactive waste 5 system to maintain the dose from radioactive effluents to be ALARA, similar performance is 6 expected during the license renewal term. Continued compliance with regulatory requirements 7 is expected during the license renewal term; therefore, the staff concludes that the impacts from 8 radioactive effluents would be SMALL. 9 4.9.3 Electromagnetic Fields-Acute Effects 10 Based on the GEIS, the NRC found that electric shock resulting from direct access to energized 11 conductors or from induced charges in metallic structures has not been a problem at most 12 operating nuclear power plants and generally is not expected to be a problem during the license 13 renewal term. However, site -specific review is required to determine the significance of the 14 electric shock potential along portions of the transmission lines within the scope of this 15 document. 16 In the GEIS (NRC 1996), the NRC found that without a review of the conformance of each 17 nuclear plant transmission line with National Electrical Safety Code (NESC) criteria, it was not 18 possible to determine the significance of the electric shock potential (IEEE 2002). Evaluation of 19 individual plant transmission lines is necessary because electric shock safety was not 20 addressed in the licensing process for some plants. For other plants, land use in the vicinity o f 21 transmission lines may have changed, or power distribution companies may have upgraded line 22 voltage. The NRC uses the NESC criteria as its baseline to assess the potential human health 23 impact of the induced current from an applicant's transmission lines. As discussed in the GEIS, 24 the issue of electric shock is of small significance for transmission lines that are operated in 25 adherence with the NESC criteria. To comply with 10 CFR 51.53(c)(3)(ii)(H), Entergy provided 26 an assessment of the impact of the proposed action on the potential shock hazard from the 27 transmission lines. 28 GGNS electrical output is delivered to the Baxter -Wilson Steam Electric Station Extra High 29 Voltage (EHV) switchyard and the Franklin EHV Switching Station through two 500 -kilovolt (kV) 30 transmission lines. The Baxter -Wilson transmission line is a 22 -mi (35-km) single-circuit line 31 that spans from the 500 -kV switchyard located at GGNS to the Baxter -Wilson Steam Electric 32 Station EHV switchyard. The Franklin transmission line is a 43.6 -mi (70.2-km) single-circuit line 33 that spans from the 500 -kV switchyard located at GGNS to the Franklin EHV Switching Station. 34 There is also a 500 -kV line that spans approximately 300 ft (90 m) from the GGNS Turbine 35 Building to the 500-kV switchyard located on site. Entergy Mississippi, Inc. (EMI) owns and 36 operates the transmission lines constructed to connect GGNS to the electric grid. 37 Entergy completed an acute shock analysis for the transmission lines using the software 38 "EMF-10 Electric Field Induction" developed by the Electric Power Research Institute (EPRI). 39 The input parameters included the design features of the Franklin and Baxter -Wilson 40 transmission lines and a large tractor -trailer was assumed to be the maximum vehicle size 41 under the lines. The minimum clearance on the Franklin line above any of the travel ways 42 mentioned was 35.4 ft (10.8 m). The minimum clearance above any of the travel ways 43 mentioned on the Baxter -Wilson line was 44.5 ft (13.6 m). The maximum induced current 44 calculated for those power lines was 2.03 mA on the Franklin transmission line. The minimum 45 clearance at any point on the 500 -kV line that spans approximately 300 ft (90 m) from the 46 GGNS Turbine Building to the 500 -kV switchyard located on site was 70 ft (21.3 m). Since that 47 Environmental Impacts of Operation 4-18 clearance is almost twice the clearance used in the acute shock analyses for the Baxter -Wilson 1 and Franklin transmission lines, this span would not induce a current greater than the 2 NESC 5 mA criterion. Therefore, the lines meet the NESC 5 mA criterion (Entergy 2011 a). 3 The GGNS transmission line corridor crosses over mostly rural agricultural and forest land, with 4 the exception of the Franklin transmission line, which crosses over portions of highways and 5 rivers in the area. EMI inspects all transmission lines 230-kV and above at least three times 6 each year. Any problems or hazards related to vegetation are recorded in an electronic 7 database and assigned to crews for mitigation. Also, transmission lines 230 -kV and above are 8 presently scheduled to receive herbicide every 2 years to maintain proper clearances from 9 conductors. EMI also uses aerial patrols to inspect their transmission lines and works with 10 internal and external customers to investigate and resolve potential problems, such as building 11 or roadway construction projects and pipeline installation or maintenance. EMI's current 12 maintenance practices associated with maintaining transmission line clearances will continue 13 during the license renewal term (Entergy 2011 a). 14 The NRC staff reviewed the information Entergy provided to document the results of its acute 15 shock evaluation of its transmission lines. The staff notes that Entergy used appropriate 16 assumptions in its calculations: identification of the transmission lines covered by 17 10 CFR 51.53(c)(3)(ii)(H), the use of the maximum vehicle size to be located below the 18 transmission lines, and software developed by EPRI-the nationally recognized expert in this 19 area. Based on this information, the NRC staff concludes that the potential impacts from 20 electric shock during the renewal period would be SMALL. 21 4.9.4 Electromagnetic Fields -Chronic Effects 22 In the GEIS, the effects of chronic exposure to 60 -Hz electromagnetic fields from power lines 23 were not designated as Category 1 or 2, and will not be until a scientific consensus is reached 24 on the health implications of these fields. 25 The potential effects of chronic exposure from these fields continue to be studied and are not 26 known at this time. The National Institute of Environmental Health Sciences (NIEHS) directs 27 related research through the U.S. Department of Energy (DOE). 28 The report by NIEHS (NIEHS 1999) contains the following conclusion: 29 The NIEHS concludes that ELF -EMF (extremely low frequency -electromagnetic 30 field) exposure cannot be recognized as entirely safe because of weak scientific 31 evidence that exposure may pose a leukemia hazard. In our opinion, this finding 32 is insufficient to warrant aggressive regulatory concern. However, because 33 virtually everyone in the United States uses electricity and therefore is routinely 34 exposed to ELF -EMF, passive regulatory action is warranted such as continued 35 emphasis on educating both the public and the regulated community on means 36 aimed at reducing exposures. The NIEHS does not believe that other cancers or 37 non-cancer health outcomes provide sufficient evidence of a risk to currently 38 warrant concern. 39 This statement is not sufficient to cause the NRC staff to change its position with respect to the 40 chronic effects of electromagnetic fields. The NRC staff considers the GEIS finding of 41 "UNCERTAIN" still appropriate and will continue to follow developments on this issue. 42 4.10 Socioeconomics 43 The socioeconomic issues applicable to GGNS are shown in Table 4 -9. Section 2.2.9 of this SEIS 44 describes the socioeconomic conditions near GGNS. 45 Environmental Impacts of Operation 4-19 Table 4-9. Socioeconomics Issues 1 Issues GEIS Section Category Housing impacts 4.7.1 2 Public services: public safety, social services, tourism & recreation 4.7.3, 4.7.3.3, 4.7.3.4, 4.7.3.6 1 Public services: public utilities 4.7.3.5 2 Public services: education (license renewal) 4.7.3.1 1 Offsite land use (license renewal term) 4.7.4 2 Public Services: transportation 4.7.3.2 2 Historic & archaeological resources 4.7.7 2 Aesthetic impacts (license renewal term) 4.7.6 1 Aesthetic impacts of transmission lines (license renewal term) 4.5.8 1 Environmental justice: minority and low -income populations 4.10.1(a) 2 Table source: Table B -1 in Appendix B, Subpart A, to 10 CFR Part 51; (a)NRC 201 3a 4.10.1 Generic Socioeconomic Issues 2 The applicant's ER, scoping comments, and other available data records on GGNS, were 3 reviewed and evaluated for new and significant information. The review included a data 4 gathering site visit to GGNS. No new and significant information was identified during this 5 review that would change the conclusions presented in the GEIS. Therefore, for these 6 Category 1 issues, impacts during the renewal term are not expected to exceed those 7 discussed in the GEIS. For GGNS, the staff incorporates the GEIS conclusions by reference. 8 Impacts for Category 2 issues and the uncategorized issue (environmental justice) are 9 discussed in Sections 4.10.2 through 4. 10.7. In evaluating the potential socioeconomic impacts 10 resulting from license renewal, the NRC uses as its baseline the existing socioeconomic 11 conditions described in Section 2.2.9 of this SEIS. These baseline socioeconomic conditions 12 include existing housing, transportation, offsite land use, demographic, public services, and 13 economic conditions affected by ongoing operations at the nuclear power plant. 14 4.10.2 Housing 15 Appendix C of the GEIS presents a population characterization method based on two factors, 16 sparseness and proximity (GEIS, Section C.1.4). Sparseness measures population density 17 within 20 miles (32 kilometers) of the site, and proximity measures population density and city 18 size within 50 miles (80 kilometers). Each factor has categories of density and size 19 (GEIS, Table C.1). A matrix is used to rank the population category as low, medium, or high 20 (GEIS, Figure C.1). 21 According to the 2010 Census, an estimated 23,406 people lived within 20 mi (32 km) of GGNS, 22 which equates to a population density of 19 persons per mi 2 (Entergy 2011a). This translates to 23 a Category 1, "most sparse" population density using the GEIS measure of sparseness (less 24 than 40 persons per mi 2 and no community with 25,000 or more persons within 20 mi). An 25 estimated 329,043 people live within 50 mi (80 km) of GGNS with a population density of 26 42 persons per mi 2 (Entergy 2011a). This translates to a Category 1 density, using the GEIS 27 measure of proximity (no cities with 100,000 or more persons and less than 50 persons per mi 2 28 Environmental Impacts of Operation 4-20 within 50 mi). Therefore, GGNS is located in a low population area based on the GEIS 1 sparseness and proximity matrix. 2 Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, states that impacts on housing availability 3 may be SMALL, MODERATE, or LARGE. MODERATE or LARGE housing impacts of the 4 workforce associated with refurbishment may be associated with plants located in sparsely 5 populated areas or in areas with growth control measures that limit housing development. 6 Since Entergy has no planned refurbishment activities at GGNS and Claiborne, Hinds, 7 Jefferson, and Warren counties are not subject to growth-control measures that would limit 8 housing development; any changes in employment at GGNS would have little noticeable effect 9 on housing availability in these counties. Since Entergy has no plans to add non -outage 10 employees during the license renewal period, employment levels at GGNS would remain 11 relatively constant with no additional demand for permanent housing during the license renewal 12 term. Based on this information, there would be no impact on housing during the license 13 renewal term beyond what already has been experienced. Therefore, the NRC staff concludes 14 that the impacts would be SMALL. 15 4.10.3 Public Services -Public Utilities 16 Impacts on public utility services (e.g., water, sewer) are considered SMALL if the public utility 17 has the ability to respond to changes in demand and would have no need to add or modify 18 facilities. Impacts are considered MODERATE if service capabilities are overtaxed during 19 periods of peak demand. Impacts are considered LARGE if additional system capacity is 20 needed to meet ongoing demand. 21 Analysis of impacts on the public water systems considered both plant demand and 22 plant-related population growth. Section 2.1.7 describes the permitted withdrawal rate and 23 actual use of water for reactor cooling at GGNS. 24 Since Entergy has no plans to add non -outage employees during the license renewal period, 25 employment levels at GGNS would remain relatively unchanged with no additional demand for 26 public water services. Public water systems in the region are adequate to meet the demands of 27 residential and industrial customers in the area. Therefore, there would be no impact to public 28 water services during the license renewal term beyond what is already being experienced. 29 Therefore, the NRC staff concludes that the impacts would be SMALL. 30 4.10.4 Public Services -Transportation 31 Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 states the following: 32 Transportation impacts (level of service) of highway traffic generated...during the 33 term of the renewed license are generally expected to be of SMALL significance. 34 However, the increase in traffic associated with additional workers and the local 35 road and traffic control conditions may lead to impacts of MODERATE or LARGE 36 significance at some sites. 37 The regulation in 10 CFR 51.53(c)(3)(ii)(J) requires all applicants to assess the impacts of 38 highway traffic generated by the proposed project on the level of service of local highways 39 during the term of the renewed license. Since Entergy has no plans to add non -outage 40 employees during the license renewal period, traffic volume and levels of service on roadways 41 in the vicinity of GGNS would not change. Therefore, there would be no transportation impacts 42 during the license renewal term beyond what is already being experienced. Therefore, the N RC 43 staff concludes that the impacts would be SMALL. 44 Environmental Impacts of Operation 4-21 4.10.5 Offsite Land Use 1 Offsite land use during the license renewal term is a Category 2 issue (10 CFR Part 51, Subpart 2 A, Appendix B, Table B -1). Table B -1 notes that; "significant changes in land use may be 3 associated with population and tax revenue changes resulting from license renewal." Section 4 4.7.4 of the GEIS defines the magnitude of land -use changes as a result of plant operation 5 during the license renewal term as SMALL when there will be little new development and 6 minimal changes to an area's land use pattern, as MODERATE when there will be considerable 7 new development and some changes to the land use pattern, and LARGE when there will be 8 large-scale new development and major changes in the land use pattern. 9 Tax revenue can affect land use because it enables local jurisdictions to provide the public 10 services (e.g., transportation and utilities) necessary to support development. Section 4.7.4.1 of 11 the GEIS states that the assessment of tax -driven land use impacts during the license renewal 12 term should consider the size of the plant's tax payments relative to the community's total 13 revenues, the nature of the community's existing land use pattern, and the extent to which the 14 community already has public services in place to support and guide development. If the plant's 15 tax payments are projected to be small relative to the community's total revenue, tax driven land 16 use changes during the plant's license renewal term would be SMALL, especially where the 17 community has pre -established patterns of development and has provided public services to 18 support and guide development. Section 4.7.2.1 of the GEIS states that if tax payments by the 19 plant owner are less than 10 percent of the taxing jurisdiction's revenue, the significance level 20 would be SMALL. If tax payments are 10 to 20 percent of the community's total revenue, new 21 tax-driven land use changes would be MODERATE. If tax payments are greater than 22 20 percent of the community's total revenue, new tax -driven land use changes would be 23 LARGE. This would be especially true where the community has no pre -established pattern of 24 development or has not provided adequate public services to support and guide development. 25 As discussed in Sections 4.10.2, 4.10.3, and 4.10.4, it is not expected that there would be any 26 change in the staffing levels at GGNS or increased demand for additional housing, public 27 services related to public utilities, and transportation during the license renewal period. 28 Therefore, the NRC staff concludes that the impacts would be SMALL. 29 4.10.5.1 Population -Related Impacts 30 Since Entergy has no plans to add non -outage employees during the license renewal period, 31 there would be no plant operations -driven population increase in the vicinity of GGNS. 32 Therefore, there would be no population -related offsite land use impacts during the license 33 renewal term beyond what has already been experienced. Therefore, the NRC staff concludes 34 that the impacts would be SMALL. 35 4.10.5.2 Tax Revenue -Related Impacts 36 As discussed in Chapter 2, Entergy pays property taxes for GGNS to the State of Mississippi. 37 Part of these taxes are distributed to counties near GGNS. Since Entergy started making 38 property tax payments, local county populations have been in decline and land use conditions 39 have generally remained unchanged. Therefore, tax revenue from GGNS as a proportion of 40 total tax revenue in the ROI has had little or no effect on land use conditions within these 41 counties. Since employment levels would remain relatively unchanged with no increase in the 42 assessed value of GGNS, annual property tax payments also would be expected to remain 43 relatively unchanged throughout the license renewal period. Based on this information, there 44 would be no tax -revenue-related offsite land use impacts during the license renewal term 45 beyond those already being experienced. Therefore, the NRC staff concludes that the impacts 46 would be SMALL. 47 Environmental Impacts of Operation 4-22 4.10.6 Historic and Archaeological Resources 1 The National Historic Preservation Act (NHPA) requires Federal agencies to consider the effects 2 of their undertakings on historic properties. Historic properties are defined as resources eligible 3 for listing on the National Register of Historic Places (NRHP). The criteria for eligibility are listed 4 in 36 CFR 60.4 and include association with significant events in history; association with the 5 lives of persons significant in the past; embodiment of distinctive characteristics of type, period, 6 or construction; and sites or places that have yielded or are likely to yield important information. 7 The historic preservation review process (Section 106 of the National Historic Preservation Act 8 of 1966, as amended [NHPA]) is outlined in regulations issued by the Advisory Council on 9 Historic Preservation (ACHP) in 36 CFR Part 800. In accordance with 36 CFR 800.8(c), the 10 NRC has elected to use the NEPA process to comply with the obligations found under 11 Section 106 of the NHPA. 12 In accordance with 36 CFR 800.8(c), the NRC initiated Section 106 consultation with the ACHP 13 and the Mississippi and Louisiana State Historic Preservation Office s (SHPOs) in January 2012, 14 by notifying them of the agency's intent to review a request from Entergy to renew the GGNS 15 operating license (NRC 2012 f, 2012 g, 2012h). On February 28, 2012, the Mississippi SHPO 16 responded to the NRC's letter stating its opinion that the proposed license renewal will have no 17 adverse effect on historic properties (MDAH 2012 a). No comments were received from the 18 ACHP or the Louisiana SHPO as a result of these consultation letters. 19 The NRC also initiated consultation on the proposed GGNS license renewal with four Federally 20 recognized tribes: the Jena Band of Choctaw Indians, the Mississippi Band of Choctaw Indians , 21 the Choctaw Nation of Oklahoma, and the Tunica -Biloxi Tribe of Louisi ana (NRC 2012 i). In 22 letters to the tribes, the NRC supplied information about the proposed action (license renewal) 23 and the definition of the area of potential effect, and stated that the NHPA review would be 24 integrated with the NEPA process, according to 35 CFR 800.8. The NRC invited the Tribes to 25 participate in the identification of potentially affected historic properties near GGNS and the 26 scoping process. The Choctaw Nation of Oklahoma, Jena Band of Choctaw Indians, and the 27 Mississippi Band of Choctaw Indians responded. The Tribes did not raise any concerns through 28 scoping comments and requested updates throughout the review process (see Appendix D). 29 The staff reviewed information on historic and archaeological resources provided in the 30 applicant's ER. It also conducted a review at the Mississippi Department of Archives and 31 History (MDAH) and identified 17 previously recorded archaeological resources on GGNS 32 property; surveys conducted in 1972 and 2006 of the archaeological, architectural, and historic 33 resources on and around GGNS property; and multiple surveys that intersected the 34 transmission lines (MDAH 2012 b). One site identified in these surveys, 22Cb528, is located on 35 GGNS property and is considered potentially eligible for listing in the NRHP. Site 22Cb528 is 36 an Archaic Period village consisting of ceramics and lithics at various stages of production, and 37 it has been determined that the site should be avoided or tested further to determine eligibility 38 (Entergy 2011 a; MDAH 2012 b). Along the transmission lines, seven sites were identified as 39 being within or very near to the transmission line rights -of-way; one is listed in the NRHP; four 40 others would require further evaluation to determine eligibility status and are considered 41 potentially eligible until a determination is made; and the remaining two are ineligible. 42 Background research also identified nine NRHP -listed resources within a 10 -mi (16km) radius of 43 the facility; however, none are located within the boundaries of the GGNS property. 44 As noted in Section 2.2.10.1, the area near where the Grand Gulf Mound was located has high 45 potential for subsurface archaeological deposits. Additionally, areas on the property could have 46 historic resources related to the Grand Gulf town site or the Civil War battles that took place on 47 and near the GGNS property. Because the GGNS property has been surveyed for historic and 48 Environmental Impacts of Operation 4-23 archaeological resources, it is likely that the undiscovered resources would be subsurface 1 deposits. 2 Entergy currently has no planned changes or ground -disturbing activities associated with 3 license renewal at GGNS. However, given the high potential for the discovery of additional 4 historic and archaeological resources at GGNS, Entergy has formal guidelines in its 5 Environmental Reviews and Evaluations Nuclear Management Manual (EN-EV-115) for 6 protecting archaeological resources. The procedure advises Entergy staff on consulting with 7 the appropriate SHPO, and the NRC, as applicable, before ground -disturbing activities take 8 place at GGNS. An additional procedure (EN -EV-121) requires work to be stopped if evidence 9 of a historical or archaeological artifact is found during ground disturbance. The vegetation 10 management plan for transmission lines, however, does not specifically mention vegetation 11 maintenance near cultural resources (AM-ERS-FAC-001). Entergy could minimize any possible 12 effects to cultural resources found within transmission line corridors by adding procedures for 13 maintenance near cultural resources. GGNS also is governed by Mississippi State burial law, 14 which requires a work stoppage if human remains are unexpectedly uncovered. 15 Based on the review of Mississippi SHPO files for the region, published literature, and 16 information Entergy and consulting parties provided, the staff concludes that the potential 17 impact from license renewal of GGNS on historic or archaeological resources is SMALL, and 18 there would be no adverse effect on historic properties as specified in 36 CFR 800.4(d)(1). 19 Entergy could further reduce any potential effect to historic and archaeological resources at the 20 GGNS site by referencing its formal guidelines for protecting historic and archaeological 21 resources in its vegetation management plan. 22 4.10.7 Environmental Justice 23 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 24 protection regulation, 10 CFR Part 51. With respect to environmental justice concerns, the 25 revision amends Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new 26 Category 2 issue, "Minority and low-income populations," to evaluate the impacts of continued 27 operations and any refurbishment activities during the license renewal term on minority 28 populations and low-income populations living in the vicinity of the plant. Environmental justice 29 was listed in Table B-1 as a concern but was not evaluated in the 1996 GEIS and therefore, is 30 addressed in each SEIS. 31 Under Executive Order (EO) 12898 (59 FR 7629, February 16, 1994 ), Federal agencies are 32 responsible for identifying and addressing, as appropriate, disproportionately high and adverse 33 human health and environmental impacts on minority and low -income populations. In 2004, the 34 Commission issued a Policy Statement on the Treatment of Environmental Justice Matters in 35 NRC Regulatory and Licensing Actions (69 FR 52040, August 24, 2004 ), which states, "The 36 Commission is committed to the general goals set forth in EO 12898, and strives to meet those 37 goals as part of its NEPA review process." 38 The Council of Environmental Quality (CEQ) provides the following information in Environmental 39 Justice: Guidance Under the National Environmental Policy Act (CEQ 1997): 40 Disproportionately High and Adverse Human Health Effects. Adverse health 41 effects are measured in risks and rates that could result in latent cancer fatalities, 42 as well as other fatal or nonfatal adverse impacts on human health. Adverse 43 health effects may include bodily impairment, infirmity, illness, or death. 44 Disproportionately high and adverse human health effects occur when the risk or 45 rate of exposure to an environmental hazard for a minority or low -income 46 population is significant (as employed by NEPA) and appreciably exceeds the 47 Environmental Impacts of Operation 4-24 risk or exposure rate for the general population or for another appropriate 1 comparison group. 2 Disproportionately High and Adverse Environmental Effects. A 3 disproportionately high environmental impact that is significant (as defined by 4 NEPA) refers to an impact or risk of an impact on the natural or physical 5 environment in a low -income or minority community that appreciably exceeds the 6 environmental impact on the larger community. Such effects may include 7 ecological, cultural, human health, economic, or social impacts. An adverse 8 environmental impact is an impact that is determined to be both harmful and 9 significant (as employed by NEPA). In assessing cultural and aesthetic 10 environmental impacts, impacts that uniquely affect geographically dislocated or 11 dispersed minority or low -income populations or American Indian tribes are 12 considered. 13 The environmental justice analysis assesses the potential for disproportionately high and 14 adverse human health or environmental effects on minority populations and low -income 15 populations that could result from the operation of GGNS during the renewal term. In assessing 16 the impacts, the following definitions of minority individuals and populations and low -income 17 population were used (CEQ 1997): 18 Minority individuals. Individuals who identify themselves as members of the 19 following population groups: Hispanic or Latino, American Indian or Alaska Native, 20 Asian, Black or African American, Native Hawaiian or Other Pacific Islander, or two or 21 more races, meaning individuals who identified themselves on a Census form as 22 being a member of two or more races (e.g., Hispanic and Asian). 23 Minority populations. Minority populations are identified when (1) the minority 24 population of an affected area exceeds 50 percent or (2) the minority population 25 percentage of the affected area is meaningfully greater than the minority population 26 percentage in the general population or other appropriate unit of geographic analysis. 27 Low-income population. Low-income populations in an affected area are identified 28 with the annual statistical poverty thresholds from the Census Bureau's Current 29 Population Reports, Series P60, on Income and Poverty. 30 4.10.7.1 Minority Population 31 According to 2010 Census data, 53.2 percent of the population residing within a 50 -mi (80-km) 32 radius of GGNS identified themselves as minority individuals. The largest minority group was 33 Black or African American (51.3 percent), followed by Hispanic or Latino (of any race) 34 (2.0 percent) (CAPS 2012). 35 According to 2010 Census data, minority populations in the socioeconomic region of influence 36 (ROI) (Claiborne, Hinds, Jefferson, and Warren Counties) comprised 69.4 percent of the total 37 four-county population (see Table 2-12). Figure 4-1 shows minority population block groups, 38 using 2010 Census data for race and ethnicity, within a 50 -mi (80-km) radius of GGNS. 39 Census block groups were considered minority population block groups if the percentage of the 40 minority population within any block group exceeded 53.2 percent (the percent of the minority 41 population within the 50 -mi [80-km] radius of GGNS). A minority population exists if the 42 percentage of the minority population within the block group is meaningfully greater than the 43 minority population percentage in the 50 -mi (80-km) radius. Approximately 144 of the 294 44 census block groups located within the 50 -mi (80-km) radius of GGNS were determined to have 45 meaningfully greater minority populations. 46 Environmental Impacts of Operation 4-25 Minority population block groups are concentrated on the east side of the Mississippi River and 1 include the c ensus block group containing GGNS. According to the 2010 Census, 2 approximately 85.4 percent of the Port Gibson population identified themselves as minority. 3 4.10.7.2 Low-Income Population 4 According to 2010 American Community Survey Census data, an average of 16.3 percent of 5 families and 21.1 percent of individuals residing in the 24 counties within a 50 -mi (80-km) radius 6 of GGNS were identified as living below the Federal poverty threshold in 2010. The 7 2010 Federal poverty threshold was $22,314 for a family of four (USCB 2012). 8 According to the 2010 Census, 16.7 percent of families and 21.2 percent of individuals in 9 Mississippi were living below the Federal poverty threshold in 2010, and the median household 10 income for Mississippi was $37,881 (USCB 2012). Claiborne and Jefferson Counties had lower 11 median household incomes and higher percentages of families and individuals living in poverty 12 compared to State averages. Hinds and Warren Counties had higher median incomes when 13 compared to the State average. Claiborne County had a median household income average of 14 $24,150 and 35.0 percent of individuals and 27.6 percent of families living below the poverty 15 level. Hinds County had a median household income average of $39,215 and 22.5 percent of 16 individuals and 17.7 percent of families living below the poverty level. Jefferson County had a 17 median household income of $24,304 and 39.0 percent of individuals and 29.3 percent of 18 families living below the poverty level. Warren County had a median household income 19 average of $40,404 and 21.4 percent of individuals and 16.5 percent of families living below the 20 poverty level (USCB 2012). 21 Figure 4-2 shows low-income census block groups within a 50 -mi (80-km) radius of GGNS. 22 Census block groups were considered low -income population block groups if the percentage of 23 individuals living below the Federal poverty threshold within any block group exceeded the 24 percent of the individuals living below the Federal poverty threshold within the 50 -mi (80-km) 25 radius of GGNS. Approximately 120 of the 294 census block groups located within the 50 -mi 26 (80-km) radius of GGNS were determined to have meaningfully greater low -income populations. 27 Environmental Impacts of Operation 4-26 Figure 4-1. 2010 Census Minority Block Groups Within a 50 -mi Radius of GGNS 1 Source: USCB 2012 2 Environmental Impacts of Operation 4-27 Figure 4-2. 2010 Census Low -Income Block Groups Within a 50 -mi Radius of GGNS 1 Source: USCB 2012 2 Environmental Impacts of Operation 4-28 Low-income block groups are distributed across the 50 -mi (80-km) radius area around GGNS , 1 with no particular concentrations. The nearest low -income population to GGNS is located in 2 Port Gibson, Mississippi, and several other low -income block groups are in close proximity to 3 GGNS. 4 4.10.7.3 Analysis of Impacts 5 The NRC addresses environmental justice matters for license renewal through (1) identifying 6 the location of minority and low -income populations that the continued operation of the nuclear 7 power plant may affect during the license renewal term, and (2) determining whether there 8 would be any potential human health or environmental effects to these populations and special 9 pathway receptors, and (3) determining if any of the effects may be disproportionately high and 10 adverse. 11 Figures 4-1 and 4-2 identify the location of minority and low -income block group populations 12 residing within a 50 -mi (80-km) radius of GGNS. This area of impact is consistent with the 13 impact analysis for public and occupational health and safety, which also focuses on 14 populations within a 50 -mi (80-km) radius of the plant. Chapter 4 presents the assessment of 15 environmental and human health impacts for each resource area. The analyses of impacts for 16 all environmental resource areas indicated that the impact from license renewal would b e 17 SMALL. 18 Potential impacts to minority and low -income populations (including migrant workers or Native 19 Americans) mostly would consist of socioeconomic and radiological effects; however, radiation 20 doses from continued operations during the license renewal term are expected to continue at 21 current levels and would remain within regulatory limits. Chapter 5 of this SEIS discusses the 22 environmental impacts from postulated accidents that might occur during the license renewal 23 term, which include both design -basis and severe accidents. In both cases, the staff has 24 generically determined that impacts associated with design -basis accidents are SMALL 25 because nuclear plants are designed and operated to successfully withstand such accidents, 26 and the probability weighted impact risks associated with severe accidents also were SMALL. 27 Therefore, based on this information and the analysis of human health and environmental 28 impacts presented in Chapters 4 and 5 of this SEIS, there would be no disproportionately high 29 and adverse impacts to minority and low -income populations from the continued operation of 30 GGNS during the license renewal ter

m. 31 4.10.7.4 Subsistence Consumption of Fish and Wildlife 32 As part of addressing environmental justice concerns associated with license renewal, the staff 33 also assessed the potential radiological risk to special population groups (such as migrant 34 workers or Native Americans) from exposure to radioactive material received through their 35 unique consumption and interaction with the environment. These include subsistence 36 consumption of fish, native vegetation, surface waters, sediments, and local produce; 37 absorption of contaminants in sediments through the skin; and inhalation of airborne radioactive 38 material released from the plant during routine operation. This analysis is presented below.

39 The special pathway receptors analysis is an important part of the environmental justice 40 analysis because consumption patterns may reflect the traditional or cultural practices of 41 minority and low-income populations in the area, such as migrant workers or Native Americans. 42 Section 4-4 of Executive Order 12898 (1994) directs Federal agencies, whenever practical and 43 appropriate, to collect and analyze information on the consumption patterns of populations that 44 rely principally on fish and/or wildlife for subsistence and to communicate the risks of these 45 consumption patterns to the public. In this SEIS, the NRC considered whether there were any 46 Environmental Impacts of Operation 4-29 means for minority or low -income populations to be disproportionately affected by examining 1 impacts to African American, American Indian, Hispanics, migrant workers, and other traditional 2 lifestyle special pathway receptors. The assessment of special pathways took into account the 3 levels of radiological and nonradiological contaminants in native vegetation, crops, soils and 4 sediments, groundwater, surface water, fish, and game animals on or near GGNS. 5 The following is a summary discussion of the staff's evaluation from Section 4.9.2 of the 6 radiological environmental monitoring programs that assess the potential impacts for 7 subsistence consumption of fish and wildlife near the GGNS site. 8 Entergy has an ongoing comprehensive REMP to assess the impact of GGNS operations on the 9 environment. To assess the impact of nuclear power plant operations, samples are collected 10 annually from the environment and analyzed for radioactivity. A plant effect would be indicated 11 if the radioactive material detected in a sample was significantly larger than background levels. 12 Two types of samples are collected. The first type, control samples, are collected from areas 13 beyond the measurable influence of the nuclear power plant or any other nuclear facility. These 14 samples are used as reference data to determine normal background levels of radiation in the 15 environment. These samples are then compared with the second type of samples, indicator 16 samples, collected near the nuclear power plant. Indicator samples are collected from areas 17 where any contribution from the nuclear power plant will be at its highest concentration. These 18 samples are then used to evaluate the contribution of nuclear power plant operations to 19 radiation or radioactivity levels in the environment. An effect would be indicated if the 20 radioactivity levels detected in an indicator sample were significantly larger than the control 21 sample or background levels. 22 Samples of environmental media are collected from the aquatic and terrestrial pathways in the 23 vicinity of GGNS. The aquatic pathways include groundwater, surface water, drinking water, 24 fish, and shoreline sediment. The terrestrial pathways include airborne particulates and food 25 products (i.e., broad leaf vegetation). During 2011, analyses performed on samples of 26 environmental media at GGNS showed no significant or measurable radiological impact above 27 background levels from site operations (Entergy 2012 a). 28 Based on the radiological environmental monitoring data from GGNS, the staff finds that no 29 disproportionately high and adverse human health impacts would be expected in special 30 pathway receptor populations in the region as a result of subsistence consumption of water, 31 local food, fish, and wildlife. 32 4.11 Evaluation of New and Potentially Significant Information 33 The staff has not identified new and significant information on environmental issues related to 34 operation during the renewal term. The staff also determined that information provided during 35 the public comment period did not identify any new issue that requires site -specific assessment. 36 The staff reviewed the discussion of environmental impacts associated with operation during the 37 renewal term in the GElS and has conducted its own independent review, including a public 38 involvement process (e.g., public meetings) to identify issues with new and significant 39 information. 40 New and significant information is information that identifies a significant environmental issue 41 not covered in the GEIS and codified in Table B -1 of 10 CFR Part 51, Subpart A, Appendix B, 42 or information that was not considered in the analyses summarized in the GEIS and that leads 43 to an impact finding that is different from the finding presented in the GEIS and codified in 44 10 CFR Part 51. 45 Environmental Impacts of Operation 4-30 In accordance with 10 CFR 51.53(c), the ER that the applicant submit s must provide an analysis 1 of the Category 2 issues in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B. Additionally, 2 it must discuss actions to mitigate any adverse impacts associated with the proposed action and 3 environmental impacts of alternatives to the proposed action. In accordance with 4 10 CFR 51.53(c)(3), the ER does not need to contain an analysis of any Category 1 issue 5 unless there is new and significant information on a specific issue. 6 The NRC also has a process for identifying new and significant information. That process is 7 described in NUREG -1555, Supplement 1, Standard Review Plans for Environmental Reviews 8 for Nuclear Power Plants, Supplement 1: Operating License Renewal (NRC 1999b, 2013b). 9 The search for new information includes: 10 review of an applicant's ER and the process for discovering and evaluating 11 the significance of new information, 12 review of public comments, 13 review of environmental quality standards and regulations, 14 coordination with Federal, State, and local environmental protection and 15 resource agencies, and 16 review of the technical literature. 17 New information that the staff discovered is evaluated for significance using the criteria set forth 18 in the GEIS. For Category 1 issues in which new and significant information is identified, 19 reconsideration of the conclusions for those issues is limited in scope to assessment of the 20 relevant new and significant information; the scope of the assessment does not include other 21 facets of an issue that the new information does not affect. 22 4.12 Cumulative Impacts 23 As described in Section 1.4 of this SEIS, the NRC has approved a revision to its environmental 24 protection regulation, 10 CFR Part 51. With respect to cumulative impacts , t he revision amends 25 Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 by adding a new Category 2 issue, 26 "Cumulative impacts," to evaluate the potential cumulative impacts of license renewal. 27 The staff considered potential cumulative impacts in the environmental analysis of continued 28 operation of GGNS during the renewed license term. Cumulative impacts may result when the 29 environmental effects associated with the proposed action are overlaid or added to temporary or 30 permanent effects associated with other past, present, and reasonably foreseeable actions. 31 Cumulative impacts can result from individually minor, but collectively significant, actions taking 32 place over a period of time. It is possible that an impact that may be SMALL by itself could 33 result in a MODERATE or LARGE cumulative impact when considered in combination with the 34 impacts of other actions on the affected resource. Likewise, if a resource is regionally declining 35 or imperiled, even a SMALL individual impact could be important if it contributes to or 36 accelerates the overall resource decline. 37 For the purposes of this cumulative analysis, past actions are those before the receipt of the 38 license renewal application. Present actions are those related to the resources at the time of 39 current operation of the power plant, and future actions are those that are reasonably 40 foreseeable through the end of plant operation including the period of extended operation. 41 Therefore, the analysis consider s potential impacts through the end of the current license terms 42 as well as the 20 -year license renewal term. The geographic area over which past, present, 43 Environmental Impacts of Operation 4-31 and reasonably foreseeable actions would occur is dependent on the type of action considered 1 and is described below for each resource area. 2 To evaluate cumulative impacts, the incremental impacts of the proposed action, as described 3 in Section s 4.1-4.10, are combined with other past, present, and reasonably foreseeable future 4 actions regardless of what agency (Federal or non -Federal) or person undertakes such actions. 5 The staff used the information provided in the ER, responses to requests for additional 6 information; information from other Federal, State, and local agencies; scoping comments, and 7 information gathered during the audit at the GGNS site to identify other past, present, and 8 reasonably foreseeable actions. 9 To be considered in the cumulative analysis, the staff determined if the project would occur 10 within the noted geographic areas of interest and within the period of extended operation, if it 11 was reasonably foreseeable, and if there would be potential overlapping effect with the 12 proposed project. For past actions, consideration within the cumulative impacts assessment i s 13 resource and project specific. In general, the effects of past actions are included in the 14 description of the affected environment in Chapter 2, which serves as the baseline for the 15 cumulative impacts analysis. However, past actions that continue to have an overlapping effect 16 on a resource potentially affected by the proposed action are considered in the cumulative 17 analysis. Other actions and projects that were noted during this review and considered in the 18 cumulative impact analysis are described below: 19 modification and management of the Mississippi River basin 20 construction of fossil -fuel power plant(s) to meet regional electricity demands 21 climate change 22 increased agricultural activities 23 maintenance of transmission line crossings through the Homochitto National Forest 24 continued operation of independent spent fuel storage installation (ISFSI) at GGNS 25 Additionally, NRC prepared an FEIS in 2006 in response to an application for an early site 26 permit (ESP) for the construction and operation of a new nuclear power plant at GGNS 27 (NRC 2006). On April 5, 2007, the NRC issued an ESP for the GGNS site. In 2008, Entergy 28 submitted an application for a combined license for a new boiling -water reactor at GGNS , 29 designated as Unit 3. However, in January 2009, Entergy informed the NRC that it was 30 considering alternate reactor design technologies and requested the NRC suspend its review 31 effort until further notice. Accordingly, the construction of Unit 3 at GGNS is considered a 32 reasonably foreseeable future action and is included in the cumulative impacts assessment 33 (NRC 2006). 34 4.12.1 Air Quality 35 This section addresses the direct and indirect effects of license renewal on air quality when 36 added to the aggregate effects of other past, present, and reasonably foreseeable future 37 actions. In evaluating the potential impacts on air quality associated with license renewal, the 38 NRC staff uses as its baseline the existing air quality conditions described in Section 2.2.2 .1 of 39 this SEIS. These baseline conditions encompass the existing air quality conditions (EPA's 40 National Ambient Air Quality Standard (NAAQS) county designations) potentially affected by air 41 emissions from continued operations. As described in Section 2.2.2.1, the Mobile (Alabama) -42 Pensacola-Panama City (Florida) -Southern Mississippi Interstate Air Quality Control Region 43 (AQCR) (40 CFR 81.68), which encompasses GGNS, is designated as an attainment area for 44 all criteria pollutants except for part of De Soto County, Mississippi, which is designated as a 45 marginal nonattainment area for the 2008 8 -hour ozone standard and is located about 200 miles 46 (322 km) north-northeast of GGNS. Other nearby nonattainment areas include the Birmingham 47 Environmental Impacts of Operation 4-32 area in Alabama for PM2.5 and the Houston -Galveston-Brazoria area in Texas for 8 -hour ozone , 1 located about 240 mi (386 km) east-northeast and west -southwest of GGNS, respectively. T he 2 nearest maintenance area for 8 -hour ozone is located about 90 mi (145 km) south of GGNS. 3 Currently, GGNS is operating under a "synthetic minor" permit, which covers site-wide 4 combustion emission sources, such as diesel generators, fire water pump engines, and cooling 5 towers (GGNS 2008 a). GGNS operations are in compliance with its air permit and Entergy has 6 no plans for refurbishments or other license renewal -related construction activities that would 7 affect permitted operations for the license renewal term (Entergy 2011 a). Annual emissions of 8 criteria pollutants, volatile organic compounds (VOCs), and hazardous air pollutants (HAPs) at 9 GGNS vary from year to year but are well below the plant's permitted "synthetic minor" 10 emissions limits (see Table 2-1), based on actual operating hours reported to MDEQ. 11 Considering the distances to the nearest nonattainment and maintenance areas around GGNS, 12 prevailing wind directions, and the minor nature of air emissions from GGNS, emissions from 13 GGNS operations are not anticipated to affect current attainment or maintenance area status. 14 Accordingly, air emissions from continued operation of the plant and associated effects on 15 ambient air quality would not be expected to change during the license renewal term. 16 As discussed in Section 2.2.2.1, operations at GGNS release greenhouse gas (GHG) emissions 17 as follows: carbon dioxide (CO 2), methane (CH 4), and nitrous oxide (N 2O) from fuel combustion; 18 hydrofluorocarbons (HFCs) in the two plant cooling water chillers; and sulfur hexafluoride (SF

6) 19 in three electric disconnect switches. Perfluorocarbons (PFCs) currently are not used at GGNS.

20 Combustion-related GHG emissions (such as CO 2, CH 4, and N 2O) at GGNS are minor. The 21 permitted combustion sources are designed for efficiency and operated intermittent ly throughout 22 the year (i.e., often only for testing and preventive maintenance). Other combustion-related 23 GHG emission sources at GGNS include commuter, visitor, support, and delivery vehicle traffic 24 within, to, and from the plant. In addition, small amounts of HFCs and SF 6 are released into the 25 atmosphere during normal operations or at various stages of the equipment's life cycle. Total 26 annual GHG emissions from the GGNS site were estimated to be about 5,980 tons CO2e 27 (5,425metric tons CO2e) in 2011 (GGNS 2012a; EPA 2011b), which is well below the EPA's 28 mandatory reporting threshold of 25,000 metric tons CO 2e per year (74 FR 56264). 29 To estimate the amount of GHG releases potentially avoided by continued GGNS operation, its 30 electricity generation can be compared to an equivalent amount of electricity generation in 31 fossil-fuel power plant(s). For 2009, the composite CO2e emission factor (representing an 32 average of all operating fossil -fuel power plants) is approximately 1,107 lb/MWh for the 33 Mississippi Valley subregion (EPA 2012a). GGNS generates approximately 11,500 GWh per 34 year, at 1,475 MWe and a capacity factor of 89 percent based on a 2007 -2009 average 35 (Entergy 2011 a). Thus, GGNS 's generating capacity avoids the release of approximatel y 36 6.4 million tons (5.8 million metric tons) of CO2e. This is approximately 2

3.5 percent

of the 37 27.0 million tons (24.5 million metric tons) CO2e emitted by fossil fuel electricity generation in 38 Mississippi in 2009 (EPA 2012a). This also equals about 0.08 percent of total U.S. GHG 39 emissions of 7 ,520 million tons (6 , 822 million metric tons) CO2e, in 2010 (EPA 2012b). 40 The Intergovernmental Panel on Climate Change (IPCC 2011) also estimated GHG emission 41 factors during the life cycle of nuclear power plants along with other renewable and conventional 42 power generation technologies. Estimated median GHG emission factors of 16 g CO2e/kWh for 43 nuclear energy are comparable to those for renewable energy (ranging from 4 g CO2e/kWh for 44 hydropower to 46 g CO2e/kWh for photovoltaic solar energy) but far lower than those for fossil 45 fuel energy (ranging from 469 g CO 2e/kWh for natural gas to 1 , 001 g CO 2e/kWh for coal). 46 Entergy did not report any foreseeable projects that could contribute to cumulative impacts to air 47 quality (Entergy 2011 a). If a project with the potential to affect air quality did occur, permitting 48 Environmental Impacts of Operation 4-33 and licensing requirements would limit its impact. The review of the GGNS Unit 3 combined 1 license (COL) application is currently on hold. However, if the facility were to be built in the 2 future, impacts on air quality that may result from construction will be temporary. The impacts of 3 construction on air quality would be from ground -clearing, grading and excavation activities that 4 raise dust, emissions from construction equipment, and emissions resulting from construction 5 workforce transportation. The impacts of operation on air quality would be from releases to the 6 environment of heat and moisture from the cooling towers, emissions from operation of auxiliary 7 equipment, and emissions from the workforce. The operation of Unit 3 would have air 8 emissions similar to those of the existing GGNS plant. NRC (2006) concluded that the impacts 9 of construction and operation of a proposed unit would be SMALL. 10 As discussed in Section 2.2.2, patterns of ambient temperature and precipitation at Jackson 11 International Airport generally are increasing slowly based on data from 1960 to 2011 12 (NCDC 1990, 2012). Recent research on climate change effects in the United States done by 13 the U.S. Global Change Research Program (USGCRP), a Federal Advisory Committee 14 (USGCRP 2009), was considered in preparation of this document. In the near term (2010 -2029 15 projected average change), which includes the first 5 years of the period of extended operation, 16 the temperatures around GGNS are projected to rise an additional 2-3 °F (1.1-1.7 °C), 17 compared to the recent past (1961 -1979). In 2040 -2059, which includes the last 5 years of the 18 period of extended operation, the temperatures around GGNS are projected to rise an additional 19 3-4 °F (1.7-2.2 °C) compared to the recent past. Over the past 50 years, average precipitation 20 around GGNS has increased about 5 -10 percent. Future changes in total precipitation are 21 more difficult to project than those in temperatures, but models generally predict that in the 22 Southeast region of the United States, encompassing GGNS, precipitation rates will decrease in 23 winter, spring, and summer relative to current precipitation rates (USGCRP 2009). During the 24 past 50 years, more severe weather, such as tornadoes and severe thunderstorms, ha s been 25 reported. This increase is widely believed to be due to improvements in monitoring 26 technologies such as Doppler radars combined with changes in population and increasi ng 27 public awareness. Considering these factors, there is no clear trend in the frequency or 28 strength of tornadoes since the 1950s in the United States as a whole. The power and 29 frequency of Atlantic hurricanes has increased in recent decades, and the intensity of these 30 storms is likely to increase in this century. However, an increase in the frequency of hurricanes 31 making landfall has not been observed in recent decades; therefore, there may not necessarily 32 be an increase in the number of these storms that make landfall in the future (USGCRP 2009). 33 Changes in hurricanes are difficult to project because many countervailing forces are involved. 34 Given that there is no planned site refurbishment associated with the GGNS license renewal 35 and, therefore, no additional air emissions beyond those noted in Section 2.2.2.1 from continued 36 operations of GGNS, the incremental impacts to cumulative air quality impacts near GGNS 37 would be SMALL. Although not identified, other reasonably foreseeable projects could result in 38 cumulative impacts to air quality. However, permitting and licensing requirements and various 39 mitigation measures likely would limit air quality impacts such that air quality continues to meet 40 applicable air quality standards. 41 Based on the above discussion, the staff concludes that combined with the emissions from 42 other past, present, and reasonably foreseeable future actions, cumulative impacts on ambient 43 air quality and global climate change from operations at GGNS would be SMALL. 44 4.12.2 Water Resources 45 This section addresses the direct and indirect effects of license renewal on water resources 46 when added to the aggregate effects of other past, present, and reasonably foreseeable future 47 actions. The geographic area considered in the cumulative aquatic resources analysis includes 48 Environmental Impacts of Operation 4-34 the vicinity of GGNS, including the Mississippi River basin near GGNS. As described in 1 Sections 4.4 and 4.5, the incremental impacts on water resources from continued operation of 2 GGNS during the license renewal term would be SMALL. 3 4.12.2.1 Cumulative Impacts on Surface Water Resources 4 The review of the GGNS Unit 3 COL application is currently on hold. However, this facility, if 5 built in the future, has the potential to influence surface water use and availability within the 6 geographic area. NRC (2006) determined that the normal makeup flow rate of the new nuclear 7 facility would be approximately 3,175 L/s (50,320 gpm), and the maximum expected makeup 8 flow would be 5,400 L/s (85,000 gpm). In addition, approximately 25 percent of this water would 9 be returned to the Mississippi River as blowdown. NRC (2006) concluded that a new nuclear 10 unit would withdraw only a small amount of water relative to the total river flow (about 0.2 11 percent) at even the lowest minimum river discharge conditions recorded for the area . Climate 12 patterns and increased water demands upstream of GGNS , also may increase the number of 13 water users and rate of withdrawal from the Mississippi River (Caffey et al. 2002). Continued 14 regulation of the flow by the U.S. Army Corps of Engineers is expected to preserve the course 15 and flow of the Mississippi River. Building and operating a new nuclear unit and other activities 16 beyond GGNS would not be expected to noticeably alter water resources within the Mississippi 17 River because the Mississippi River is an abundant source of surface water. 18 Similar to surface water use and availability, the proposed new nuclear unit at GGNS has 19 potential to influence surface water quality within the geographic area considered because the 20 proposed new unit would discharge into the Mississippi River. However, the flow of water in the 21 Mississippi River is so large that a new reactor is unlikely to change the river's basic water 22 quality. As discussed in Section 4.12 .3.2, historically the Mississippi River has experienced 23 decreased water quality from other land-use activities such as agriculture, industrial 24 development, and urban sprawl. However, with the implementation of the Clean Water Act, the 25 water quality of the past few decades has progressively improved. In addition, the proposed 26 new units and other water discharges in the area would obtain and comply with its NPDES 27 permit, which would define the limits of certain chemical and thermal properties of the 28 discharge. 29 Therefore, the staff concludes that the cumulative impact on the site's surface water use and 30 quality are SMALL. 31 4.12.2.2 Cumulative Impacts on Groundwater Resources 32 Activities that could potentially impact groundwater use in the area of interest include public 33 water supply companies, the construction and operating of the proposed new nuclear reactor , 34 and continued operations of GGNS. Most groundwater users outside of the GGNS site obtain 35 their water from public water supply companies that get their water from deep aquifers 36 (Catahoula Aquifer and deeper aquifer). The public water supply companies distribute the water 37 to customers via buried pipes and this operation is expected to continue for the reasonably 38 foreseeable future. The existing unit and the new nuclear unit proposed in the COL application 39 (review currently on hold) at GGNS have the potential to influence groundwater use within the 40 geographic area considered . However, it is expected the future reactor would not consume 41 groundwater from the deep underlying aquifers (GGNS 2008a) used by the public water supply 42 companies, similar to the existing unit at GGNS. Instead, makeup water and potable water for 43 the new reactor would be drawn from groundwater near surface aquifers that either have a 44 direct or indirect hydraulic connection to the Mississippi River. These aquifers near GGNS are 45 not connected to the deep aquifers. In addition, abundant water supplies exist from the deeper 46 aquifer accessed by the water supply companies to supply the needs of other future land -use 47 activities in the area. 48 Environmental Impacts of Operation 4-35 Activities that could potentially impact groundwater quality in the area of interest include the 1 construction and operation of the proposed new nuclear reactor, continued operations of GGNS, 2 and other land use actions that could result in contaminants reaching groundwater. However, 3 the groundwater quality of aquifers used as a source of public water is not likely to be noticeably 4 altered by present and future activities at GGNS or in the region. This is due to the large 5 thickness of low permeability geologic deposits that overly (i.e. protect) these aquifers from 6 surface contaminants. In addition, as discussed in Section 2.2.5, the EPA has identified the 7 Catahoula Aquifer as a sole source aquifer and will work to protect the deep groundwater 8 resources from contamination from projects that receive federal financial assistance. As such, 9 the MDEQ's Wellhead Protection Program will manage potential present and future sources of 10 contamination that are located near public water supply wells that obtain water from the 11 Catahoula Aquifer. No activities have been identified at or near GGNS that could impact the 12 quality of the Catahoula and deeper aquifers. These regulatory programs are expected to 13 continue to protect groundwater quality from future land -use activities. 14 Therefore, the staff concludes that the cumulative impact on the site's ground water use and 15 quality are SMALL. 16 4.12.3 Aquatic Resources 17 This section addresses the direct and indirect effects of license renewal on aquatic resources , 18 including protected aquatic species, when added to the aggregate effects of other past, present, 19 and reasonably foreseeable future actions. The cumulative impact is the total effect on the 20 aquatic resources of all actions taken, no matter who has taken the actions. The geographic 21 area considered in the cumulative aquatic resources analysis includes the vicinity of GGNS, 22 including the Mississippi River basin near GGNS and on site aquatic features such as Hamilton 23 and Gin Lakes, the borrow pit, three small ponds, streams "A" and "B," and ephemeral 24 drainages. Consistent with other agencies use of the term "baseline" and CEQ's NEPA 25 guidance, the term "baseline" pertains to the condition of the resource without the action, i.e., 26 under the no -action alternative. Under the no action alternative, the plant would shut down and 27 the resource would conceptually return to its condition without the plant (which is not necessarily 28 the same as the condition before the plant was constructed). The baseline, or benchmark, for 29 assessing cumulative impacts on aquatic resources takes into account the pre -operational 30 environment as recommended by the EPA (1999) for its review of NEPA documents: 31 Designating existing environmental conditions as a benchmark may focus the 32 environmental impact assessment too narrowly, overlooking cumulative impacts 33 of past and present actions or limiting assessment to the proposed action and 34 future actions. For example, if the current environmental condition were to serve 35 as the condition for assessing the impacts of relicensing a dam, the analysis 36 would only identify the marginal environmental changes between the continued 37 operation of the dam and the existing degraded state of the environment. In this 38 hypothetical case, the affected environment has been seriously degraded for 39 more than 50 years with accompanying declines in flows, reductions in fish 40 stocks, habitat loss, and disruption of hydrologic functions. If the assessment 41 took into account the full extent of continued impacts, the significance of the 42 continued operation would more accurately express the state of the environment 43 and thereby better predict the consequences of relicensing the dam. 44 Sections 2.2.6 and 2.2.8 present an overview of the conditions of the Mississippi River basin 45 near GGNS and the history and factors that led to its current condition. Since the 1700s, efforts 46 to control flooding and increase navigation along the Mississippi River have changed th e 47 relative abundance of various habitats within the river. In addition, levees have decreased the 48 connectivity of aquatic life within floodplain habitats and the Mississippi River because of the 49 Environmental Impacts of Operation 4-36 decrease in flooding events when biota can move in between floodplain habitats and the river. 1 In addition to physical changes to aquatic habitat, runoff has led to habitat degradation and 2 decreased water quality. Land use changes within the Mississippi River basin have introduced 3 new industrial and chemical inputs into the river (Brown et al. 2005). The introduction of 4 non-native species also has threatened many protected, native species near GGNS. As 5 described in Section 2.2.6.2, the staff compared aquatic surveys from 1972 through 1974 with 6 surveys from 2006 through 2008 (FishNet 2012). Of the 25 species recorded in the earlier 7 surveys, 8 species (32 percent) were collected and 17 species (68 percent) were not collected 8 in the later surveys (FishNet 2012). These results indicate that many species that once 9 inhabitated the Mississippi River may no longer exist near GGNS. 10 Many natural and human activities can influence the current and future aquatic life in the area 11 surrounding GGNS. Potential biological stressors include continued potential thermal stress 12 from GGNS as described in Section 4.8.2.5; modifications to the Mississippi River; runoff from 13 industrial, agricultural, and urban areas; other water users and dischargers; and, climate 14 change, as described in Section 4.12.3.4. 15 4.12.3.1 Modifications to the Mississippi River 16 The relative abundance of hard substrate, deep channel, and river bank habitat has been 17 largely influenced by human activities to decrease flooding events and increase navigability. 18 The U.S. Army Corps of Engineers (USACE) and Mississippi River Commission continue to 19 oversee a comprehensive river management program that includes: 20 levees for containing flood flows; 21 floodways for the passage of excess flows past critical reaches of the 22 Mississippi River; 23 channel improvement and stabilization to provide an efficient and reliable 24 navigation channel, increase the flood -carrying capacity of the river, and 25 protect the levee system; and, 26 tributary basin improvements for major drainage basins to include dams and 27 reservoirs, pumping plants, auxiliary channels and pumping stations 28 (MRC 2012). 29 Implementing this management program will continue to affect the relative availability of aquatic 30 habitats, resulting in, for example, a decrease in the amount of soft sediment river bank habitat 31 and an increase in the amount of hard substrates (e.g., riprap or other materials used to line the 32 river bank). Consequently, invertebrates that depend on a hard surface for attachment, and can 33 colonize human -made materials, such as tires, concrete, or riprap used to line river banks, likely 34 will continue to increase in relative abundance as compared to species that require soft 35 sediments along the river bank. 36 The Mississippi River Commission also implements various programs to support the 37 sustainability of aquatic life within the Mississippi River. For example, the Davis Pond and 38 Caernarvon freshwater diversion structures divert more than 18,00 0 ft 3/s (510 m 3/s) of fresh 39 water to coastal marshlands. The input of freshwater helps to preserve the marsh habitat and 40 reduce coastal land loss (MRC 2012). In addition, the Mississippi River Commission conducted 41 research and determined that using grooved articulated concrete mattresses to line river banks 42 can help support benthic invertebrate and fish populations. For example, using grooved 43 articulated concrete mattresses increases larval insect production, which is an important source 44 of prey for many fish (MRC 2012). 45 Environmental Impacts of Operation 4-37 4.12.3.2 Runoff from Industrial, Agricultural, and Urban Areas 1 Nearly 40 percent of the land within the contiguous United States drains into the Mississippi 2 River. Land use changes and industrial activities within this area have had a substantial impact 3 on aquatic habitat and water quality within the Mississippi River. For example, historically, the 4 Mississippi River has experienced decreased water quality as a result of industrial discharges, 5 agricultural runoff, municipal sewage discharges, surface runoff from mining activity, and 6 surface runoff from municipalities. However, over the past few decades, water quality within the 7 Mississippi River has improved because of the implementation of the Clean Water Act and other 8 environmental regulations (Caffey et al. 2002). For example, most of the older, first -generation 9 chlorinated insecticides have been banned since the late 1970s. Similarly, the addition and 10 upgrading of numerous municipal sewage treatment facilities, rural septic systems, and animal 11 waste management systems ha ve helped to significantly decrease the concentration of median 12 fecal coliform bacteria in the Mississippi River (Caffey et al. 2002). Despite the trend of 13 improving water quality within the Mississippi River, trace levels of some contaminants and 14 increased nutrients from agricultural lands remain a source of concern for aquatic life (Caffey et 15 al. 2002; Rabalais et al. 2009). 16 4.12.3.3 Other Water Users and Discharges 17 Several other currently existing and proposed facilities withdraw water from the Mississippi 18 River. For example, Entergy previously proposed to build a new nuclear reactor at the GGNS 19 site, which would withdraw water from the Mississippi River as a source of cooling water 20 (NRC 2006). In addition, climate patterns and increased water demands upstream of GGNS 21 also may increase the number of water users and rate of withdrawal from the Mississippi River 22 (Caffey et al. 2002). Aquatic life, especially threatened and endangered species, rely on 23 sufficient flow within streams and rivers to survive. Also, fish and other aquatic life could be 24 impinged and entrained within the new nuclear unit and other facility water intake systems. 25 Entergy proposed to use a clos ed-cycle cooling system, which would minimize impingement 26 and entrainment (NRC 2006). In addition, as described in Section 4.1 2.3.1, continued 27 regulation of the flow by the U.S. Army Corps of Engineers is expected to preserve the course 28 and flow of the Mississippi River. Building and operating a new nuclear unit and other activities 29 beyond GGNS would not be expected to noticeably alter aquatic resources within the 30 Mississippi River. 31 A new reactor at GGNS and other water users along the Mississippi River also would discharge 32 cooling water and other effluents into the Mississippi River. NRC (2006) considered the impacts 33 to aquatic resources from discharge of heated effluent (e.g., water temperature, dissolved 34 oxygen, thermal stratification, impact to fauna), cold shock, and chemical treatment of the 35 cooling water and determined that the effluent would not noticeably alter aquatic resources. 36 Additionally, Entergy and other water dischargers would be required to comply with NPDES 37 permits that must be renewed every 5 years, allowing MDEQ to ensure the permit limits provide 38 the appropriate level of environmental protection. 39 4.12.3.4 Climate change 40 Climate change could noticeably alter aquatic resources near GGNS. In the southeastern 41 United States, precipitation during the fall has increased 30 percent from 1901 to 2007 and the 42 overall amount of heavy downpours also has increased (USGCRP 2009). Heavy downpours 43 can increase the rate of runoff and pollutants reaching the Mississippi River because the 44 heavier precipitation, and the pollutants washed away in the runoff, have less time to be 45 absorbed in the soil before reaching the river and other surface waterbodies. Climate change 46 models predict continued increases in heavy downpours in the southeastern United States. 47 Environmental Impacts of Operation 4-38 Climate models also predict increasing temperatures in the southeast, especially during spring 1 and summer (USGCRP 2009). Increased temperatures and nutrients in runoff could lead to a 2 decline in oxygen within small streams, lakes, and shallow aquatic habitats. During periods of 3 low oxygen, many fish and other aquatic life may not be able to survive. Increased 4 temperatures also may increase the frequency of shellfish -borne illness, alter the distribution of 5 native fish, increase the local loss of threatened and endangered species, and increase the 6 displacement of native species by non -native species (USGCRP 2009). 7 Since the 1970s, there has been an increase in the amount of moderate to severe drought, 8 especially during spring and summer. Climate models predict a continued increase in the 9 amount and severity of droughts, which can lead to water use conflicts (USGCRP 2009). 10 Regulatory programs will be required to ensure sufficient water and flow is available within 11 surface waterbodies to provide habitat for aquatic life, especially threatened and endangered 12 species. 13 4.12.3.5 Conclusion 14 The direct and indirect impacts to aquatic resources from historical Mississippi River 15 modifications and pollutants and sediments introduced into the river have had a substantial 16 effect on aquatic life and their habitat. The incremental impacts from GGNS are SMALL for 17 aquatic resources because GGNS operation would have minimal impacts on aquatic life due to 18 use of a closed-cycle cooling system and Ranney wells. The cumulative stress from the 19 activities described above, spread across the geographic area of interest depends on many 20 factors that the NRC staff cannot quantify. This stress may noticeably alter some aquatic 21 resources. For example, climate change may increase the temperature of the Mississippi River 22 and rate of runoff into the river. This may noticeably alter the habitat for species most sensitive 23 to nutrient loading, high levels of contaminants, and higher temperatures. In addition, a 24 comparison of fish surveys from 1972 through 1974 and from 2006 through 2008 suggests that 25 some species no longer inhabitate the Mississippi River near GGNS (FishNet 2012). Therefore, 26 the staff concludes that the cumulative impacts from the proposed license renewal and other 27 past, present, and reasonably foreseeable projects would be MODERATE. 28 4.12.4 Terrestrial Resources 29 This section addresses past, present, and future actions that could result in cumulative impacts 30 on the terrestrial species and habitats described in Section 2.2.7, including protected terrestrial 31 species. For purposes of this analysis, the geographic area considered in the evaluation 32 includes the GGNS site and the in -scope transmission line corridors. As explained for aquatic 33 resources, the baseline for this assessment is the condition of the resource without the action, 34 i.e., under the no -action alternative. 35 4.12.4.1 Historic Conditions 36 Section 2.2.7 discusses the ecoregions in which the GGNS site lies -the Mississippi Valley 37 Alluvial Plain and Mississippi Valley Loess Plain. This region consists of irregular plains with a 38 thick layer of highly erodible loess deposits, oak -hickory and oak -hickory-pine forests, and 39 streams with low gradients and silty substrates. When GGNS was built, forests and agriculture 40 were the dominant land types. Between 1973 and 2000, agricultural lands decreased by 41 6.8 percent, while developed land increased by 4.0 percent (USGS 2001). Forested land 42 remained relatively constant and accounted for 43 to 44 percent of land cover over the time 43 period (USGS 2001). 44 On the immediate site, Mississippi Power & Light Company cleared about 270 ac (109 ha) of 45 upland habitat for GGNS buildings and related infrastructure. The terrestrial habitats on the 46 Environmental Impacts of Operation 4-39 undeveloped portions of the site have not changed significantly since GGNS's construction 1 (Entergy 2011 a). The two primary habitat changes between preconstruction and present day 2 are in the bottomland scrub -shrub wetlands (east of Gin Lake) and the upland open fields and 3 clearings, in which Entergy has planted American sycamore (Platanus occidentali) and loblolly 4 pine (Pinus taeda), respectively. 5 4.12.4.2 GGNS Unit 3 6 The review of the GGNS Unit 3 COL application is currently on hold. However, if the facility 7 were to be built in the future, Entergy (2011a) anticipates that onsite land disturbance would be 8 primarily limited to previously disturbed areas of the site. GGNS Unit 3 may require the 9 construction of new transmission lines. The impacts from such construction would vary 10 depending on the types of habitat the lines would cross and whether such transmission lines are 11 routed along existing transmission line corridor

s. Terrestrial resource impacts resulting from 12 operation of G GNS Unit 3 would be similar to impacts of operation of GGNS and would be 13 SMALL. 14 4.12.4.3 Agricultural Runoff 15 Within Claiborne County, 531 ac (126,073 ha) of land were used for cultivation of major crops 16 as of 2006 (NRC 2006). The 2000 National Water Quality Inventory reported that agricultural 17 nonpoint source pollution accounted for the second largest source of impairments to wetlands 18 (EPA 2012 a). Fertilizers and pesticides can affect wetlands and bottomlands in a variety of 19 ways. Because wetlands and bottomlands are often at lower elevation than surrounding land, 20 these habitats receive much of the runoff first, and that runoff persists because it is unable to 21 drain to lower ground. This can result in bioaccumulation of pollutants and changes to species 22 composition and abundance. Species that rely on wetlands, such as birds and amphibians, are 23 more sensitive to these environmental stressors than other animal groups.

24 4.12.4.4 National Forests 25 The Franklin transmission line crosses through the Homochitto National Forest to the southeast 26 of the GGNS site. This national forest will continue to provide valuable habitat to native wildlife 27 and migratory birds during the proposed license renewal period. As habitat fragmentation 28 resulting from various types of development increases, these areas will become ecologically 29 more important because they will provide large areas of natural habitat. 30 4.12.4.5 Climate Change 31 Since 1970, the average annual temperature in the southeastern United States has risen by 32 about 2 °F (1.1 °C) and the number of freezing days has declined by 4 to 7 days per year 33 (USGCRP 2009). Over the next several decades, the U.S. Global Change Research Program 34 (USGCRP 2009) estimates that the average temperatures in the region will rise by an additional 35 4.5 °F (2.5 °C). The Gulf Coast states, including Mississippi, will have less rainfall in winter and 36 spring, and higher temperatures will increase the frequency, duration, and intensity of drought. 37 Hurricane intensity also will likely increase (USGCRP 2009). Changes in the climate will shift 38 many wildlife population ranges and alter migratory patterns. Such changes could favor 39 non-native invasive species and promote population increases of insect pests and plant 40 pathogens. Climate change will likely alter the severity or frequency of precipitation, flooding, 41 and fire. Climate change may also exacerbate the effects of existing stresses in the natural 42 environment, such as those caused by habitat fragmentation, invasive species, nitrogen 43 deposition and runoff from agriculture, and air emissions. 44 Environmental Impacts of Operation 4-40 4.12.4.6 Conclusion 1 Section 4.7 of this SEIS concludes that the impact from the proposed license renewal would not 2 noticeably alter the terrestrial environment, and, thus, would be SMALL. However, as 3 environmental stressors such as agricultural runoff and climate change continue over the 4 proposed license renewal term, certain attributes of the terrestrial environment (such as species 5 diversity and distribution) are likely to noticeably change. The staff does not expect these 6 impacts to destabilize any important attributes of the terrestrial environment because such 7 impacts will cause gradual change, which should allow the terrestrial environment to 8 appropriately adapt. The staff concludes that the cumulative impacts of the proposed license 9 renewal of GGNS plus other past, present, and reasonably foreseeable future projects or 10 actions would result in MODERATE impacts to terrestrial resources. 11 4.12.5 Human Health 12 The NRC and EPA have developed radiological dose limits for protection of the public and 13 workers to address the cumulative impact of acute and long -term exposure to radiation and 14 radioactive material. These dose limits are codified in 10 CFR Part 20 and 40 CFR Part 190. 15 For the purpose of this analysis, the area within a 50 -mi (80-km) radius of GGNS was included. 16 The radiological environmental monitoring program Entergy conducted in the vicinity of the 17 GGNS site measures radiation and radioactive materials from all sources (i.e., hospitals and 18 other licensed users of radioactive material); therefore, the monitoring program measures 19 cumulative radiological impacts. There currently are no other nuclear power reactors or 20 uranium fuel cycle facilities within the 50-mi (80-km) radius of the GGNS site. 21 Radioactive effluent and environmental monitoring data for the 5 -year period from 200 8 to 2012 22 were reviewed as part of the cumulative impacts assessment. In Section 4.9.1 of this SEIS, the 23 staff concluded that impacts of radiation exposure to the public and workers (occupational) from 24 operation of GGNS during the renewal term are SMALL. The NRC and the State of Mississippi 25 would regulate any future actions in the vicinity of the GGNS site that could contribute to 26 cumulative radiological impacts. 27 Entergy constructed an independent spent fuel storage installation (ISFSI) on the GGNS site in 28 2000 for the storage of its spent fuel. The installation and monitoring of this facility is governed 29 by NRC requirements in 10 CFR Part 72, "Licensing Requirements for the Independent Storage 30 of Spent Nuclear Fuel, High -Level Radioactive Waste, and Reactor -Related Greater Than 31 Class C Waste." Radiation from this facility, as well as from the operation of GGNS, is required 32 to be within the radiation dose limits in 10 CFR Part 20, 40 CFR Part 190, and 10 CFR Part 72. 33 The NRC carries out periodic inspections of the ISFSI to verify its compliance with its licensing 34 and regulatory requirements. 35 In September 2010, Entergy applied to the NRC for an extended power uprate (EPU). In 36 July 2012, the NRC issued an amendment approving the power increase (NRC 2012j). The 37 staff considered the environmental impacts of the EPU in this evaluation. 38 As discussed in Section 4.12, review of the application for the proposed new nuclear reactor 39 designated as GGNS Unit 3 is on hold. However, GGNS Unit 3 is considered in the cumulative 40 impacts section since it is a reasonable and foreseeable future action. 41 The cumulative radiological impacts from GGNS Unit 1, the ISFSI, and the proposed GGNS 42 Unit 3, would be required to meet the radiation dose limits in 10 CFR Part 20 and 43 40 CFR Part 190. For these reasons, the staff concludes that cumulative radiological impacts 44 would be SMALL. 45 Environmental Impacts of Operation 4-41 4.12.6 Socioeconomics 1 This section addresses socioeconomic factors that have the potential to be affected directly or 2 indirectly by changes in operations at GGNS in addition to the aggregate effects of other past, 3 present, and reasonably foreseeable future actions. The primary geographic area of interest 4 considered in this cumulative analysis is Claiborne, Hinds, Jefferson, and Warren Counties 5 where approximately 81 percent of GGNS employees reside (see Table 2-7). This is where the 6 economy, tax base, and infrastructure most likely would be affected since GGNS workers and 7 their families reside, spend their income, and use their benefits within these counties. 8 As discussed in Section 4.10 of this SEIS, continued operation of GGNS would have no impact 9 on socioeconomic conditions in the region during the license renewal term beyond what is 10 already being experienced. Since Entergy has no plans to hire additional non -outage workers 11 during the license renewal term, overall expenditures and employment levels at GGNS are 12 expected to remain relatively unchanged with no additional or increased demand for permanent 13 housing and public services. In addition, since employment levels and tax payments would not 14 change, there would be no population or tax revenue -related land use impacts. Based on this 15 and other information presented in Chapter 4 of this SEIS, there would be no contributory effect 16 from the continued operation of GGNS on socioeconomic conditions in the region beyond what 17 is currently being experienced. The only cumulative contributory effects would come from the 18 other planned activities in the region independent of GGNS operations. T herefore, the staff 19 concludes that the cumulative socioeconomic impacts would be SMALL. 20 4.12.6.1 Environmental Justice 21 The environmental justice cumulative impact analysis assesses the potential for 22 disproportionately high and adverse human health and environmental effects on minority and 23 low-income populations that could result from past, present, and reasonably foreseeable future 24 actions including GGNS operations during the renewal term. Adverse health effects are 25 measured in terms of the risk and rate of fatal or nonfatal adverse impacts on human health. 26 Disproportionately high and adverse human health effects occur when the risk or rate of 27 exposure to an environmental hazard for a minority or low -income population is significant and 28 exceeds the risk or exposure rate for the general population or for another appropriate 29 comparison group. Disproportionately high environmental effects refer to impacts or risk of 30 impact on the natural or physical environment in a minority or low -income community that are 31 significant and appreciably exceed the environmental impact on the larger community. Such 32 effects may include biological, cultural, economic, or social impacts. Some of these potential 33 effects have been identified in resource areas presented in Chapter 4 of this SEIS. Minority and 34 low-income populations are subsets of the general public residing in the area and all would be 35 exposed to the same hazards generated from GGNS operations. As previously discussed in 36 this chapter, the impact from license renewal for all resource areas (e.g., land, air, water, 37 ecology, and human health) would be SMALL. 38 As discussed in Section 4.10.7 of this SEIS, there would be no disproportionately high and 39 adverse impacts to minority and low -income populations from the continued operation of GGNS 40 during the license renewal term. Since Entergy has no plans to hire additional non -outage 41 workers during the license renewal term, employment levels at GGNS are expected to remain 42 relatively unchanged with no additional or increased demand for housing or increased traffic. 43 Based on this information and the analysis of human health and environmental impacts 44 presented in Chapters 4 and 5, it is not likely there would be any disproportionately high and 45 adverse contributory effect on minority and low -income populations from the continued 46 operation of GGNS during the license renewal term. 47 Environmental Impacts of Operation 4-42 4.12.7 Historic and Archaeological Resources 1 This section addresses the direct and indirect effects of license renewal on historic and cultural 2 resources, in and around GGNS, when added to the aggregate effects of other past, present, 3 and reasonably foreseeable actions. Section 2.2.10 discusses the cultural background and 4 known historic and archaeological resources in and around GGNS. 5 As described in Section 4. 10.6, the NRC staff concluded that license renewal would have a 6 SMALL impact on historic and cultural resources at GGNS. However, any future 7 ground-disturbing maintenance and operations activities during the license renewal term could 8 affect undiscovered historic and archaeological resources . In addition, future construction and 9 operation of a new nuclear power plant site at GGNS would have the potential to result in 10 impacts on cultural resources through inadvertent discovery during ground -disturbing activities. 11 Future urbanization near GGNS could also affect historic and archaeological resources. 12 Given the high potential for historic and archaeological resources to be present at GG NS, as 13 well as the existing historic and archaeological resources presented in Section 2.2.10.2, GGNS 14 has procedures regarding protection of cultural resources. Any ground-disturbing maintenance 15 and operations activities during the GGNS license renewal term or construction of a new 16 nuclear power plant would be reviewed in accordance with these procedures. These 17 procedures are designed to ensure that investigations and consultations are conducted as 18 needed and that existing or potentially existing cultural resources are adequately protected. 19 Should historic or archaeological resources be encountered during construction, work would 20 cease until Entergy environmental personnel would perform an evaluation and consider possible 21 mitigation measures through consultation with the Mississippi SHPO. Any future urbanization 22 that might directly or indirectly affect historic or archaeological resources (i.e. inadvertent 23 discovery, viewshed impacts) would be required to comply with applicable State and Federal 24 laws regarding protection of cultural and archaeological resources, and any impacts would be 25 mitigated accordingly. 26 Based on this information, the NRC staff finds that the continued operation of GGNS during the 27 license renewal term would not incrementally contribute to cumulative impacts on historic and 28 archaeological resources within GGNS and in the surrounding area. Therefore, the cumulative 29 impact on historic and archaeological resources during the license renewal term would be 30 SMALL. 31 4.12.8 Summary of Cumulative Impacts 32 The staff considered the potential impacts resulting from the operation of GGNS during the 33 period of extended operation and other past, present, and reasonably foreseeable future actions 34 near GGNS. The preliminary determination is that the potential cumulative impacts would range 35 from SMALL to LARGE, depending on the resource. Table 4-10 summarizes the cumulative 36 impacts on resources areas. 37 Environmental Impacts of Operation 4-43 Table 4-10. Summary of Cumulative Impacts on Resource Areas 1 Resource area Cumulative impact Air Quality Considering the distances to the nearest nonattainment and maintenance areas around GGNS, prevailing wind directions, and the minor nature of air emissions from GGNS, emissions from GGNS operations are not anticipated to affect current attainment or maintenance area status. Accordingly, air emissions from continued operation of the plant and associated impacts on ambient air quality would not be expected to change during the license renewal term.

Based on the above discussion, the NRC staff concludes that combined with the emissions from other past, present, and reasonably foreseeable future actions, cumulative impacts on ambient air quality and global climate change from operations at GGNS would be SMALL. Water Resources The watersheds contributing flow to the two streams on the GGNS site are nearly contained within the site, and the remaining drainage area outside the site area would not be expected to change significantly. Therefore, changes in surface water supply outside the site would not alter the surface water conditions of the site's two streams. No activity at the GGNS site by itself, nor other activities outside the site, would be expected to alter fundamentally the character of the Mississippi River. The cumulative impacts from past, present, and reasonably foreseeable future actions on surface water resources during the license renewal term would be SMALL. In the region around GGNS, public water is obtained from deep underlying aquifers. Past, present and future activities at the GGNS site have not and will not use these aquifers as a source of water. Throughout the region, the groundwater quality of the deep underlying aquifers is protected from land -use activities by thick layers of low permeability geologic deposits and by government regulatory programs. The cumulative impact on groundwater use will be SMALL because abundant good water quality groundwater is and will continue to be readily available for public use. Based on the above considerations, the cumulative impacts from past, present, and reasonably foreseeable future actions on groundwater resources during the licens e renewal term would be SMALL. Aquatic Ecology The direct and indirect impacts to aquatic resources from historical Mississippi River modifications and pollutants and sediments introduced into the river have had a substantial effect on aquatic life and their habitat. The incremental impacts from GGNS are SMALL for aquatic resources because GGNS uses a closed-cycle cooling system and Ranney wells. The cumulative stress from the activities described in Section 4.12.3, spread across the geographic area of interest depends on many factors that NRC staff cannot quantify. This stress may noticeably alter some aquatic resources. The cumulative impacts from the proposed license renewal and other past, present, and reasonably foreseeable projects would be MODERATE. Terrestrial Ecology The NRC staff examined the cumulative effects of the construction of GGNS, agricultural runoff, nearby parks and conservation areas, and climate change. The NRC staff concludes that the minimal terrestrial impacts of continued GGNS operations would not contribute to the overall decline in the condition of terrestrial resources. The NRC staff believes that the cumulative impacts of other and future actions during the term of license renewal on terrestrial habitat and associated species, when added to past, present, and reasonably foreseeable future actions, would be MODERATE.

Environmental Impacts of Operation 4-44 Resource area Cumulative impact Human Health The radiological dose limits for protection of the public and workers have been developed by the NRC and EPA to address the cumulative impact of acute and long-term exposure to radiation and radioactive material. The NRC and the State of Mississippi would regulate any future actions in the vicinity of the GGNS site that could contribute to cumulative radiological impacts. In addition, the cumulative radiological impacts from operation of GGNS, the ISFSI , and a projected additional reactor unit would be required to meet the radiation dose limits in 10 CFR Part 20 and 40 CFR Part 190. For these reasons, cumulative radiological impacts would be SMALL. Socioeconomics As discussed in Section 4. 10, continued operations during the license renewal term would have no impact on socioeconomic conditions in the region beyond those already being experienced. In addition, there would be no disproportionately high and adverse impacts to minority and low -income populations from the continued operations during the license renewal term. The cumulative effects on socioeconomic conditions and environmental justice populations in the region from past, present, and reasonably foreseeable future actions including continued operations combined with other planned activities in the region is not expected to increase appreciably beyond what is currently being experienced. T herefore, cumulative socioeconomic impacts would be SMALL. Cultural Resources As discussed in Section 4. 10.6 of this SEIS, continued operation of GGNS during the license renewal term is likely to have a SMALL impact on historical or archaeological resources. Any future ground -disturbing activities may affect undiscovered historic and archaeological resources; however, any such activity would be reviewed in accordance with Entergy procedures designed to adequately protect historic and archaeological resources. Future urbanization would be governed by appropriate State and Federal laws to mitigate impacts on historic and archaeological resources. Therefore, the cumulative impacts on historic and archaeological resources during the license renewal term would be SMALL. 4.13 References 1 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for 2 protection against radiation." 3 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic licensing of 4 production and utilization facilities." 5 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy , Part 51, "Environmental 6 protection regulations for domestic licensing and related regulatory functions." 7 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for 8 renewal of operating licenses for nuclear power plants." 9 40 CFR Part

81. Code of Federal Regulations, Title 40, Protection of the Environment, Part 81, 10 "Designation of areas for air quality planning purposes."

11 40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 12 "Environmental radiation protection standards for nuclear power operations." 13 50 CFR Part 402. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 402, 14 "Interagency cooperation -Endangered Species Act of 1973, as amended." 15 Environmental Impacts of Operation 4-45 59 FR 7629. Executive Order 12898. Federal actions to address environmental justice in 1 minority populations and low -income populations. Federal Register 59(32):7629 -7634. 2 February 16, 1994. 3 69 FR 52040. U.S. Nuclear Regulatory Commission. Policy statement on the treatment of 4 environmental justice matters in NRC regulatory and licensing actions. Federal Register 5 69(163):52040 -52048. August 24, 2004. 6 74 FR 56264. U.S. Environmental Protection Agency. Mandatory reporting of greenhouse 7 gases; final rule." Federal Register 74(209):56260 -56519. October 30, 2009. 8 Brown A.V., Brown K.B., Jackson D.C. & Pierson W.K. 2005. The lower Mississippi River and its 9 tributaries. In A.C. Benke & C.E. Cushing eds. Rivers of North America. New York, Academi c 10 Press. 11 Caffey, R. H. , P. Coreil, and D. Demcheck. 2002. Mississippi River Water Quality: Implications 12 for Coastal Restoration, Interpretive Topic Series on Coastal Wetland Restoration in Louisiana, 13 Coastal Wetland Planning, Protection, and Restoration Act (eds.), National Sea Grant Library 14 No. LSU-G 002. 15 [CEQ] Council on Environmental Quality. 1997. Environmental Justice: Guidance Under the 16 National Environmental Policy Act. December 10. Available at 17 <http://www.epa.gov/compliance/ej/resources/policy/ej_guidance_nepa_ceq1297.pdf > 18 (accessed 19 July 2012). Agencywide Documents Access and Management System (ADAMS) 19 Accession No. ML082520150. 20 [Entergy] Entergy Operations, Inc. 2009

a. Grand Gulf Nuclear Station Unit 1. 2008 Annual 21 Radiological Environmental Operating Report. Port Gibson, MS. ADAMS No. ML091240225.

22 [Entergy] Entergy Operations, Inc. 2009

b. Grand Gulf Nuclear Station Unit 1. 2008 Annual 23 Radioactive Effluent Release Report. Port Gibson, MS. ADAMS Accession No.

ML091310016. 24 [Entergy] Entergy Operations, Inc. 2010

a. Grand Gulf Nuclear Station Unit 1. 2009 Annual 25 Radiological Environmental Operating Report. Port Gibson, MS. ADAMS Accession 26 No. ML101130028.

27 [Entergy] Entergy Operations, Inc. 2010

b. Grand Gulf Nuclear Station Unit 1. 2009 Annual 28 Radioactive Effluent Release Repor

t. Port Gibson, MS. ADAMS Accession No.

ML101200085. 29 [Entergy] Entergy Operations, Inc. 2011

a. Grand Gulf Nuclear Station, Unit 1, License Renewal 30 Application , Appendix E, Applicant's Environmental Report.

Port Gibson: MS. October 2011. 31 425 p. ADAMS Accession No. ML11308A234. 32 [Entergy] Entergy Operations, Inc. 2011b. Grand Gulf Nuclear Station Unit 1. 2010 Annual 33 Radiological Environmental Operating Report. Port Gibson, MS. ADAMS Accession 34 No. ML111190213. 35 [Entergy] Entergy Operations, Inc. 2011c. Grand Gulf Nuclear Station Unit 1. 2010 Annual 36 Radioactive Effluent Release Report. Port Gibson, MS. ADAMS Accession No. ML111190097. 37 [Entergy] Entergy Operations, Inc. 2012

a. Grand Gulf Nuclear Station Unit 1.

2011 Annual 38 Radiological Environmental Operating Report. Port Gibson, MS. ADAMS Accession 39 No. ML0812606810. 40 [Entergy] Entergy Operations, Inc. 2012

b. Grand Gulf Nuclear Station Unit 1. 2011 Annual 41 Radioactive Effluent Release Report. Port Gibson, MS. ADAMS Accession No.

ML12121A593. 42 Environmental Impacts of Operation 4-46 [Entergy] Entergy Operations, Inc. 2013a. Grand Gulf Nuclear Station Unit 1. 2012 Annual 1 Radiological Environmental Operating Report. Port Gibson, MS. ADAMS Accession No. 2 ML13121A394. 3 [Entergy] Entergy Operations, Inc. 201 3b. Grand Gulf Nuclear Station Unit 1. 2012 Annual 4 Radioactive Effluent Release Report. Port Gibson, MS. ADAMS Accession No. ML13121A244. 5 [EPA] U.S. Environmental Protection Agency. 1999. Consideration of Cumulative Impacts in 6 EPA Review of NEPA Documents. EPA -315-R-99-002. Office of Federal Activities (2252A), 7 Washington, D.C. 8 [EPA] U.S. Environmental Protection Agency. 2011a. eGRID, eGRID2012 Version 1.0. 9 Available at <http://www.epa.gov/cleanenergy/energy -resources/egrid/index.html> (accessed 10 26 June 2012). 11 [EPA] U.S. Environmental Protection Agency. 2011b. Emission Factors for Greenhouse Gas 12 Inventories, last modified November 7, 2011. Available at 13 <http://www.epa.gov/climateleaders/documents/emission -factors.pdf> (accessed 18 Dec 2012). 14 [EPA] U.S. Environmental Protection Agency. 2012

a. "Agriculture." Available at 15 <http://water.epa.gov/polwaste/nps/agriculture.cfm> (accessed 11 May 2012).

16 [EPA] U.S. Environmental Protection Agency. 2012b. Inventory of U.S. Greenhouse Gas 17 Emissions and Sinks: 1990 -2010. EPA 430 R 001. April 15, 2012. Available at 18 <http://www.epa.gov/climatechange/Downloads/ghgemissions/US -GHG-Inventory-2012-Main-19 Text.pdf> (accessed 26 June 2012). 20 [FWS] U.S. Fish and Wildlife Service. 2007. "Pallid Sturgeon (Scaphirhynchus albus) 5-Year 21 Review: Summary and Evaluation." Billings, MT. June 13, 2007. 120 p. Available at 22 <http://ecos.fws.gov/docs/five_year_review/doc1059.pdf> (accessed 10 January 2013). 23 [FWS] U.S. Fish and Wildlife Service. 2012a. Letter from S. Ricks, Mississippi Field Office 24 Supervisor, FWS, to D. Drucker, Project Manager, NRC. Reply to request for concurrence with 25 list of protected species and habitats for Grand Gulf license renewal review. February 3, 2012. 26 ADAMS Accession No. ML12047A113. 27 [FWS] U.S. Fish and Wildlife Service. 2012b. Letter from J.D. Weller, Louisiana Field Office 28 Supervisor, FWS, to D. Wrona, RPB2 Branch Chief, NRC. Reply to request for concurrence with 29 list of protected species and habitats for Grand Gulf license renewal review. February 29, 2012. 30 ADAMS Accession No. ML12082A141. 31 [FWS] U.S. Fish and Wildlife Service. 2012c. Letter from K. Herrington, Panama City Office, 32 FWS, to M. Moser, RERB Aquatic Biologist, NRC. Reply to Inquiry regarding Gulf Sturgeon at 33 Grand Gulf Nuclear Station. July 2, 2012. ADAMS Accession No. ML12226A158. 34 [FWS] U.S. Fish and Wildlife Service. 2012d. "Bayou Darter (Etheostoma rubrum) 5-Year 35 Review: Summary and Evaluation." Jackson, MS: FWS Southeast Region. May 9, 2012. 16 p. 36 Available at <http://ecos.fws.gov/docs/five_year_review/doc3989.pdf> (accessed 10 Jan 2013). 37 [FWS] U.S. Fish and Wildlife Service. 2013. "Guidance for Preparing a Biological Assessment." 38 Accessed September 12, 2013. Available at 39 http://www.fws.gov/midwest/endangered/section7/pdf/BAGuidance.pdf 40 [GGNS] Grand Gulf Nuclear Station. 2008

a. Grand Gulf Nuclear Station (GGNS), Facility 41 No. 0420-00023, Renewal of Existing Synthetic Minor Operating Permit No. 0420

-00023, 42 Correspondence GEXO -2008/00086. November 25, 2008. (ADAMS Accession 43 No. ML12157A448). 44 Environmental Impacts of Operation 4-47 [GGNS] Grand Gulf Nuclear Station. 2008b. Grand Gulf Nuclear Station, Unit 3 COL 1 Application, Part 3, Environmental Report, pages 4 -5 to 4-13 and 6-4, February 2008. ADAMS 2 Accession No ML080640404. 3 [GGNS] Grand Gulf Nuclear Station. 2012

a. Response to Request for Additional Information 4 (RAI) Dated April 23, 2012, Grand Gulf Nuclear Station, Unit 1. ADAMS Accession 5 No. ML12157A173.

6 [GGNS] Grand Gulf Nuclear Station. 2012

b. Response to Request for Additional Information 7 (RAI) Dated May 8, 2012 Grand Gulf Nuclear Station, Unit 1. ADAMS Accession 8 No. ML12158A445. 9 [IEEE] Institute of Electrical and Electronics Engineers, Inc. 2002. National Electrical Safety 10 Code. 11 [IPCC] Intergovernmental Panel on Climate Change. 2011. Renewable Energy Sources and 12 Climate Change Mitigation, Special Report of the IPCC. O. Edenhofer, R. 13 Pichs-Madruga, Y. Sokona, K. Seyboth, P. Matschoss, S. Kadner, T. Zwickel, P. Eickemeier, 14 G. Hansen, S. Schlomer, C. von Stechow, editors. Cambridge University Press, Cambridge, 15 U.K. and New York, NY. Available at

<http://srren.ipcc -16 wg3.de/report/IPCC_SRREN_Full_report.pdf > (accessed 18 April 2012) 17 [LDWF] Louisiana Department of Wildlife and Fisheries. 2012. Letter from A. Bass , Coordinator , 18 Louisiana Natural Heritage Program, to D. Wrona, RPB2 Branch Chief, NRC.

Subject:

Grand 19 Gulf Nuclear Station license renewal. February 1 6, 2012. ADAMS Accession No. 20 ML12060 A 098. 21 [MDAH] Mississippi Department of Archives and History. 2012

a. Letter from G. Williamson, 22 Mississippi Department of Archives and History, to David J. Wrona, NRC.

Subject:

Grand Gulf 23 Nuclear Station, Unit 1, License Renewal 50 -416 MDAH Project Log #01 -171-12 (Previously 24 #02-053-11), Choctaw County. February 28, 2012, ADAMS Accession No. ML12073A084. 25 [MDAH] Mississippi Department of Archives and History. 2012

b. Site file search conducted by 26 K. Wescott, Argonne National Laboratory, and E. Larson, U.S.

Nuclear Regulatory Commission, 27 at the MDAH, Jackson, Mississippi on March 29 and 30, 2012. 28 [MDWFP] Mississippi Department of Wildlife, Fisheries, and Parks. 2012. Letter from 29 A. Sanderson, Ecologist, Mississippi Natural Heritage Program, to D. Wrona, RPB2 Branch 30 Chief, NRC.

Subject:

Reply to request for protected species and habitat information for Grand 31 Gulf license renewal review. February 13, 2012. ADAMS Accession No. ML12055A312. 32 [MRC] Mississippi River Commission. 2012. Mississippi Valley Division: Mississippi River and 33 Tributaries Project. URL Available at: http://www.mvd.usace.army.mil/mrc/mrt/index.php 34 (Accessed on 20 June 2012). 35 Missouri Census Data Center Circular Area Profiling System (CAPS) 2012. Version 10C. Using 36 Data from Summary File 1, 2010 Census Summary of Census Tracts in a 50 -mile radius around 37 the GGNS (32.01 Lat., -91.05 Long.). Accessed June 2012. 38 [NCDC] National Climatic Data Center. 1990. 1989 Local Climatological Data Annual Summary 39 with Comparative Data, Jackson, Mississippi. National Oceanic and Atmospheric 40 Administration, National Environmental Satellite, Data, and Information Service. Available at 41 <http://www7.ncdc.noaa.gov/IPS/lcd/lcd.html > (accessed 22 June 2012). 42 [NCDC] National Climatic Data Center. 2012. 2011 Local Climatological Data Annual Summary 43 with Comparative Data, Jackson, Mississippi (KJAN). National Oceanic and Atmospheric 44 Environmental Impacts of Operation 4-48 Administration, Satellite and Information Service. Available at 1 <http://www7.ncdc.noaa.gov/IPS/lcd/lcd.html > (accessed 19 June 2012). 2 [NEI] Nuclear Energy Institute. 2007. Industry Ground Water Protection Initiative - Final 3 Guidance Document. Washington, DC: Nuclear Energy Institute. NEI 07 -07 (Final]. 4 August 2007. ADAMS Accession No. ML091170588. 5 [NIEHS] National Institute of Environmental Health Sciences. 1999. NIEHS Report on Health 6 Effects from Exposure to Power -Line Frequency Electric and Magnetic Fields. Publication 7 No. 99-4493. Research Triangle Park, NC: NIEHS. 80 p. Available at 8 <http://www.niehs.nih.gov/about/materials/niehsreport.pdf > (accessed 19 July 2012). 9 [NMFS] National Marine Fisheries Service. 2012. Letter from D. Bernhart, Southeast Assistant 10 Regional Administrator for Protected Resources, to D. Wrona, RPB2 Branch Chief, NRC. 11

Subject:

Reply to request for list of species at Grand Gulf Nuclear Station, Unit 1. 12 March 1, 2012. ADAMS Accession No. ML12065A167. 13 [NRC] U.S. Nuclear Regulatory Commission. 1973. Final Environmental Statement Related to 14 the Construction of Grand Gulf Nuclear Station Units 1 and 2. ADAMS Accession 15 No. ML021370537. 16 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 17 for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG -1437, Volumes 1 18 and 2. May 1996. ADAMS Accession Nos. ML040690705 and ML040690738. 19 [NRC] U.S. Nuclear Regulatory Commission. 1999

a. Section 6.3 - Transportation, Table 9.1, 20 Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic 21 Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC:

22 NRC. NUREG -1437, Volume 1, Addendum 1. August 1999. ADAMS Accession 23 No. ML04069 0 720. 24 [NRC] U.S. Nuclear Regulatory Commission. 1999

b. NUREG-1555, Supplement 1, Standard 25 Review Plans for Environmental Reviews for Nuclear Power Plants, Supplement 1: Operating 26 License Renewal. October 1999. Available at: http://www.nrc.gov/reading

-rm/doc-27 collections/nuregs/staff/sr1555/s1/sr1555s1.pdf. 28 [NRC] U.S. Nuclear Regulatory Commission. 2006. Environmental Impact Statement for an 29 Early Site Permit (ESP) at the Grand Gulf ESP Site. Washington, DC: NRC. Final Report. 30 NUREG-1817. April 2006. 876 p. ADAMS Accession No. ML060900037. 31 [NRC] U.S. Nuclear Regulatory Commission. 2012

a. Letter from D. Wrona, RPB2 Branch Chief, 32 NRC, to R. Watson, Louisiana Field Office, FWS.

Subject:

Request for list of protected species 33 within the area under evaluation for the Grand Gulf Nuclear Station, Unit 1, license renewal 34 application. January 19, 2012. ADAMS Accession No. ML11349A001. 35 [NRC] U.S. Nuclear Regulatory Commission. 2012

b. Letter from D. Wrona, RPB2 Branch Chief, 36 NRC, to S. Ricks, Mississippi Field Office, FWS.

Subject:

Request for list of protected species 37 within the area under evaluation for the Grand Gulf Nuclear Station, Unit 1, license renewal 38 application. January 20, 2012. ADAMS Accession No. ML12025A069. 39 [NRC] U.S. Nuclear Regulatory Commission. 2012

c. Letter from D. Wrona, RPB2 Branch Chief, 40 NRC, to D. Bernhart, Southeast Assistant Regional Administrator for Protected Resources, 41 NMFS.

Subject:

Request for list of protected species within the area under evaluation for the 42 Grand Gulf Nuclear Station, Unit 1, license renewal application. January 19, 2012. ADAMS 43 Accession No. ML11350A173. 44 Environmental Impacts of Operation 4-49 [NRC] U.S. Nuclear Regulatory Commission. 2012

d. Letter from D. Wrona, RPB2 Branch Chief, 1 NRC, to S. Surrette, Mississippi Natural Heritage Program, Mississippi Department of Wildlife, 2 Fisheries, and Parks.

Subject:

Request for list of protected species within the area under 3 evaluation for the Grand Gulf Nuclear Station, Unit 1, license renewal application. 4 January 20, 2012. ADAMS Accession No. ML11349A003. 5 [NRC] U.S. Nuclear Regulatory Commission. 2012

e. Letter from D. Wrona, RPB2 Branch Chief, 6 NRC, to C. Michon, Louisiana Natural Heritage Program, Louisiana Department of Wildlife and 7 Fisheries.

Subject:

Request for list of protected species within the area under evaluation for the 8 Grand Gulf Nuclear Station, Unit 1, license renewal application. February 6, 2012. ADAMS 9 Accession No. ML12005A163. 10 [NRC] U.S. Nuclear Regulatory Commission. 2012

f. Letter from D.J. Wrona, NRC, to R.

11 Nelson, Advisory Council on Historic Preservation.

Subject:

Grand Gulf Nuclear Station License 12 Renewal Environmental Review. January 19, 2012. ADAMS Accession No. ML11348A088. 13 [NRC] U.S. Nuclear Regulatory Commission. 2012

g. Letter from D.J. Wrona, NRC, to Phil 14 Boggan, Office of Historic Preservation.

Subject:

Grand Gulf Nuclear Station License Renewal 15 Environmental Review. January 20, 2012. ADAMS Accession No. ML11348A353. 16 [NRC] U.S. Nuclear Regulatory Commission. 2012

h. Letter from D.J. Wrona, NRC, to H.T.

17 Holmes, Mississippi Department of Archives and History.

Subject:

Grand Gulf Nuclear Station, 18 Unit 1, License Renewal Environmental Review. January 19, 2012. ADAMS Accession No. 19 ML11348A090. 20 [NRC] U.S. Nuclear Regulatory Commission. 2012

i. Letters from D.J. Wrona, NRC, to Chief 21 Gregory E. Pike, Choctaw Nation of Oklahoma; The Honorable Phyliss Anderson, Chief, 22 Mississippi Band of Choctaw Indians; Chairman Earl J. Barbry Jr., Tunica

-Biloxi Tribe of 23 Louisiana; and Principal Chief B. Cheryl Smith, Jena Band of Choctaw Indians.

Subject:

24 Request for Scoping Comments Concerning the Grand Gulf Nuclear Station, Unit 1, License 25 Renewal Application Review. January 19, 2012. ADAMS Accession No. ML11342A121. 26 [NRC] U.S. Nuclear Regulatory Commission. 2012

j. Letter from A. B. Wa ng, NRC, to Vice 27 President, Operations, Entergy Operations, Inc.,

Subject:

Grand Gulf Nuclear Station, Unit 1 -28 Issuance of Amendment RE: Extended Power Uprage. J ul y 18, 2012 (TAC No. ME4679) 29 ADAMS Accession No. ML121 210020. 30 [NRC] U.S. Nuclear Regulatory Commission. 2013a. Generic Environmental Impact Statement 31 for License Renewal of Nuclear Plants. Washington, DC: Office of Nuclear Reactor Regulation. 32 NUREG-1437, Revision 1, Volumes 1, 2, and 3. June 2013. ADAMS Accession Nos. 33 ML13106A241, ML13106A242, and ML13106A244. [NRC] U.S. Nuclear Regulatory 34 Commission. 2013b. Standard Review Plans for Environmental Reviews for Nuclear Power 35 Plants, Supplement 1: Operating License Renewal. Washington, D.C .: Office of Nuclear Reactor 36 Regulation. NUREG-1555, Supplement 1, Revision 1. June 2013. ADAMS Accession No. 37 ML13106A246. 38 of coastal 39 waters. ICES Journal of Marine Science, 66:1528 -1537. 40 [USCB] U.S. Census Bureau. 2012. American FactFinder, 2010 American Community Survey 41 and Data Profile Highlights Information on Mississippi Counties: Adams, Amite, Claiborne, 42 Copiah, Franklin, Hinds, Issaquena, Jefferson, Lincoln, Madison, Rankin, Sharkey, Simpson, 43 Warren, Wilkinson, Yazoo; and Louisiana Counties: Caldwell, Catahoula, Concordia, East 44 Carroll, Franklin, Madison, Richland, Tensas. Available at <http://factfinder.census.gov > and 45 <http://quickfacts.census.gov > (accessed April 2012). 46 Environmental Impacts of Operation 4-50 [USFS] U.S. Forest Service. 2003. Decision Notice and Finding of No Significant Impact: Utility 1 Corridor Maintenance for Wildlife Habitat Enhancement. September 2003. 139 p. Meadville, 2 MS: USFS Southern Region 8. ADAMS Accession No. ML12157A550. 3 [USGCRP] U.S. Global Change Research Program. 2009. Global Climate Change Impacts in 4 the United States. Karl TR, Melillo JM, Peterson TC, eds. Cambridge University Press: 5 New York, NY. Available at <http://library.globalchange.gov/products/assessments/2009 -6 national-climate-assessment/2009 -global-climate-change-impacts-in-the-united-states> 7 (accessed 11 May 2012). 8 [USGS] U.S. Geological Survey. 2001. "Mississippi Valley Loess Plains." Available at 9 <http://landcovertrends.usgs.gov/east/eco74Report.html > (accessed 13 June 2012). 10 5-1 5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS 1 This chapter describes environmental impacts from postulated accidents that might occur during 2 the period of extended operation. The term "accident" refers to any unintentional event outside 3 the normal plant operational envelope that results in a release or the potential for release of 4 radioactive materials into the environment. Two classes of postulated accidents are evaluated 5 in NUREG-1437 , Generic Environmental Impact Statement (GEIS) for License Renewal of 6 Nuclear Plants (NRC 1996). These are design -basis accidents (DBAs) and severe accidents. 7 5.1 Design-Basis Accidents 8 To receive U.S. Nuclear Regulatory Commission (NRC) approval to operate a nuclear power 9 facility, an applicant for an initial operating license must submit a safety analysis report (SAR) as 10 part of its application. The SAR presents the design criteria and design information for the 11 proposed reactor and comprehensive data on the proposed site. The SAR also discusses 12 various hypothetical accident situations and the safety features that are provided to prevent and 13 mitigate accidents. The NRC staff reviews the application to determine whether the plant 14 design meets the Commission's regulations and requirements and includes, in part, the nuclear 15 plant design and its anticipated response to an accident. 16 DBAs are those accidents that both the licensee and NRC staff evaluate to ensure that the plant 17 can withstand normal and abnormal transients and a broad spectrum of postulated accidents 18 without undue hazard to the health and safety of the public. A number of these postulated 19 accidents are not expected to occur during the life of the plant, but are evaluated to establish 20 the design basis for the preventive and mitigative safety systems of the facility. The acceptance 21 criteria for DBAs are described i n Title 10 of the Code of Federal Regulations (10 CFR) Part 50, 22 "Domestic Licensing of Production and Utilization Facilities," and 10 CFR Part 100, "Reactor 23 Site Criteria." 24 The environmental impacts of DBAs are evaluated during the initial licensing process, and the 25 ability of the plant to withstand these accidents is demonstrated to be acceptable before 26 issuance of the operating license. The results of these evaluations are found in licensee 27 documentation, such as the applicant's final safety analysis report, the safety evaluation report, 28 the final environmental statement, and Section 5.1 of this supplemental environmental impact 29 statement. A licensee is required to maintain the acceptable design and performance criteria 30 throughout the life of the plant, including any extended -life operation. The consequences for 31 these events are evaluated for the hypothetical maximum exposed individual; as such, changes 32 in the plant environment will not affect these evaluations. Because of the requirements that 33 continuous acceptability of the consequences and aging management programs be in effect for 34 the period of extended operation, the environmental impacts, as calculated for DBAs, should not 35 differ significantly from initial licensing assessments over the life of the plant, including the 36 period of extended operation. Accordingly, the design of the plant relative to DBAs during the 37 period of extended operation is considered to remain acceptable, and the environmental 38 impacts of those accidents were not examined further in the GEIS. 39 The Commission has determined that the environmental impacts of DBAs are of SMALL 40 significance for all plants because the plants were designed to successfully withstand these 41 accidents. Therefore, for the purposes of license renewal, DBAs are designated as a 42 Category 1 issue (Table 5-1). The early resolution of the DBAs makes them a part of the 43 current licensing basis of the plant; the current licensing basis of the plant is to be maintained by 44 Environmental Impacts of Postulated Accidents 5-2 the licensee under its current license and, therefore, under the provisions of 10 CFR 54.30, 1 "Matters Not Subject to Renewal Review," is not subject to review under license renewal. 2 Table 5-1. Issues Related to Postulated Accidents 3 Issue Category Design-basis accidents 1 Severe accidents 2 Two issues related to postulated accidents are evaluated under the National Environmental Policy A ct in the license renewal review, design -basis accidents, and severe accidents . No new and significant information related to DBAs was identified during the review of the 4 Entergy Operations, Inc., (Entergy) Environmental Report (ER) (Enter gy 2011) or evaluation of 5 other available information. Therefore, there are no impacts related to these issues beyond 6 those discussed in the GEIS. 7 5.2 Severe Accidents 8 Severe nuclear accidents are those that are more severe than DBAs because they could 9 result in substantial damage to the reactor core, whether or not there are serious offsite 10 con sequences. In the GEIS, the NRC staff assessed the impacts of severe accidents during the 11 license renewal period, using the results of existing analyses and site -specific information to 12 conservatively predict the environmental impacts of severe accidents for each plant during the 13 renewal period. 14 Severe accidents initiated by external phenomena such as tornadoes, floods, earthquakes, 15 fires, and sabotage have not traditionally been discussed in quantitative terms in final 16 environmental statements and were not specifically considered for the Grand Gulf Nuclear 17 Station (GGNS) site in the GEIS (NRC 1996). However, the GEIS did evaluate existing impact 18 assessments performed by the NRC and by the industry at 44 nuclear plants in the 19 United States and concluded that the risk from beyond -design-basis earthquakes at existing 20 nuclear power plants is SMALL. The GEIS for license renewal performed a discretionary 21 analysis of terrorist acts in connection with license renewal and concluded that the core damage 22 and radiological release from such acts would be no worse than the damage and release 23 expected from internally initiated events. In the GEIS, the Commission concludes that the 24 probability -weighted consequences of severe accidents are SMALL and, additionally, that the 25 risks from other external events are adequately addressed by a generic consideration of 26 internally initiated severe accidents (NRC 1996). 27 Based on information in the GEIS, the Commission found that 28 The probability -weighted consequences of atmospheric releases, fallout onto 29 open bodies of water, releases to ground water, and societal and economic 30 impacts from severe accidents are small for all plants. However, alternatives to 31 mitigate severe accidents must be considered for all plants that have not 32 considered such alternatives. 33 The NRC staff identified no new and significant information related to postulated accidents 34 during the review of Entergy's ER (Entergy 2011, 2012c) or evaluation of other available 35 information. Therefore, there are no impacts related to these issues beyond those discussed in 36 the GEIS. However, in accordance with 10 CFR 51.53(c)(3)(ii)(L), the NRC staff has reviewed 37 Environmental Impacts of Postulated Accidents 5-3 severe accident mitigation alternative s (SAMAs) for GGNS. The results of the review are 1 discussed in Section 5.3. 2 5.3 Severe Accident Mitigation Alternatives 3 If the NRC staff has not previously evaluated SAMAs for the applicant's plant in an 4 environmental impact statement (EIS) or related supplement or in an environmental 5 assessment, 10 CFR 51.53(c)(3)(ii)(L) requires that license renewal applicants consider 6 alternatives to mitigate severe accidents. The purpose of this consideration is to ensure that 7 plant changes (i.e., hardware, procedures, and training) with the potential for improving severe 8 accident safety performance are identified and evaluated. SAMAs have not previously been 9 considered for GGNS; therefore, the remainder of Chapter 5 addresses those alternatives. 10 5.3.1 Overview of SAMA Process 11 This section presents a summary of the results of the SAMA evaluation for GGNS conducted by 12 Entergy, as described in Attachment E of Entergy's ER (Entergy 201 1, 2012c), the NRC staff's 13 review of Entergy's SAMA evaluation provided in detail in Appendix F, and associated requests 14 for additional information (RAIs) issued by the NRC staff and responses from Entergy 15 (Entergy 2012a, 2012b, 2012c, 2012d). The NRC staff performed its review with contract 16 assistance from the Center for Nuclear Waste Regulatory Analyses. 17 The SAMA evaluation for GGNS was conducted with a four -step approach. In the first step, 18 Entergy quantified the level of risk associated with potential reactor accidents using the 19 plant-specific probabilistic risk assessment (PRA) and other risk models. 20 In the second step, Entergy examined the major risk contributors and identified possible ways 21 (SAMAs) of reducing that risk. Common ways of reducing risk are changes to components, 22 systems, procedures, and training. 23 In the third step, Entergy estimated the benefits and the costs associated with each of the 24 candidate SAMAs. Estimates were made of how much each SAMA could reduce risk. Those 25 estimates were developed in terms of dollars in accordance with NRC guidance for performing 26 regulatory analyses. The cost s of implementing the candidate SAMAs also were estimated. 27 In the fourth step , Entergy compared the cost and benefit of each of the remaining SAMAs t o 28 determine whether the SAMA was cost-beneficial, meaning the benefits of the SAMA were 29 greater than the cost (a positive cost -benefit ratio). Finally, the four potentially cost -beneficial 30 SAMAs are evaluated to determine if they are in the scope of license renewal, i.e., are they 31 subject to aging management. 32 5.3.2 Estimate of Risk 33 Entergy submitted an assessment of SAMAs for the GGNS as part of the ER 34 (Entergy 2011, 2012c). The assessments were based on the most recent GGNS PRA available 35 at that time, a plant -specific offsite consequence analysis performed using the MELCOR 36 Accident Consequence Code System 2 (MACCS2) computer code, and insights from the GGNS 37 individual plant examination (IPE) (Entergy 1992) and individual plant examination of external 38 events (IPEEE) (Entergy 1995). 39 Entergy combined two distinct analyses to form the basis for the risk estimates used in the 40 SAMA analysis: (1) the GGNS Level 1 and 2 PRA model, and (2) a supplemental analysis of 41 offsite consequences and economic impacts (essentially a Level 3 PRA model) developed 42 specifically for the SAMA analysis. The SAMA analysis is based on the most recent GGNS 43 Environmental Impacts of Postulated Accidents 5-4 Level 1 and Level 2 PRA model available at the time of the ER, referred to as the 2010 1 extended power uprate (EPU) model. 2 The GGNS core damage frequency (CDF) is approximately 2.9 x 106 per reactor year as 3 determined from quantification of the Level 1 PRA model with the revised Level 2 model. This 4 value was used as the baseline CDF in the SAMA evaluations (Entergy 2012c, 2012d). The 5 CDF is based on the risk assessment for internally initiated events, which includes internal 6 flooding. Entergy did not explicitly include the contribution from external events within the 7 GGNS risk estimates; however, it did account for external event impacts on the potential risk 8 reduction associated with SAMA implementation by multiplying the estimated risk reduction for 9 internal events by a factor of

11. This is discussed further in Sections F.2.2 and F.6.2. Using 10 the calculated risk reduction as a quantitative measure of the potential benefit from SAMA 11 implementation, Entergy performed a cost

-benefit comparison, as described in Section 5.3.5. 12 The breakdown of CDF by initiating event is provided in Table 5-2. As shown in this table, loss 13 of offsite power and power conversion system available transient are the dominant contributors 14 to the CDF. Not listed explicitly in Table 5 -2 because multiple initiators contribute to their 15 occurrence, station blackout s contribute about 37 percent (1.1 x 106 per reactor year) of the 16 total CDF, while anticipated transients without scram contribute about 0.2 percent 17 (4.4 x 109 per reactor year) to the total CDF (Entergy 2012c). 18 The Level 2 PRA model that forms the basis for the GGNS SAMA evaluation is essentially a 19 new model and reflects power uprate conditions. The Level 2 model uses containment event 20 trees (CETs) containing both phenomenological and systemic events. The Level 1 core 21 damage sequences are binned into accident classes (or plant damage states) that provide the 22 interface between the Level 1 and Level 2 CET analysis. The CETs are linked directly to the 23 Level 1 event trees, and CET nodes are evaluated using subordinate trees and logic rules. 24 Table 5-2. GGNS Core Damage Frequency (CDF) for Internal Events 25 Initiating Event CDF (per year)

% CDF Contribution Loss of Offsite Power Initiator 1.2 x 106 40 Power Conversion System Available Transient 5.9 x 107 20 Loss of Power Conversion System Initiator 2.5 x 107 8 Loss of Condensate Feed Water Pumps 2.3 x 107 8 Loss of Instrument Air 1.4 x 107 5 Closure of Main Steam Isolation Valves (Initiator) 1.2 x 107 4 Loss of Service Transformer 21 1.2 x 107 4 Large Loss of Coolant Accident (LOCA) 9.7 x 108 3 Loss of Service Transformer 11 8.3 x 108 3 Loss of Alternating Current Division 2 Initiator 6.2 x 108 2 Other Initiating Events1 3.3 x 108 1 Loss of Alternating Current Division 1 Initiator 2.7 x 108 1 Intermediate LOCA 1.4 x 108 1 Total CDF (Internal Events) 2.9 x 106 100 1 Multiple initiating events, with each contributing 

0.3 percent

or less Environmental Impacts of Postulated Accidents 5-5 The CET considers the influence of physical and chemical processes on the integrity of the 1 containment and on the release of fission products once core damage has occurred. The 2 quantified CET sequences are binned into a set of end states that are subsequently grouped 3 into 13 release categories (or release modes) that provide the input to the Level 3 4 consequence analysis. The frequency of each release category was obtained by summing the 5 frequency of the individual accident progression CET endpoints binned into the release 6 category. Source terms were developed for the release categories using the results of Modular 7 Accident Analysis Program (MAAP 4.0.6) computer code calculations. From these results, 8 source terms were chosen to be representative of the release categories. The results of this 9 analysis for GGNS are provided in the revised Table E.1-9 of ER Attachment E (Entergy 2012c). 10 Entergy computed offsite consequences for potential releases of radiological material using the 11 MACCS2 Version 1.13.1 code and analyzed exposure and economic impacts from its 12 determination of offsite and onsite risks. Inputs for these analyses include plant -specific and 13 site-specific input values for core radionuclide inventory, source term and release 14 characteristics, site meteorological data, projected population distribution and growth within a 15 50-mile (80-kilometer) radius, emergency response evacuation modeling, and local economic 16 data. Radionuclide inventory in the reactor core is based on a plant -specific evaluation and 17 corresponds to that for the extended power uprate to 4,408 megawatts thermal (Entergy 2011). 18 The estimation of onsite impacts (in terms of clean up and decontamination costs and 19 occupational dose) is based on guidance in NUREG/BR -0184 , Regulatory Analysis Technical 20 Evaluation Handbook (NRC 1997). 21 In the ER, the applicant estimated the dose risk to the population within 80 kilometers (50 miles) 22 of the GGNS site to be 0.00609 person-sieverts (Sv) per year (0.609 person-roentgen 23 equivalent in man (rem) per year) (Entergy 2012c). The breakdown of the population dose risk 24 and offsite economic cost risk by containment release mode is summarized in Table 5-3. 25 Medium releases provide the greatest contribution, totaling approximately 67 percent of the 26 population dose risk and 75 percent of the offsite economic cost risk for all timings. High early 27 (H/E) releases alone contribute only about 10 percent, and high releases for all timings 28 contribute 17 percent of the population dose risk. 29 The NRC staff has reviewed Entergy's data and evaluation methods and concludes that the 30 quality of the risk analyses is adequate to support an assessment of the risk reduction potential 31 for candidate SAMAs. Accordingly, the NRC staff based its assessment of offsite risk on the 32 CDFs and offsite doses reported by Entergy. 33 5.3.3 Potential Plant Improvements 34 Entergy's process for identifying potential plant improvements (SAMAs) consisted of the 35 following elements: 36 review of industry documents and consideration of other plant-specific 37 enhancements not identified in published industry documents 38 review of potential plant improvements identified in the GGNS IPE and IPEEE 39 review of potential modifications for the risk-significant events in the current 40 GGNS PRA Levels 1 and 2 models 41 Environmental Impacts of Postulated Accidents 5-6 Table 5-3. Base Case Mean Population Dose Risk and Offsite Economic Cost Risk 1 for Internal Events 2 Release Mode Population Dose Risk 1 Offsite Economic Cost Risk ID 2 Frequency (per year) person-rem/yr % Contribution

$/yr % Contribution H/E 1.0 x 107 6.2 x 102 10 1.7 x 10+2 11 H/I 1.2 x 108 6.2 x 103 1 1.7 x 10+1 1 H/L 9.2 x 108 3.8 x 102 6 9.6 x 10+1 6 M/E 3.7 x 107 1.7 x 101 28 4.8 x 10+2 32 M/I 1.8 x 107 1.2 x 101 20 3.3 x 10+2 22 M/L 3.0 x 107 1.2 x 101 19 3.2 x 10+2 21 L/E 4.1 x 109 4.0 x 104 <0.1 3.0 x 101 <0.1 L/I 3.6 x 108 1.2 x 102 2 2.7 x 10+1 2 L/L 4.4 x 107 7.8 x 102 13 7.4 x 10+1 5 LL/E 2.2 x 109 7.9 x 107 <0.1 1.0 x 103 <0.1 LL/I 2.1 x 109 3.8 x 107 <0.1 9.7 x 104 <0.1 LL/L 7.1 x 109 2.0 x 103 <1  3.4 x 10 <1 NCF 1.4 x 106 5.0 x 104 <0.1 6.4 x 101 <0.1   6.1 x 101 100 1.5 x 10+3 100  1 Unit Conversion Factor:  1 Sv = 100 rem 2 Release Mode Nomenclature (Magnitude/Timing)

Magnitude: High (H) - Greater than 10 percent release fraction for Cesium Iodide Medium (M) - 1 to 10 percent release fraction for Cesium Iodide Low (L) - 0.1 to 1 percent release fraction for Cesium Iodide Low-low (LL) - Less than 0.1 percent release fraction for Cesium Iodide No containment failure (NCF) - Much less than 0.1 percent release fraction for Cesium Iodide Timing: Early (E) - Less than 4 hours Intermediate (I) - 4 to 24 hours Late (L) - Greater than 24 hours Based on this process, Entergy identified an initial set of 249 candidate SAMAs, referred to as 3 Phase I SAMAs. In Phase I of the evaluation, Entergy performed a qualitative screening of 4 the initial list of SAMAs and eliminated SAMAs from further consideration using the 5 following criteria: 6 t he SAMA modified features not applicable to GGNS. 7 the SAMA has already been implemented at GGNS. 8 the SAMA is similar in nature and could be combined with another SAMA 9 candidate. 10 Environmental Impacts of Postulated Accidents 5-7 Based on this screening, 60 of the Phase I SAMA candidates were screened out because they 1 were not applicable to GGNS, 98 candidates were screened out because they had already been 2 implemented at GGNS, and 28 candidates were screened out because they were similar in 3 nature and could be combined with another SAMA candidate. Thus, a total of 186 SAMAs were 4 eliminated, leaving 63 SAMAs for further evaluation. The results of the Phase I screening 5 analysis for each SAMA candidate were provided in a response to an NRC staff RAI 6 (Entergy 2012 a). The remaining SAMAs, referred to as Phase II SAMAs, are listed in 7 Table E.2-2 of Attachment E to the ER in the original submittal (Entergy 2011) and in the 8 revised analysis (Entergy 2012c). In Phase II, a detailed evaluation was performed for each of 9 t he 63 remaining SAMA candidates. 10 The NRC staff concludes that Entergy used a systematic and comprehensive process for 11 identifying potential plant improvements for GGNS, and that the set of SAMAs evaluated in the 12 ER, together with those evaluated in response to NRC staff inquiries, is reasonably 13 comprehensive and, therefore, acceptable. This search included reviewing insights from the 14 GGNS plant -specific risk studies that included internal initiating events, as well as fire, seismic, 15 and other external initiated events, and reviewing plant improvements considered in previous 16 SAMA analyses. 17 5.3.4 Evaluation of Risk Reduction and Costs of Improvements 18 In the ER, the applicant evaluated the risk -reduction potential of the 63 SAMAs that were not 19 screened out in the Phase I analysis and retained for the Phase II evaluation. The SAMA 20 evaluations were performed using generally conservative assumptions. 21 Except for two SAMAs associated with internal fires, Entergy used model re -quantification to 22 determine the potential benefits for each SAMA. The CDF, population dose, and offsite 23 economic cost reductions were estimated using the GGNS 2010 EPU PRA model for the nonfire 24 SAMAs. The changes made to the model to quantify the impact of SAMAs are detailed in 25 Section E.2.3 of Attachment E to the ER (Entergy 2011). Bounding evaluations (or analysis 26 cases) were performed to address specific SAMA candidates or groups of similar SAMA 27 candidates. For the two fire -related SAMAs (SAMA Nos. 54 and 55), the benefit was 28 determined by assuming the CDF contribution for the fire area impacted by the SAMA was 29 reduced to zero and that the resulting benefit was determined by the product of the fraction of 30 the internal events total CDF represented by the fire area CDF and the maximum total internal 31 events benefit. 32 For the SAMAs determined to be potentially cost -beneficial, Table 5-4 lists the assumptions 33 considered to estimate the risk reduction, the estimated risk reduction in terms of percent 34 reduction in CDF, population dose risk and offsite economic cost risk, and the estimated total 35 benefit (present value) of the averted risk. The estimated benefits reported in Table 5-4 reflect 36 the combined benefit in both internal and external events. The determination of the benefits for 37 the various SAMAs is further discussed in Section F.6. 38 Entergy estimated the costs of implementing the 63 Phase II SAMAs through the use of other 39 licensees' estimates for similar improvements and the development of site -specific cost 40 estimates, where appropriate. Information on the assumptions, risk reduction, estimated total 41 benefit, and implementation costs for the 63 Phase II SAMAs is presented in Table F-5. 42 Environmental Impacts of Postulated Accidents 5-8 Table 5-4. Severe Accident Mitigation Alternatives Cost -Benefit Analysis for GGNS. Percentage Risk Reductions are 1 Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) 2 Analysis Case, Analysis Assumption, Individual SAMA, and Cost Estimate

% Risk Reduction CDF PDR OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 28. Increase Availability of Containment Heat Removal Assumption:  Eliminates failure of cooled flow from residual heat removal pump A and B SAMA No. 39-Procedural change to cross

-tie open cycle cooling system to enhance containment spray system

$25,000  17.8% 45.6% 50.2% $2 97 ,000 $8 92 ,000 Case 30. Increase Availability of the Condensate Storage Tank Assumption:  Eliminates failure of high pressure core spray and reactor  core isolation cooling suction SAMA No. 42-Enhance procedures to refill condensate storage tank from demineralized water or service water system
$200,000  4.4% 12.6% 13.5% $77,000 $231,000 Case 43. Increase Recovery Time of Emergency Core Cooling System Upon Loss of Standby Service Water Assumption:  Eliminates failure of standby service water to the low pressure core spray room cooler SAMA No. 59-Increase operator training for alternating operation of the low

-pressure emergency core cooling system pumps (low-pressure coolant injection and low -pressure core spray) for loss of standby service water scenarios

$50,000  4.5% 5.2% 5.5% $53,300 $1 60 ,000 Environmental Impacts of Postulated Accidents 5-9 Analysis Case, Analysis Assumption, Individual SAMA, and Cost Estimate
% Risk Reduction CDF PDR OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 22. Increase Availability of the Diesel Generator System through Heating, Ventilation, and Air Conditioning Improvements Assumption:  Eliminates failure of heating, ventilation, and air conditioning for diesel generator rooms SAMA (Unnumbered) in Response to Request for Additional Information No.

8a-Revise procedures to direct the operator monitoring a running diesel generator to ensure that the ventilation system is running or take action to open doors or use portable fans

$50,000 to $200,000  23.9% 16.6% 12.3% $237,000 $711,000 Environmental Impacts of Postulated Accidents 5-10 Entergy stated the following cost ranges were used based on the review of previous 1 SAMA applications.

2 Table 5-5. Estimated Cost Ranges for SAMA Applications 3 Type of Change Estimated Cost Range Procedural only

$25K to $50K Procedural change with engineering or training required
$50K to $200K Procedural change with engineering and testing or training required $200K to $300K Hardware modification
$100K to >$1,000K Source:  Entergy 2011 Entergy stated that the GGNS site

-specific cost estimates were based on the engineering 4 judgment of project engineers experienced in performing design changes at the facility. The 5 detailed cost estimates considered engineering, labor, materials, and support functions, such as 6 planning, scheduling, health physics, quality assurance, security, safety, and fire watch. T he 7 estimates included a 20 percent contingency on the design and installation costs but did not 8 account for inflation, replacement power during extended outages necessary for SAMA 9 implementation, or increased maintenance or operation costs following SAMA implementation. 10 In response to an NRC staff RAI concerning the applicability of cost estimates taken directly 11 from previous SAMA applications, Entergy stated that engineering judgment by project 12 engineers familiar with the costs of modifications at Entergy plants was used to determine if the 13 cited cost estimates from other SAMA analyses were valid for GGNS. If the GGNS project 14 engineers' rough conceptual cost estimate of the modification was larger than the other plant's 15 cost estimate, the other plant's estimate was adopted without further detailed cost analysis 16 (Entergy 2012a). 17 The NRC staff reviewed the applicant's cost estimates, presented in Table E.2-2 of 18 Attachment E to the ER in the original submittal (Entergy 2011) and as a response to NRC staff 19 RAIs (Entergy 2012a, 2012c). For certain improvements, the NRC staff also compared the cost 20 estimates to estimates developed elsewhere for similar improvements, including estimates 21 developed as part of other licensees' analyses of SAMAs for operating reactors. The NRC staff 22 concludes that, with the above clarifications, the cost estimates provided by Entergy are 23 sufficient and appropriate for use in the SAMA evaluation. 24 5.3.5 Cost-Benefit Comparison 25 If the implementation costs for a candidate SAMA exceeded the calculated benefit, the SAMA 26 was determined to be not cost -beneficial. If the benefit exceeded the estimated cost, the SAMA 27 candidate was considered to be cost -beneficial. In Entergy's original submittal and revised 28 analysis, three SAMA candidates were found to be potentially cost -beneficial 29 (Entergy 2011, 2012c). In response to an RAI by NRC staff concerning potential low-cost 30 alternatives, Entergy determined that a procedure revision to direct that the operator monitoring 31 a running diesel ensure the ventilation system is running, or take action to open doors, or use 32 portable fans would be potentially cost-beneficial (Entergy 2012a, 2012c). Results of the 33 cost-benefit evaluation are presented in Table 5-4 for the four potentially cost -beneficial 34 Environmental Impacts of Postulated Accidents 5-11 SAMAs. Entergy initiated a condition report to evaluate these potentially cost -beneficial SAMAs 1 within the corrective action process. 2 The potentially cost -beneficial SAMAs are: 3 SAMA No. 39-Change procedure to cross tie open cycle cooling system to 4 enhance containment spray system. 5 SAMA No. 42-Enhance procedures to refill condensate storage tank from 6 demineralized water or service water system. 7 SAMA No. 59-Increase operator training for alternating operation of the low 8 pressure emergency core cooling system pumps (low -pressure coolant 9 injection and low pressure core spray) for loss of standby service water 10 scenarios. 11 SAMA (Unnumbered) in Response to RAI No. 8a-Revise procedures to 12 direct the operator monitoring a running diesel generator to ensure that the 13 ventilation system is running or take action to open doors or use portable 14 fans. 15 A sensitivity analysis considered two cases: a discount rate of 7 percent with a 33-year period 16 for remaining plant life and a lower (i.e., more conservative) discount rate of 3 percent with a 17 20-year license renewal period (Entergy 2011). Based on its sensitivity analysis, Entergy did 18 not identify any additional cost -beneficial SAMAs. Sensitivity analysis results were recast in the 19 revised SAMA analysis (Entergy 2012c). In response to an NRC RAI on the unexpected large 20 increase in the sensitivity to the discount rate shown in the revised results, Entergy described 21 that the sensitivity calculation for the lower discount rate of 3 percent inadvertently included the 22 cumulative effect of both the longer time period of remaining plant life of 33 years and the lower 23 discount rate (Entergy 2012d). Without the additional effect from a longer time period, 24 increases in the benefit solely because of a lower discount rate would be smaller than those 25 results reported by Entergy (2012c). 26 Individual (as well as cumulative) increases in the estimated benefits from the sensitivity 27 parameters were smaller than the factor of 3 applied by the applicant to account for uncertainty. 28 In the revised analysis, neither individual nor cumulative sensitivity effects resulted in benefit 29 estimates for individual SAMAs that exceeded GGNS implementation costs beyond the SAMAs 30 previously identified by Entergy to be potentially cost -beneficial. Based primarily on 31 NUREG/BR-0184 (NRC 1997) and discount rate guidelines in NEI 05-01 (NEI 2005), t he 32 cost-benefit analysis performed by Entergy was consistent with the guidance. The applicant 33 considered possible increases in benefits from analysis uncertainties on the results of the SAMA 34 assessment. In the ER (Entergy 2011), Entergy stated that the 95 th percentile value of the 35 GGNS CDF was a factor of 2.38 greater than the mean CDF. A multiplication factor of 3 was 36 selected by the applicant to account for uncertainty. This multiplication factor was applied in 37 addition to a separate multiplication factor of 11 for CDF increases caused by external events. 38 Entergy's assessment accounted for the potential risk -reduction benefits associated with both 39 internal and external events. NRC staff considers the multipliers of 3 for uncertainty and 11 for 40 external events provide adequate margin and are acceptable for the SAMA analysis. 41 5.3.6 Conclusions 42 Entergy considered 249 candidate SAMAs based on risk -significant contributors at GGNS from 43 updated probabilistic safety assessment models, its review of SAMA analyses from other 44 boiling-water reactor (BWR) plants, NRC and industry documentation of potential plant 45 Environmental Impacts of Postulated Accidents 5-12 improvements, and GGNS individual plant examination of internal and external events, including 1 available updates. Phase I screening reduced the list to 63 unique SAMA candidates by 2 eliminating SAMAs that were not applicable to GGNS, had already been implemented at GGNS, 3 or were combined into a more comprehensive or plant -specific SAMA. 4 For the remaining SAMA candidates, Entergy performed a cost -benefit analysis. Entergy's 5 cost-benefit analysis identified three potentially cost-beneficial SAMAs (Phase II SAMA 6 Nos. 39, 42, and 59). In response to an NRC staff RAI concerning potential low-cost 7 alternatives, Entergy identified one additional cost -beneficial SAMA. Sensitivity cases were 8 analyzed for the present value discount rate and time period for remaining plant life. No 9 additional SAMAs were identified as potentially cost -beneficial from the sensitivity analysis. 10 NRC staff reviewed the Entergy SAMA analysis and concludes that, subject to the discussion in 11 this chapter and Appendix F, the methods used and implementation of the methods were 12 sound. On the basis of the applicant's treatment of SAMA benefits and costs, NRC staff finds 13 that the SAMA evaluations performed by Entergy are reasonable and sufficient for the license 14 renewal submittal. 15 The NRC staff agrees with Entergy's conclusion that four candidate SAMAs are potentially 16 cost-beneficial, a decision based on a reasonable treatment of costs, benefits, and 17 uncertainties. This conclusion of a small number of potentially cost -beneficial SAMAs is 18 consistent with the low residual level of risk stated in the GGNS PRA and the fact that Entergy 19 has already implemented the plant improvements identified from the IPE and IPEEE. 20 Finally, the four potentially cost -beneficial SAMAs are evaluated to determine if they are in the 21 scope of license renewal, i.e., are they subject to aging management. This evaluation considers 22 whether the systems, structures, and components (SSCs) associated with these SAMAs: 23 (1) perform their intended function without moving parts or without a change in configuration or 24 properties; and (2) that these SSCs are not subject to replacement based on qualified life or 25 specified time period. Because the potentially cost -beneficial SAMAs do not relate to aging 26 management during the period of extended operation, they do not need to be implemented as 27 part of license renewal in accordance with 10 CFR Part 54. Nevertheless, Entergy issued a 28 condition report under the corrective action process to evaluate these potentially cost -beneficial 29 SAMAs. The NRC staff accepts this course of action. 30 5.4 References 31 [Entergy] Entergy Operations, Inc. 1992. "Individual Plant Examination (IPE) for Grand Gulf 32 Nuclear Station Unit 1." December 1992. 33 [Entergy] Entergy Operations, Inc. 1995. Letter from M.J. Meisner, Entergy, to U.S. NRC 34 Document Control Desk.

Subject:

"Grand Gulf Nuclear Station Docket No.

50-416 License 35 No. NPF-29 Individual Plant Examination of External Events (IPEEE) Schedule Final 36 Submittal." November 15, 1995 (not publicly available). 37 [Entergy] Entergy Operations, Inc. 2011. Grand Gulf Nuclear Station, Unit 1, License Renewal 38 Application , Appendix E, Applicant's Environmental Report, Operating License Renewal Stage . 39 Agencywide Documents Access and Management System (ADAMS) Accession 40 No. ML11308A234. 41 [Entergy] Entergy Operations, Inc. 2012a. Letter from Michael Perito, Entergy, to U.S. Nuclear 42 Regulatory Commission Document Control Desk.

Subject:

"Response to Request for Additional 43 Information (RAI) on Severe Accident Mitigation Alternatives dated May 21, 2012, Grand Gulf 44 Environmental Impacts of Postulated Accidents 5-13 Nuclear Station, Unit 1, Docket No. 50-416, License No. NPF -29." Port Gibson, MS. 1 July 19, 2012. Accessible at ADAMS Accession No. ML12202A056. 2 [Entergy] Entergy Operations, Inc. 2012b. Letter from Michael Perito, Entergy, to U.S. Nuclear 3 Regulatory Commission Document Control Desk.

Subject:

"Response to Request for Additional 4 Information (RAI) on Severe Accident Mitigation Alternatives dated August 23, 2012, Grand Gulf 5 Nuclear Station, Unit 1, Docket No. 50

-416, License No. NPF-29." Port Gibson, MS. 6 October 2, 2012. Accessible at ADAMS Accession No. ML12277A082. 7 [Entergy] Entergy Operations, Inc. 2012c. Letter from Michael Perito, Entergy, to U.S. Nuclear 8 Regulatory Commission Document Control Desk.

Subject:

"Reanalysis of Severe Accident 9 Mitigation Alternatives, Grand Gulf Nuclear Station, Unit 1, Docket No.

50-416, License 10 No. NPF-29." Port Gibson, MS. November 19, 2012. Accessible at ADAMS Accession 11 No. ML12325A174. 12 [Entergy] Entergy Operations, Inc. 2012d. Letter from Kevin J. Mulligan, Entergy, to 13 U.S. Nuclear Regulatory Commission Document Control Desk.

Subject:

"Response to 14 Clarification Questions on Reanalysis of Severe Accident Mitigation Alternatives (SAMA) Letter 15 dated November 19, 2012, Grand Gulf Nuclear Station, Unit 1, Docket No. 50-416, License 16 No. NPF-29." Port Gibson, MS. December 19, 2012. ADAMS Accession No. ML12359A038. 17 [NEI]Nuclear Energy Institute. 2005. "Severe Accident Mitigation Alternative (SAMA) Analysis 18 Guidance Document." NEI 05 -01, Revision A. Washington, DC. November 2005. 19 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 20 for License Renewal of Nuclear Plants. NUREG-1437, Washington, DC. Accessible at 21 <http://www.nrc.gov/reading -rm/doc-collections/nuregs/staff/sr1437/> (accessed 22 August 29, 2012). 23 [NRC] U.S. Nuclear Regulatory Commission. 1997. Regulatory Analysis Technical Evaluation 24 Handbook. NUREG/BR -0184. Washington, DC. ADAMS No. ML050190193. 25

6-1 6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE, 1 SOLID WASTE MANAGEMENT, AND GREENHOUSE GAS EMISSIONS 2 6.1 The Uranium Fuel Cycle 3 This section addresses issues related to the uranium fuel cycle and solid waste management 4 during the period of extended operation (listed in Table 6-1). The uranium cycle includes 5 uranium mining and milling, the production of uranium hexafluoride, isotopic enrichment, fuel 6 fabrication, reprocessing of irradiated fuel, transportation of radioactive materials an d 7 management of low -level wastes and high -level wastes related to uranium fuel cycle activities. 8 The generic potential impacts of the radiological and non -radiological environmental impacts of 9 the uranium fuel cycle and transportation of nuclear fuel and wastes are described in detail in 10 the Generic Environmental Impact Statement (GEIS) (NRC 1996, 1999). They are based, in 11 part, on the generic impacts provided in Title 10, Part 51.51(b) of the Code of Federal 12 Regulations (10 CFR 51.51(b)), Table S-3, "Table of Uranium Fuel Cycle Environmental Data," 13 and in 10 CFR 51.52(c), Table S-4, "Environmental Impact of Transportation of Fuel and Waste 14 to and from One Light-Water-Cooled Nuclear Power Reactor." 15 Table 6-1. Issues Related to the Uranium Fuel Cycle and Solid Waste Management. 16 There are nine generic issues related to the fuel cycle and waste management. There are no 17 site-specific issues. 18 Issues GEIS Sections Category Offsite radiological impacts (individual effects from other than the disposal of spent fuel and high-level waste) 6.1; 6.2.1; 6.2.2.1; 6.2.2.3; 6.2.3; 6.2.4; 6.6 1 Offsite radiological impacts (collective effects) 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6 1 Offsite radiological impacts (spent fuel and high-level waste disposal) 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6 1 Non-radiological impacts of the uranium fuel cycle 6.1; 6.2.2.6; 6.2.2.7; 6.2.2.8; 6.2.2.9; 6.2.3; 6.2.4; 6.6 1 Low-level waste storage and disposal 6.1; 6.2.2.2; 6.4.2; 6.4.3; 6.4.3.1; 6.4.3.2; 6.4.3.3; 6.4.4; 6.4.4.1; 6.4.4.2; 6.4.4.3; 6.4.4.4; 6.4.4.5; 6.4.4.5.1; 6.4.4.5.2; 6.4.4.5.3; 6.4.4.5.4; 6.4.4.6; 6.6 1 Mixed waste storage and disposal 6.4.5.1; 6.4.5.2; 6.4.5.3; 6.4.5.4; 6.4.5.5; 6.4.5.6; 6.4.5.6.1; 6.4.5.6.2; 6.4.5.6.3; 6.4.5.6.4; 6.6 1 Onsite spent fuel 6.1; 6.4.6; 6.4.6.1; 6.4.6.2; 6.4.6.3; 6.4.6.4; 6.4.6.5; 6.4.6.6; 6.4.6.7; 6.6 1 Non-radiological waste 6.1; 6.5; 6.5.1; 6.5.2; 6.5.3; 6.6 1 Transportation 6.1; 6.3.1; 6.3.2.3; 6.3.3; 6.3.4; 6.6, Addendum 1 1 The NRC staff's evaluation of the environmental impacts associated with spent nuclear fuel is 19 addressed in two issues in Table 6 -1, "Offsite radiological impacts (spent fuel and high-level 20 waste disposal)" and "Onsite spent fuel." However, as explained later in this section, the scope 21 of the evaluation of these issues in this supplemental environmental impact statement (SEIS) 22 has been revised. T he issue, "Offsite radiological impacts (spent fuel and high -level waste 23 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-2 disposal)," from Table 6 -1 is not evaluated in this SEIS. In addition, the issue, "Onsite spent 1 fuel" only evaluates the environmental impacts during the license renewal term. 2 For the term of license renewal, the NRC staff did not find any new and significant information 3 related to the remaining uranium fuel cycle and solid waste management issues listed in 4 Table 6-1 during its review of the GGNS environmental report (ER) (Entergy 2011), the site 5 visit, and the scoping process. Therefore, there are no impacts related to these issues beyond 6 those discussed in the GEIS. For these Category 1 issues, the GEIS concludes that the 7 impacts are SMALL, except for the issue, "Offsite radiological impacts (collective effects)," which 8 the NRC has not assigned an impact level. This issue assesses the 100 -year radiation dose to 9 the U.S. population (i.e., collective effects or collective dose) from radioactive effluents released 10 as part of the uranium fuel cycle for a nuclear power plant during the license renewal term 11 compared to the radiation dose from natural background exposure. It is a comparative 12 assessment for which there is no regulatory standard to base an impact level. 13 For the radiological impacts resulting from spent fuel and high-level waste disposal and the 14 onsite storage of spent fuel, which will occur after the reactors have been permanently 15 shutdown, the NRC's Waste Confidence Decision and Rule represented the Commission's 16 generic determination that spent fuel can continue to be stored safely and without significant 17 environmental impacts for a period of time after the end of the licensed life for operation. This 18 generic determination meant that the NRC did not need to consider the storage of spent fuel 19 after the end of a reactor's licensed life for operation in National Environmental Policy Act 20 (NEPA) documents that support its reactor and spent fuel storage application reviews. 21 The NRC first adopted the Waste Confidence Decision and Rule in 1984. The NRC amended 22 the decision and rule in 1990, reviewed them in 1999, and amended them again in 2010 23 (49 FR 34694; 55 FR 38474; 64 FR 68005; and 75 FR 81032 and 81037). The Waste 24 Confidence Decision and Rule are codified in 10 CFR 51.23. 25 On December 23, 2010, the Commission published in the Federal Register a revision of the 26 Waste Confidence Decision and Rule to reflect information gained from experience in the 27 storage of spent fuel and the increased uncertainty in the siting and construction of a permanent 28 geologic repository for the disposal of spent nuclear fuel and high -level waste (75 FR 81032 and 29 81037). In response to the 2010 Waste Confidence Decision and Rule, the states of New York, 30 New Jersey, Connecticut, and Vermont -along with several other parties -challenged the 31 Commission's NEPA analysis in the decision, which provided the regulatory basis for the rule. 32 On June 8, 2012, the United States Court of Appeals, District of Columbia Circuit in New York v. 33 NRC, 681 F.3d 471 (D.C. Cir. 2012) vacated the NRC's Waste Confidence Decision and Rule, 34 after finding that it did not comply with NEPA. 35 In response to the court's ruling, the Commission, in CLI 16 (NRC 2012 a), determined that it 36 would not issue licenses that rely upon the Waste Confidence Decision and Rule until the issues 37 identified in the court's decision are appropriately addressed by the Commission. In CLI 16, 38 the Commission also noted that the decision not to issue licenses only applies to final license 39 issuance; all licensing reviews and proceedings should continue to move forward. 40 In addition, the Commission directed, in SRM-COMSECY-12-0016 (NRC 2012b), that the NRC 41 staff proceed with a rulemaking that includes the development of a generic environmental 42 impact statement (EIS) to support a revised Waste Confidence Rule and to publish both the EIS 43 and the revised decision and rule in the Federal Register within 24 months (by 44 September 2014). The Commission indicated that both the EIS and the revised Waste 45 Confidence Rule should build on the information already documented in various NRC studies 46 and reports, including the existing environmental assessment that the NRC developed as part of 47 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-3 the 2010 Waste Confidence Decision and Rule. The Commission directed that any additional 1 analyses should focus on the issues identified in the court's decision. The Commission also 2 directed that the NRC staff provide ample opportunity for public comment on both the draft EIS 3 and the proposed rule. 4 The revised rule and supporting EIS are expected to provide the necessary NEPA analyses of 5 waste confidence -related human health and environmental issues. As directed by the 6 Commission, the NRC will not issue a renewed license before the resolution of waste 7 confidence -related issues. This will ensure that there w ill be no irretrievable or irreversible 8 resource commitments or potential harm to the environment before waste confidence impacts 9 have been addressed. 10 If the results of the Waste Confidence Rule and supporting EIS identify information that requires 11 a supplement to this SEIS, the NRC staff will perform any appropriate additional NEPA review 12 for those issues before the NRC makes a final licensing decision. 13 6.2 Greenhouse Gas Emissions 14 This section discusses the potential impacts from greenhouse gases (GHGs) emitted from the 15 nuclear fuel cycle. The GEIS does not directly address these emissions, and its discussion is 16 limited to an inference that substantial carbon dioxide (CO

2) emissions may occur if coal- or 17 oil-fired alternatives to license renewal are carried out.

18 6.2.1 Existing Studies 19 Since the development of the GEIS, the relative volumes of GHGs emitted by nuclear and other 20 electricity generating methods have been widely studied. However, estimates and projections 21 of the carbon footprint of the nuclear power lifecycle vary depending on the type of study done. 22 Additionally, considerable debate also exists among researchers on the relative effects of 23 nuclear and other forms of electricity generation on GHG emissions. Existing studies on GHG 24 emissions from nuclear power plants generally take two different forms: 25 (4) qualitative discussions of the potential to use nuclear power to reduce GHG emissions and 26 mitigate global warming, and 27 (5) technical analyses and quantitative estimates of the actual amount of GHGs generated by 28 the nuclear fuel cycle or entire nuclear power plant life cycle and comparisons to the 29 operational or life cycle emissions from other energy generation alternatives. 30 6.2.1.1 Qualitative Studies 31 The qualitative studies consist primarily of broad, large -scale public policy, or investment 32 evaluations of whether an expansion of nuclear power is likely to be a technically, economically, 33 or politically workable means of achieving global GHG reductions. Studies the staff found 34 during the subsequent literature search include the following: 35 Evaluations to determine if investments in nuclear power in developing 36 countries should be accepted as a flexibility mechanism to assist 37 industrialized nations in achieving their GHG reduction goals under the Kyoto 38 Protocols (IAEA 2000, NEA 2002, Schneider 2000). Ultimately, the parties to 39 the Kyoto Protocol did not approve nuclear power as a component under the 40 clean development mechanism (CDM) because of safety and waste disposal 41 concerns (NEA 2002). 42 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-4 Analyses developed to assist governments, including the United States, in 1 making long-term investment and public policy decisions in nuclear power 2 (Hagen et al. 2001, Keepin 1988, MIT 2003). 3 Although the qualitative studies sometimes reference and critique the existing quantitative 4 estimates of GHGs produced by the nuclear fuel cycle or life cycle, their conclusions generally 5 rely heavily on discussions of other aspects of nuclear policy decisions and investment, such as 6 safety, cost, waste generation, and political acceptability. Therefore, these studies typically are 7 not directly applicable to an evaluation of GHG emissions associated with the proposed license 8 renewal for a given nuclear power plant. 9 6.2.1.2 Quantitative Studies 10 A large number of technical studies, including calculations and estimates of the amount of 11 GHGs emitted by nuclear and other power generation options, are available in the literature and 12 were useful in the staff's efforts to address relative GHG emission levels. Examples of these 13 studies include -but are not limited to -Mortimer (1990), Andseta et al. (1998), Spadaro (2000), 14 Storm van Leeuwen and Smith (2008), Fritsche (2006), Parliamentary Office of Science and 15 Technology (POST) (2006), Atomic Energy Authority (AEA) (2006), Weisser (2006), Fthenakis 16 and Kim (2007), and Dones (2007). In addition, Sovacool (2008) provides a review and 17 synthesis of studies in existence through 2008; however, the Sovacool synthesis ultimately uses 18 only 19 of the 103 studies initially considered (the remaining 84 were excluded because they 19 were more than 10 years old, not publicly available, available only in a language other than 20 English, or they presented methodological challenges by relying on inaccessible data, providing 21 overall GHG estimates without allocating relative GHG impacts to different parts of the nuclear 22 lifecycle, or they were otherwise not methodologically explicit). 23 Comparing these studies and others like them is difficult because the assumptions and 24 components of the lifecycles that the authors evaluate vary widely. Examples of areas in which 25 differing assumptions make comparing the studies difficult include the following: 26 energy sources that may be used to mine uranium deposits in the future, 27 reprocessing or disposal of spent nuclear fuel, 28 current and potential future processes to enrich uranium and the energy 29 sources that will power them, 30 estimated grades and quantities of recoverable uranium resources, 31 estimated grades and quantities of recoverable fossil fuel resources, 32 estimated GHG emissions other than CO 2, including the conversion to CO 2 33 equivalents per unit of electric energy produced, 34 performance of future fossil fuel power systems, 35 projected capacity factors for alternatives means of generation, and 36 current and potential future reactor technologies. 37 In addition, studies may vary with respect to whether all or parts of a power plant's lifecycle are 38 analyzed (i.e., a full lifecycle analysis will typically address plant construction, operations, 39 resource extraction -for fuel and construction materials, and decommissioning), whereas a 40 partial lifecycle analysis primarily focuses on operational differences. In addition, as 41 Sovacool (2008) noted, studies vary greatly in terms of age, data availability, and 42 methodological transparency. 43 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-5 In the case of license renewal, a GHG analysis for the portion of the plant's lifecycle attributable 1 to license renewal (operation for an additional 20 years) would not involve GHG emissions 2 associated with construction because construction activities already have been completed at the 3 time of relicensing. In addition, the proposed action of license renewal also would not involve 4 additional GHG emissions associated with facility decommissioning because that 5 decommissioning must occur whether the facility is relicensed or not. However, in many 6 studies, the specific contribution of GHG emissions from construction, decommissioning, or 7 other portions of a plant's lifecycle cannot be clearly separated from one another. In such 8 cases, an analysis of GHG emissions would overestimate the GHG emissions attributed to a 9 specific portion of a plant's lifecycle. As Sovacool (2008) noted, many of the available analyses 10 provide markedly lower GHG emissions per unit of plant output when one assumes that a power 11 plant operates for a longer period of time. Nonetheless, available studies supply some 12 meaningful information on the relative magnitude of the emissions among nuclear power plants 13 and other forms of electric generation, as discussed in the following sections. 14 In Tables 6-2, 6-3, and 6-4, the staff presents the results of the above -mentioned quantitative 15 studies to supply a weight -of-evidence evaluation of the relative GHG emissions that may result 16 from the proposed license renewal compared to the potential alternative use of coal -fired, 17 natural gas -fired, and renewable generation. Most studies from Mortimer (1990) onward 18 (through Sovacool 2008) indicate that uranium ore grades and uranium enrichment processes 19 are leading determinants in the ultimate GHG emissions attributable to nuclear power 20 generation. These studies show that the relatively lower order of magnitude of GHG emissions 21 from nuclear power, when compared to fossil -fueled alternatives (especially natural gas), could 22 potentially disappear if available uranium ore grades drop sufficiently while enrichment 23 processes continued to rely on the same technologies. 24 Sovacool's synthesis of 19 existing studies found that nuclear power generation causes carbon 25 emissions in a range of 1.4 grams of carbon equivalent per kilowatt -hour (g C eq/kWh) to 26 288 g C eq/kWh, with a mean value of 66 g C eq/kWh. The results of his synthesis and the results 27 of others' efforts are included in the tables in this section. 28 6.2.1.3 Summary of Nuclear Greenhouse Gas Emissions Compared to Coal 29 Considering that coal fuels the largest share of electricity generation in the United States and 30 that its burning results in the largest emissions of GHGs for any of the likely alternatives to 31 nuclear power generation, including GGNS, many of the available quantitative studies focused 32 on comparing the relative GHG emissions of nuclear to coal -fired generation. The quantitative 33 estimates of the GHG emissions associated with the nuclear fuel cycle (and, in some cases, the 34 nuclear lifecycle), as compared to an equivalent coal -fired plant, are presented in Table 6-2. 35 The following table does not include all existing studies, but it gives an illustrative range of 36 estimates that various sources have developed. 37 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-6 Table 6-2. Nuclear Greenhouse Gas Emissions Compared to Coal 1 Source GHG Emission Results Mortimer (1990) Nuclear-230,000 tons CO 2 Coal-5,912,000 tons CO 2 Note: Future GHG emissions from nuclear to increase because of declining ore grade. Andseta et al. (1998) Nuclear energy produces 1.4% of the GHG emissions compared to coal. Note: Future reprocessing and use of nuclear -generated electrical power in the mining and enrichment steps are likely to change the projections of earlier authors, such as Mortimer (1990). Spadaro (2000) Nuclear-2.5-5.7 g Ceq/kWh Coal-264-357 g Ceq/kWh Fritsche (2006) (values estimated from graph in Figure 4) Nuclear-33 g Ceq/kWh Coal-950 g Ceq/kWh POST (2006) (nuclear calculations from AEA 2006) Nuclear-5 g Ceq/kWh Coal->1 ,000 g Ceq/kWh Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 6.8 g Ceq/kWh. Future improved technology and carbon capture and storage could reduce coal -fired GHG emissions by 90%. Weisser (2006) (compilation of results from other studies) Nuclear-2.8-24 g C eq/kWh Coal-950-1,250 g Ceq/kWh Sovacool (2008) Nuclear-66 g Ceq/kWh Coal -960-1,050 g Ceq/kWh (coal adopted from Gagnon et al. 2002) 6.2.1.4 Summary of Nuclear Greenhouse Gas Emissions Compared to Natural Gas 2 The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle (and, in 3 some cases, the nuclear lifecycle), as compared to an equivalent natural gas -fired plant, are 4 presented in Table 6-3. The following table does not include all existing studies, but it gives an 5 illustrative range of estimates various sources have developed. 6 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-7 Table 6-3. Nuclear Greenhouse Gas Emissions Compared to Natural Gas 1 Source GHG Emission Results Spadaro (2000) Nuclear-2.5-5.7 g Ceq/kWh Natural g as-120-188 g C eq/kWh Storm van Leeuwen and Smith (2008) Nuclear fuel cycle produces 20 -33% of the GHG emissions compared to natural gas (at high ore grades). Note: Future nuclear GHG emissions will increase because of declining ore grade. Fritsche (2006) (values estimated from graph in Figure 4) Nuclear-33 g Ceq/kWh Cogeneration combined cycle natural g as-150 g C eq/kWh POST (2006) (nuclear calculations from AEA, 2006) Nuclear-5 g Ceq/kWh Natural g as-500 g Ceq/kWh Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 6.8 g Ceq/kWh. Future improved technology and carbon capture and storage could reduce natural gas GHG emissions by 90%. Weisser (2006) (compilation of results from other studies) Nuclear-2.8-24 g C eq/kWh Natural g as-440-780 g C eq/kWh Dones (2007) Author critiqued methods and assumptions of Storm van Leeuwen and Smith (2005), and concluded that the nuclear fuel cycle produces 15-27% of the GHG emissions of natural gas. Sovacool (2008) Nuclear-66 g Ceq/kWh Natural g as-443 g Ceq/kWh (natural gas adopted from Gagnon et al. 2002) 6.2.1.5 Summary of Nuclear Greenhouse Gas Emissions Compared to Renewable Energy 2 Sources 3 The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle (and, in 4 some cases, the nuclear lifecycle), as compared to equivalent renewable energy sources, are 5 presented in Table 6-4. Calculation of GHG emissions associated with these sources is more 6 difficult than the calculations for nuclear energy and fossil fuels because of the large variation in 7 efficiencies and capacity factors because of their different technologies, sources, and locations. 8 For example, the efficiency of solar and wind energy is highly dependent on the wind or solar 9 resource in a particular location. Similarly, the range of GHG emissions estimates for 10 hydropower varies greatly depending on the type of dam or reservoir involved (if used at all). 11 Therefore, the GHG emissions estimates for these energy sources have a greater range of 12 variability than the estimates for nuclear and fossil fuel sources. The following table does not 13 include all existing studies, but it gives an illustrative range of estimates various sources have 14 developed. 15 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-8 Table 6-4. Nuclear Greenhouse Gas Emissions Compared to Renewable Energy Sources 1 Source GHG Emission Results Mortimer (1990) Nuclear-230,000 tons CO 2 Hydropower -78,000 tons CO 2 Wind power -54,000 tons CO 2 Tidal power -52,500 tons CO 2 Note: Future GHG emissions from nuclear are expected to increase because of declining ore grade. Spadaro (2000) Nuclear-2.5-5.7 g Ceq/kWh Solar PV-27.3-76.4 g Ceq/kWh Hydroelectric -1.1-64.6 g Ceq/kWh Biomass-8.4-16.6 g Ceq/kWh Wind-2.5-13.1 g Ceq/kWh Fritsche (2006) (values estimated from graph in Figure 4) Nuclear-33 g Ceq/kWh Solar PV-125 g Ceq/kWh Hydroelectric -50 g Ceq/kWh Wind-20 g Ceq/kWh POST (2006) (nuclear calculations from AEA 2006) Nuclear-5 g Ceq/kWh Biomass-25-93 g Ceq/kWh Solar PV-35-58 g Ceq/kWh Wave/Tidal 50 g Ceq/kWh Hydroelectric-5-30 g Ceq/kWh Wind-4.64-5.25 g Ceq/kWh Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 6.8 g Ceq/kWh. Weisser (2006) (compilation of results from other studies) Nuclear-2.8-24 g C eq/kWh Solar PV-43-73 g Ceq/kWh Hydroelectric-1-34 g Ceq/kWh Biomass-35-99 g Ceq/kWh Wind-8-30 g Ceq/kWh Fthenakis and Kim (2007) Nuclear-16-55 g Ceq/kWh Solar PV-17-49 g Ceq/kWh Sovacool (2008) (adopted from other studies) Nuclear-66 g Ceq/kWh Wind-9-10 g Ceq/kWh Hydroelectric (small, distributed) 13 g Ceq/kWh Biogas digester-11 g C eq/kWh Solar thermal-13 g Ceq/kWh Biomass-14-35 g Ceq/kWh Solar PV-32 g Ceq/kWh Geothermal (hot, dry rock) -38 g Ceq/kWh (solar PV value adopted from Fthenakis et al. 2008; all other renewable generation values adopted from Pehnt 2006) 6.2.2

Conclusions:

Relative Greenhouse Gas Emissions 2 The sampling of data presented in Tables 6-2 , 6-3, and 6-4 demonstrates the challenges of 3 any attempt to determine the specific amount of GHG emission attributable to nuclear energy 4 production sources because different assumptions and calculation methods will yield differing 5 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-9 results. The differences and complexities in these assumptions and analyses will further 1 increase when they are used to project future GHG emissions. Nevertheless, several 2 conclusions can be drawn from the information presented. 3 First, the various studies show a general consensus that nuclear power currently produces 4 fewer GHG emissions than fossil -fuel-based electrical generation (e.g., GHG emissions from a 5 complete nuclear fuel cycle currently range from 2.5 -66 grams of carbon equivalent per kilowatt 6 hour (g C eq/kWh), as compared to the use of coal plants (264-1, 250 g C eq/kWh) and natural gas 7 plants (120 -780 g C eq/kWh)). The studies also provide estimates of GHG emissions from five 8 renewable energy sources based on current technology. These estimates included 9 solar-photovoltaic (17 -125 g C eq/kWh), hydroelectric (1 -64.6 g C eq/kWh), biomass 10 (8.4-99 g C eq/kWh), wind (2.5 -30 g C eq/kWh), and tidal (25-50 g C eq/kWh). The range of these 11 estimates is wide, but the general conclusion is that current GHG emissions from nuclear power 12 generation are of the same order of magnitude as from these renewable energy sources. 13 Second, the studies show no consensus on future relative GHG emissions from nuclear power 14 and other sources of electricity. There is substantial disagreement among the various authors 15 about the GHG emissions associated with declining uranium ore concentrations, future uranium 16 enrichment methods, and other factors, including changes in technology. Similar disagreement 17 exists about future GHG emissions associated with coal and natural gas for electricity 18 generation. Even the most conservative studies conclude that the nuclear fuel cycle currently 19 produces fewer GHG emissions than fossil -fuel-based sources and is expected to continue to 20 do so in the near future. The primary difference between the authors is the projected cross -over 21 date (the time at which GHG emissions from the nuclear fuel cycle exceed those of 22 fossil-fuel-based sources) or whether cross -over will actually occur. 23 Considering current estimates and future uncertainties, it appears that GHG emissions 24 associated with the proposed GGNS relicensing action are likely to be lower than those 25 associated with fossil fuel-based energy sources. The staff bases this conclusion on the 26 following rationale: 27 As shown in Tables 6-2 and 6-3, current estimates of GHG emissions from 28 the nuclear fuel cycle are far below those for fossil fuel-based energy 29 sources. 30 License renewal of a nuclear power plant such as GGNS may involve 31 continued GHG emissions caused by uranium mining, processing, and 32 enrichment, but will not result in increased GHG emissions associated with 33 plant construction or decommissioning (since the plant will have to be 34 decommissioned at some point whether the license is renewed or not). 35 Few studies predict that nuclear fuel cycle emissions will exceed those of 36 fossil fuels within a timeframe that includes the GGNS period of extended 37 operation. Several studies suggest that future extraction and enrichment 38 methods, the potential for higher -grade resource discovery, and technology 39 improvements could extend this timeframe. 40 With respect to the comparison of GHG emissions among the proposed GGNS license renewal 41 action and renewable energy sources: 42 It appears likely that there will be future technology improvements and 43 changes in the type of energy used for mining, processing, manufacturing, 44 and constructing facilities of all types. 45 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-10 Currently, the GHG emissions associated with the nuclear fuel cycle and 1 renewable energy sources are within the same order of magnitude. 2 Because nuclear fuel production is the most significant contributor to possible 3 future increases in GHG emissions from nuclear power -and since most 4 renewable energy sources lack a fuel component -it is likely that GHG 5 emissions from renewable energy sources w ill be lower than those 6 associated with GGNS at some point during the period of extended operation. 7 The staff provides additional discussion on the contribution of GHG to cumulative air quality 8 impacts in Section 4.11.2 of this supplemental EIS. 9 6.3 References 10 75 FR 81032. U.S. Nuclear Regulatory Commission. Consideration of environmental impacts of 11 temporary storage of spent f uel after cessation of reactor operation. Federal Register 12 75(246):81032 -81037. December 23, 2010. 13 75 FR 81037. U.S. Nuclear Regulatory Commission. Waste confidence decision update. 14 Federal Register 75(246):81037 -81076. December 23, 2010. 15 [AEA] AEA Technology. 2006. "Carbon Footprint of the Nuclear Fuel Cycle, Briefing Note." East 16 Kilbride. UK: British Energy Group. March 2006. Available at <http://www.british -energy.com/ 17 documents/carbon_footprint.pd f> (accessed 21 May 2012 ). 18 Andseta S, Thompson MJ, Jarrell JP, Pendergast DR. 1998. CANDU Reactors and Greenhouse 19 Gas Emissions. Proceedings of the 19 th Annual Conference, Canadian Nuclear Society

20 1998 October 18

-21; Toronto, Ontario. Available at <http://www.computare.org/Support% 21 20documents/Publications/Life%20Cycle.htm>

(accessed 21 May 2012). 22 [Entergy] Entergy Operations, Inc. 2011. Grand Gulf Nuclear Station, Unit 1, License Renewal 23 Application , Appendix E, Applicant's Environmental Report, Operating License Renewal Stage. 24 Agencywide Documents Access and Management System (ADAMS)

Accession No. 25 ML11308A234. 26 Dones R. 2007. Critical Note on the Estimation by Storm Van Leeuwen JW and Smith P of the 27 Energy Uses and Corresponding CO 2 Emissions for the Complete Nuclear Energy Chain. 28 Villigen, Switzerland: Paul Sherer Institute. April 2007. Available at 29 <http://gabe.web.psi.ch/pdfs/Critical%20note%20GHG%20PSI.pdf> (accessed 21 May 2012 ). 30 Fritsche UR. 2006. Comparison of Greenhouse -Gas Emissions and Abatement Cost of Nuclear 31 and Alternative Energy Options from a Life -Cycle Perspective. Freiburg, Germany: Oko -Institut. 32 January 2006. Available at <http://www.oeko.de/oekodoc/315/2006 -017-en.pdf> (accessed 33 21 May 2012). 34 Fthenakis VM, Kim HC. 2007. Greenhouse -gas emissions from solar -electric and nuclear 35 power: A life cycle study. Energy Policy 35(4):2549 -2557. 36 [IAEA] International Atomic Energy Agency. 2000. Nuclear Power for Greenhouse Gas 37 Mitigation under the Kyoto Protocol: The Clean Development Mechanism (CDM). Vienna, 38 Austria: IAEA. November 2000. Available at <http://www.iaea.org/Publications/Booklets/ 39 GreenhouseGas/greenhousegas.pdf> (accessed 22 May 2012 ). 40 Environmental Impacts of the Uranium Fuel Cycle, Solid Waste Management, and Greenhouse Gas Emissions 6-11 Mortimer N. 1990. World warms to nuclear power. SCRAM Safe Energy Journal Dec 89/Jan90. 1 Available at <http://www.no2nuclearpower.org.uk/articles/mortimer_se74.php> (accessed 2 22 May 2012). 3 [NEA and OECD] Nuclear Energy Agency and the Organization for Economic Co -operation and 4 Development. 2002. Nuclear Energy and the Kyoto Protocol. Paris, France: OECD. Available at 5 <http://www.nea.fr/ndd/reports/2002/nea3808 -kyoto.pdf> (accessed 22 May 2012 ). 6 [NRC] U.S. Nuclear Regulatory Commission. Code Manual for MACCS2: Volume 1, User's 7 Guide. Washington, DC. NRC. NUREG/CR -6613. May 1998. ADAMS Accession 8 No. ML063550020. 9 [NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3 -Transportation, Table 9.1, 10 Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic 11 Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: 12 NRC. NUREG -1437, Volume 1, Addendum 1. August 1999. ADAMS Accession 13 No. ML04069720. 14 [NRC] U.S. Nuclear Regulatory Commission. 2012a. "Commission, Memorandum and Order 15 CLI-12-16." August 7, 2012. ADAMS Accession No. ML12220A094. 16 [NRC] U.S. Nuclear Regulatory Commission. 2012b. "SRM-COMSECY-12-0016-Approach for 17 Addressing Policy Issues Resulting from Court Decision To Vacate Waste Confidence Decision 18 and Rule." September 6, 2012. ADAMS Accession No. ML12250A032. 19 [POST] Parliamentary Office of Science and Technology. 2006. Carbon footprint of electricity 20 generation. Postnote 268. October 2006. Available at <http://www.parliament.uk/ 21 documents/post/postpn268.pdf> (accessed 22 May 2012 ). 22 Schneider M. 2000. Climate Change and Nuclear Power. Gland, Switzerland: WWF -World 23 Wildlife Fund for Nature. April 2000. Available at <http://assets.panda.org/downloads/ 24 fullnuclearreprotwwf.pdf> (accessed 22 May 2012 ). 25 Sovacool, BK. 2008. "Valuing the Greenhouse Gas Emissions from Nuclear Power: A Critical 26 Survey." Energy Policy 36:2940-2953. 27 Spadaro JV, Langlois L, Hamilton B. 2000. "Greenhouse Gas Emissions of Electricity 28 Generation Chains: Assessing the Difference." Vienna, Austria: International Atomic Energy 29 Agency. 30 Storm van Leeuwen JW, Smith P. 2008. Nuclear Power -The Energy Balance. Chaam, 31 Netherlands: Ceedata Consultancy. February 2008. Available at <http://www.stormsmith.nl/> 32 (accessed 22 May 2012 ). 33 Weisser D. 2006. A guide to life -cycle greenhouse gas (GHG) emissions from electric supply 34 technologies. Energy 32(9): 1543 -1559. Available at 35 <http://www.iaea.org/OurWork/ST/NE/Pess/assets/GHG_manuscript_pre -36 print_versionDanielWeisser.pdf>

(accessed 22 May 2012).

37

7-1 7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING 1 Environmental impacts from the activities associated with the decommissioning of any reactor 2 before or at the end of an initial or renewed license are evaluated in Supplement 1 of 3 NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear 4 Facilities Regarding the Decommissioning of Nuclear Power Reactors (NRC 2002). The 5 U.S. Nuclear Regulatory Commission (NRC) staff 's (the staff's) evaluation of the environmental 6 impacts of decommissioning -presented in NUREG -0586, Supplement 1-notes a range of 7 impacts for each environmental issue. 8 Additionally, the incremental environmental impacts associated with decommissioning activities 9 resulting from continued plant operation during the renewal term are discussed in 10 NUREG-1437, Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear 11 Plants (NRC 1996, 1999). The GEIS includes a determination of whether the analysis of the 12 environmental issue could be applied to all plants and whether additional mitigation measures 13 would be warranted. Issues were then assigned a Category 1 or a Category 2 designation. 14 Section 1.4 in Chapter 1 explains the criteria for Category 1 and Category 2 issues and defines 15 the impact designations of SMALL, MODERATE, and LARGE. The staff analyzed site-specific 16 issues (Category

2) for Grand Gulf Nuclear Station (GGNS) and assigned them a significance 17 level of SMALL, MODERATE, or LARGE, or not applicable to GGNS because of site 18 characteristics or plant features. There are no Category 2 issues related to decommissioning.

19 7.1 Decommissioning 20 Table 7-1 lists the Category 1 issues in Table B-1 of Title 10 of the Code of Federal 21 Regulations (CFR) Part 51, Subpart A, Appendix B that are applicable to GGNS 22 decommissioning following the renewal term. 23 Table 7-1. Issues Related to Decommissioning 24 Issues GEIS section Category Radiation doses 7.3.1; 7.4 1 Waste management 7.3.2; 7.4 1 Air quality 7.3.3; 7.4 1 Water quality 7.3.4; 7.4 1 Ecological resources 7.3.5; 7.4 1 Socioeconomic impacts 7.3.7; 7.4 1 Decommissioning would occur whether GGNS were shut down at the end of its current 25 operating license or at the end of the period of extended operation. There are no site-specific 26 issues related to decommissioning. 27 A brief description of the staff's review and the GEIS conclusions, as codified in Table B-1, 28 10 CFR Part 51, for each of the issues follows: 29 Radiation doses. Based on information in the GEIS, the NRC noted that "[d]oses to the public 30 will be well below applicable regulatory standards regardless of which decommissioning method 31 Environmental Impacts of Decommissioning 7-2 is used. Occupational doses would increase no more than 1 person-rem (1 person-mSv) 1 caused by buildup of long -lived radionuclides during the license renewal term." 2 Waste management. Based on information in the GEIS, the NRC noted that 3 "[d]ecommissioning at the end of a 20-year license renewal period would generate no more 4 solid wastes than at the end of the current license term. No increase in the quantities of 5 Class C or greater than Class C wastes would be expected." 6 Air quality. Based on information in the GEIS, the NRC noted that "[a]ir quality impacts of 7 decommissioning are expected to be negligible either at the end of the current operating term or 8 at the end of the license renewal term." 9 Water quality. Based on information in the GEIS, the NRC noted that "[t]he potential for 10 significant water quality impacts from erosion or spills is no greater whether decommissioning 11 occurs after a 20 -year license renewal period or after the original 40 -year operation period, and 12 measures are readily available to avoid such impacts." 13 Ecological resources. Based on information in the GEIS, the NRC noted that 14 "[d]ecommissioning after either the initial operating period or after a 20 -year license renewal 15 period is not expected to have any direct ecological impacts." 16 Socioeconomic impacts. Based on information in the GEIS, the NRC noted that 17 "[d]ecommissioning would have some short -term socioeconomic impacts. The impacts would 18 not be increased by delaying decommissioning until the end of a 20 -year relicense period, but 19 they might be decreased by population and economic growth." 20 Entergy Operations, Inc. (Entergy) stated in its environmental report (ER) (Entergy 2011) that it 21 is not aware of any new and significant information on the environmental impacts of GGN S 22 license renewal. The staff has not found any new and significant information during its 23 independent review of Entergy's ER, the site visit, the scoping process, or its evaluation of other 24 available information. Therefore, the NRC staff concludes that there are no impacts related to 25 these issues, beyond those discussed in the GEIS. For all of these issues, the NRC staff 26 concluded in the GEIS that the impacts are SMALL, and additional plant -specific mitigation 27 measures are not likely to be sufficiently beneficial to be warranted. 28 7.2 References 29 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 30 protection regulations for domestic licensing and related regulatory functions." 31 [Entergy] Entergy Operations, Inc. 2011. Grand Gulf Nuclear Station, Unit 1, License Renewal 32 Application. Appendix E, Applicant's Environmental Report. Agencywide Documents Access 33 and Management System (ADAMS) Accession No. ML11308A234. 34 [NRC] U.S. Nuclear Regulatory Commission. 1996. GEIS. NRC. NUREG -1437. May 1996. 35 ADAMS Accession Nos. ML040690705 and ML040690738. 36 [NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3 -Transportation, Table 9.1, 37 Summary of findings on NEPA issues for license renewal of nuclear power plants. In: GEIS. 38 NRC. NUREG -1437, Volume 1, Addendum 1. August 1999. ADAMS Accession 39 No. ML04069720. 40 [NRC] U.S. Nuclear Regulatory Commission. 2002. Final Generic Environmental Impact 41 Statement on Decommissioning of Nuclear Facilities Regarding the Decommissioning of 42 Nuclear Power Reactors. Washington, DC: NRC. NUREG -0586, Supplement 1. 43 November 2002. ADAMS Accession Nos. ML023470304 and ML02350029 5.44 8-1 8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES 1 The National Environmental Policy Act (NEPA) requires the consideration of a range of 2 reasonable alternatives to the proposed action in an environmental impact statement (EIS). In 3 this case, the proposed action is whether to issue a renewed license for Grand Gulf Nuclear 4 Station (GGNS), which will allow the plant to operate for 20 years beyond its current license 5 expiration date. A license is just one of many conditions that a licensee must meet in order to 6 operate its nuclear plant. State regulatory agencies and the owners of the nuclear power plant 7 ultimately decide whether the plant will operate, and economic and environmental 8 considerations play a primary role in this decision. The U.S. Nuclear Regulatory Commission 9 (NRC)'s responsibility is to ensure the safe operation of nuclear power facilities and not to 10 formulate energy policy or encourage or discourage the development of alternative power 11 generation (or replacement power alternatives). 12 The license renewal process is designed to assure safe operation of the nuclear power plant 13 and protection of the environment during the license renewal term. Under the NRC's 14 environmental protection regulations in Title 10, Part 51, of the Code of Federal Regulations 15 (10 CFR Part 51), which implement Section 102(2) of NEPA, renewal of a nuclear power plant 16 operating license requires the preparation of an EIS. 17 To support the preparation of these EISs, the NRC staff (the staff) prepared the Generic 18 Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG -1437, 19 in 1996. The license renewal GEIS was prepared to assess the environmental impacts of 20 continued nuclear power plant operations during the license renewal term. The intent was to 21 determine which environmental impacts would result in essentially the same impact at all 22 nuclear power plants and which ones could result in different levels of impacts at different plants 23 and would require a plant -specific analysis to determine the impacts. For those issues that 24 could not be generically addressed, the NRC develops a plant -specific supplemental 25 environmental impact statement (SEIS) to the GEIS. 26 NRC regulations in 10 CFR 51.71(d) for license renewal require that a SEIS consider and weigh 27 the environmental effects of the proposed action [license renewal]; the 28 environmental impacts of alternatives to the proposed action; and alternatives 29 available for reducing or avoiding adverse environmental effects [.] 30 While the GEIS reached generic conclusions on many environmental issues associated with 31 license renewal, it did not determine which alternatives are reasonable or reach conclusions 32 about site -specific environmental impact levels. As such, the NRC must evaluate environmental 33 impacts of alternatives on a site -specific basis. 34 As stated in Chapter 1 of this SEIS, alternatives to renewing GGNS's operating license must 35 meet the purpose and need for the proposed action. They must do the following: 36 provide an option that allows for power generation capability beyond the term of 37 a current nuclear power plant operating license to meet future system generating 38 needs, as such needs may be determined by State, utility, and, where 39 authorized, Federal (other than NRC) [decisionmakers]. (NRC 1996) 40 The NRC ultimately makes no decision about which alternative (or the proposed action) to carry 41 out because that decision falls to the appropriate energy -planning decisionmakers. 42 Environmental Impacts of Alternatives 8-2 Comparing the environmental effects of these 1 alternatives will help the NRC decide if the 2 adverse environmental impacts of license renewal 3 are great enough to deny the option of license 4 renewal for energy -planning decisionmakers 5 (10 CFR 51.95(c)(4)). If the NRC acts to issue a 6 renewed license, all of the alternatives, including 7 the proposed action, will be available to 8 energy-planning decisionmakers. If the NRC 9 decides not to renew the license, then 10 energy-planning decisionmakers may no longer 11 elect to continue operating GGNS and will have to 12 resort to another alternative -which may or may 13 not be one of the alternatives considered in this 14 section-to meet the energy needs that GGNS 15 now satisfies. 16 In evaluating alternatives to license renewal, 17 energy technologies or options currently in 18 commercial operation are considered, as well as 19 some technologies not currently in commercial 20 operation but likely to be commercially available 21 by the time the current GGNS operating license 22 expires. The current GGNS operating license will expire on November 1, 2024, and reasonable 23 alternatives must be available (constructed, permitted, and connected to the grid) by the time 24 the current GGNS license expires to be considered likely to become available. 25 The staff eliminated alternatives that cannot meet future system needs and whose costs or 26 benefits do not justify inclusion in the range of reasonable alternatives. The staff evaluated the 27 remaining alternatives, which are discussed in -depth in this chapter. Each alternative 28 eliminated from detailed study is briefly discussed in Section 8.5, and a basis for its removal is 29 provided. In total, 16 energy technology options and alternatives to the proposed action were 30 considered (see text box) and then narrowed to the four alternatives considered in 31 Sections 8.1-8.4. The no -action alternative is considered in Section 8.6. 32 The GEIS presents an overview of some energy technologies but does not reach any 33 conclusions about which alternatives are most appropriate. Since 1996, many energy 34 technologies have evolved significantly in capability and cost, while regulatory structures have 35 changed to either promote or impede development of particular alternatives. 36 As a result, the analyses include updated information from sources such as the Energy 37 Information Administration (EIA), other organizations within the U.S. Department of Energy 38 (DOE), the U.S. Environmental Protection Agency (EPA), industry sources and publications , 39 and information submitted by the applicant in its environmental report (ER). 40 The evaluation of each alternative considers the environmental impacts across seven impact 41 categories: (1) air quality, (2) groundwater use and quality, (3) surface water use and quality, 42 (4) ecology, (5) human health, (6) socioeconomics, and (7) waste management. A three -level 43 standard of significance -SMALL, MODERATE, or LARGE -is used to show the intensity of 44 environmental effects for each alternative that is evaluated in depth. The order of presentatio n 45 is not meant to imply increasing or decreasing level of impact, nor does it imply that an 46 energy-planning decisionmaker would select one or another alternative. 47 Alternatives Evaluated In -Depth: new nuclear natural gas -fired combined cycle (NGCC) supercritical coal -fired combination alternative (NGCC, demand -side management, purchased power, and biomass) Other Alternatives Considered: demand-side management wind power solar power hydroelectric power wave and ocean energy geothermal power municipal solid waste biomass oil-fired power fuel cells purchased power delayed retirement

Environmental Impacts of Alternatives 8-3 For each alternative where it is feasible to do so, the NRC considers the environmental effects 1 of locating the alternative at the existing GGNS site. Selecting the existing plant site allows for 2 the maximum use of existing transmission and cooling system infrastructures and minimizes the 3 overall environmental impact. 4 In addition, to ensure that the alternatives analysis is consistent with State and regional energy 5 policies, the NRC reviewed energy relevant statutes, regulations, and policies. The NRC also 6 considered the current generation capacity mix and electricity production data within Mississippi, 7 where GGNS is located and production data for Entergy's six operating companies that operate 8 under a System Agreement. The System Agreement allows the operating companies to share 9 generating capacity power reserves, provides the basis for the planning, construction and 10 operation of electric generation and transmission, and regulates the price for whol esale 11 electricity used or exchanged by the Entergy operating companies (Entergy 2012). In 2010, 12 electric generators in Mississippi had an installed generating capacity of approximately 13 15,691 megawatts electric (MWe). This capacity included units fueled by natural gas 14 (74 percent), coal (16 percent), nuclear (8 percent), and biomass-fired generation (1.5 percent) 15 (EIA 2012 a). In 2010, the electric industry in Mississippi provided approximately 54.5 million 16 megawatt-hours of electricity. Electricity produced in Mississippi was dominated by natural gas 17 (54 percent) followed by coal (25 percent), nuclear (18 percent), and biomass -fired generation 18 (2.8 percent) (EIA 2012 a). 19 Sections 8.1-8.4 describe the environmental impacts of alternatives to license renewal. These 20 alternatives include a new nuclear generation option in Section 8.1; a new natural gas -fired 21 combined-cycle (NGCC) plant in Section 8.2; a new supercritical pulverized coal (SCPC) plant 22 in Section 8.3; and a combination alternative of NGCC, demand -side management (DSM), 23 purchased power, and biomass-fired generation in Section 8.4. A summary of these 24 alternatives considered in depth is provided in Table 8-1. In Section 8.5, alternatives 25 considered but eliminated from detailed study are briefly discussed. Finally, Section 8.6 26 describes environmental effects that may occur if the NRC takes no action and does not issue a 27 renewed license for GGNS. Section 8.7 summarizes the impacts of each of the alternatives 28 considered in detail. 29 Environmental Impacts of Alternatives 8-4 Table 8-1. Summary of Alternatives Considered In Depth 1 New Nuclear Alternative Natural Gas (NGCC) Alternative Supercritical Pulverized Coal (SCPC) Alternative Combination Alternative Summary of Alternative One unit ESBWR nuclear plant Three 530-MWe units for a total of 1,590 MWe Three 583-MWe SCPC units (total of 1,749 MWe) One 530-MWe NGCC unit; Nine 50-MW biomass units (360 MWe total); 280 MWe from DSM; and

305 MWe from purchased power Location At GGNS; Would use existing infrastructure, including Ranney wells, draft cooling tower, and transmission lines At GGNS; Would use existing infrastructure, including Ranney wells, draft cooling tower, and transmission lines An existing power plant site (other than GGNS) in Mississippi; Some infrastructure upgrades may be required NGCC at GGNS; Biomass units at 9 sites throughout Mississippi; DSM and purchased power throughout Mississippi Cooling System Ranney wells

Consumptive water use would be similar to GGNS Unit 1 Ranney wells

Consumptive water use would be less than GGNS Unit 1 Closed-cycle with natural-draft cooling towers; Consumptive water use would be similar to GGNS Unit 1 NGCC unit same as the NGCC alternative but water use would be 1/3 less; Closed

- cycle cooling for biomass uni ts Land Requirements 234 ac (95 ha) (Entergy 2011); 1,000 ac (400 ha) for uranium mining and processing (NRC 1996) 195 acres (79 hectares) (NRC 1996); 5,700 ac (2,307 ha) for wells, collection site, pipeline (NRC 1996) 2,744 ac (1,110 ha) for the plant (NRC 1996); 35,508 ac (14,370 h a) for coal mining and waste disposal (NRC 1996) NGCC unit approximately 1/3 the land as for the NGCC alternative; 15 ac (6 ha) for each 50-MWe biomass unit, for a total of 135 ac (55 ha) (NREL 2003, Palmer Renewable Energy 2011) Work Force 3,150 during construction; 690 during operations (Entergy 2011) 1,900 during construction; 150 during operations (NRC 1996) 4,035 during construction; 404 during operations (NRC 1996) NGCC portion would require 633 during construction and 50 during operations (NRC 1996); Biomass units would require 450 during construction and 198 during operations 8.1 New Nuclear Generation 2 In this section, the NRC evaluates the environmental impacts of a new nuclear generation 3 alternative at the GGNS site. 4 Environmental Impacts of Alternatives 8-5 The NRC considers the construction of a new nuclear plant to be a reasonable alternative to 1 GGNS license renewal because nuclear generation currently provides baseload power in 2 Entergy's service territory and Entergy has expressed interest in adding nuclear generation to 3 its energy portfolio. For example, on October 16, 2003, an application was submitted for an 4 early site permit (ESP) on the existing GGNS site and the NRC issued an ESP on April 7, 2007 5 (NRC 2012a). An ESP is an NRC approval of a site for one or more nuclear power facilities. 6 Before construction and operation of any new nuclear unit(s), Entergy would need to obtain a 7 construction permit and operating license. On February 27, 2008, Entergy submitted an 8 application for a combined operating license (COL) for an Economic Simplified Boiling -Water 9 Reactor (ESBWR) at the GGNS site. On January 9, 2009, Entergy informed the NRC that it 10 was considering alternate reactor design technologies and requested that the NRC suspend its 11 review effort (NRC 2012b). Entergy continues to evaluate the potential for new nuclear 12 generation and could pursue it as an option for meeting long -term baseload needs in the future 13 (Entergy 2009, 2010). Although the ESP does not specify a scheduled timeline, the NRC 14 determined that there is sufficient time for Entergy to prepare and submit an application, build, 15 and operate a new nuclear unit before the GGNS license expires in November 2024. This 16 section presents the environmental impacts of the new nuclear generation alternative, which 17 includes constructing and operating one new nuclear plant at the GGNS site. 18 In evaluating the new nuclear alternative, the NRC assumed that a replacement reactor would 19 be installed on the GGNS site, allowing for the maximum use of existing ancillary facilities such 20 as the cooling system and transmission infrastructure. The GGNS site is situated on 21 2,100 acres (ac) (850 hectares [ha]), of which, approximately 1,000 ac (405 ha), is in a 22 floodplain and not suitable for plant construction. The remaining 1,100 ac (445 ha) would be 23 sufficient for construction of a new nuclear plant (Entergy 2011). The NRC assumed that the 24 replacement reactor would be an ESBWR. Although the NRC has suspended its review of the 25 COL application, it uses information from the ESP EIS in the following sections, where 26 applicable, because it provides a site -specific environmental analysis of a new nuclear plant at 27 the GG NS site. 28 For the purpose of this analysis, the NRC assumed that the new reactor would have a net 29 electrical output of 1,475 MWe, which would be the same output as the existing reactor. 30 Entergy (2008) estimated that 234 ac (95 ha) would be required for new reactor construction for 31 the power block and ancillary facilities, and that sufficient acreage was available on the GGNS 32 site. T he heat-rejection demands of a new nuclear unit would be similar to those of the existing 33 reactor. Therefore , the NRC assumed that the new reactor would use the existing cooling 34 system (including natural draft cooling towers and intake and discharge structures), and that no 35 structural modifications would be needed. The existing transmission lines leaving the site, as 36 well as construction, drinking water and Ranney wells are expected to serve the new reactor 37 with no modifications required. 38 The NRC also considered the installation of multiple small and modular reactors at the GGNS 39 site as an alternative to renewing the GGNS license. The NRC established the Advanced 40 Reactor Program in the Office of New Reactors because of considerable interest in small and 41 modular reactors along with anticipated license applications by vendors. As of December 2012, 42 the NRC has not received any applications. Because there are no applications to construct and 43 operate small modular reactors on a commercial scale, this analysis focused on nuclear 44 generation by larger nuclear units. 45 8.1.1 Air Quality 46 As discussed in Section 2.2.2.1, the GGNS site is located in Claiborne County, Mississippi, 47 which is on the western edge of the Mobile (Alabama) -Pensacola-Panama City 48 Environmental Impacts of Alternatives 8-6 (Florida)-Southern Mississippi Interstate Air Quality Control Region (AQCR) (40 CFR 81.68). 1 The area across the Mississippi River from the site is in the Monroe (Louisiana) -El Dorado 2 (Arkansas) Interstate AQCR (40 CFR 81.92). EPA has designated all of the counties in these 3 AQCRs adjacent to the GGNS site as in compliance with the National Ambient Air Quality 4 Standards (NAAQS) (40 CFR 81.310). The State of Mississippi is in attainment with primary 5 and secondary NAAQS for all criteria pollutants, except De Soto County, which is located about 6 200 miles (322 km) north-northeast of GGNS and part of which is a marginal nonattainment 7 area for the 2008 8 -hour ozone standard. 8 Construction activities for a new nuclear alternative would cause some localized temporary air 9 quality impacts because of fugitive dust emissions from operation of earth -moving and 10 material-handling equipment. Emissions from construction worker vehicles and motorized 11 construction equipment exhaust would be temporary. The NRC assumes that mitigation 12 measures, including wetting of unpaved roads and construction areas, and seeding or mulching 13 bare areas would control and reduce fugitive dust. 14 During operations, a new nuclear alternative would have air emissions similar to those of the 15 existing GGNS plant. These emissions are primarily from testing of emergency generators and 16 diesel pumps and the periodic use of auxiliary boilers or generators during outages (Entergy 17 2011). The NRC expects a new nuclear alternative to have similar air permitting conditions and 18 regulatory requirements as the existing plant. For example, a new nuclear alternative would be 19 subject to conditions in an air permit established by the Mississippi Department of 20 Environmental Quality (MDEQ) (Entergy 2011). 21 Subpart P of 40 CFR Part 51 contains the visibility protection regulatory requirements, including 22 the review of new sources to be constructed in attainment or unclassified areas that may affect 23 visibility in any mandatory Class I Federal area (designated national parks and wilderness 24 areas). If a new nuclear plant were located close to a mandatory Class I Federal area, 25 additional air pollution control requirements may be required. As noted in Section 2.2.2.1, there 26 are no mandatory Class I Federal areas within 186 mi (300 km) of the GGNS site. 27 8.1.1.1 Greenhouse Gases 28 Operation of a new nuclear alternative would have similar effects on climate change as the 29 existing GGNS (which are discussed in Section 4.2). Operation of the reactor does not result in 30 the release of GHGs. However, GHG emissions do result from some activities, such as the 31 periodic use of auxiliary boilers or generators, worker vehicles, and motorized construction 32 equipment exhaust. The impacts on climate from a new nuclear alternative on the GGNS site 33 would be SMALL. 34 8.1.1.2 Conclusion 35 The overall air quality impacts of a new nuclear plant located at the GGNS site would not 36 noticeably alter air quality, therefore, air quality impacts would be SMALL. 37 8.1.2 Groundwater Resources 38 The amount of groundwater required for construction of a new nuclear alternative would be 39 much less than required during plant operation. Water for construction would be obtained from 40 the existing Ranney wells. Groundwater quality and use impacts from construction of a new 41 nuclear alternative are expected to be SMALL. 42 The amount of water required to operate a new nuclear power plant would be similar to that 43 required for the existing power plant. Cooling water would be obtained from the existing 44 Ranney wells. The potable water system would operate from existing wells using similar 45 Environmental Impacts of Alternatives 8-7 chemicals, processes, and withdrawal rates as the existing GGNS facility. Groundwater quality 1 and use impacts from operation of a new nuclear alternative are expected to be SMALL. 2 8.1.3 Surface Water Resources 3 If dredging of streams or rivers occurs during construction, surface water quality immediately 4 downstream of the dredging activities could be temporarily degraded by increases in suspended 5 sediment concentration. During operation, a new nuclear alternative would discharge blowdown 6 from the cooling system at approximately the same rate as the existing unit. Stormwater 7 discharge, blowdown, sanitary, and other effluents, would be regulated under a National 8 Pollutant Discharge Elimination System (NPDES) permit. Given that the discharge rate and 9 composition would be similar to the existing plant and regulated by an NPDES permit and the 10 effects of any dredging needed for construction would be temporary, the impacts to surface 11 water use and quality are expected to be SMALL. 12 8.1.4 Aquatic Ecology 13 Construction activities for the new nuclear alternative (such as construction of heavy -haul roads 14 and the power block) could affect onsite aquatic features, including the Mississippi River near 15 GGNS, Hamilton and Gin Lakes, a borrow pit, three small ponds, streams "A" and "B," and 16 ephemeral drainages. Minimal impacts on aquatic ecology resources are expected because the 17 plant operator would likely implement best management practices (BMPs) to minimize erosion 18 and sedimentation. Stormwater control measures, which would be required to comply with 19 Mississippi NPDES permitting, would minimize the flow of disturbed soils into aquatic features. 20 To bring new materials to the site, the plant operator would dredge near the barge slip to 21 transport some materials using barges, which could result in increased sedimentation and 22 turbidity within aquatic habitats in the Mississippi River. Permits and certifications from the 23 U.S. Army Corps of Engineers and other agencies would require the implementation of BMPs to 24 minimize impacts. Due to the short -term nature of the dredging activities, the hydrological 25 alterations to aquatic habitats would be localized and temporary. 26 During operations, the new nuclear alternative would require a similar amount of cooling water 27 to be withdrawn from Ranney wells and a similar amount of water to be discharged into the 28 Mississippi River as required for GGNS. The number of fish and other aquatic resources 29 affected by cooling water discharge operations, such as thermal stress, would be similar to 30 those of GGNS. 31 Consultation under several Federal acts, including the Endangered Species Act (ESA) and 32 Magnuson-Stevens Act, would be required to assess the occurrence and potential impacts to 33 Federally protected aquatic species and habitats within affected surface waters. Coordination 34 with State natural resource agencies would further ensure that Entergy would take appropriate 35 steps to avoid or mitigate impacts to State-listed species, habitats of conservation concern, and 36 other protected species and habitats. The NRC assumes that these consultations would result 37 in avoidance or mitigation measures that would minimize or eliminate potential impacts to 38 protected aquatic species and habitats. 39 The impacts on aquatic ecology would be minor because erosion and sedimentation would be 40 minimized by BMPs during construction and stormwater and surface water discharges would be 41 managed by regulatory permits similar to the existing plant. Therefore, the staff concludes that 42 impacts on aquatic ecology would be SMALL 43 Environmental Impacts of Alternatives 8-8 8.1.5 Terrestrial Ecology 1 Entergy estimates that construction of a new nuclear alternative, including a reactor unit and 2 auxiliary facilities would affect 234 ac (95 ha) of land on the GGNS site, which is a slightly 3 smaller area of land than that disturbed for construction of GGNS. A new nuclear alternative 4 would use existing site infrastructure, transmission lines, and cooling system to the extent 5 practicable. Thus, only minimal disturbances to undisturbed land would occur for a new nuclear 6 alternative. However, the level of direct impacts would vary based on the specific location of 7 new buildings and infrastructure on the site. Erosion and sedimentation, fugitive dust, and 8 construction debris impacts would be minor with implementation of appropriate BMPs. 9 Construction noise could modify wildlife behavior; however, these effects would be temporary. 10 Road improvements or construction of additional service roads to facilitate construction could 11 result in the temporary or permanent loss of terrestrial habitat. Impacts to terrestrial habitats 12 and species from the operation of a new nuclear alternative would be similar to those of GGNS 13 and would, therefore, be SMALL. Impacts to terrestrial habitats and species from transmission 14 line operation and corridor vegetation maintenance would be similar in magnitude and intensity 15 to those resulting from operating nuclear reactors and would, therefore, be SMALL . The offsite 16 land requirement (1,000 ac [400 ha]) and impacts associated with uranium mining and fuel 17 fabrication to support a new nuclear alternative would be no different from those occurring in 18 support of GGNS. Overall, the impacts from construction of a new nuclear alternative on 19 terrestrial species and habitats would be MODERATE, and the impacts of operation would be 20 SMALL. 21 As discussed under aquatic ecology impacts, consultation with U.S. Fish and Wildlife Service 22 (FWS) under the ESA would avoid potential adverse impacts to Federally listed species or 23 adverse modification or destruction of designated critical habitat. Coordination with State 24 natural resource agencies would further ensure that Entergy would take appropriate steps to 25 avoid or mitigate impacts to State-listed species, habitats of conservation concern, and other 26 protected species and habitats. The NRC assumes that these consultations would result in 27 avoidance or mitigation measures that would minimize or eliminate potential impacts to 28 protected terrestrial species and habitats. Consequently, the impacts of construction and 29 operation of a new nuclear alternative on protected species and habitats would be SMALL. 30 8.1.6 Human Health 31 Impacts on human health from construction of a new nuclear alternative would be similar to 32 impacts associated with the construction of any major industrial facility. Compliance with worker 33 protection rules would control those impacts on workers at acceptable levels. Impacts from 34 construction on the general public would be minimal because the plant operator would limit 35 active construction area access to authorized individuals assuming BMPs are followed. Impacts 36 on human health from the construction of a new nuclear alternative would be SMALL. 37 The human health effects from the operation of a new nuclear alternative would be similar to 38 those of the existing GGNS plant. Therefore, impacts on human health from the operation of a 39 new nuclear alternative would be SMALL. 40 8.1.7 Land Use 41 The GEIS generically evaluates the impacts of constructing and operating various replacement 42 power plant alternatives on land use, both on and off each plant site. The analysis of land use 43 impacts focuses on the amount of land area that would be affected by the construction and 44 operation of a new single -unit nuclear power plant at the GGNS site. 45 Environmental Impacts of Alternatives 8-9 Entergy estimated 234 ac (95 ha) of land would be needed to construct and operate a new 1 single-unit nuclear power plant on the GGNS site (Entergy 2011). A sufficient amount of land is 2 available on the GGNS site for a new nuclear power plant. Maximizing the use of the 3 established infrastructure at the existing nuclear power plant site would further reduce t he 4 amount of additional land needed to support the new unit. Land use impacts from constructing 5 and operating one new unit at the GGNS site would be SMALL. 6 The GEIS also estimated an additional 1,000 acres (400 ha) of land would be affected by 7 uranium mining and processing during the life of the new nuclear alternative. Impacts 8 associated with uranium mining and fuel fabrication to support the new nuclear alternative would 9 generally be no different from those occurring in support of the existing GGNS facility. Since the 10 new unit would be located at GGNS, overall land use impacts from a new nuclear alternative 11 would be SMALL. 12 8.1.8 Socioeconomics 13 Socioeconomic impacts are defined in terms of changes to the demographic and economic 14 characteristics and social conditions of a region. For example, the number of jobs created by 15 the construction and operation of a power plant could affect regional employment, income, and 16 expenditures. 17 This alternative would create two types of jobs: (1) construction jobs, which are transient, short 18 in duration, and less likely to have a long -term socioeconomic impact; and (2) power plant 19 operation jobs, which have a greater potential for permanent, long -term socioeconomic impacts. 20 Workforce requirements for the construction and operation of the new nuclear generation 21 alternative were evaluated to measure its possible effects on current socioeconomic conditions. 22 Entergy estimated a construction workforce of up to 3,150 (maximum) workers would be 23 required to build a single-unit nuclear plant (Entergy 2011). The relative economic impact of 24 construction workers on the local economy and tax base would vary, with the greatest impacts 25 occurring in the communities where the majority of construction workers reside and spend their 26 income. As a result, local communities could experience a short -term economic "boom" from 27 increased tax revenue and income generated by construction worker expenditures and the 28 increased demand for temporary (rental) housing and business services. After completing 29 construction of the new nuclear plant, local communities could experience a return to 30 pre-construction economic conditions. Given the magnitude of the estimated number of 31 workers, socioeconomic impacts during construction in communities near the GGNS site could 32 range from SMALL to LARGE. 33 Entergy estimated that 690 operations workers would be required at a new nuclear power plant , 34 which is equivalent to the number of operations workers at GGNS (Entergy 2011). GGNS 35 operations workers would likely transfer from the existing facility to the new nuclear power plant. 36 This would not have a noticeable effect on socioeconomic conditions in the region. 37 Socioeconomic impacts associated with the operation of a new nuclear alternative at the GGNS 38 site would therefore be SMALL. 39 8.1.9 Transportation 40 Transportation impacts associated with construction and operation of a new nuclear alternative 41 would consist of commuting workers and truck deliveries of construction materials to the power 42 plant site. During periods of peak construction activity, up to 3,150 workers could be commuting 43 daily to the site (Entergy 2011). Workers commuting to the construction site would use site 44 access roads and the volume of traffic on nearby roads could increase substantially during shift 45 Environmental Impacts of Alternatives 8-10 changes. In addition to commuting workers, trucks would be transporting construction materials 1 and equipment to the worksite, thus increasing the amount of traffic on local roads. The 2 increase in vehicular traffic would peak during shift changes, resulting in temporary levels of 3 service impacts and delays at intersections. Materials also could be delivered by barge to the 4 GGNS site. Traffic-related transportation impacts during construction likely would range from 5 MODERATE to LARGE. 6 Traffic-related transportation impacts on local roads would be greatly reduced after construction 7 is completed. The estimated number of operations workers would be 690 (Entergy 2011). 8 Transportation impacts would include daily commuting by the operating workforce, equipment 9 and materials deliveries, and the removal of commercial waste material to offsite disposal or 10 recycling facilities by truck. Traffic-related transportation impacts would be similar to those 11 experienced during current operations at GGNS, because the new unit would employ the same 12 number of workers as GGNS currently employs. Overall, for a new nuclear alternative, 13 transportation impacts would be SMALL during operations. 14 8.1.10 Aesthetics 15 The analysis of aesthetic impacts focuses on the degree of contrast between the new nuclear 16 alternative and the surrounding landscape and the visibility of the new power plant. 17 During construction, clearing and excavation would occur on site. Some of these activities may 18 be visible from offsite roads. Since the GGNS site already appears industrial, construction of 19 the new plant would appear similar to onsite activities during refueling outages. 20 During reactor operations, the visual appearance of the GGNS site would not change since the 21 power block for the new nuclear reactor would look virtually identical to the existing GGNS 22 power block. Adding a new reactor unit would increase the overall size of developed land at the 23 GGNS site. Given the industrial appearance of the GGNS site and the similarity of the new unit 24 to the existing unit, the new reactor unit would blend in with the surroundings . In addition, the 25 amount of noise generated during reactor operations of a new nuclear alternative would be the 26 same as those generated during existing GGNS operations, which consists predominantly of the 27 noise from routine industrial processes and communications. In general, aesthet ic changes 28 would be limited to the immediate vicinity of the GGNS site, and any impacts would be SMALL. 29 8.1.11 Historic and Archaeological Resources 30 The potential for impacts on historic and archaeological resources from a new nuclear 31 alternative would vary greatly depending on the location of the proposed plants on the GGNS 32 site. Any construction on the GGNS site would need to avoid the previously identified Grand 33 Gulf Mound area (Site 22Cb522) and Archaic Period village (22Cb528), as described in 34 Section 2.2.10.2 of this document. As portions of the GGNS site have been previously 35 identified as not containing significant historic and archaeological resources, use of these areas 36 for the new nuclear alternative would result in a SMALL impact on historic and archaeological 37 resources. Alternate plant locations on the GGNS site would need to be surveyed and 38 inventoried for potential resources. Resources found in these surveys would need to be 39 evaluated for eligibility on the National Register of Historic Properties (NRHP) and mitigation of 40 adverse effects would need to be addressed if eligible resources were encountered. The level 41 of impact at these locations would vary depending on the specific resources found to be present 42 in the area of potential effect. However, given that the preference is to use previously surveyed 43 and/or disturbed areas, avoidance of significant historic and archaeological resources should be 44 possible and effectively managed under current laws and regulations. Therefore, the impacts 45 on historic and archaeological resources from the new nuclear alternative would be SMALL. 46 Environmental Impacts of Alternatives 8-11 8.1.12 Environmental Justice 1 The environmental justice impact analysis evaluates the potential for disproportionately high and 2 adverse human health, environmental, and socioeconomic effects on minority and low -income 3 populations that could result from the construction and operation of a new power plant. Adverse 4 health effects are measured in terms of the risk and rate of fatal or nonfatal adverse impacts on 5 human health. Disproportionately high and adverse human health effects occur when the risk or 6 rate of exposure to an environmental hazard for a minority or low -income population is 7 significant and exceeds the risk or exposure rate for the general population or for another 8 appropriate comparison group. Disproportionately high environmental effects refer to impacts or 9 risk of impact on the natural or physical environment in a minority or low -income community that 10 are significant and appreciably exceed the environmental impact on the larger community. 11 Such effects may include biological, cultural, economic, or social impacts. Some of these 12 potential effects have been discussed in the other sections of this chapter. For example, 13 increased demand for rental housing during replacement power plant construction could 14 disproportionately affect low -income populations that rely on inexpensive rental housing. 15 Section 4.9.7, Environmental Justice, presents demographic information about minority and low -16 income populations living near the GGNS site. 17 Potential impacts to minority and low -income populations from the construction of a new nuclear 18 power plant at the GGNS site would mostly consist of environmental and socioeconomic effects 19 (e.g., noise, dust, traffic, employment, and housing impacts). Noise and dust impacts during 20 construction would be short -term and primarily limited to onsite activities. Minority and low -21 income populations residing along site access roads would be directly affected by increased 22 commuter vehicle and truck traffic. However, because of the temporary nature of construction, 23 these effects are not likely to be high and adverse and would be contained to a limited time 24 period during certain hours of the day. Increased demand for rental housing during construction 25 could cause rental costs to rise disproportionately affecting low -income populations living near 26 GGNS who rely on inexpensive housing. However, given the proximity of GGNS to the 27 Jackson and Vicksburg metropolitan areas, some workers could commute to the construction 28 site, thereby reducing the need for rental housing. 29 Potential impacts to minority and low -income populations from nuclear power plant operations 30 would be similar to those of the existing GGNS plant. Radiation doses from the new nuclear 31 power plant are expected to be well below regulatory limits. People living near the power plant 32 would be exposed to the same potential effects from the existing GGNS power plant operations 33 and any impacts would depend on the magnitude of the change in ambient air quality 34 conditions. Permitted air emissions are expected to remain within regulatory standards. 35 Based on this information and the analysis of human health and environmental impacts 36 presented in this section, the construction and operation of a new nuclear power plant would not 37 have disproportionately high and adverse human health and environmental effects on minority 38 and low-income populations living near GGNS. 39 8.1.13 Waste Management 40 During the construction of a new nuclear plant, land clearing and other construction activities 41 would generate waste that could be recycled, disposed of on site, or shipped to an offsite waste 42 disposal facility. Because the new nuclear plant would be constructed on the previously 43 disturbed GGNS site, the amount of wastes produced would be less than comparable 44 construction on an unimproved property. 45 Environmental Impacts of Alternatives 8-12 During the operational stage, normal plant operations, routine plant maintenance, and cleaning 1 activities would generate nonradioactive waste as well as mixed waste, low-level waste, and 2 high-level waste. Quantities of nonradioactive waste (discussed in Section 2.1.3 of this 3 document) and radioactive waste (discussed in Section 6.1 of this document) generated by 4 GGNS would be comparable to that generated by a new nuclear alternative. 5 According to the GEIS (NRC 1996), the generation and management of solid nonradioactive 6 and radioactive waste during the license renewal term is not expected to result in significant 7 environmental impacts. A new single -unit nuclear plant would generate waste streams similar 8 to the existing nuclear plant. Based on this information, waste impacts would be SMALL for a 9 new single -unit nuclear plant located at the GGNS site. 10 8.1.14 Summary of Impacts of New Nuclear Generation 11 Table 8-2 summarizes the environmental impacts of the new nuclear alternative compared to 12 continued operation of GGNS. 13 Table 8-2. Summary of Environmental Impacts of the New Nuclear Alternative 14 Compared to Continued Operation of GGNS 15 Category New Nuclear Generation (use existing infrastructure) Continued GGNS Operation Air Quality SMALL SMALL Groundwater Resources SMALL SMALL Surface Water Resources SMALL SMALL Aquatic Ecology SMALL SMALL Terrestrial Ecology SMALL to MODERATE SMALL Human Health SMALL SMALL Land Use SMALL SMALL Socioeconomics SMALL to LARGE SMALL Transportation SMALL to LARGE SMALL Aesthetics SMALL SMALL Historic and Archaeological Resources SMALL SMALL Waste Management a SMALL SMALL a As described in Chapter 6, the issue, "offsite radiological impacts (spent fuel and high level waste disposal)," is not evaluated in this EIS.

8.2 Natural

Gas -Fired Combined -Cycle Generation 16 In this section, the NRC evaluates the environmental impacts of natural gas -fired 17 combined-cycle (NGCC) generation at the GGNS site. 18 In 2010, natural gas accounted for 54 percent of all electricity generated in Mississippi, a 19 144 percent increase from 10 years earlier in 2000 (EIA 2012b). Natural gas provides the 20 greatest share of electrical power in Mississippi (EIA 2012b). Development of new natural 21 gas-fired plants may be affected by perceived or actual action to limit greenhouse gas (GHG) 22 emissions. Like other fossil fuel sources, natural gas -fired plants are a source of GHG, 23 principally carbon dioxide (CO 2). A gas-fired power plant, however, produces significantly fewer 24 GHGs per unit of electrical output than other fossil fuel -powered plants. In addition, NGCC 25 systems can have high capacity factors and are capable of economically providing baseload 26 power. Natural gas-fired power plants are a feasible and commercially available option for 27 providing baseload electrical generating capacity beyond GGNS's current license expiration. 28 Environmental Impacts of Alternatives 8-13 Therefore, the NRC considered NGCC generation a reasonable alternative to GGNS license 1 renewal. 2 NGCC plants differ considerably from coal -fired boilers and existing nuclear power plants. 3 NGCC plants obtain the majority of their electrical output from a gas -turbine and subsequently 4 generate additional power through a second steam turbine -cycle without any fuel combustion. 5 This combined -cycle approach provides greater thermal efficiency than a single -cycle system, 6 with efficiencies reaching 60 percent (as compared to typical thermal efficiencies of coal -fired 7 plants of 39 percent) (Siemens 2007, NETL 2007). Because the natural gas -fired alternative 8 generates much of its power from a gas -turbine combined -cycle plant and the overall thermal 9 efficiency of this type of plant is high, an NGCC alternative would require less cooling water than 10 GGNS. Thus, the NRC assumed that the NGCC alternative would use the existing cooling 11 system (including natural draft cooling towers and intake and discharge structures), and that the 12 cooling system at GGNS could meet the heat -rejection demands of the NGCC alternative with 13 no structural modifications. 14 To replace the 1,475 MWe that GGNS generates, the NRC considered three hypothetical 15 gas-fired units, each with a net capacity of 530 MWe, for the NGCC alternative. For purposes of 16 this analysis, the hypothetical units would be similar to General Electric's (GE's) H-class 17 gas-fired combined -cycle units. While any number of commercially available combined-cycle 18 units could be installed in a variety of combinations to replace the power GGNS currently 19 produces, GE's H -class units are highly efficient models that would minimize environmental 20 impacts. Other manufacturers, such as Siemens, offer similar high efficiency models. 21 This 1, 590 MWe NGCC plant would consume 70.7 billion cubic feet (ft

3) (2,000 million cubic 22 meters [m 3]) of natural gas annually, assuming an average heat content of 1,020 British thermal 23 unit(s) per cubic feet (BTU/ft 3). Natural gas would be extracted from the ground through wells, 24 then treated to remove impurities (such as hydrogen sulfide), and blended to meet pipeline gas 25 standards before arriving at the plant site. This gas

-fired alternative would produce relatively 26 little waste, primarily in the form of spent catalysts used for control of nitrogen oxide (NO x) 27 emissions. 28 GGNS is situated on a 2,100 ac (850 ha) site. Approximately 1,000 ac (405 ha) are located in a 29 floodplain and not suitable for a NGCC plant, and 169 ac (68 ha) are dedicated to existing 30 GGNS facilities and structures. Entergy's ER concluded that buildable land of sufficient acreage 31 and appropriate location would be available to support an onsite NGCC plant (Entergy 2011). 32 Site crews would clear vegetation, prepare the site surface and relocate existing facilities, if 33 necessary, and begin excavations for foundations and buried utilities before other crews begin 34 actual construction on the plant and associated infrastructure. The three NGCC units would be 35 approximately 100 f eet (ft) (30 meters [m]) tall, with two exhaust stacks up to 150 ft (46 m) tall. 36 Also, offsite impacts would occur as a result of construction of a natural gas pipeline connecting 37 the site to existing infrastructure. 38 8.2.1 Air Quality 39 The GGNS site is located in Claiborne County, Mississippi, which is on the western edge of the 40 Mobile (Alabama) -Pensacola-Panama City (Florida) -Southern Mississippi Interstate Air Quality 41 Control Region (AQCR) (40 CFR 81.68 ). The area across the Mississippi River from the site is 42 in the Monroe (Louisiana) -El Dorado (Arkansas) Interstate AQCR (40 CFR 81.92). EPA has 43 designated all of the counties in these AQCRs adjacent to the GGNS site as in compliance with 44 the National Ambient Air Quality Standards (NAAQS) (40 CFR 81.310). The State o f 45 Mississippi is in attainment with NAAQS for all criteria pollutants, except De Soto County, which 46 Environmental Impacts of Alternatives 8-14 is located about 200 miles (322 km) north-northeast of GGNS and part of which recently was 1 designated as a marginal nonattainment area for the 2008 8 -hour ozone standard. 2 Construction activities for this alternative would generate fugitive dust. However, mitigation 3 measures, including wetting of unpaved roads and construction areas, and seeding or mulching 4 bare areas would minimize fugitive dust. Construction worker vehicles and motorized 5 construction equipment would create exhaust emissions. However, these emissions would end 6 upon completion of construction. 7 Various Federal and state regulations aimed at controlling air pollution would affect a fossil 8 fuel-fired power plant, including an NGCC alternative located in Mississippi. A new NGCC 9 plant, which will be located in an attainment or unclassified area, would qualify as a new 10 major-emitting industrial facility and would be subject to Prevention of Significant Deterioration 11 (PSD) requirements under the Clean Air Act (CAA) (EPA 2012a). The NGCC alternative would 12 need to comply with the standards of performance for electric utility steam generating units set 13 forth in 40 CFR Part 60 Subpart KKKK. The plant also would require an operating permit from 14 MDEQ. 15 If the NGCC alternative were located close to a mandatory Class I area, additional air pollution 16 control requirements would be required (Subpart P of 40 CFR Part 51) as mandated by the 17 Regional Haze Rule. The rule would likely not apply to this NGCC alternative, however, 18 because there are no Class I Federal areas within 186 mi (300 km) of the GGNS site 19 (EPA 2012b). 20 The emissions from the NGCC alternative, projected by the staff based on published EIA data, 21 EPA emission factors, performance characteristics for this alternative, and likely emission 22 controls, would be: 23 sulfur oxides (SO x)-123 tons (111 metric tons [MT]) per year 24 nitrogen oxides (NO x)-469 tons (425 MT) per year 25 particulate matter 10 (PM 10) and 2.5 (PM2.5)-238 tons (216 MT) 26 per year 27 carbon monoxide (CO)-1,082 tons (982 MT) per year 28 carbon dioxide (CO 2)-4.0 million tons (3.6 million MT) per year 29 8.2.1.1 Sulfur Oxide and Nitrogen Oxide 30 As stated above, the NGCC alternative would produce 123 tons (111 MT) per year of SO x and 31 469 tons (425 MT) per year of NO x based on the use of dry low -NO x combustion technology and 32 use of selective catalytic reduction to significantly reduce NO x emissions. The new plant would 33 be subjected to the continuous monitoring requirements of SO 2 and NO x as specified in 34 40 CFR Part 75. 35 8.2.1.2 Greenhouse Gases 36 The NGCC alternative would release GHGs, such as CO 2 and methane. The NGCC alternative 37 would emit approximately 4.0 million tons (approximately 3.6 million MT) per year of CO 2 38 emissions. The plant would be subjected to continuous monitoring requirements for CO 2, as 39 specified in 40 CFR Part 75. 40 On July 12, 2012, EPA issued a final rule tailoring the criteria that determine which stationary 41 sources and modification to existing projects become subject to permitting requirements for 42 GHG emissions under the PSD and Title V Programs of the CAA (77 FR 41051). According to 43 this rule, GHGs are a regulated new source review pollutant under the PSD major source 44 Environmental Impacts of Alternatives 8-15 permitting program if the source is otherwise subject to PSD (for another regulated new source 1 review pollutant) and has a GHG potential to emit equal to or greater than 75,000 tons 2 (68,000 MT) per year of CO 2 equivalent ("carbon dioxide equivalent" adjusts for different global 3 warming potentials for different GHGs). Beginning January 2, 2011, operating permits issued to 4 major sources of GHGs under the PSD or Title V Federal permit programs must contai n 5 provisions requiring the use of Best Available Control Technology (BACT) to limit the emissions 6 of GHGs if those sources would be subject to PSD or Title V permitting requirements. If the 7 NGCC alternative meets the GHG emission thresholds established in the rule, then GHG 8 emissions from this alternative would be regulated under the PSD and Title V permit programs. 9 8.2.1.3 Particulates 10 The NGCC alternative would produce uncontrolled emission of 238 tons (216 MT) per year of 11 particulates, all of which would be emitted as PM 10 and PM2.5. Small amounts of particulate 12 would be released as drift from the cooling tower. However, because the NGCC facility would 13 have a smaller heat rejection demand than GGNS, the drift would be less than what is currently 14 released from the cooling tower at GGNS. 15 As described above, onsite activities during the construction of an NGCC plant would generate 16 fugitive dust as well as exhaust emissions from vehicles and motorized equipment. These 17 impacts would be short-term and construction crews would use applicable dust control 18 measures to minimize dust generation. 19 8.2.1.4 Hazardous Air Pollutants 20 In December 2000, EPA issued regulatory findings (65 FR 79825) on emissions of hazardous 21 air pollutants (HAPs) from electric utility steam -generating units, which identified that natural 22 gas-fired plants emit HAPs such as arsenic, formaldehyde and nickel and stated: 23 . . . the impacts due to HAP emissions from natural gas -fired electric utility steam 24 generating units were negligible based on the results of the study. The 25 Administrator finds that regulation of HAP emissions from natural gas -fired 26 electric utility steam generating units is not appropriate or necessary. 27 As a result of the EPA Administrator's conclusion, the staff finds no significant air quality effects 28 from HAPs. 29 8.2.1.5 Conclusion 30 The impact from SO 2 and NO X emissions would be noticeable and subject to a Title V permit. 31 GHG emissions also would be noticeable; CO 2 emissions would be almost two orders of 32 magnitude larger than the threshold in EPA's tailoring rule for GHG (75,000 tons [68,000 MT] 33 per year of carbon dioxide equivalent) that would trigger a regulated new source review. The 34 overall air quality impacts associated with construction and operation of an NGCC alternative 35 located at the GGNS site would be SMALL to MODERATE. 36 8.2.2 Groundwater Resources 37 The amount of groundwater required for construction of the NGCC alternative would be much 38 less than required during plant operation. Water for construction would be obtained from the 39 existing Ranney wells. Groundwater quality and use impacts from construction of the NGCC 40 alternative are expected to be SMALL. 41 The amount of water required to operate the three -unit NGCC alternative would be less than 42 that required for the existing power plant. Cooling water would be obtained from the existing 43 Ranney wells. Potable water and other plant groundwater requirements would be similar to 44 Environmental Impacts of Alternatives 8-16 GGNS. Groundwater quality and use impacts from operation of the NGCC alternative are 1 expected to be SMALL. 2 8.2.3 Surface Water Resources 3 If dredging of streams or rivers occurs during construction, surface water quality immediately 4 downstream of the dredging activities could be temporarily degraded by increased suspended 5 sediment. During plant operations, an NGC C alternative would discharge cooling system 6 blowdown at approximately half of the current facility rate. Stormwater discharge, blowdown, 7 sanitary, and other effluents would be permitted under an NPDES permit. Given these 8 assumptions, the impacts on surface water use and quality would be SMALL. 9 8.2.4 Aquatic Ecology 10 Construction activities for the NGCC alternative (such as construction of heavy -haul roads, a 11 new pipeline, and the power block) could affect onsite aquatic features, including the Mississippi 12 River near GGNS, Hamilton and Gin Lakes, a borrow pit, three small ponds, streams "A" and 13 "B," and ephemeral drainages. Minimal impacts on aquatic resources are expected because 14 the plant operator would likely implement BMPs to minimize erosion and sedimentation. 15 Stormwater control measures, which would be required to comply with Mississippi NPDES 16 permitting, would minimize the flow of disturbed soils into aquatic habitats. To bring new 17 materials to the site, NRC assumed the plant operator would dredge near the barge slip to 18 transport some materials using barges, which could result in increased sedimentation and 19 turbidity within aquatic habitats in the Mississippi River. Permits and certifications from the 20 U.S. Army Corps of Engineers and other agencies would require the implementation of BMPs to 21 minimize impacts. Due to the short -term nature of the dredging activities, the hydrological 22 alterations to aquatic habitats would be localized and temporary. 23 During operations, the NGCC alternative would require less cooling water to be withdrawn from 24 Ranney wells, and less water to be discharged into the Mississippi River than required for 25 GGNS. Therefore, thermal impacts would be less for the NGCC alternative than GGNS. The 26 cooling system for a new NGCC plant would have similar chemical discharges as GGNS. Air 27 emissions from the NGCC plant would emit particulates that would settle onto the river surface 28 and introduce a new source of pollutants as described in Section 8.1.1. However, the flow of 29 the Mississippi River would likely dissipate and dilute the concentration of pollutants resulting in 30 minimal exposure to aquatic biota. 31 Consultation under several Federal acts, including the ESA and Magnuson -Stevens Act, would 32 be required to assess the occurrence and potential impacts to Federally protected aquatic 33 species and habitats within affected surface waters. Coordination with State natural resource 34 agencies would further ensure that the NGCC operator would take appropriate steps to avoid or 35 mitigate impacts to State-listed species, habitats of conservation concern, and other protected 36 species and habitats. The NRC assumes that these consultations would result in avoidance or 37 mitigation measures that would minimize or eliminate potential impacts to protected aquatic 38 species and habitats. 39 The impacts on aquatic ecology would be minor because construction activities would require 40 BMPs and stormwater management permits. Also, surface water discharge for this alternative 41 would be less than for GGNS. Deposition of pollutants into aquatic habitats from the plant's ai r 42 emissions would be minimal because the concentration of pollutants would be diluted with the 43 river flow. Therefore, the staff concludes that impacts on aquatic ecology would be SMALL. 44 Environmental Impacts of Alternatives 8-17 8.2.5 Terrestrial Ecology 1 Construction of an NGCC alternative would occur on the GGNS site and would use existing 2 transmission lines. Because the onsite land requirement is relatively small (225 ac [91 ha]), the 3 entire NGCC alternative construction footprint would likely be sited in already developed areas 4 of the GGNS site, which would minimize impacts to terrestrial habitats and species. However, 5 the level of direct impacts would vary based on the specific location of new buildings and 6 infrastructure on the site. Offsite construction would occur mostly on land where gas extraction 7 is already occurring. Erosion and sedimentation, fugitive dust, and construction debris impacts 8 would be minor with implementation of BMPs. Construction noise could modify wildlife 9 behavior; however, these effects would be temporary. Road improvements or construction of 10 additional service roads to facilitate construction could result in the temporary or permanent loss 11 of terrestrial habitat. Construction of gas pipelines along existing, previously disturbed utility 12 corridors would result in temporary noise and displacement of wildlife, but would minimize the 13 removal or destruction of undisturbed habitats. Impacts to terrestrial habitats and species from 14 transmission line operation and corridor vegetation maintenance, and operation of the cooling 15 towers would be similar in magnitude and intensity as those resulting from GGNS and would, 16 therefore, be SMALL. Overall, the impacts of construction and operation of an NGCC 17 alternative to terrestrial habitats and species would be SMALL to MODERATE. 18 As discussed under aquatic ecology impacts, consultation with the FWS under the ESA would 19 ensure that the construction and operation of an NGCC alternative would not adversely affect 20 any Federally listed species or adversely modify or destroy designated critical habitat. 21 Coordination with State natural resource agencies would further ensure that the NGCC operator 22 would take appropriate steps to avoid or mitigate impacts to State -listed species, habitats of 23 conservation concern, and other protected species and habitats. The NRC assumes that these 24 consultations would result in avoidance or mitigation measures that would minimize or eliminate 25 potential impacts to protected terrestrial species and habitats. Consequently, the impacts of 26 construction and operation of a new nuclear alternative on protected species and habitats would 27 be SMALL. 28 8.2.6 Human Health 29 Impacts on human health from construction of the NGCC alternative would be similar to impacts 30 associated with the construction of any major industrial facility. Compliance with worker 31 protection rules would control those impacts on workers at acceptable levels. The plant 32 operator would likely follow BMPs, such as limiting active construction area access to 33 authorized individuals. Impacts on human health from the construction of the NGCC alternative 34 would be SMALL. 35 During operations, human health effects of gas -fired generation are generally low. However, in 36 Table 8.2 of the GEIS (NRC 1996), the staff identified cancer and emphysema as potential 37 health risks from gas -fired plants. NO x emissions contribute to ozone formation, which in turn 38 contributes to human health risks. Emission controls on the NGCC alternative can be expected 39 to maintain NO x emissions well below air quality standards established to protect human health, 40 and emissions trading or offset requirements mean that overall NO x releases in the region would 41 not increase. Health risks for workers also may result from handling spent catalysts used for 42 NO x control that may contain heavy metals. However, health risks can be minimized through 43 the use of occupational health and safety procedures and protective equipment. Impacts on 44 human health from the operation of the NGCC alternative would be SMALL. 45 Environmental Impacts of Alternatives 8-18 8.2.7 Land Use 1 The GEIS generically evaluates the impact of constructing and operating various replacement 2 power plant alternatives on land use, both on and off each plant site. The analysis of land use 3 impacts focuses on the amount of land area that would be affected by the construction and 4 operation of a three -unit NGCC power plant at the GGNS site. Locating the new NGCC power 5 plant at the GGNS site would maximize the availability of support infrastructure and reduce the 6 need for additional land. 7 Entergy estimated 195 acres (79 hectares) would be required for construction of power block, 8 support facilities and a natural gas pipeline to the nearest natural gas distribution line for a 9 1,584 MWe NGCC alternative (Entergy 2011). Depending on the location and availability of 10 existing natural gas pipelines, a 100 -ft-wide right -of-way would be needed for a new pipeline. 11 Land use impacts from NGCC construction would be SMALL to MODERATE. 12 In addition to onsite land requirements, land would be required off site for natural gas wells and 13 collection stations. Scaling from GEIS estimates, approximately 5,700 ac (2,307 ha) (based on 14 3,600 ac per 1,000 MWe and 1,584 MWe for NGCC) (NRC 1996) would be required for wells, 15 collection stations, and pipelines to bring the gas to the plant. Most of this land requirement 16 would occur on land where gas extraction already occurs. 17 The elimination of uranium fuel for GGNS would partially offset some of the land requirements 18 for an NGCC alternative. Scaling from GEIS estimates, approximately 1,033 ac (418 ha) (based 19 on 35 ac/yr disturbed per 1,000 MWe for 20 yr) would no longer be needed for mining and 20 processing uranium during the operating life of the plant (NRC 1996). Land use impacts during 21 power plant operations would be SMALL. 22 8.2.8 Socioeconomics 23 Socioeconomic impacts are defined in terms of changes to the demographic and economic 24 characteristics and social conditions of a region. For example, the number of jobs created by 25 the construction and operation of a power plant could affect regional employment, income, and 26 expenditures. 27 The alternative would create two types of jobs: (1) construction jobs, which are transient, short 28 in duration, and less likely to have a long -term socioeconomic impact; and (2) power plant 29 operation jobs, which have a greater potential for permanent, long -term socioeconomic impacts. 30 Workforce requirements for the construction and operation of the NGCC alternative were 31 evaluated for their possible effects on current socioeconomic conditions. 32 Scaling from GEIS estimates, the construction workforce would peak at 1,900 workers. The 33 relative economic impact of this many workers on the local economy and tax base would vary 34 with the greatest impacts occurring in the communities where the majority of construction 35 workers would reside and spend their income. As a result, local communities could experience 36 a short-term economic "boom" from increased tax revenue and income generated by 37 construction expenditures and the increased demand for temporary (rental) housing and 38 business services. 39 After completing the installation of the three-unit NGCC plant, local communities could 40 experience a return to pre -construction economic conditions. Based on this information and 41 given the number of workers, socioeconomic impacts during construction in communities near 42 the GGNS site could range from SMALL to MODERATE. 43 Scaling from GEIS estimates, an NGCC alternative would employ approximately 150 workers 44 during operation. GGNS has an operation workforce of approximately 690. The potential 45 Environmental Impacts of Alternatives 8-19 reduction in overall employment at the GGNS site would likely affect property tax revenue and 1 income in local communities and businesses. In addition, the permanent housing market could 2 also experience increased vacancies and decreased prices if operations workers and their 3 families move out of the region. Socioeconomic impacts during operations of an NGCC 4 alternative could range from SMALL to MODERATE. 5 8.2.9 Transportation 6 Transportation impacts associated with construction and operation of an NGCC alternative 7 would consist of commuting workers and truck deliveries of construction materials. During 8 periods of peak construction activity, up to 1,900 worker would be commuting daily to GGNS, a 9 substantial increase from the GGNS current operational force of 690 workers. The increase in 10 vehicular traffic would peak during shift changes, resulting in temporary levels of service 11 impacts and delays at intersections. Pipeline construction and modification to existing natural 12 gas pipeline systems could also have a temporary impact. Materials also could be delivered by 13 barge or rail. Traffic -related transportation impacts during construction likely would be 14 MODERATE. 15 Traffic-related transportation impacts would be greatly reduced after completing the installation 16 of the NGCC alternative. Transportation impacts would include daily commuting by the 17 operating workforce, equipment and materials deliveries, and the removal of commercial waste 18 material to offsite disposal or recycling facilities by truck. The estimated NGCC alternative 19 operation workforce of approximately 150 is considerably less than the GGNS operation 20 workforce of approximately 690. Traffic-related transportation impacts would be considerably 21 less than current operations because an NGCC alternative would employ far fewer workers than 22 the existing GGNS. Since fuel is transported by pipeline, the transportation infrastructure would 23 experience little to no increased traffic from fuel operations. Overall, transportation impacts 24 would be SMALL during plant operations. 25 8.2.10 Aesthetics 26 The analysis of aesthetic impacts focuses on the degree of contrast between an NGCC 27 alternative and the surrounding landscape and the visibility of an NGCC alternative at the 28 GGNS site. During construction, clearing and excavation would occur on site. Some of these 29 activities may be visible from offsite roads. Since the GGNS site already appears industrial, 30 construction of an NGCC alternative would appear similar to onsite activities during refueling 31 outages. 32 The three NGCC units would be approximately 100 ft (30 m) tall, with exhaust stacks up to 33 150 ft (46 m) tall. The facility would be visible off site during daylight hours, and some 34 structures may require aircraft warning lights. The plant would use the existing natural draft 35 cooling tower, which is over 500 ft (152 m) high (Entergy 2011). Noise generated during NGCC 36 power plant operations would be limited to routine industrial processes and communications. 37 Pipelines delivering natural gas fuel could be audible off site near gas compressor stations. 38 In general, given the industrial appearance of the GGNS site, an NGCC alternative would blend 39 in with the surroundings if the existing GGNS facility remains. Aesthetic changes would be 40 limited to the immediate vicinity of the existing GGNS site, and any impacts would be SMALL. 41 8.2.11 Historic and Archaeological Resources 42 The potential for impacts on historic and archaeological resources from an NGCC alternative 43 would vary greatly depending on the location of the proposed plants on the GGNS site. Any 44 Environmental Impacts of Alternatives 8-20 construction would need to avoid the previously identified Grand Gulf Mound area 1 (Site 22Cb522) and Archaic Period village (22Cb528) as described in Section 2.2.10.2 of this 2 document. As portions of the GGNS site have been previously identified as not containing 3 significant historic and archaeological resources, use of these areas for an NGCC alternative 4 would result in a SMALL impact on historic and archaeological resources. Alternate plant and 5 new pipeline locations would need to be surveyed and inventoried for potential resources. 6 Resources found in these surveys would need to be evaluated for eligibility on the National 7 Register of Historic Places (NRHP) and mitigation of adverse effects would need to be 8 addressed if eligible resources were encountered. The level of impact at these locations would 9 vary depending on the specific resources found to be present in the area of potential effect. 10 However, given that the preference is to use previously surveyed and/or disturbed areas, 11 avoidance of significant historic and archaeological resources should be possible and effectively 12 managed under current laws and regulations. Therefore, the impacts on historic and 13 archaeological resources from the NGCC alternative would be SMALL. 14 8.2.12 Environmental Justice 15 The environmental justice impact analysis evaluates the potential for disproportionately high and 16 adverse human health, environmental, and socioeconomic effects on minority and low -income 17 populations that could result from the construction and operation of a new power plant. As 18 previously discussed in Section 8.1.12, such effects may include human health, biological, 19 cultural, economic, or social impacts. Section 4.10.7, Environmental Justice, presents 20 demographic information about minority and low -income populations residing in the vicinity of 21 the GGNS site. 22 Potential impacts to minority and low -income populations from the construction and operation of 23 an NGCC alternative at the GGNS site would mostly consist of environmental and 24 socioeconomic effects (e.g., noise, dust, traffic, employment, and housing impacts). Noise and 25 dust impacts during construction would be short -term and primarily limited to onsite activities. 26 Minority and low -income populations residing along site access roads would be directly affected 27 by increased commuter and truck traffic. However, because of the temporary nature of 28 construction, these effects are not likely to be high and adverse and would be contained to a 29 limited time period during certain hours of the day. Increased demand for rental housing during 30 construction could cause rental costs to rise disproportionately affecting low -income populations 31 living near GGNS who rely on inexpensive housing. However, given the proximity of GGNS to 32 the Jackson and Vicksburg metropolitan areas, workers could commute to the construction site, 33 thereby reducing the need for rental housing. 34 As discussed in Section 4.10.7.1, 144 of the 294 census block groups located within the 50 -mi 35 (80-km) radius of GGNS were determined to have meaningfully greater minority populations 36 than the other census block groups within the 50 -mi (80-km) radius of GGNS. However, 37 emissions from the NGCC alternative are expected to be maintained within regulatory 38 standards. Accordingly, disproportionately high and adverse impacts on minority and low 39 income populations are not expected. 40 Based on this information and the analysis of human health and environmental impacts 41 presented in this section, the construction and operation of an NGCC alternative would not have 42 disproportionately high and adverse human health and environmental effects on minority and 43 low-income populations in the vicinity of GGNS. 44 Environmental Impacts of Alternatives 8-21 8.2.13 Waste Management 1 During the construction stage of this alternative, land clearing and other construction activities 2 would generate waste that can be recycled, disposed of on site, or shipped to an offsite waste 3 disposal facility. Because an NGCC alternative would most likely be constructed on previously 4 disturbed portions of the GGNS site, the amount of wastes produced during land clearing would 5 be minimal. 6 During the operational stage, spent selective catalytic reduction catalysts used to control NO x 7 emissions would make up the majority of the industrial waste generated by this alternative. 8 Because the specific NO x emission control equipment cannot be specified at this time, the 9 amount of spent catalysts that would be generated during each year of operation of the NGCC 10 alternative also cannot be calculated with precision. However, the amount would be modest. 11 During operations, domestic and sanitary wastes would be expected to decrease from amounts 12 now generated because of a reduced operating workforce for the NGCC alternative in 13 comparison to GGNS. 14 According to the GEIS (NRC 1996) a natural gas -fired plant would generate minimal waste; 15 therefore, waste impacts would be SMALL for an NGCC alternative located at the GGNS site. 16 8.2.14 Summary of Impacts of NGCC Alternative 17 Table 8-3 summarizes the environmental impacts of the NGCC alternative compared to 18 continued operation of GGNS. 19 Table 8-3. Summary of Environmental Impacts of the NGCC Alternative 20 Compared to Continued Operation of GGNS 21 Category NGCC Alternative (use existing infrastructure) Continued GGNS Operation Air Quality SMALL to MODERATE SMALL Groundwater Resources SMALL SMALL Surface Water Resources SMALL SMALL Aquatic Ecology SMALL SMALL Terrestrial Ecology SMALL to MODERATE SMALL Human Health SMALL SMALL Land Use SMALL to MODERATE SMALL Socioeconomics SMALL to MODERATE SMALL Transportation SMALL to MODERATE SMALL Aesthetics SMALL SMALL Historic and Archaeological Resources SMALL SMALL Waste Management a SMALL SMALL a As described in Chapter 6, the issue, "offsite radiological impacts (spent fuel and high level waste disposal)," is not evaluated in this EIS.

8.3 Supercritical

Pulverized Coal -Fired Generation 22 In this section, the NRC evaluates the environmental impacts of supercritical pulverized coal 23 (SCPC) generation. 24 In 2010, coal -fired generation accounted for 25 percent of all electricity generated in Mississippi, 25 a 32 percent decrease from 10 years earlier in 2000 (EIA 2012b). Coal provides the second 26 greatest share of electrical power in Mississippi (EIA 2012b). Historically, coal has been the 27 Environmental Impacts of Alternatives 8-22 largest source of electricity in the United States and is expected to remain so through 2035 1 (EIA 2011a). Supercritical coal -fired plants are a feasible, commercially available option for 2 providing electrical generating capacity beyond GGNS's current license expiration. Therefore, 3 the NRC considered supercritical coal -fired generation a reasonable alternative to GGNS 4 license renewal. 5 Baseload coal units have proven their reliability and can routinely sustain capacity factors as 6 high as 85 percent. Among the technologies available, pulverized coal boilers producing 7 supercritical steam (SCPC boilers) are increasingly common for new coal -fired plants given their 8 generally high thermal efficiencies and overall reliability. Although SCPC facilities are more 9 expensive to construct than subcritical coal -fired plants, SCPC facilities consume less fuel per 10 unit output, reducing environmental impacts. In a supercritical coal -fired power plant, burning 11 coal heats pressurized water. As the supercritical steam and water mixture moves through 12 plant pipes to a turbine generator, the pressure drops and the mixture flashes to steam. The 13 heated steam expands across the turbine stages, which then spin and turn the generator to 14 produce electricity. After passing through the turbine, any remaining steam is condensed back 15 to water in the plant's condenser. 16 To replace the 1,475 MWe that GGNS generates, the NRC considered three hypothetical SCPC 17 units, each with a net capacity of 538 MWe. The hypothetical SCPC alternative would be 18 located at a site other than GGNS because insufficient space exists at the GGNS site to support 19 this alternative (Entergy 2011). The NRC assumes that the SCPC site would be located in 20 Mississippi. Using an existing site (such as an existing power plant site) would maximize 21 availability of infrastructure and reduce disruption to land and populations. However, impacts 22 would be greater if the SCPC alternative were located at a site that has been previously 23 disturbed but not located at an existing power plant site. For example, the site might need new 24 intake and discharge facilities and a new cooling system. The SCPC alternative would use 25 about the same amount of water as GGNS, and the NRC assumes the cooling system would 26 use a closed-cycle system with natural draft cooling towers. 27 Various coal sources are available to coal -fired power plants in Mississippi. For the purpose of 28 this evaluation, the NRC assumes that the SCPC alternative would burn a combination of 29 lignite, bituminous, and subbituminous coal, based on the type of coal used in electric plants in 30 Mississippi. Coal -fired power plants in Mississippi are fueled by coal shipped primarily from 31 Mississippi, Colorado, and Wyoming. EIA reported that in 2009, Mississippi produced electricity 32 from coal with a heating value of 8,541 BTU/lb, sulfur content of 0.53 percent, and ash content 33 of 11.27 percent (EIA 2010a). The NRC used a CO 2 emission factor of 210 lb/million BTU for 34 CO 2 calculations in this evaluation, based on the type of coal burned in Mississippi and CO 2 35 emissions factors for types of coal as reported by the EIA (EIA 2012c). Based on technology 36 forecasts from EIA, the staff expects that the SCPC alternative would operate at a heat rate of 37 8,740 BTU/kWh (EIA 2011b). Depending on the specific site, construction of onsite visible 38 structures could include the boilers, exhaust stacks, intake/discharge structures, transmission 39 lines, and an electrical switchyard. Based on GEIS estimates, the SCPC alternative would 40 require approximately 2,744 ac (1,110 ha) of land, although it is assumed that most of this land 41 would have been previously disturbed. To build the SCPC alternative, site crews would clear 42 the plant site of vegetation, prepare the site surface, and begin excavation before other crews 43 began actual construction on the plant and associated infrastructure. Construction materials 44 would be delivered by rail spur, truck, or barge. 45 The NRC also considered an integrated gasification combined-cycle (IGCC) coal -fired plant. 46 IGCC is an emerging technology for generating electricity with coal that combines modern coal 47 gasification technology with both gas -turbine and steam -turbine power generation. The 48 technology is cleaner than conventional pulverized coal plants because major pollutants can be 49 Environmental Impacts of Alternatives 8-23 removed from the gas stream before combustion. An IGCC alternative would also generate 1 less waste than the pulverized coal -fired alternative. IGCC units do not produce ash or 2 scrubber wastes. In spite of the advantages, the NRC concludes that a new IGCC plant is not a 3 reasonable alternative for the following reasons: 4 The few existing IGCC plants in the United States have considerably smaller 5 capacity (approximately 250 MWe each) than GGNS (1,475 MWe); 6 System reliability of existing IGCC plants has been lower than pulverized coal 7 plants; 8 IGCC plants are more expensive than comparable pulverized coal plants 9 (NETL 2007); 10 Existing IGCC plants have had an extended (though ultimately successful) 11 operational testing period (NPCC 2005); and, 12 A lack of overall plant performance warranties for IGCC plants has hindered 13 commercial financing (NPCC 2005). 14 Mississippi Power is constructing a 582 MWe IGCC plant in Kemper County, Mississippi. The 15 plant is scheduled to begin operations in May 2014 and is experiencing legal, regulatory, and 16 financial challenges (Reuters 2012). 17 8.3.1 Air Quality 18 Mississippi contains three designated air quality control regions

the Northeast Mississippi 19 Intrastate Air Quality Control Region (AQCR); the Mobile (Alabama)

-Pensacola-Panama City 20 (Florida)-Southern Mississippi Interstate AQCR; a nd, the Mississippi Delta Intrastate AQCR 21 (40 CFR 81.62, 40 CFR 81.68, 40 CFR 81.122 ). The State of Mississippi is in attainment with 22 national primary and secondary air quality standards for all criteria pollutants , except De Soto 23 County which is located about 200 miles (322 km) north-northeast of GGNS and part of which is 24 designated as a marginal nonattainment area for the 2008 8 -hour ozone standard. 25 Construction activities for this alternative would generate fugitive dust. However, mitigation 26 measures, including wetting of unpaved roads and construction areas, and seeding or mulching 27 bare areas would minimize fugitive dust. Construction worker vehicles and motorized 28 construction equipment would create exhaust emissions. However, these emissions would end 29 upon completion of construction. 30 Various Federal and State regulations aimed at controlling air pollution would affect the SCPC 31 alternative. A new SCPC plant would qualify as a new major -emitting industrial facility and 32 would require a PSD permit if the location is in attainment or unclassifiable with the NAAQS and 33 a Title V operating permit that would specify limits to emissions of all criteria pollutants. 34 The SCPC alternative would also need to comply with new source performance standards (see 35 40 CFR 60 Subpart Da and limits for particulate matter and opacity (40 CFR 60.42(a)), SO 2 36 (40 CFR 60.43(a)), and NO x (40 CFR 60.44 Subpart Da(a)(1)). If the SCPC alternative were 37 located close to a mandatory Class I area, additional air pollution control requirements would be 38 required (Subpart P of 40 CFR Part 51) as mandated by the Regional Haze Rule. The rule 39 would not apply to this coal -fired alternative, however, because there are no Class I Federal 40 areas within 186 mi (300 km) of the GGNS site (EPA 2012b). 41 Emissions from the SCPC alternative, projected by the staff based on published EIA data, EPA 42 emission factors, and performance characteristics for this alternative and likely emission 43 controls, would be: 44 Environmental Impacts of Alternatives 8-24 sulfur oxides (SO X)-2,869 tons (2,603 MT) per year 1 nitrogen oxides (NO X)-3,118 tons (2,829 MT) per year 2 particulate matter (PM 10)-80 tons (73 MT) per year 3 (PM2.5)-21 tons (19 MT) per year 4 carbon monoxide (CO) -1,547 tons (1,403 MT) per year 5 carbon dioxide (CO 2)-11.1 million tons (10.1 million MT) per year 6 8.3.1.1 Sulfur Oxide and Nitrogen Oxide 7 As stated above, the SCPC alternative would produce 2,869 tons (2,603 MT) total SO X 8 emissions per year. SO 2 emissions from an SCPC alternative would be subject to the 9 requirements of Title IV of the CAA. Title IV regulations were enacted to reduce emissions of 10 SO 2 and NO x by restricting emissions of these pollutants from power plants. Title IV caps 11 aggregate annual power plant SO 2 emissions and imposes controls on SO 2 emissions through a 12 system of marketable allowances. EPA issues one allowance for each ton of SO 2 that a unit is 13 allowed to emit. New units do not receive allowances, but are required to have secured 14 allowances (or offsets) from existing sources to cover their SO 2 emissions. Owners of new units 15 must therefore purchase allowances from owners of other power plants or reduce SO 2 16 emissions at other power plants they own. Allowances can be banked for use in future years. 17 Thus, provided a new SCPC power plant is able to purchase sufficient allowances to operate, it 18 would not add to net regional SO 2 emissions, although it might do so locally. 19 An SCPC alternative at an alternate site would most likely employ various available NO x control 20 technologies, which can involve combustion modifications, post -combustion controls, or both. 21 Combustion modifications include low -NO x burners, overfire air, and operational modifications. 22 Post-combustion processes include selective catalytic reduction and selective non -catalytic 23 reduction. An effective combination of the combustion modifications and post -combustion 24 processes allow the reduction of NO x emissions by up to 95 percent. 25 8.3.1.2 Greenhouse Gases 26 An SCPC alternative would release GHGs, such as CO 2 during operations as well as during 27 mining, processing, and transportation, which the GEIS indicates could contribute to global 28 warming and connected climate changes. The amount of CO 2 released per unit of power 29 produced would depend on the quality of the fuel and the firing conditions and overall firing 30 efficiency of the boiler. As discussed above, the NRC assumes that a coal -fired alternative 31 would burn the same coal as was burned in Mississippi in 2009 with a CO 2 emission factor of 32 210 lb/million BTU. 33 On July 12, 2012, EPA issued a final rule tailoring the criteria that determine which stationary 34 sources and modifications to existing projects become subject to permitting requirements for 35 GHG emissions under the PSD and Title V Programs of the CAA (77 FR 41051). According to 36 this rule, GHGs are a regulated new source review pollutant under the PSD major source 37 permitting program if the source is otherwise subject to PSD (for another regulated new source 38 review pollutant) and has a GHG potential to emit equal to or greater than 75,000 tons 39 (68,000 MT) per year of CO 2 equivalent ("carbon dioxide equivalent" adjusts for different global 40 warming potentials for different GHGs). Beginning January 2, 2011, operating permits issued to 41 major sources of GHGs under the PSD or Title V Federal permit programs must contain 42 provisions requiring the use of Best Available Control Technology (BACT) to limit the emissions 43 of GHGs if those sources would be subject to PSD or Title V permitting requirements. If the 44 SCPC alternative meets the GHG emission thresholds established in the rule, then GHG 45 emissions from this alternative would be regulated under the PSD and Title V permit programs. 46 Environmental Impacts of Alternatives 8-25 8.3.1.3 Particulates 1 As described above, onsite activities during the construction of an SCPC alternative would also 2 generate fugitive dust as well as emissions from vehicles and motorized equipment. These 3 impacts would be intermittent, temporary, and minimized by dust -control measures. 4 During operations, the SCPC alternative would produce 80 tons (73 MT) per year and 21 tons 5 (19 MT) per year of particulate matter PM 10 and PM2.5 , respectively. The SCPC alternative 6 would use fabric filters to remove particulates from flue gases with an expected 99.9 percent 7 removal efficiency (NETL 2007). Coal -handling equipment would introduce fugitive dust 8 emissions when fuel is being transferred to onsite storage and then moved from storage for use 9 in the plant. 10 8.3.1.4 Hazardous Air Pollutants 11 In addition to being major sources of criteria pollutants, coal -fired plants can also be sources of 12 HAPs as a result of hazardous constituents contained in the coal. EPA has determined that 13 coal- and oil-fired electric utility steam -generating units are significant emitters of the following 14 HAPs: arsenic, beryllium, cadmium, chromium, dioxins, hydrogen chloride, hydrogen fluoride, 15 lead, manganese, and mercury (EPA 2000b). EPA concluded that mercury is the HAP of 16 greatest concern and that (1) a link exists between coal combustion and mercury emissions, 17 (2) electric utility steam -generating units are the largest domestic source of mercury emissions, 18 and (3) certain segments of the U.S. population (e.g., the developing fetus and subsistence 19 fish-eating populations) are believed to be at potential risk of adverse health effects resulting 20 from mercury exposures caused by the consumption of contaminated fish (EPA 2000b). 21 Consequently, the SCPC alternative would be subject to the Mercury and Air Toxics Standards 22 rule that was finalized in March 2011. The rule set technology -based emission limitation 23 standards for all HAPs. The rule applies to coal -fired power plants with a capacity of 25 MWe or 24 greater. 25 8.3.1.5 Conclusion 26 While the GElS mentions global warming from unregulated CO 2 emissions and acid rain from 27 SO 2 and NO x emissions as potential impacts, it does not quantify emissions from coal-fired 28 power plants. However, the GElS does imply that air impacts from coal plant operation would 29 be substantial (NRC 1996). The above analysis shows that emissions of air pollutants, 30 including SO x, NO x, CO, and particulates, far exceed those produced by the existing nuclear 31 power plant during operation, as well as those of the other fossil fuel alternatives considered in 32 this section. The NRC analysis of air quality impacts for an SCPC alternative indicates that 33 impacts would have clearly noticeable effects, but given existing regulatory regimes, permit 34 requirements, and emissions controls, the coal -fired alternative would not destabilize air quality. 35 Federal and state regulations would require the installation of pollution control equipment to 36 meet applicable local requirements and permit conditions and may eventually require 37 participation in emissions trading scenarios. Therefore, air impacts from an SCPC alternative 38 located at an alternate site would be MODERATE. 39 8.3.2 Groundwater Resources 40 The amount of groundwater required for construction of the SCPC alternative would be much 41 less than required during plant operation. NRC assumes that ground water use for construction 42 would comply with State and local permit and monitoring requirements. Groundwater quality 43 and use impacts from construction of the SCPC alternative are expected to be SMALL. 44 The amount of water required to operate the SCPC alternative would be similar to that required 45 for GGNS. Potable water and other plant groundwater requirements would be similar to GGNS. 46 Environmental Impacts of Alternatives 8-26 Coal, fly ash, and clinker storage could cause groundwater contamination, but with proper 1 storage facility design and operation, the impacts could be mitigated. Given these assumptions, 2 the impacts to groundwater use and quality would be SMALL. 3 8.3.3 Surface Water Resources 4 The SCPC cooling system would consist of natural draft cooling towers requiring approximately 5 the same amount of water as the existing nuclear plant. Within the service territory, the 6 Mississippi River, other rivers, alluvial aquifers, or reservoirs might be a source of cooling water. 7 If the Mississippi River or its alluvial aquifer w as used, other consumers of surface water are 8 unlikely to be affected because of the large volume of water flowing within the river and in its 9 alluvium. In other rivers, if the amount of water flowing is large, the impact on other surface 10 water users is likely to be minor. If the water flow is moderate and there are few other surface 11 water users, the impact on other surface water users should also be minor. However, impacts 12 on other surface water users could result in the case of a small river with many surface water 13 users. The NRC assumes that the SCPC would not be sited on a small river with many surface 14 water users. These impacts could be mitigated by the use of more efficient cooling technology 15 or other water sources (i.e., import water, perhaps by pipeline from other surface water bodies). 16 If dredging of streams or rivers occurs during construction, surface water quality immediately 17 downstream of the dredging activities could be temporarily degraded by increases in suspended 18 sediment concentration. During plant operation, surface water discharges largely would consist 19 of cooling tower blowdown similar to GGNS. Assuming public sewers are not available, process 20 waste and treated sanitary wastewater effluent may also be discharged to the surface water 21 body. An NPDES permit would regulate discharges. Runoff from coal storage, fly ash, and 22 clinker material would be controlled and regulated by an NPDES permit. Overall, impacts to 23 surface water use and quality would be SMALL. 24 8.3.4 Aquatic Ecology 25 Construction activities for the SCPC alternative (such as construction of heavy -haul roads and 26 the power block) could affect onsite aquatic features. Minimal impacts on aquatic ecology 27 resources are expected because the plant operator would likely implement BMPs to minimize 28 erosion and sedimentation. Stormwater control measures, which would be required to comply 29 with Mississippi NPDES permitting, would minimize the flow of disturbed soils into aquatic 30 habitats. Depending on the available infrastructure at the selected site, the SCPC alternative 31 may require modification or expansion of the existing intake or discharge structures, or 32 construction of new intake and discharge structures. Construction of new or modified intake 33 and discharge structures may require dredging. In addition, dredging may be required to 34 transport new materials to the site, which could result in increased sedimentation and turbidity. 35 Dredging activities would require BMPs for in -water work to minimize sedimentation and 36 erosion. Due to the short -term nature of the dredging activities, the hydrological alterations to 37 aquatic habitats would likely be localized and temporary. 38 During operations, the SCPC alternative would require a similar amount of cooling water as 39 GGNS. However, the cooling water may be withdrawn from surface water bodies, rather than 40 from groundwater. If the cooling water is withdrawn from surface water bodies, aquatic 41 resources may be impacted from impingement and entrainment. Impingement and 42 entertainment would be minimized because NRC assumes that the plant would use a 43 closed-cycle cooling system. A similar amount of water would be discharged as at GGNS. 44 Therefore, thermal impacts would be similar for the SCPC alternative as for GGNS. The cooling 45 system for a new SCPC plant would have similar chemical discharges as GGNS, but the air 46 Environmental Impacts of Alternatives 8-27 emissions from the SCPC plant would emit ash and particulates that could settle onto a river 1 surface and introduce a new source of pollutants. However, the flow of the river would likely 2 dissipate and dilute the concentration of pollutants resulting in minimal exposure to aquatic 3 biota. 4 Consultation under several Federal acts, including the ESA and Magnuson -Stevens Act, would 5 be required to assess the occurrence and potential impacts to Federally protected aquatic 6 species and habitats within affected surface waters. Coordination with Mississippi natural 7 resource agencies would further ensure that the plant operator would take appropriate steps t o 8 avoid or mitigate impacts to state-listed species, habitats of conservation concern, and other 9 protected species and habitats. The NRC assumes that these consultations would result in 10 avoidance or mitigation measures that would minimize or eliminate potential impacts to 11 protected aquatic species and habitats. 12 The impacts on aquatic ecology would be minor because construction activities would require 13 BMPs and stormwater management permits. Deposition of pollutants into aquatic habitats from 14 the plant's air emissions would be minimal because the concentration of pollutants would be 15 diluted with the river flow. Therefore, the staff concludes that impacts on aquatic ecology would 16 be SMALL. 17 8.3.5 Terrestrial Ecology 18 Construction of an SCPC alternative would require 2,744 ac (1,110 ha) of land, which would 19 include construction of the plant and associated infrastructure. The SCPC alternative may 20 require up to 35,508 ac (14,370 ha) of additional land for coal mining and processing. Because 21 of the relatively large land requirement for the site, a portion of the site would likely be land that 22 had not been previously disturbed, which would directly affect terrestrial habitat by destroying 23 existing vegetation communities and displacing wildlife. This alternative could also include 24 construction of new transmission lines and a railroad spur, depending on the specific site, which 25 would require additional habitat loss and fragmentation. Thus, the level of direct impacts would 26 vary substantially based on site selection. Offsite construction would occur mostly on land 27 where coal extraction is ongoing. Erosion and sedimentation, fugitive dust, and construction 28 debris impacts would be minor with implementation of appropriate BMPs. Construction noise 29 could modify wildlife behavior; however, these effects would be temporary. Road improvements 30 or construction of additional service roads to facilitate construction could result in the temporary 31 or permanent loss of terrestrial habitat. Operational impacts to terrestrial habitats and species 32 from transmission line operation and corridor vegetation maintenance, and operation of the 33 cooling system would be similar in magnitude and intensity as those resulting from GGNS. 34 Because of the potentially large area of undisturbed habitat that could be affected from 35 construction of an SCPC alternative, the impacts of construction to terrestrial habitats and 36 species could range from MODERATE to LARGE depending on the specific site location. The 37 impacts of operation would be SMALL to MODERATE. 38 As discussed under aquatic ecology impacts, consultation with FWS under the ESA would avoid 39 potential ly adverse impacts to Federally listed species or adverse modification or destruction of 40 designated critical habitat. Coordination with State natural resource agencies would further 41 ensure that the plant operator would take appropriate steps to avoid or mitigate impacts to 42 State-listed species, habitats of conservation concern, and other protected species and habitats. 43 The NRC assumes that these consultations would result in avoidance or mitigation measures 44 that would minimize or eliminate potential impacts to protected terrestrial species and habitats. 45 Consequently, the impacts of construction and operation of a new nuclear alternative on 46 protected species and habitats would be SMALL. 47 Environmental Impacts of Alternatives 8-28 8.3.6 Human Health 1 Impacts on human health from construction of the SCPC alternative would be similar to impacts 2 associated with the construction of any major industrial facility. Compliance with worker 3 protection rules would control those impacts on workers at acceptable levels. Impacts from 4 construction on the general public would be minimal because the plant operator would likely 5 follow BMPs and limit access to the active construction area to authorized individuals. Impacts 6 on human health from the construction of the SCPC alternative would be SMALL. 7 Coal-fired power plants introduce worker risks from coal and limestone mining, coal and 8 limestone transportation, and disposal of coal combustion residues and scrubber wastes. In 9 addition, there are public risks from inhalation of stack emissions and the secondary effects of 10 eating foods grown in areas subject to deposition from plant stacks. 11 Human health risks of coal -fired power plants are described, in general, in Table 8.2 of the GEIS 12 (NRC 1996). Cancer and emphysema as a result of the inhalation of toxins and particulates are 13 identified as potential health risks to occupational workers and members of the public 14 (NRC 1996). The human health risks associated with coal -fired power plants, both for 15 occupational workers and members of the public, are greater than those of the current GGNS 16 reactor , because of exposures to chemicals such as mercury; SO x; NO x; radioactive elements, 17 such as uranium and thorium contained in coal and coal ash; and polycyclic aromatic 18 hydrocarbon (PAH) compounds, including benzo(a)pyrene. 19 Regulations restricting emissions enforced by either EPA or delegated state agencies have 20 reduced potential health effects, but have not entirely eliminated them. These agencies also 21 impose site -specific emission limits as needed to protect human health. Even if the SCPC 22 alternative were located in a nonattainment area, emission controls and trading or offset 23 mechanisms could prevent further regional degradation; however, local effects could be visible. 24 Many of the byproducts of coal combustion responsible for health effects are largely controlled, 25 captured, or converted in modern power plants, although some level of health effects may 26 remain. 27 Aside from emissions impacts, the SCPC alternative introduces the risk of coal pile fires and for 28 those plants that manage coal combustion residue liquids and sludge in waste impoundments, 29 the release of the waste may result because of a failure of the impoundment. Good 30 housekeeping practices to control coal dust greatly reduce the potential for coal dust explosions 31 or coal pile fires. Although there have been several instances in recent years, sludge 32 impoundment failures are still rare. Free water could also be recovered from such waste 33 streams and recycled and the solid or semi -solid portions removed to permitted offsite disposal 34 facilities. 35 Overall, given extensive health -based regulation and controls likely to be imposed as permit 36 conditions applicable to waste handling and disposal, the staff expects human health impacts 37 from operation of the SCPC alternative at an alternate site to be SMAL L. 38 8.3.7 Land Use 39 The GEIS generically evaluates the impact of constructing and operating various replacement 40 power plant alternatives on land use, both on and off each power plant site. The analysis of 41 land use impacts focuses on the amount of land area that would be affected by the construction 42 and operation of an SCPC power plant at an existing power plant site other than GGNS. 43 Based on scaled GEIS estimates, approximately 2 ,744 ac (1,100 ha) would be needed to 44 support an SCPC alternative to replace GGNS, excluding land needed for coal mining and 45 Environmental Impacts of Alternatives 8-29 processing. It is expected that the SCPC alternative would be located at an existing power plant 1 site or otherwise disturbed industrial site, and thus the land use impacts from construction would 2 range from SMALL to MODERATE. 3 Offsite land use impacts would occur from coal mining, in addition to land use impacts from the 4 construction and operation of the new power plant. Using the GEIS estimate, the SCPC 5 alternative might require up to 35,508 ac (14,370 ha) of land for coal mining and waste disposal 6 during power plant operations, based on an assumption of 22,000 ac (8,903 ha) of land required 7 per 1,000 MWe and a 1,614 MWe SCPC plant (NRC 1996). However, much of the land in 8 existing coal mining areas has already experienced some level of disturbance. 9 The elimination of uranium fuel for GGNS would partially offset some of the land requirements 10 for the SCPC alternative. Scaling from GEIS estimates, approximately 1,033 ac (418 ha) 11 (based on an assumption of 35 ac/yr disturbed per 1,000 MWe) would no longer be needed for 12 mining and processing uranium during the operating life of the SCPC plant (NRC 1996). 13 Overall, land use impacts from SCPC power plant operations would be SMALL to MODERATE 14 depending on the extent of coal mining. 15 8.3.8 Socioeconomics 16 As previously discussed, socioeconomic impacts are defined in terms of changes to the 17 demographic and economic characteristics and social condition of a region. For example, the 18 number of jobs created by the construction and operation of a power plant could affect regional 19 employment, income, and expenditures. This alternative would create two types of jobs

20 (1) construction jobs, which are transient, short in duration, and less likely to have a long

-term 21 socioeconomic impacts; and (2) power plant operation jobs, which have a greater potential for 22 permanent, long -term socioeconomic impacts. Workforce requirements for the construction and 23 operation of the SCPC alternative were evaluated to measure their possible effects on current 24 socioeconomic conditions . 25 Scaling from GEIS estimates, the construction workforce would peak at 4,035 workers. The 26 relative economic impact of this many workers on the local economy and tax base would vary, 27 with the greatest impacts occurring in the communities where the majority of construction 28 workers would reside and spend their income. As a result, local communities could experience 29 a short-term "boom" from increased tax revenue and income generated by construction 30 expenditures and the increased demand for temporary (rental) housing and business services. 31 After construction, local communities could be temporarily affected by the loss of construction 32 jobs, the associated loss in demand for business services, and the rental housing market could 33 experience increased vacancies and decreased prices. The impact of construction on 34 socioeconomic conditions could range from SMALL to MODERATE because of the fluctuation 35 of the workforce. 36 Scaling from GEIS estimates, the workforce during plant operations would be 404 workers. This 37 alternative would result in a loss of approximately 690 relatively high -paying jobs at GGNS, with 38 a corresponding reduction in purchasing activity and tax contributions to the regional economy. 39 However, a larger amount of property taxes may be paid to local jurisdictions under the SCPC 40 alternative as more land may be required for coal -fired power plant operations than GGNS. 41 Therefore, socioeconomic impacts during operations could range from SMALL to MODERATE. 42 8.3.9 Transportation 43 Transportation impacts associated with construction of the SCPC alternative would consist of 44 commuting workers and truck deliveries of construction materials. During periods of peak 45 Environmental Impacts of Alternatives 8-30 construction activity, 4,035 workers could be commuting daily to the site significantly adding to 1 the normal flow of traffic (NRC 1996). Vehicular traffic would peak during shift changes, 2 resulting in temporary levels of service impacts and delays at intersections. Materials also could 3 be delivered by rail or barge, depending on site location. Traffic -related transportation impacts 4 during construction likely would range from MODERATE to LARGE. 5 Once construction of the SCPC alternative is complete, traffic-related transportation impacts on 6 local roads would be greatly reduced. The estimated number of operations workers would be 7 404 (NRC 1996). Traffic on roadways would peak during shift changes, resulting in temporary 8 levels of service impacts and delays at intersections. Frequent deliveries of coal and limestone 9 by rail would cause levels of service impacts on certain roads because of delays at railroad 10 crossings. Onsite coal storage would make it possible to receive several trains per day at a site 11 with rail access. Limestone delivered by rail could also add additional traffic (though 12 considerably less traffic than that generated by coal deliveries). If a site on navigable waters 13 were used, barge delivery of coal and other materials would be feasible. Overall, the SCPC 14 alternative transportation impacts would be SMALL to MODERATE during plant operations. 15 8.3.10 Aesthetics 16 The analysis of aesthetics impacts focuses on the degree of contrast between the SCPC 17 alternative and the surrounding landscape and the visibility of the new SCPC plant at an existing 18 power plant site or a former plant (brownfield) site. Most construction, clearing, and excavation 19 activities would take place within the existing power plant or brownfield site, and these activities 20 could be visible from offsite roads. Since power plant and brownfield sites look industrial, 21 construction -related activities would appear similar to other ongoing industrial activities. 22 The SCPC plant buildings would be approximately 100 ft (30 m) tall, with two to four exhaust 23 stacks up to 150 ft (46 m) tall. The SCPS alternative would be visible offsite during daylight 24 hours and some structures may require aircraft warning lights. Condensate plumes from the 25 cooling towers would add to the visual impact. The cooling towers would be 400 -500 ft 26 (122-152 m) in height. The power block of the SCPC alternative could look very similar to 27 GGNS. Noise generated during power plant operations would be limited to routine industrial 28 processes and communications. 29 In general, given the industrial appearance of existing industrial and brownfield sites, the SCPC 30 alternative would blend in with the surroundings. Aesthetic changes would therefore be limited 31 to the immediate vicinity of the existing power plant and brownfield sites, and any impacts would 32 be SMALL. 33 8.3.11 Historic and Archaeological Resources 34 Lands needed to support construction of an SCPC plant and associated corridors would need to 35 be surveyed for historic and archaeological resources. Resources found in these surveys would 36 need to be evaluated for eligibility on the National Register of Historic Properties (NRHP) and 37 mitigation of adverse effects would need to be addressed if eligible resources were 38 encountered. When constructing an SCPC plant on a previously disturbed former plant 39 (brownfield) site, an inventory may still be necessary if the site has not been previously 40 surveyed or to verify the level of disturbance and evaluate the potential for intact subsurface 41 resources. The potential for impacts on historic and archaeological resources from the SCPC 42 alternative would vary greatly depending on the resource richness and location of the proposed 43 site. However, given that the preference is to use a previously disturbed former plant site, 44 avoidance of significant historic and archaeological resources should be possible and effectively 45 Environmental Impacts of Alternatives 8-31 managed under current laws and regulations. Therefore, the impacts on historic and 1 archaeological resources from the SCPC alternative would be SMALL to MODERATE. 2 8.3.12 Environmental Justice 3 The environmental justice impact analysis evaluates the potential for disproportionately high and 4 adverse human health, environmental, and socioeconomic effects on minority and low -income 5 populations that could result from the construction and operation of a new power plant. As 6 previously discussed in Section 8.1.12, such effects may include human health, biological, 7 cultural, economic, or social impacts. 8 Potential impacts to minority and low -income populations from the construction of an SCPC 9 alternative would mostly consist of environmental and socioeconomic effects (e.g., noise, dust, 10 traffic, employment, and housing impacts). Noise and dust impacts from construction would be 11 short-term and primarily limited to onsite activities. Minority and low -income populations 12 residing along site access roads would be directly affected by increased commuter vehicle 13 traffic during shift changes and truck traffic. However, because of the temporary nature of 14 construction, these effects are not likely to be high and adverse and would be contained to a 15 limited time period during certain hours of the day. Increased demand for rental housing during 16 construction could cause rental costs to rise disproportionately affecting low -income populations 17 who rely on inexpensive housing. However, given the likelihood of locating the SCPC 18 alternative at the site of an existing or former power plant and the proximity of most power plant 19 sites to metropolitan areas, workers could commute to the construction site, thereby reducing 20 the need for rental housing. 21 Potential impacts to minority and low -income populations from operation of an SCPC plant 22 would consist mainly of the effects of emissions. Because permitted emissions are expected to 23 remain within regulatory standards, impacts are not expected to be high and adverse. 24 Based on this information and the analysis of human health and environmental impacts 25 presented in this section, the construction and operation of the SCPC alternative would not have 26 disproportionately high and adverse human health and environmental effects on minority and 27 low-income populations. 28 8.3.13 Waste Management 29 During construction of an SCPC alternative, land clearing and other construction activities would 30 generate waste that could be recycled, disposed of on site, or shipped to an offsite waste 31 disposal facility. Because the alternative would be constructed at an existing power plant site, 32 or a previously disturbed site, the amounts of wastes produced during land clearing would be 33 reduced. 34 The burning of coal generates coal combustion products (CCP) such as bottom ash or fly ash (a 35 dry solid) and sludge (a semi -solid byproduct of emission control system operation). According 36 to the American Coal Ash Association, in 2010, approximately 130 million tons of CCPs were 37 generated by coal -fueled electric utilities. Fly ash accounted for over 67 million tons of CCP, 38 bottom ash accounted for over 17 million tons, and scrubber sludge about 22 million tons. 39 Approximately 38 percent of the fly ash and 42 percent of the bottom ash was recycled. 40 Approximately 48 percent of the scrubber sludge was recycled (ACAA 2010). The boilers 41 comprising the SCPC alternative are assumed to have the following pollution control devices: 42 fabric filter for particulate control, operating at 99 .9 percent removal 43 efficiency; 44 Environmental Impacts of Alternatives 8-32 wet calcium carbonate SO 2 scrubber, operating at 95 percent removal 1 efficiency; and 2 l ow-NO x burners with overfire air and selective catalytic reduction for nitrogen 3 oxide controls capable of attaining a NO x removal of 86 percent. 4 This coal-fired alternative would produce roughly 696,839 tons (632,173 MT) of ash, and 5 50 percent (348,420 tons [316,086 MT]) of the ash would be recycled for beneficial use. 6 Disposal of the remaining waste could have noticeable effects. However, proper disposal, 7 monitoring, and management practices as required by local ordinances and State regulations 8 would minimize these impacts. After closure of the waste site and revegetation, the land could 9 be available for other uses. 10 The impacts from waste generated during operation of this SCPC alternative would be 11 MODERATE because the impacts would be clearly visible but would not destabilize important 12 resources. 13 8.3.14 Summary of Impacts of SCPC Alternative 14 Table 8-4 summarizes the environmental impacts of the SCPC alternative compared to 15 continued operation of GGN S. 16 Table 8-4. Summary of Environmental Impacts of the SCPC Alternative 17 Compared to Continued Operation of GGNS 18 Category SCPC Alternative Continued GGNS Operation Air Quality MODERATE SMALL Groundwater Resources SMALL SMALL Surface Water Resources SMALL SMALL Aquatic Ecology SMALL SMALL Terrestrial Ecology SMALL to LARGE SMALL Human Health SMALL SMALL Land Use SMALL to MODERATE SMALL Socioeconomics SMALL to MODERATE SMALL Transportation SMALL to LARGE SMALL Aesthetics SMALL SMALL Historic and Archaeological Resources SMALL to MODERATE SMALL Waste Management a MODERATE SMALL a As described in Chapter 6, the issue, "offsite radiological impacts (spent fuel and high level waste disposal)," is not evaluated in this EIS.

8.4 Combination

Alternative 19 In this section, the NRC evaluates the environmental impacts from a combination of 20 alternatives. This combination includes 530 MWe from one NGCC unit similar to the units 21 described in Section 8.2, 360 MWe from biomass-fired units, 280 MWe from demand -side 22 management (DSM), and 305 MWe from purchased power. 23 The NRC assumed that one new NGCC unit of the type described in Section

8.2 would

be 24 constructed and installed at the GGNS site with a capacity of 530 MWe. The NRC estimates 25 that it would require about one third of the area necessary for the alternative considered in 26 Section 8.2 and that construction and operational effects would scale accordingly. 27 Environmental Impacts of Alternatives 8-33 The NRC assumed that biomass -fired generation, located in Mississippi, would replace 1 360 MWe of GGNS output. Electricity generation from biomass -fired generation is currently the 2 only commercially available renewable resource in operation in Mississippi, with a total of 3 235 MWe installed capacity (EIA 2012a). The development of biomass resources is also 4 consistent with Entergy's Strategic Resource Plan (SRP). The SRP estimates about 700 MWe 5 of new renewable energy generation (spread across Entergy's six current operating companies) 6 will come from biomass -fired generation from 2009 to 2019 (Entergy 2009). The SRP 7 concluded that by 2019, commercially available renewable energy is expected to be limited 8 primarily to biomass -fired generation in Mississippi. Mississippi currently does not require 9 electric utilities to generate a portion of their electricity from renewable sources. 10 The NRC assumed a DSM program would replace 280 MWe of GGNS output. Although 11 Mississippi does not require DSM programs, Entergy commissioned a study by ICF International 12 to calculate possible savings through a DSM program (ICF 2009). According to the study, the 13 potential energy savings across Entergy's six operating companies could reach 729 MWe by 14 2019 and 1,050 MWe by 2029 (Entergy 2009). Because Entergy Mississippi, Inc. (EMI) 15 represents 13 percent of Entergy's total energy sales, the NRC estimates that the potential 16 savings would reach 95 MWe by 2019 and 136 MWe by 2029 in Mississippi. In addition, the 17 Federal Energy Regulatory Commission (FERC) evaluated potential energy savings using DSM 18 in 5- and 10-year horizons for four development scenarios that varied in level of participation 19 (FERC 2009). FERC's analysis indicates that by the year 2019, the achievable participation 20 scenario would yield a 1,602 MWe peak demand reduction in Mississippi (FERC 2009). Since 21 EMI provides 34 percent of Mississippi's electricity generation, if these demand reductions were 22 achieved, it would translate to a reduction of 539 MWe for EMI. The 280 MWe reduction in 23 energy use for this alternative falls between the ICF International and FERC study outcomes 24 projecting potential DSM savings. Therefore, the NRC finds 280 MWe of DSM savings to be a 25 reasonable portion of the combination alternative. No major construction would be necessary 26 for the DSM component of the combination alternative. 27 For the combination alternative, the NRC assumes that nine 50 MWe biomass -fired units with a 28 capacity factor of 80 percent would be required to replace 360 MWe of GGNS output. Biomass 29 resources typically include forest residue, primary mill residues, secondary mill residues, and 30 urban wood residues (NREL 2005). The biomass -fired units would be similar in appearance 31 and operation to fossil fuel -fired power plants. The technology used for conversion of biomass 32 to electricity would be direct combustion, which involves the burning of biomass, producing hot 33 gases which, in turn, boil water to produce steam. The steam is used to spin a turbine that 34 generates electricity. Biomass combustion systems also require feedstock storage and 35 handling systems, as well as a cooling water system with cooling towers. The NRC assumes 36 that approximately 15 ac (6 ha) of land would be required for each 50 -MWe plant, for a total of 37 135 ac (55 ha) (NREL 2003, Palmer Renewable Energy 2011). The combustion of biomass 38 resources would affect air quality, but would generate fewer SO 2 and NO x emissions per unit of 39 energy delivered than coal. In addition, environmental impacts would occur from harvesting 40 wood resources. Biomass -fired power plants generate greater emissions than either natural 41 gas or nuclear plants of equal electrical generation capacity (NREL 1999). 42 For the combination alternative, 305 MWe would be purchased to replace that amount of GGNS 43 generation. In its Strategic Resource Plan, Entergy's Reference Planning Scenario assumes 44 that by the time GGNS's license expir es in November 2024, EMI will purchase 500 MWe from 45 non-Entergy generation (Entergy 2009). Therefore, it is reasonable to assume that 305 MWe 46 will be available for purchase. The impacts of purchased power could be wide -ranging, 47 depending on the energy type and location selected. The power would likely come from the 48 most common types of energy generation in the region: gas, coal, or nuclear plants. 49 Environmental Impacts of Alternatives 8-34 Construction and operation impacts would be similar to those described in Sections 8.1 1 through 8.3. The purchased power would either be purchased from existing plants, or from new 2 plant construction, depending on the availability of power sources. Additional impacts could 3 occur if new plants need to be built to produce the additional 305 MWe of power. 4 8.4.1 Air Quality 5 Air quality impacts would result primarily from the energy generated from the NGCC and 6 biomass-fired units. There also would be impacts to air quality from the purchased power 7 portion of the alternative, with the magnitude of impact dependent on the source of the 8 purchased power. As described in Section 8.4, the purchased power would likely come from 9 the most common types of energy generation in the region: gas, coal, or nuclear plants. 10 Therefore, air quality impacts would be similar to those described in Sections 8.1.1, 8.2.1, and 11 8.3.1. Impacts to air quality from the NGCC portion would be similar to the impacts in 12 Section 8.2.1, but scaled down by approximately one -third. 13 Mississippi contains three designated air quality control regions

the Northeast Mississippi 14 Intrastate Air Quality Control Region (AQCR); the Mobile (Alabama)

-Pensacola-Panama City 15 (Florida)-Southern Mississippi Interstate AQCR; a nd, the Mississippi Delta Intrastate AQCR 16 (40 CFR 81.62, 40 CFR 81.68, 40 CFR 81.122 ). The State of Mississippi is in attainment with 17 national primary and secondary air quality standards for all criteria pollutants , except De Soto 18 County which is located about 200 miles (322 km) north-northeast of GGNS and part of which is 19 designated as a marginal nonattainment area for the 2008 8 -hour ozone standard. 20 Construction activities for this alternative would generate fugitive dust. However, mitigation 21 measures, including wetting of unpaved roads and construction areas, and seeding or mulching 22 bare areas would minimize fugitive dust. Construction worker vehicles and motorized 23 construction equipment would create exhaust emissions. However, these emissions would end 24 upon completion of construction. 25 Various Federal and State regulations aimed at controlling air pollution would impact NGCC and 26 biomass-fired facilities located in Mississippi. Both the NGCC plant and biomass -fired units 27 would be subject to NAAQS, which would limit emissions for criteria pollutants and reflect 28 existing ambient air quality at the selected location. Biomass -fired generation produces air 29 quality impacts similar to that of coal. Emissions from the 50-MWe facilities may not be large 30 individually, but cumulatively could have more significant air quality impacts. Both the NGCC 31 and biomass -fired plants would qualify as new major emitting industrial facilities and would be 32 subject to PSD requirements under the Clean Air Act (CAA) (EPA 2012 a). The NGCC and 33 biomass-fired plants would require Title V operating permits that would specify limits to 34 emissions of all criteria pollutants. The NGCC portion of the alternative would need to comply 35 with new source performance standards (40 CFR Part 60 Subpart KKKK) and the biomass -36 portion of the alternative would need to comply with 40 CFR Part Subpart Db. If the NGCC or 37 biomass-fired plants were located close to a mandatory Class I area, additional air pollution 38 control requirements might be required (Subpart P of 40 CFR Part 51) as mandated by the 39 Regional Haze Rule. The rule would not apply to this alternative, however, because there are 40 no Class I Federal areas in Mississippi or within 186 -mi (300-km) of the GGNS site 41 (EPA 2012b). 42 The emissions from the NGCC portion of the combination alternative, projected by the staff 43 based on published EIA data, EPA emission factors, and performance characteristics for this 44 alternative, and likely emission controls, would be: 45 Environmental Impacts of Alternatives 8-35 sulfur oxides (SO X)-41 tons (37 MT) per year 1 nitrogen oxides (NO X)-156 tons (142 MT) per year 2 p(PM 10) and 2.5 (PM2.5)-79 tons (72 MT) per 3 year 4 carbon monoxide (CO)-361 tons (327 MT) per year 5 carbon dioxide (CO 2)-1.3 million tons (1.2 million MT) per year 6 National Energy Technology Laboratory (NETL) estimated emissions factors for biomass -fired 7 power plants by averaging 34 biomass facilities in California and based on a heat rate of 8 13.8 MMBTU/MWh. Emissions from the nine biomass -fired plants considered in this alternative 9 could vary based on technology or other factors. The emissions from all nine of the 10 biomass-fired plants under the combination alternative, based on emissions factors and the heat 11 rate estimated by National Renewable Energy Laboratory (NREL) would be: 12 SO X-126 tons (114 MT) per year 13 NO X-2,681 tons (2,432 MT) per year 14 (PM 10) and (PM2.5)-650 tons (590 MT) 15 per year 16 CO-13,560 tons (12,302 MT) per year 17 8.4.1.1 Sulfur Oxide and Nitrogen Oxide 18 The natural gas -fired plant would produce SO x and NO x based on the use of the dry low -NO x 19 combustion technology and selective catalytic reduction to significantly reduce NO x emissions. 20 Both the NGCC and biomass -fired plants would be subject to the continuous monitoring 21 requirements of SO 2 and NO x specified in 40 CFR Part 75. 22 8.4.1.2 Greenhouse Gases 23 Both the NGCC and biomass -fired plants would release GHGs, such as CO 2 and methane, and 24 would be subject to continuous monitoring requirements for CO 2, as specified in 25 40 CFR Part 75. 26 On July 12 2012, EPA issued a rule tailoring the criteria that determine which stationary sources 27 and modifications to existing projects become subject to permitting requirements for GHG 28 emissions under the PSD and Title V Programs of the CAA (77 FR 41051). According to this 29 rule, GHGs are a regulated new source review pollutant under the PSD major source permitting 30 program if the source is otherwise subject to PSD (for another regulated new source review 31 pollutant) and has a GHG potential to emit equal to or greater than 75,000 tons (68,000 MT) per 32 year of CO 2 equivalent ("carbon dioxide equivalent" adjusts for different global warming 33 potentials for different GHGs). Beginning January 2, 2011, operating permits issued to major 34 sources of GHGs under the PSD or Title V Federal permit programs must contain provisions 35 requiring the use of Best Available Control Technology (BACT) to limit the emissions of GHGs if 36 those sources would be subject to PSD or Title V permitting requirements. If the alternative 37 meets the GHG emission thresholds established in the rule, then GHG emissions from this 38 alternative would be regulated under the PSD and Title V permit programs. 39 8.4.1.3 Particulates 40 Both the NGCC and biomass -fired plants would produce particulates. For the biomass-fired 41 plants, fugitive particulate matter emissions would be produced from the wood fuel receiving, 42 Environmental Impacts of Alternatives 8-36 processing, and storage operations, but they could be minimized using enclosures and a water 1 misting system (Palmer Renewable Energy 2011). 2 As described above, construction activities associated with both the NGCC and biomass -fired 3 plants would generate fugitive dust as well as exhaust emissions from vehicles and motorized 4 equipment. These impacts would be short-term and would be minimized by dust control 5 measures. 6 8.4.1.4 Hazardous Air Pollutants 7 In December 2000, EPA issued regulatory findings (EPA 2000) on emissions of HAPs from 8 electric utility steam -generating units, which identified that natural gas -fired plants emit HAPs 9 such as arsenic, formaldehyde and nickel and stated that 10 . . . the impacts due to HAP emissions from natural gas -fired electric utility steam 11 generating units were negligible based on the results of the study. The 12 Administrator finds that regulation of HAP emissions from natural gas -fired 13 electric utility steam generating units is not appropriate or necessary. 14 As a result of the EPA's conclusion, the staff finds no significant air quality effects from HAPs for 15 the NGCC portion of the combination alternative. The biomass -fired plants would also release 16 HAPs, but each 50 -MWe unit is likely to emit less than 10 tons/yr (9.1 MT/yr) of any individual 17 HAP or 25 tons/yr (22.7 MT/yr) for any combination of HAPs (Palmer Renewable Energy 2011). 18 8.4.1.5 Conclusion 19 Air quality impacts would result primarily from the NGCC and biomass -fired portions of the 20 combination alternative. The purchased power portion would likely come from gas, coal, and/or 21 nuclear sources, the largest sources of power generation in Mississippi. The impacts to air 22 quality from gas, coal, and nuclear power are described in Sections 8.1.1, 8.2.1, and 8.3.1, but 23 they would be proportionally smaller. Air quality impacts from the DSM portion of the 24 combination alternative would be negligible. Based on this information, the overall air quality 25 impacts of the combination alternative would be SMALL to MODERATE. 26 8.4.2 Groundwater Resources 27 Twenty-one percent of the power supplied by this alternative will be purchased power from 28 some combination of natural gas, coal, or nuclear power plants. The impact of these types of 29 power plants on groundwater use and quality are described in Sections 8.1 through 8.3. 30 Impacts on groundwater for these types of facilities have been characterized as SMALL for both 31 operation and construction. If power is purchased from existing facilities, impacts would be 32 smaller than that described in Sections 8.1 through 8.3 because no construction would occur. 33 Impacts on groundwater use and quality for purchased power would be SMALL. 34 Twenty-four percent of the power supplied by this alternative would come from biomass -fired 35 generation. A biomass -fired plant would be similar in appearance and operation to a coal -fired 36 power plant. Groundwater would be consumed to construct the new plants. The amount of 37 construction water consumed would be much less than the amount consumed by long -term 38 operation of the biomass-fired plants. Potable water and other plant groundwater requirements 39 would be about one -third of GGNS requirements. Impacts from biomass -fired generation on 40 groundwater use and quality would be SMALL. 41 Thirty-six percent of the power supplied by this alternative would come from the combustion of 42 natural gas. The hydrologic impact of this type of power plant on groundwater use and quality 43 would be less than that described in Section 8.2 because one NGCC unit, rather than three 44 Environmental Impacts of Alternatives 8-37 NGCC units, would be built for the combination alternative. Therefore, impacts on groundwater 1 use and quality would be SMALL. 2 Nineteen percent of the power for this alternative would come from DSM and impacts on 3 groundwater use and quality would be SMALL. 4 The impact of the combination alternative on groundwater use and quality would be SMALL. 5 8.4.3 Surface Water Resources 6 Twenty-one percent of the power supplied by this alternative will be purchased power from 7 some combination of gas, coal, or nuclear power plants. The impact of these types of power 8 plants on surface water use and quality are SMALL and are described in Sections 8.1 through 9 8.3. The impact of the purchased power portion of this alternative on surface water would be 10 SMALL. 11 Twenty-four percent of the power supplied by this alternative would come from biomass -fired 12 generation. If dredging of streams or rivers occurs during construction of the biomass facilities, 13 surface water quality immediately downstream of the dredging activities could be temporarily 14 degraded by increases in suspended sediment concentration. In addition, the biomass facilities 15 would require cooling water. Within the service territory, the Mississippi River, other rivers, or 16 reservoirs might be a source of cooling water. The small size of these facilities means the 17 impact on surface water use and quality would be SMALL. 18 Thirty-six percent of the power supplied by this alternative would come from the combustion of 19 natural gas. The hydrologic impact of this type of power plant on surface water use and quality 20 is described in Section 8.2. During plant operations, the NGCC plant in the combination 21 alternative would discharge cooling system blowdown at approximately one-sixth of the existing 22 GGNS rate. Stormwater discharge, blowdown, sanitary, and other effluents would be permitted 23 under an NPDES permit. The impacts on surface water use and quality from the NGCC portion 24 of this alternative would be SMALL. 25 Nineteen percent of the power for this alternative would come from DSM and impacts on 26 surface water use and quality would be SMALL. 27 The impact of the combination alternative on surface water use and quality would be SMALL. 28 8.4.4 Aquatic Ecology 29 Construction activities for the combination alternative (such as construction of heavy -haul roads, 30 and the power blocks for the NGCC and biomass -fired plants) could affect onsite aquatic 31 features at GGNS for the NGCC plant and onsite aquatic features that may occur where the 32 biomass-fired plants would be built. Minimal impacts on aquatic ecology resources are 33 expected because BMPs would likely be used to minimize erosion and sedimentation. 34 Stormwater control measures, which would be required to comply with Mississippi NPDES 35 permitting, would minimize the flow of disturbed soils into aquatic features. Depending on the 36 available infrastructure at the selected biomass-fired plant sites, new or expanded intake and 37 discharge structures may be required. Construction of new or modified intake and discharge 38 structures may require dredging. In addition, dredging may be required to transport new 39 materials to the NGCC and biomass -fired plant sites, which could result in increased 40 sedimentation and turbidity. Dredging activities would require BMPs for in -water work to 41 minimize sedimentation and erosion. Due to the short -term nature of the dredging activities, the 42 hydrological alterations to aquatic habitats would likely be localized and temporary. 43 Environmental Impacts of Alternatives 8-38 During operations, the NGCC plant would require approximately one -third of the cooling water 1 to be discharged into the Mississippi River compared to the NGCC alternative analyzed in 2 Section 8.2. Therefore, the thermal impacts would be less for the combination alternative than 3 for license renewal and the NGCC alternative. The cooling system for a new NGCC plant would 4 have similar chemical discharges as GGNS, but the air emissions from the NGCC plant would 5 emit particulates that would settle onto the river surface and introduce a new source of 6 pollutants that would not exist if GGNS continued operating. However, the flow of the 7 Mississippi River would dissipate pollutants, which would minimize the exposure of fish and 8 other aquatic organisms to pollutants. 9 During operations, the biomass -fired plants would require cooling water. If cooling water is 10 withdrawn from and discharged into surface water bodies, aquatic resources may be impacted 11 from impingement, entrainment, and thermal stress. Impingement, entertainment, and thermal 12 stress would be minimized because the NRC assumes that the biomass -fired plants would use 13 closed-cycle cooling systems. 14 Consultation under several Federal acts, including the ESA and Magnuson -Stevens Act, would 15 be required to assess the occurrence and potential impacts to Federally protected aquatic 16 species and habitats within affected surface waters. Coordination with State natural resource 17 agencies would further ensure that the plant operators would take appropriate steps to avoid or 18 mitigate impacts to State-listed species, habitats of conservation concern, and other protected 19 species and habitats. The NRC assumes that these consultations would result in avoidance or 20 mitigation measures that would minimize or eliminate potential impacts to protected aquatic 21 species and habitats. 22 The DSM portion of this alternative would have little to no impact on aquatic resources because 23 there would be little to no water required. 24 The impacts to aquatic resources from purchased power would be similar to those already 25 described for the NGCC, SCPC, and nuclear alternatives. If power is purchased at existing 26 plants, the impacts would likely be smaller than those analyzed for the NGCC, SCPC, and 27 nuclear alternatives because no construction impacts would occur. 28 The impacts on aquatic ecology would be minor for the combination alternative because 29 construction activities would require BMPs and stormwater management permits and the 30 discharge for this alternative would be similar to or less than for GGNS. Therefore, the impacts 31 on aquatic ecology would be SMALL. 32 8.4.5 Terrestrial Ecology 33 The NGCC component of this alternative would be smaller and require less land than the NGCC 34 plant described in Section 8.

2. This alternative assumes that the NGCC plant would be located 35 on the GGNS site, and predominantly previously developed or pre

-disturbed land would be 36 affected. The impacts of construction and operation of this alternative on terrestrial species and 37 habitats would be SMALL because of this alternative's extensive use of developed land. The 38 DSM portion of this alternative would have no impact on terrestrial species and habitats. The 39 purchased power portion of the alternative would have wide -ranging impacts that are hard to 40 specifically assess because this portion of the alternative could include a mixture of coal, gas, 41 and nuclear across many different sites. However, the purchased power portion of this 42 alternative would be more likely to intensify already existing effects at power generating facilities 43 than create wholly new effects on terrestrial species and habitats. The biomass portion of this 44 alternative would disturb a total of 135 ac (55 ha) over nine sites (an average of 15 ac [6 ha] per 45 site). Depending on the location of the biomass -fired plant sites, terrestrial habitat could be 46 destroyed or fragmented during construction. Particulate air pollution resulting from operation of 47 Environmental Impacts of Alternatives 8-39 the biomass -fired plants could accumulate in waterways and wetlands and be taken up by 1 plants and animals. However, air emissions could be reduced by the use of advanced 2 technologies aimed at lowering emissions. Because of the difficulty of characterizing impacts 3 resulting from this combination alternative, the staff concludes that impacts could range from 4 SMALL to MODERATE. 5 As discussed under aquatic ecology impacts, consultation with FWS under the ESA would avoid 6 potential adverse impacts to Federally listed species or adverse modification or destruction of 7 designated critical habitat. Coordination with State natural resource agencies would further 8 ensure that plant operators would take appropriate steps to avoid or mitigate impacts to 9 State-listed species, habitats of conservation concern, and other protected species and habitats. 10 The NRC assumes that these consultations would result in avoidance or mitigation measures 11 that would minimize or eliminate potential impacts to protected terrestrial species and habitats. 12 Consequently, the impacts of construction and operation of a new nuclear alternative on 13 protected species and habitats would be SMALL. 14 8.4.6 Human Health 15 Impacts on human health from construction of the NGCC, biomass -fired and purchased power 16 portions of this alternative would be similar to impacts associated with the construction of any 17 major industrial facility. Compliance with worker protection rules would control those impacts on 18 workers at acceptable levels. Impacts from construction on the general public would be minimal 19 since limiting active construction area access to authorized individuals is expected assuming the 20 plant operator follows BMPs. Impacts on human health from the construction of the NGCC, 21 biomass-fired and purchased power portions of this alternative would be SMALL. 22 Construction and operation impacts for the DSM portion of this alternative would be minimal and 23 localized to activities such as weatherization efficiency of an end -user's home or facility. The 24 GEIS notes that the environmental impacts are likely to be centered on indoor air quality 25 (NRC 1996). This is because of increased weatherization of the home in the form of extra 26 insulation and reduced air turnover rates from the reduction in air leaks. However, the actual 27 impact is highly site specific and not yet well established. Impacts on human health from the 28 construction activities involved in the DSM portion of this alternative would be SMALL. 29 Human health effects of gas -fired generation are generally low, although in Table 8.2 of the 30 GEIS (NRC 1996), the staff identified cancer and emphysema as potential health risks from 31 gas-fired plants. NO x emissions contribute to ozone formation, which in turn contributes to 32 human health risks. Emission controls on the NGCC portion of this alternative can be expected 33 to maintain NO x emissions well below air quality standards established to protect human health, 34 and emissions trading or offset requirements mean that overall NO x releases in the region would 35 not increase. Health risks for workers may also result from handling spent catalysts used for 36 NO x control that may contain heavy metals. Impacts on human health from the operation of the 37 NGCC portion of the combination alternative would be SMALL. 38 Using biomass for energy consists of the direct burning of forest residue/wood waste, which 39 would likely include forest residue, primary mill residues, secondary mill residues, or urban 40 wood residues. Given this method of fuel for power generation, the health impacts would be 41 similar to those found in a fossil -fuel power generation facility. As discussed in the NGCC and 42 the SCPC alternatives, regulations restricting emissions enforced by either EPA or delegated 43 state agencies have reduced the potential health effects from plant emissions, but have not 44 entirely eliminated them. These agencies also impose site -specific emission limits as needed to 45 protect human health. As discussed in the NGCC and SCPC alternatives, proper emissions 46 controls would protect workers and the public from the harmful effects of burning the biomass 47 Environmental Impacts of Alternatives 8-40 fuel. Therefore, impacts to human health from the biomass portion of the combination 1 alternative would be SMALL. 2 Purchased power most likely would come from natural gas, coal, or nuclear power generating 3 plants. The human health impacts from the operation of these types of plants are discussed in 4 detail in the NGCC, SCPC, and nuclear alternatives sections of this chapter. The human health 5 impacts from the operation of power -generation plants that would provide purchased power are 6 SMALL. 7 Overall, human health risks to occupational workers and to members of the public from the 8 combination alternative would be SMALL. 9 8.4.7 Land Use 10 The GEIS generically evaluates the impact of constructing and operating various replacement 11 power plant alternatives on land use, both on and off each plant site. The analysis of land use 12 impacts focuses on the amount of land area that would be affected by the construction and 13 operation of a combination alternative consisting of a natural gas -fired power plant (one NGCC 14 unit), biomass -fired power plants, DSM, and purchased power. 15 Land use impacts for the NGCC plant would be approximately one -third of that described for the 16 NGCC alternative discussed in Section 8.2.7 as it would require three units and the combination 17 alternative would require one unit. 18 The biomass power plants would require approximately 15 ac (6 ha) per 50 -MWe unit for a total 19 of 135 ac (55 ha) on an industrial zoned brownfield site. Forest residue and wood waste are 20 byproducts of the timber industry, and thus activities associated with the production of this 21 feedstock will occur regardless of whether a biomass -fired power plant is available to use the 22 feedstock. Accordingly, the land use impacts associated with the production of this feedstock 23 will be the same regardless whether the feedstock is used for electricity generation or not. 24 However, additional land would be required for storing, loading, and transporting forest residue 25 and wood waste power plant feedstock. Ultimately, land use impacts would depend on the 26 characteristics of the affected forested lands and the effects of storing, loading and transporting 27 the biomass feedstock. DSM would have little to no direct land use impacts. However, quickly 28 replacing old inefficient appliances and other equipment could generate waste material and 29 potentially increase the size of landfills. However, given time for program development and 30 implementation, the cost of replacements, and the average life of an appliance; the replacement 31 process likely would be gradual. For example, older appliances would be replaced by more 32 efficient appliances as they fail (especially in the case of frequently replaced items, such as light 33 bulbs). In addition, many appliances and industrial equipment have substantial recycling value 34 and would not be disposed of in landfills. 35 Purchased power would also have no direct land use impacts. However, impacts could occur if 36 existing power plants in the region could not support the demand for purchased power. The 37 construction of any new replacement power generating facilities could substantially impact 38 existing land -use. Purchased power from coal- and natural gas -fired plants could also have a 39 noticeable impact on land use due to the amount of land required for coal mining and gas 40 drilling. Wind energy projects would have a noticeable land -use impact because of the large 41 amount of land required for wind farms. However, new replacement power generating facilities 42 could be constructed at existing power plant sites to minimize land use impacts. Impacts could 43 also be minimized by collocating any new transmission lines within existing right -of-ways. 44 The elimination of uranium fuel for GGNS would partially offset some of the land requirements 45 for the NGCC and biomass-fired power plant. Scaling from GEIS estimates, approximately 46 Environmental Impacts of Alternatives 8-41 1,033 ac (418 ha) (based on 35 ac/yr disturbed per 1,000 MWe for 20 y ears (see GEIS 6.2.2.6) 1 and 1 , 475 MWe for GGNS) would no longer be needed for mining and processing uranium 2 during the operating life of these power plants (NRC 1996). Based on this information, overall 3 land use impacts from the construction and operation of the combination alternative could range 4 from SMALL to LARGE. 5 8.4.8 Socioeconomics 6 As previously discussed, socioeconomic impacts are defined in terms of changes to the 7 demographic and economic characteristics and social conditions of a region. For example, the 8 number of jobs created by the construction and operation of NGCC and biomass-fired plants 9 could affect regional employment, income, and expenditures. This alternative would create two 10 types of jobs: (1) construction jobs, which are transient, short in duration, and less likely to have 11 a long-term socioeconomic impact; and (2) power plant jobs, which have a greater potential for 12 permanent, long -term socioeconomic impacts. Workforce requirements for the construction and 13 operation of an NGCC power plant, biomass -fired power plants, DSM, and purchased power 14 components of this combination alternative were evaluated to estimate their possible effects on 15 current socioeconomic conditions. 16 The NGCC component would be one -third the size of the NGCC alternative discussed in 17 Section 8.2.8, and would require about 633 construction workers during peak construction and 18 50 operations workers. Fifty construction workers are required for each biomass -fired plant, 19 totaling 450 construction workers if all nine units are constructed at the same time. Each 20 biomass unit is assumed to require 22 operations workers, for a total of 198 operations workers 21 for this component of the combination alternative. 22 The DSM component could generate additional employment, depending on the nature of the 23 conservation programs and the need for direct measure installations in homes and office 24 buildings. Jobs would likely be few and scattered throughout the region, and would not have a 25 noticeable effect on the local economy. 26 Purchased power from existing power plants would not generate any additional employment 27 opportunities as there would be no change in power plant operations or workforce. However, 28 new employment opportunities could be created if new electrical power generating facilities 29 were needed to support the demand for purchased power. Construction of a new replacement 30 power facility could cause noticeable short -term socioeconomic impacts, similar to those 31 described previously for the other replacement power alternatives. Operation of new 32 replacement power generating facilities would cause long-term socioeconomic impacts through 33 job creation, new housing demand, increased tax contribution, and additional purchasing 34 activity. Construction and operational impacts would vary depending on the location and type of 35 replacement power generating facility. Therefore, impacts from purchased power could range 36 from SMALL to LARGE. 37 This combination alternative would also result in a loss of approximately 690 relatively 38 high-paying jobs at GGNS, with a corresponding reduction in purchasing activity and tax 39 contributions to the regional economy. However, a larger amount of property taxes may be paid 40 to local jurisdictions from the NGCC, biomass, DSM, and purchased power components as 41 more land may be required to support this combination alternative than GGNS. 42 Because of the relatively small number of construction workers needed for the NGCC and 43 biomass-fired plants and the various locations of the biomass -fired plants, the socioeconomic 44 impact of construction on local communities and the tax base would be SMALL. Given the 45 small number of operations workers required, socioeconomic impacts associated with operation 46 of this combination alternative would also be SMALL. Construction and operational impacts 47 Environmental Impacts of Alternatives 8-42 from purchased power would range from SMALL to LARGE. Therefore, overall socioeconomic 1 impacts from this combination alternative could range from SMALL to LARGE. 2 8.4.9 Transportation 3 Transportation impacts during the construction and operation of the NGCC and biomass 4 components of this combination alternative would be less than the impacts for any of the 5 previous alternatives discussed in Sections 8.1.9, 8.2.9, and 8.3.9. This is because the 6 construction workforce for each component and the volume of materials and equipment to be 7 transported to each respective construction site would be smaller than each of the other 8 alternatives. Additionally, the transportation impacts would not be concentrated as they are in 9 the other alternatives; they would be spread out over a wider area. 10 During construction, commuting workers and trucks transporting construction materials and 11 equipment to the work site would increase the amount of traffic on local roads. The increase in 12 vehicular traffic would peak during shift changes, resulting in temporary levels of service 13 impacts and delays at intersections. Transporting heavy and oversized components on local 14 roads could have a noticeable impact over a large area. Some components and materials also 15 could be delivered by rail or barge, depending on location. Traffic -related transportation impacts 16 during construction could range from SMALL to MODERATE in the vicinity of the NGCC power 17 plant at GGNS and biomass power plant units, depending on current road capacities and 18 average daily traffic volumes. During operations, transportation impacts from the NGCC and 19 biomass portions of the combination alternative would be less noticeable than during 20 construction and would be SMALL. 21 No incremental operations impacts would be expected for the DSM or purchased power 22 components of this alternative. As previously discussed, purchased power from existing power 23 plants would not generate any additional employment opportunities as there would be no 24 change in power plant operations or workforce. Traffic volumes on local roads would remain 25 unchanged. 26 However, traffic conditions could be substantially impacted i f new electrical power generating 27 facilities were needed to support the demand for purchased power. Construction of new power 28 generating facilities would cause noticeable short -term transportation impacts on local roads 29 due to the increased volume of worker and truck delivery traffic required to build the new power 30 plant, especially during shift changes. However, traffic volumes would decrease after 31 construction is completed. Construction and operations -related transportation impacts would 32 vary depending on the location and type of facility. Therefore, impacts from purchased power 33 could range from SMALL to LARGE. 34 Based on this information, overall transportation impacts from the combination alternative could 35 range from SMALL to LARGE. 36 8.4.10 Aesthetics 37 The analysis of aesthetics impact focuses on the degree of contrast between the NGCC and 38 biomass power plants and surrounding landscapes and the visibility of a new NGCC plant at 39 GGNS and the new biomass plants. In general, aesthetic changes would be limited to the 40 immediate vicinity of these power plants, although minor visual impacts may be associated with 41 the staging, processing, and transport of biomass feedstock. 42 Aesthetic impacts from the NGCC plant component of the combination alternative would be 43 essentially the same as those described for the NGCC alternative in Section 8.2.10, except 44 there would be one unit rather than three. Plant infrastructure generally would be smaller and 45 Environmental Impacts of Alternatives 8-43 less noticeable than GGNS containment and turbine buildings. In addition to the plant 1 structures, construction of the natural gas pipeline would have a short -term impact. In general, 2 aesthetic changes would be limited to the immediate vicinity of GGNS and would be SMALL. 3 Most noise generated during NGCC plant operations would be limited to industrial processes 4 and communications. Pipelines delivering natural gas fuel could be audible off site near gas 5 compressor stations. Noise during construction activities for the NGCC alternative may be 6 detectable off site, but would be for a short duration. Pipeline companies and the plant operator 7 would need to adhere to local ordinances regarding maximum noise levels during construction 8 and operations. Therefore, impacts from noise would be SMALL. 9 The biomass plant would look similar to other fossil fuel power plants with a boiler stack and 10 cooling towers. In addition, it would have feedstock storage, handling, and processing facilities, 11 similar to a timber mill. Combustion exhaust and cooling steam plumes may be visible in close 12 proximity to the plant depending on atmospheric conditions. Noise during construction activities 13 and plant operations may be detectable off site. The plant operator would need to adhere to 14 local ordinances regarding maximum noise levels during construction and operations. 15 Therefore, impacts from noise would be SMALL. 16 No aesthetic or noise impacts would be expected for the DSM and purchased power 17 components of this alternative. However, impacts could occur if new electrical power 18 generating facilities were needed to support the demand for purchased power. Impacts would 19 vary depending on the location and type of power generating facility. If constructed at an 20 existing power plant site, aesthetic changes would be limited and any impacts could range from 21 SMALL to MODERATE due to the industrial appearance of the site . However, if constructed in 22 a rural and previously undisturbed area, the effects could range from MODERATE to LARGE. 23 Therefore, aesthetic impacts from purchased power could range from SMALL to LARGE. 24 Based on this information, overall aesthetic impacts from the combination alternative could 25 range from SMALL to LARGE. 26 8.4.11 Historic and Archaeological Resources 27 Impacts on historic and archaeological resources from the NGCC and biomass power plant 28 components of this alternative would be similar to those discussed for the NGCC alternative in 29 Section 8.

2. A cultural resource survey and inventory would be needed before construction 30 could begin for either alternative.

Resources found in these surveys would need to be 31 evaluated for eligibility on the National Register of Historic Properties (NRHP) and mitigation of 32 adverse effects would need to be addressed if eligible resources were encountered. 33 Construction of either alternative on a brownfield site could minimize impacts to historic and 34 archaeological resources, however a survey should still be performed to inventory cultural 35 resources and verify level of disturbance. Given that the sites for biomass -fired units are small 36 in size (approximately 15 acres) and a preference is given to use previously disturbed 37 brownfield sites, avoidance of significant historic and archaeological resources should be 38 possible and effectively managed under current laws and regulations. Impacts to historic and 39 archaeological resources from the NGCC and biomass portions of this alternative would be 40 SMALL to MODERATE. 41 No direct impacts on historic and archaeological resources are expected from DSM or 42 purchased power

. If new transmission lines were needed to convey power to consumers 43 previously served by GGNS, surveys similar to those discussed for the NGCC unit would need 44 to be performed. However, transmission lines would likely be collocated with in existing right

-of-45 ways minimizing any impacts to historic and archaeological resources, making direct impacts 46 SMALL. 47 Environmental Impacts of Alternatives 8-44 Indirectly, construction of new electrical power generating facilities and any new transmissio n 1 lines needed to support the increased demand for power from the closure of GGNS could 2 impact archaeological and historic resources. Any areas potentially affected by construction 3 and operation would need to be surveyed and evaluated for NRHP eligibility. The potential for 4 impacts on historic and archaeological resources would vary greatly depending on the location 5 of the proposed sites; however, using previously disturbed sites could greatly minimize impacts 6 to historic and archaeological resources. Areas with the greatest sensitivity could be avoided or 7 effectively managed under current laws and regulations. Impacts would also vary by type of 8 energy power facility chosen and the level of ground disturbance it would require for 9 construction and operation. Therefore, depending on the resource richness of the sites chosen 10 for construction and the type of electrical power generating facility chosen, the impacts could 11 range from SMALL to LARGE. 12 The potential for impacts on historic and archaeological resources from the combination 13 alternative would vary greatly depending on the resource richness of the location of the 14 proposed sites associated with each component of the alternative . Therefore, the overall impact 15 on historic and archaeological resources could range from SMALL to LARGE. 16 8.4.12 Environmental Justice 17 The environmental justice impact analysis evaluates the potential for disproportionately high and 18 adverse human health, environmental, and socioeconomic effects on minority and low -income 19 populations that could result from the construction and operation of a combination of NGCC and 20 biomass-fired plants, and DSM and purchased power activities. As previously discussed in 21 Section 8.1.12, such effects may include human health, biological, cultural, economic, or social 22 impacts. 23 Potential impacts to minority and low -income populations from the construction and operation of 24 a new NGCC and biomass power plants would mostly consist of environmental and 25 socioeconomic effects (e.g., noise, dust, traffic, employment, and housing impacts). Noise and 26 dust impacts during construction would be short -term and primarily limited to onsite activities. 27 Minority and low -income populations residing along site access roads would be directly affected 28 by increased commuter vehicle traffic during shift changes and truck traffic. However, because 29 of the temporary nature of construction, these effects are not likely to be high and would be 30 contained to a limited time period during certain hours of the day. Increased demand for rental 31 housing during construction could cause rental costs to rise disproportionately affecting low -32 income populations living near GGNS for the NGCC plant and the biomass -fired plant locations 33 who rely on inexpensive housing. However, given the small number of construction workers 34 and the possibility that workers could commute to the construction site, the potential increased 35 demand for rental housing would not be significant. No incremental human health or 36 environmental impacts related to construction would be expected from the purchased power or 37 DSM component of this alternative. 38 Minority and low -income populations living in close proximity to the power generating facilities 39 could be disproportionately affected by emissions associated with NGCC power plant and 40 biomass operations. However, because emissions are expected to remain within regulatory 41 standards, impacts from emissions are not expected to be high and adverse. 42 Low-income populations could benefit from weatherization and insulation programs in a DSM 43 energy conservation program. This could have a greater effect on low -income populations than 44 the general population, as low -income households generally experience greater home energy 45 burdens than the average household. Low-income populations could also be disproportionately 46 affected by increased utility bills due to the cost of purchased power. However, programs, such 47 Environmental Impacts of Alternatives 8-45 as the Mississippi Low Income Home Energy Assistance Program, are available to assist low -1 income families in paying for increased electrical costs, thus mitigating the adverse 2 socioeconomic impact of this alternative on low -income populations. 3 Overall, the construction and operation of the NGCC and biomass -fired plants, and DSM and 4 purchased power activities would not have disproportionately high and adverse human health 5 and environmental effects on minority and low -income populations. 6 8.4.13 Waste Management 7 During the construction stage for the NGCC plant, land clearing and other construction activities 8 would generate wastes that could be recycled, disposed of on site, or shipped to an offsite 9 waste disposal facility. During the operational stage, spent selective catalytic reduction 10 catalysts, which control NO X emissions from the NGCC plant, would make up the majority of 11 waste generated by this alternative. 12 For DSM, there may be an increase in wastes generated during installation or implementation of 13 energy conservation measures, such as appropriate disposal of old appliances, installation of 14 control devices, and building modifications. New and existing recycling programs would help 15 minimize the amount of generated waste. 16 For the purchased power portion of this alternative, the types of waste generated would be 17 similar to the alternatives described in Sections 8.1.13, 8.2.13, and 8.3.13. 18 During construction of a the biomass -fired plants, land clearing and other construction activities 19 would generate waste that could be recycled, disposed of on site, or shipped to an offsite waste 20 disposal facility. A wood biomass -fired plant may use as fuel the residues from forest clear cut 21 and thinning operations, noncommercial species, or harvests of forests for energy purposes. In 22 addition to the gaseous emissions, wood ash is the primary waste product of wood combustion. 23 Waste would be handled in accordance with appropriate Mississippi Commission of 24 Environmental Quality waste management regulations (MSCEQ 2012). 25 Overall, waste impacts from the combination alternative would be SMALL. 26 8.4.14 Summary of Impacts of Combination Alternative 27 Table 8-5 summarizes the environmental impacts of the combination alternative compared to 28 continued operation of GGNS. 29 Environmental Impacts of Alternatives 8-46 Table 8-5. Summary of Environmental Impacts of the Combination Alternative 1 Compared to Continued Operation of GGNS 2 Category Combination Alternative Continued GGNS Operation Air Quality SMALL to MODERATE SMALL Groundwater Resources SMALL SMALL Surface Water Resources SMALL SMALL Aquatic Ecology SMALL SMALL Terrestrial Ecology SMALL to MODERATE SMALL Human Health SMALL SMALL Land Use SMALL to LARGE SMALL Socioeconomics SMALL to LARGE SMALL Transportation SMALL to LARGE SMALL Aesthetics SMALL to LARGE SMALL Historic and Archaeological Resources SMALL to LARGE SMALL Waste Management a SMALL SMALL a As described in Chapter 6, the issue, "offsite radiological impacts (spent fuel and high level waste disposal)," is not evaluated in this EIS.

8.5 Alternatives

Considered But Dismissed 3 8.5.1 Demand-Side Management 4 Demand-side management (DSM) includes energy efficiency programs designed to improve the 5 energy efficiency of facilities and equipment, reduce energy demand through behavioral 6 changes (energy conservation), and demand response initiatives aimed to lessen customer 7 usage or change energy use patterns during peak periods (ICF 2009). Energy conservation 8 and energy efficiency would not require the addition of new generating capacity. To be 9 considered a viable alternative, a DSM alternative would need to reduce the baseload demand 10 within Entergy's Mississippi service territory by 1,475 MWe, which is equivalent to the amount 11 GGNS provides. 12 In a 2009 staff report, the Federal Energy Regulatory Commission (FERC) outlined the results 13 of a national assessment of demand response potential, required of FERC by Section 529 of the 14 Energy Independence and Security Act of 2007. The report evaluated potential energy savings 15 in 5- and 10-year horizons for four development scenarios: Business As Usual, Expanded 16 Business As Usual, Achievable Participation, and Full Participation, each representing greater 17 demand response program opportunities and proportionally increasing levels of customer 18 participation (FERC 2009). FERC's Mississippi -specific analysis indicates that by 2019, the Full 19 Participation scenario, in which the greatest level of reduction would occur, would yield a 20 2,247 MWe peak demand reduction in Mississippi (18.6 percent of projected peak demand). 21 The Business as Usual scenario suggests that demand response programs would yield a 22 reduction of 75 MWe (0.6 percent of projected peak demand) (FERC 2009). Entergy 23 Mississippi provides 33.7 percent of Mississippi's electricity, indicating that if Entergy achieved 24 the full participation demand reductions, it would yield a reduction of 765 MWe. This amount 25 would not be sufficient to replace the 1,475 MWe GGNS provides. In addition, according to an 26 ICF International study, the potential savings from energy conservation and energy efficiency 27 across Entergy's six operating companies could reach 729 MWe by 2019 and 1,0 50 MWe by 28 2029, adjusted for a reasonable implementation and approval timeline. Mississippi offers 29 voluntary financial incentive programs, an energy efficiency leasing program for public 30 institutions and hospitals, and low interest loans for energy efficiency projects, but it does not 31 require utilities to participate in DSM programs to reduce energy demand. While significant 32 Environmental Impacts of Alternatives 8-47 energy savings are possible in Mississippi through DSM, the NRC nevertheless does not 1 consider DSM to be a reasonable alternative to license renewal of GGNS. NRC evaluated an 2 alternative with DSM programs in combination with an NGCC plant, biomass -fueled plants, and 3 purchased power in Section 8.4. 4 8.5.2 Wind Power 5 As an intermittent energy source, the feasibility of wind generation to serve as baseload power 6 depends on the availability, constancy, and accessibility of wind resources within a specific 7 region. At the current stage of wind energy technology, DOE's National Renewable Energy 8 Laboratory (NREL) considers areas with annual average wind speeds around 6.5 meters per 9 second (m/s) (21 ft/s) and greater (at a height of 80 m [262 ft]) to have a wind resource suitable 10 for wind development (NREL 2012a). The majority of Mississippi has wind speeds between 4.0 11 and 5.0 m/s, although a small area in the northwest part of the state has wind speeds of 5.5 m/s 12 (NREL 2012a). NREL has estimated the windy land area and wind energy potential, including 13 potential megawatts of rated capacity and estimated potential annual wind energy generation, 14 for each state (NREL 2012b). According to their analyses, Mississippi does not have sufficient 15 wind resources for any utility -scale wind energy generation. 16 In addition, the issue of intermittent wind, and subsequent intermittent generation of power, 17 must be overcome for wind generation to provide baseload power by 2024 when the current 18 GGNS operating license expires. Currently, limited viable energy storage opportunities exist, 19 although research is ongoing to connect wind farms with storage technologies such as pumped 20 water storage, batteries, and compressed air energy storage (CAES) (EAC 2008). EIA is not 21 projecting any growth in pumped water storage capacity through 2035 (EIA 2011a). As 22 described below, the potential for new hydroelectric development in Mississippi is limited. 23 Therefore, the NRC concludes that the use of pumped water storage in combination with wind 24 farms is unlikely in Mississippi. A CAES plant is another potential storage option that could 25 possibly serve as a way for wind to provide baseload power. A CAES plant compresses air in 26 an underground storage cavern. To extract the stored energy, compressed air is combusted, 27 through a gas -turbine connected to an electrical generator (NREL 2010a). Currently, besides 28 pumped hydropower storage, deployment of storage technologies in the United States has been 29 limited to a 110 -MWe CAES facility in Alabama and two planned CAES projects with a 30 combined capacity of 450 MWe (NREL 2010a, Sandia 2012). Current and proposed CAES 31 projects have a much smaller capacity than would be necessary to replace GGNS; therefore, 32 the NRC concludes that the use of CAES in combination with wind turbines to generate 33 1,475 MWe in Mississippi is unlikely. 34 Another solution to overcoming intermittency is the concept of interconnected wind farms. Wind 35 farms located at a great distance from one another and connected through the transmission grid 36 could increase the capacity factor compared to a single wind farm in one location. As more 37 farms are interconnected, the probability that they will all experience the same wind 38 environment decreases, and the array acts more like a single wind farm with a steady wind 39 speed (Archer et al. 2007). In Mississippi, however, the wind generation potential is so low that 40 even when combined with energy storage or interconnected wind farms, it is very unlikely that 41 wind could serve as baseload power to replace GGNS. 42 Offshore Wind. The potential for offshore wind generation off the coast of Mississippi is not 43 likely sufficient to replace GGNS. Although the wind resources are generally stronger in 44 offshore areas, the wind speeds off the coast of Mississippi and Louisiana are weak compared 45 to offshore resources in other areas of the United States. Off shore from the Louisiana coast, 46 wind speeds range between 7.0-8.0 m/s at 90 m compared to 9.0 -10.0 m/s at 90 m off the 47 coast of the Northeast United States where the only utility -scale offshore wind farm has been 48 Environmental Impacts of Alternatives 8-48 approved (NREL 2010b). Texas has the most potential for offshore wind development in the 1 gulf coast with wind speeds reaching between 7.5 -9.0 m/s (NREL 2010b), and is the only State 2 in the region to express interest in developing offshore wind energy resources. The Texas 3 General Land Office has approved leases for offshore wind projects; however none have started 4 construction (offshorewindfarm.net 2012). Currently, no wind energy projects are proposed off 5 the coasts of Mississippi or Louisiana (offshorewindfarm.net 2012). 6 The capital costs for offshore wind projects are much greater than the costs for land -based wind 7 projects, which will likely prohibit offshore wind development in the near future. A paper 8 published by the U.S. Offshore Wind Collaborative estimates that initial capital costs for offshore 9 wind projects are 30 to 60 percent greater than for land -based wind projects. Construction 10 costs are 33 percent higher for offshore wind farms (USOWC 2009). Foundations for wind 11 turbines are much more expensive because they must be designed to withstand high winds and 12 waves. Costs for facility foundations, towers, transmission, and installation are much more 13 expensive than those for land -based farms (USOWC 2009). In addition, the current 14 commercially available offshore wind turbines may not be able to withstand major hurricanes. 15 Currently, the most stringent class of specifications for wind turbines assumes gusts no stronger 16 than 70 m/s, while Category 4 and 5 hurricanes, which often come through coastal Mississippi 17 and Louisiana, can have gusts greater than 80 m/s (NREL 2010c). 18 Conclusion. Given the low wind resource potential both on and off shore in Mississippi and the 19 surrounding region, high costs, and intermittency experienced in wind generation, the NRC does 20 not consider wind to be a reasonable alternative to license renewal. 21 8.5.3 Solar Power 22 Solar power, including solar photovoltaic and concentrated solar power technologies, produce 23 power generated from sunlight. Photovoltaics convert sunlight directly into electricity using solar 24 cells, made from silicon or cadmium telluride (NREL 2012c). By contrast, concentrating solar 25 power uses heat from the sun to boil water and produce steam to drive a turbine connected to a 26 generator to produce electricity (NREL 2012c). 27 In 2010, according to EIA, neither Mississippi, nor any of the surrounding States of Alabama, 28 Louisiana, or Arkansas produced any large -scale electricity from solar energy (NREL 2012d). 29 DOE's National Renewable Energy Laboratory (NREL) reports that Mississippi has average 30 solar insolation useful for solar applications ranging between 4.0 -5.9 kWh/m 2/day 31 (NREL 2012d). For utility -scale development, insolation levels below 6.5 kWh/m 2/day are not 32 considered economically viable given current technologies (BLM/DOE 2010). There is more 33 potential for solar development with local photovoltaic applications, such as rooftop solar panels 34 than through utility -scale solar facilities. In addition, a solar facility can only generate electricity 35 when the sun is shining. Energy storage can be used to overcome intermittency for solar 36 facilities, however, current and foreseeable storage technologies have a much smaller capacity 37 than would be necessary to replace GGNS (as described above in the discussion of wind 38 power). Taking all of the factors above into account, it is unlikely that solar photovoltaic or 39 concentrated solar power technologies could serve as baseload power in Mississippi. Given the 40 modest levels of solar energy available throughout the State, the lack of any installed solar 41 capacity in Mississippi and the weather -dependent intermittency of solar power, the NRC does 42 not currently consider solar energy to be a reasonable alternative to license renewal. 43 8.5.4 Hydroelectric Power 44 Hydroelectric power uses the force of water to turn turbines, which spins a generator to produce 45 electricity. In a run-of-the-river system, the force of a river current provides the force to create 46 Environmental Impacts of Alternatives 8-49 the needed pressure for the turbine. In a storage system, water is accumulated in reservoirs 1 created by dams and is released as needed to generate electricity. DOE's Idaho National 2 Environmental Engineering Laboratory completed a comprehensive survey of hydropower 3 resources in Mississippi in 1997. Mississippi has little hydroelectric potential, with a total 4 generating potential of 92 -128 MWe (INEEL 1997). EIA reported that Mississippi did not 5 generate any electricity from conventional hydroelectric power in 2010 (EIA 2012 a). Given the 6 small potential capacities and actual power generation of hydroelectric facilities in Mississippi, 7 the NRC does not consider hydroelectric power to be a reasonable alternative to license 8 renewal. 9 8.5.5 Wave and Ocean Energy 10 Wave energy is generated by the movement of a device either floating on the surface of the 11 ocean or anchored to the ocean floor. Kinetic energy from waves pumps fluid through turbines 12 to create electric power (DOE 2009). Waves, currents, and tides are often predictable and 13 reliable, making them attractive candidates for potential renewable energy generation. 14 There are modest wave energy resources available off the Gulf Coast. However, wave energy 15 technology is still in the early stages of development. The potential for wave and ocean energy 16 in Mississippi is limited because the Gulf of Mexico is shallow and semi -enclosed (TCPA 2008). 17 Because most technologies are relatively undeveloped (and none are developed on the scale of 18 GGNS), and because the Gulf of Mexico has limited potential for wave and ocean energy, the 19 NRC did not consider wave and ocean energy as a reasonable alternative to GGNS license 20 renewal. 21 8.5.6 Geothermal Power 22 Geothermal technologies extract the heat contained in geologic formations to produce steam to 23 drive a conventional steam turbine generator. Facilities producing electricity from geothermal 24 energy have demonstrated capacity factors of 95 percent or greater, making geothermal energy 25 eligible as a source of baseload electric power. However, the feasibility of geothermal power 26 generation to provide baseload power depends on the regional quality and accessibility of 27 geothermal resources. Utility-scale geothermal energy generation requires geothermal 28 reservoirs with a temperature above 200

°F (93 °C). Utility-scale power plants range from small 29 300 kWe to 50 MWe and greater (TEEIC 2012)

. In general, geothermal resources are 30 concentrated in the western United States. Specifically, these resources are found in Alaska, 31 Arizona, California, Colorado, Hawaii, Idaho, Montana, Nevada, New Mexico, Oregon, Utah, 32 Washington, and Wyoming (USGS 2008). The largest geothermal generation project in 33 Mississippi was a 0.5 MWe geothermal coproduction demonstration project completed in 2011, 34 which was funded by a Department of Energy's Research Partnership to Secure Energy for 35 America (RPSEA) grant (GEA 2012). The project generated electricity from water produced as 36 a byproduct of oil production. The 6 -month demonstration project has since been concluded. 37 The high cost to produce electricity using geothermal coproduction limited its commercial 38 deployment, though the demonstration project established its technical viability 39 (ElectraTherm 2012). No other electricity is currently being produced from geothermal 40 resources in Mississippi (DOE 2012). Given the low resource potential in Mississippi, the NRC 41 does not consider geothermal to be a reasonable alternative to GGNS license renewal. 42 8.5.7 Municipal Solid Waste 43 Municipal solid waste combustors use three types of technologies -mass burn, modular, and 44 refuse-derived fuel. Mass burning is currently the method used most frequently in the 45 Environmental Impacts of Alternatives 8-50 United States and involves no (or little) sorting, shredding, or separation. Consequently, toxic or 1 hazardous components present in the waste stream are combusted, and toxic constituents are 2 exhausted to the air or become part of the resulting solid wastes. As of 2010, approximately 3 86 waste-to-energy plants are in operation in 24 states, processing 97,000 tons of municipal 4 solid waste per day (ERC 2010). These waste -to-energy plants have an aggregate capacity of 5 2,572 MWe and can operate at capacity factors greater than 90 percent. The average 6 waste-to-energy plant produces about 50 MWe, with some reaching 77 MWe (ERC 2010). No 7 waste-to-energy facilities operate in Mississippi (ERC 2010). More than 29 average -sized 8 plants would be necessary to provide the same level of output as GGNS, increasing national 9 waste-to-energy generation by 57 percent. 10 The decision to burn municipal waste to generate energy is usually driven by the need for an 11 alternative to landfills rather than energy considerations. Given the improbability that additional 12 stable supplies of municipal solid waste would be available to support approximately 29 new 13 facilities and that no waste -to-energy plants operate in Mississippi, the NRC does not consider 14 municipal solid waste combustion to be a reasonable alternative to GGNS license renewal. 15 8.5.8 Biomass 16 Biomass resources used for biomass -fired generation include crop residues, switch grass, forest 17 residues, methane from landfills, methane from animal manure management, primary wood mill 18 residues, secondary wood mill residues, urban wood wastes, and methane from domestic 19 wastewater treatment. Using biomass -fired generation for baseload power depends on the 20 geographic distribution, available quantities, constancy of supply, and energy content of 21 biomass resources. As described in more detail in Section 8.4, the technology used for 22 conversion of biomass to electricity would be direct combustion. 23 In the GEIS, the NRC indicated a wood waste facility could provide baseload power and operate 24 with capacity factors between 70 and 80 percent (NRC 1996). Mississippi generated only 25 236 MWe from biomass fuels in 2010 (EIA 2012b). It is unlikely that Mississippi could increase 26 its capacity by adding 1,475 MWe of electricity from biomass -fired generation by the time 27 GGNS's license expires in 2024. 28 Biomass-fired generation plants generally are small and can reach capacities of 50 MWe, 29 meaning that 30 new facilities would be required before 2024. In addition, according to an 30 NREL report, Mississippi has almost 16 million tons/year total available biomass resources 31 (NREL 2005). For the hypothetical biomass plant using wood residue described in Section 8.4, 32 approximately 2,000 tons/day of fuel would be consumed to support one 50 MWe unit 33 (ARI 2007). Based on a similar consumption rate, all of the available biomass in Mississippi 34 could support 1,000 MWe of power generation. Therefore, there would be insufficient biomass 35 in Mississippi to support 1,475 MWe of biomass -fired generation. In addition, small plant sizes 36 (20-50 MWe) lead to higher capital costs per kWh. Biomass-fired power plants typically are 37 less efficient than other energy sources; the biomass industry average is 20 percent compared 38 to 35 percent average efficiency for U.S. electricity generation. An inefficient power plant can 39 be more sensitive to changes in the price of fuel inputs (i.e., wood waste). High capital costs 40 combined with low efficiency have led to electricity prices ranging from $0.08 to $0.12/kWh 41 (NREL 2003). Given the large amount of biomass resources required to replace GGNS 42 compared to available resources, and potentially high cost, the NRC does not consider biomass 43 a reasonable alternative to GGNS. The NRC evaluated an alternative with biomass -fired 44 generation in combination with an NGCC plant, DSM, and purchased power in Section 8.4. 45 Environmental Impacts of Alternatives 8-51 8.5.9 Oil-Fired Power 1 EIA projects that oil -fired plants will account for a 2 percent increase in new electricity 2 generation from 2010 to 203 0 in the United States (EIA 2008b). In Mississippi, the percent of 3 electricity from oil -fired generation fell from 7.9 percent to 0.1 percent from 2000 to 2012 4 (EIA 2012a). 5 The variable costs of oil -fired generation tend to be greater than those of nuclear or coal -fired 6 operations, and oil -fired generation tends to have greater environmental impacts than natural 7 gas-fired generation. The high cost of oil has resulted in a steady decline in its use for electricity 8 generation. Given the high cost of oil and the decline in use of oil -fired power plants in 9 Mississippi over the past 10 years, the NRC does not consider oil -fired generation a reasonable 10 alternative to GGNS license renewal. 11 8.5.10 Fuel Cells 12 Fuel cells oxidize fuels without combustion and its environmental side effects. Fuel cells 13 function as an energy conversion technology that allows the energy stored in hydrogen to be 14 converted back into electrical energy for end use (EIA 2008a). The only byproducts (depending 15 on fuel characteristics) are heat, water, and CO

2. Hydrogen fuel can come from a variety of 16 hydrocarbon resources. Natural gas typically is used as the hydrogen source.

17 Presently, fuel cells are not economically or technologically competitive with other alternatives 18 for electricity generation. EIA projects that fuel cells may cost $6,835 per installed kW (total 19 overnight capital costs, 2010 dollars), which is high compared to other alternative technologies 20 analyzed in this section (EIA 2010b). More importantly, fuel cell units are likely to be small in 21 size (approximately 10 MWe). It would be extremely costly to replace the power GGNS 22 provides; it would require approximately 148 units and modifications to the existing transmission 23 system. Given the immature status of fuel cell technology and high cost, the NRC does not 24 consider fuel cells to be a reasonable alternative to GGNS license renewal. 25 8.5.11 Purchased Power 26 Under a purchased power alternative, no new generating capacity would necessarily be built 27 and operated by Entergy. Instead, 1 ,475 MWe would be purchased from other generators. 28 Those generators could be located anywhere within or outside Entergy's service territory. 29 Entergy's six operating companies rely on purchased power for a third of their energy needs 30 (Entergy 2009). Entergy's Strategic Resource Plan states that the six operating companies plan 31 on purchasing 1,4 00 MWe in limited -term purchases (1- to 5-year contracts) by 2025 32 (Entergy 2010). Limited -term purchases expose the utility and its customers to risk associated 33 with market price volatility and power availability. In its Strategic Resource Plan, Entergy 34 outlines how it plans to manage this risk by seeking to limit the amounts of limited -term 35 purchased power used to meet reliability requirements. Entergy also recognizes that the 36 amount of uncommitted capacity in the region is declining, and that purchased power may not 37 provide sufficient resources. In that case, Entergy acknowledges that it may need to build more 38 capacity than currently anticipated (Entergy 2009). For Entergy to replace the 1,475 MWe 39 provided by GGNS, it would have to double its amount of planned power purchases. If a 40 sufficient amount of additional energy from existing plants is not available, new power plants 41 would need to be constructed. Depending on location, the incorporation of new generation 42 sources from locations that are remote or distant from load centers likely would involve 43 significant expenditures in transmission infrastructure expansions. The NRC does not consider 44 purchased power to be a reasonable alternative to GGNS license renewal. 45 Environmental Impacts of Alternatives 8-52 8.5.12 Delayed Retirement 1 Currently, Entergy owns or controls 20,559 MWe of electricity generation and fails to meet the ir 2 system reliability requirement by approximately 1 GW (Entergy 2009). This conclusion is based 3 on current capacity ratings of the existing operating facilities, the expected peak load 4 requirement, and the planning reserve margin target (Entergy 2011). In addition, the projected 5 growth in demand over the next 20 years is expected to be 600 MW e/yr (Entergy 2011). Any 6 currently operating units scheduled for retirement that could be delayed would be needed to 7 meet this projected growth in demand and would be unavailable to replace existing generation. 8 Therefore, the NRC does not consider delayed retirement to be a reasonable alternative to 9 GGNS license renewal. 10 8.6 No-Action Alternative 11 This section examines environmental effects that would occur if the NRC took no action. No 12 action in this case means that the NRC decides to not issue a renewed operating license for 13 GGNS and the license expires at the end of the current license term, in November 2024. Under 14 the no-action alternative, the plant would shut down at or before the end of the current license. 15 After shutdown, plant operators would initiate decommissioning in accordance with 16 10 CFR 50.82. 17 This section addresses only those impacts that arise directly as a result of plant shutdown. The 18 environmental impacts from decommissioning and related activities already have been 19 addressed in several other documents, including Supplement 1 of NUREG -0586, Final Generic 20 Environmental Impact Statement on Decommissioning of Nuclear Facilities Regarding the 21 Decommissioning of Nuclear Power Reactors (NRC 2002); Chapter 7 of the license renewal 22 GEIS (NRC 1996); and Chapter 7 of this SEIS. These analyses either directly address or bound 23 the environmental impacts of decommissioning whenever Entergy ceases operating GGNS. 24 Even with a renewed operating license, GGNS will eventually shut down, and the environmental 25 effects addressed in this section will occur at that time. Since these effects have not otherwise 26 been addressed in this SEIS, the impacts will be addressed in this section. As with 27 decommissioning effects, shutdown effects are expected to be similar whether they occur at the 28 end of the current license or at the end of a renewed license. 29 8.6.1 Air Quality 30 Shutdown of GGNS would result in a reduction in emissions from activities related to plant 31 operation, such as use of diesel generators and employee vehicles. The staff determined that 32 these emissions would have a SMALL impact on air quality during the renewal term (see 33 Chapter 4); therefore, if emissions decrease, the impact to air quality would also decrease and 34 would be SMALL. 35 8.6.2 Groundwater Resources 36 Shutdown of GGNS would result in a reduction in groundwater use over that of continued plant 37 operation. Since it was determined that continued plant operations would have a SMALL impact 38 on groundwater use and quality during the renewal term (see Chapter 4), the impacts of 39 shutdown on groundwater use and quality would also be SMALL. 40 Environmental Impacts of Alternatives 8-53 8.6.3 Surface Water Resources 1 Shutdown of GGNS would result in a reduction in surface water use over that of continued plant 2 operation. Since it was determined that continued plant operations would have a SMALL impact 3 on surface water use and quality during the renewal term (see Chapter 4), the impacts of 4 shutdown on surface water use and quality would also be SMALL. 5 8.6.4 Aquatic Ecology 6 If the plant were to cease operating, impacts on aquatic ecology would decrease because the 7 plant would withdraw and discharge less water than it does during operations. Shutdown would 8 reduce the already SMALL impacts on aquatic ecology. 9 8.6.5 Terrestrial Ecology 10 If the plant were to cease operating, the terrestrial ecology impacts would be SMALL, assuming 11 that no additional land disturbances on or off site would occur during decommissioning 12 activities. 13 8.6.6 Human Health 14 In Chapter 4 of this SEIS, the staff concluded that the impacts of continued plant operation on 15 human health would be SMALL. After cessation of plant operations, the amounts of radioactive 16 material released to the environment in gaseous and liquid forms, all of which are currently 17 within respective regulatory limits, would be reduced or eliminated. Therefore, the staff 18 concludes that the impact of plant shutdown on human health would also be SMALL. In 19 addition, the potential for a variety of accidents would also be reduced to only those associated 20 specifically with shutdown activities and fuel handling. In Chapter 5 of this SEIS, the staff 21 concluded that impacts of accidents during operation would be SMALL. It follows, therefore, 22 that impacts on human health from a reduced suite of potential accidents after reactor operation 23 ceases would also be SMALL. Therefore, the staff concludes that impacts on human health 24 from the no -action alternative would be SMALL. 25 8.6.7 Land Use 26 Plant shutdown would not affect onsite land use. Plant structures and other facilities would 27 remain in place until decommissioning. Most transmission lines connected to GGNS would 28 remain in service after the plant stops operating. Maintenance of most existing transmission 29 lines would continue as before. The transmission lines could be used to deliver the output of 30 any new replacement power -generating facilities added to the GGNS site. Impacts on land use 31 from plant shutdown would be SMALL. 32 8.6.8 Socioeconomics 33 Plant shutdown would have a noticeable impact on socioeconomic conditions in the 34 communities located in the immediate vicinity of GGNS. Should GGNS shut down, there would 35 be immediate socioeconomic impact from the loss of jobs (some, though not all, of the 36 690 employees would begin to leave), and tax payments may be reduced. Since the majority of 37 GGNS employees reside in Claiborne, Hinds, Jefferson, and Warren Counties, socioeconomic 38 impacts from plant shutdown would be concentrated in these counties, with a corresponding 39 reduction in purchasing activity and tax contributions to the regional economy. Revenue losses 40 from GGNS operations would directly affect Claiborne County and other state taxing districts 41 Environmental Impacts of Alternatives 8-54 that are most reliant on the nuclear plant's tax revenue. The impact of the job loss, however, 1 may not be as noticeable given the amount of time required for decommissioning of the existing 2 facilities and the proximity of GGNS to metropolitan areas. The socioeconomic impacts of plant 3 shutdown (which may not entirely cease until after decommissioning) would, depending on the 4 jurisdiction, range from SMALL to LARGE. 5 8.6.9 Transportation 6 Traffic volumes on the roads in the vicinity of GGNS would be reduced after plant shutdown. 7 Most of the reduction in traffic volume would be associated with the loss of jobs at the nuclear 8 power plant. The number of deliveries to the power plant would be reduced until 9 decommissioning. Transportation impacts would be SMALL as a result of plant shutdown. 10 8.6.10 Aesthetics 11 Plant structures and other facilities would remain in place until decommissioning. Once 12 operations cease there would be no plume from the cooling tower. Therefore, aesthetic impacts 13 of plant shutdown would be SMALL. 14 8.6.11 Historic and Archaeological Resources 15 In Chapter 4, the staff concluded that the impacts of continued plant operation on historic and 16 archaeological resources would be SMALL. Onsite land use would not be affected immediately 17 by the cessation of operations. Plant structures and other facilities are likely to remain in place 18 until decommissioning. A separate environmental review would be conducted for 19 decommissioning that would address the protection of known historic and archaeological 20 resources at GGNS. Therefore, the impacts on historic and archaeological resources from plant 21 shutdown would be SMALL. 22 8.6.12 Environmental Justice 23 Impacts to minority and low -income populations would depend on the number of jobs and the 24 amount of tax revenues lost by communities in the immediate vicinity of the power plant after 25 GGNS ceases operations. Closure of GGNS would reduce the overall number of jobs (there 26 are currently 690 employees working at GGNS) and tax revenue attributed to nuclear plant 27 operations. The reduction in tax revenue could decrease the availability of public services in 28 Claiborne County. This could disproportionately affect minority and low -income populations that 29 may have become dependent on these services. See also Appendix J of NUREG -0586, 30 Supplement 1 (NRC 2002), for additional discussion of these impacts. 31 8.6.13 Waste Management 32 If the no-action alternative were implemented, the generation of high -level waste would stop, 33 and generation of low -level and mixed waste would decrease. Waste management impacts 34 from implementation of the no -action alternative are expected to be SMALL. 35 8.6.14 Summary of Impacts of Combination Alternative 36 Table 8-6 summarizes the environmental impacts of the no -action alternative compared to 37 continued operation of GGNS. 38 Environmental Impacts of Alternatives 8-55 Table 8-6. Summary of Environmental Impacts of the No -action Alternative 1 Compared to Continued Operation of GGNS 2 Category No-action Alternative Continued GGNS Operation Air Quality SMALL SMALL Groundwater Resources SMALL SMALL Surface Water Resources SMALL SMALL Aquatic Ecology SMALL SMALL Terrestrial Ecology SMALL SMALL Human Health SMALL SMALL Land Use SMALL SMALL Socioeconomics SMALL to LARGE SMALL Transportation SMALL SMALL Aesthetics SMALL SMALL Historic and Archaeological Resources SMALL SMALL Waste Management a SMALL SMALL a As described in Chapter 6, the issue, "offsite radiological impacts (spent fuel and high level waste disposal)," is not evaluated in this EIS.

8.7 Alternatives

Summary 3 In this chapter, the staff considered the following alternatives to GGNS license renewal: new 4 nuclear generation; NGCC generation; supercritical coal -fired generation; and a combination 5 alternative of natural gas, biomass -fired generation, DSM, and purchased power. No action by 6 NRC and its effects also were considered. The impacts for all alternatives to GGNS license 7 renewal are summarized in Table 8 -7. 8 The environmental impacts of the proposed action (issuing a renewed GGNS operating license) 9 would be SMALL for all impact categories, except for the Category 1 issue, "Offsite radiological 10 impacts (collective effects)" which the Commission concluded that the impacts are acceptable. 11 The issue, "Offsite radiological impacts (spent fuel and high level waste disposal" was not 12 reviewed in this SEIS because it relies on the Commission's Waste Confidence Decision 13 (WCD). The WCD was vacated on June 8, 2012, by the U.S. Court of Appeals for the District of 14 Columbia Circuit. The WCD is explained in more detail in Chapter 6 of this SEIS. 15 In conclusion, the environmental impacts from all other alternatives would be larger than the 16 impacts associated with license renewal. As Table 8 -7 shows, all other alternatives capable of 17 meeting the needs currently served by GGNS entail potentially greater impacts than the 18 proposed action of license renewal of GGNS. To make up the lost generation if license renewal 19 is denied, the no -action alternative would necessitate the implementation of one or a 20 combination of alternatives, all of which have greater impacts than the proposed action. Hence, 21 the staff concludes that the no -action alternative will have environmental impacts greater than or 22 equal to the proposed license renewal action. 23 In this chapter, the NRC staff considered the following alternatives to GGNS license renewal: 24 new nuclear generation; NGCC generation; supercritical coal -fired generation; a combination 25 alternative of natural gas, biomass, DSM and purchased power. No action by NRC and its 26 effects were also considered. The impacts for GGNS license renewal and for all alternatives to 27 GGNS license renewal are summarized in Table 8 -7. 28 In conclusion, the environmentally preferred alternative is the license renewal of GGNS. All 29 other alternatives capable of meeting the needs currently served by GGNS entail potentially 30 Environmental Impacts of Alternatives 8-56 greater impacts than the proposed action of license renewal of GGNS. In order to make up the 1 lost generation if license renewal is denied, the no -action alternative necessitates the 2 implementation of one or a combination of alternatives, all of which have greater impacts than 3 the proposed action. Hence, the NRC staff concludes that the no -action alternative will have 4 environmental impacts greater than or equal to the proposed license renewal action. 5 Environmental Impacts of Alternatives 8-57 Table 8-7. Summary of Environmental Impacts of Proposed Action and Alternatives 1 Alternative Air Quality Groundwater and Surface Water Resources Aquatic and Terrestrial Ecology Human Health Land Use Socioeconomics (including Transportation and Aesthetics) Archaeological and Historic Resources Waste Management License renewal SMALL SMALL SMALL SMALL SMALL SMALL SMALL SMALL New nuclear at GGNS site SMALL SMALL SMALL to MODERATE SMALL SMALL SMALL to LARGE SMALL SMALL NGCC at GGNS site SMALL to MODERATE SMALL SMALL to MODERATE SMALL SMALL to MODERATE SMALL to MODERATE SMALL SMALL SCPC at alternate site MODERATE SMALL SMALL to LARGE SMALL SMALL to MODERATE SMALL to LARGE SMALL to MODERATE MODERATE Combination alternative SMALL to MODERATE SMALL SMALL to MODERATE SMALL SMALL to LARGE SMALL to LARGE SMALL to LARGE SMALL No-action alternative SMALL SMALL SMALL SMALL SMALL SMALL TO LARGE SMALL SMALL Environmental Impacts of Alternatives 8-58 8.8 References 1 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 2 protection regulations for domestic licensing and related regulatory functions." 3 40 CFR Part 51. Code of Federal Regulations, Title 40, Protection of Environment, Part 51 , 4 "Requirements for Preparation, Adoption, and Submittal of Implementation Plans." 5 40 CFR Part 60. Code of Federal Regulations, Title 40, Protection of Environment, Part 60, 6 "Standards of Performance for New Stationary Sources." 7 40 CFR 81.68. Code of Federal Regulations, Title 40, Protection of Environment, Part 81.68, 8 "Mobile (Alabama) -Pensacola-Panama City (Florida) -Southern Mississippi Interstate Air Quality 9 Control Region." 10 65 FR 79825. U.S. Environmental Protection Agency. "Regulatory finding on the emissions of 11 hazardous air pollutants from electric utility steam generating units." Federal Register 12 65 (245): 79825. December 20, 2000. 13 [ACAA] American Coal Ash Association. 2010. "Coal Combustion Products Production & Use 14 Statistics, ACAA 2010 CCP Survey Results, and Production & Use Charts." Available at 15 <http://acaa.affiniscape.com/associations/8003/files/2010_CCP_Survey_FINAL_102011.pdf > 16 (accessed 21 September 2012). 17 [ARI] Alternative Resources, Inc. 2007. Final Report of Findings. Independent Third -Party 18 Environmental Review of Russell Biomass Project. September 20. 19 Archer, CL, Jacobson MZ. 2007. Supplying baseload power and reducing transmission 20 requirements by interconnecting wind farms. Journal of Applied Meteorology and Climatology 21 46(11)1701 -1717. Available at <http://www.stanford.edu/group/efmh/winds/aj07_jamc.pdf> 22 (accessed 25 March 2012). 23 [DOE] U.S. Department of Energy. Office of Energy Efficiency and Renewable Energy. 2009. 24 "Ocean Energy Technology Overview." Available at 25 <http://www1.eere.energy.gov/femp/pdfs/44200.pdf > (accessed 20 June 2012). 26 [DOE] Department of Energy. Office of Energy Efficiency and Renewable Energy. 2012. 27 "Geothermal Projects Database 2012." Available at 28 <http://www4.eere.energy.gov/geothermal/projects > (accessed 20 June 2012). 29 [BLM, DOE] U.S. Department of the Interior, Bureau of Land Management (BLM) and DOE. 30 2010. Draft Programmatic Environmental Impact Statement for Solar Energy Development in 31 Six Southwestern States (DES 10 -59; DOE/EIS -0403). December. Available at 32 <http://www.solareis.anl.gov/documents/dpeis/index.cfm> (accessed 12 October 2012) 33 [EAC] Electricity Advisory Committee. 2008. Bottling Electricity: Storage as a Strategic Tool for 34 Managing Variability and Capacity Concerns in the Modern Grid. December 2008. Available at 35 <http://www.beaconpower.com/files/EAC_Report_Energy_Storage_Manage_Grid_Variability_D 36 ec%202008.pdf > (accessed 24 May 2012). 37 [EIA] U.S. Energy Information Administration. 2008

a. The Impact of Increased Use of Hydrogen 38 on Petroleum Consumption and Carbon Dioxide Emissions. Available at 39 <http://www.eia.gov/oiaf/servicerpt/hydro/hfct.html

> (accessed 24 May 2012). 40 [EIA] U.S. Energy Information Administration. 2008b. Annual Energy Outlook 2011 with 41 Projections to 2030. Available at <http://205.254.135.7/oiaf/archive/aeo08/index.html > 42 (accessed 21 June 2012). 43 Environmental Impacts of Alternatives 8-59 [EIA] U.S. Energy Information Administration. 2010a. Cost and Quality of Fuels for Electric 1 Plants, November. Available at <http://205.254.135.7/electricity/cost_quality/pdf/cqa2009.pdf > 2 (accessed 20 June 2012). 3 [EIA] U.S. Energy Information Administration 2010

b. Updated Capital Cost Estimates for 4 Electricity Generation Plants. November. Available at 5 <http://www.eia.gov/oiaf/beck_plantcosts/pdf/updatedplantcosts.pdf> (accessed 25 May 2012).

6 [EIA] U.S. Energy Information Administration. 2011a. Annual Energy Outlook 2011 with 7 Projections to 2035. April. Available at 8 <http://www.eia.gov/forecasts/archive/aeo11/pdf/0383(2011).pdf > (accessed 25 May 2012). 9 [EIA] U.S. Energy Information Administration. 2011b. Assumptions to the Annual Energy 10 Outlook 2011. Washington, DC: DOE/EIA. July 2011. 11 [EIA] U.S. Energy Information Administration. 2012a. Mississippi Electricity Profile, 2010 Edition. 12 Available at <http://205.254.135.7/electricity/state/mississippi/ > (accessed 25 May 2012). 13 [EIA] U.S. Energy Information Administration. 2012b. Mississippi Renewable Energy Profile, 14 2010 Edition. Available at <http://205.254.135.7/renewable/state/mississippi/index.cfm > 15 (accessed 24 May 2012). 16 [EIA] U.S. Energy Information Administration 2012c. Emission Factors and Global Warming 17 Potentials. Available at <http://www.eia.gov/oiaf/1605/emission_factors.html> (accessed 18 20 June 2012). 19 ElectraTherm, 2012. Mississippi Oilfield Generates Low -Temperature, Emission Free 20 Geothermal Energy at the Wellhead. Available at 21 <http://electratherm.com/docs/Denbury%20White%20Paper.pdf > (accessed 20 June 2012). 22 [Entergy] Entergy Operations, Inc. 2008. Grand Gulf Nuclear Station, Unit 3 COL Applications, 23 Part 3 Environmental Report. 24 [Entergy] Entergy Operations, Inc. 2009. Strategic Resource Plan. Available at 25 <http://www.entergy -neworleans.com/content/irp/Chapters1_12.pdf> (accessed 6 June 2012). 26 [Entergy] Entergy Operations, Inc. 2010. 2009 Strategic Resource Plan Refresh. September. 27 [Entergy] Entergy Operations, Inc. 2011. Grand Gulf Nuclear Station, Unit 1, License Renewal 28 Application , Appendix E, Applicant's Environmental Report. Agencywide Documents Access 29 and Management System (ADAMS) Accession No. ML11308A234. 30 [Entergy] Entergy Operations, Inc. 2012. Hot Topics: System Agreement. Available at 31 <http://www.entergy.com/content/about_entergy/hot_topics/system_agreement.pdf> (accessed 32 14 June 2012). 33 [EPA] U.S. Environmental Protection Agency. 2012

a. New Source Review. July 3, 2012. 34 Available at <http://www.epa.gov/nsr/>

(accessed 23 July 2012). 35 [EPA] U.S. Environmental Protection Agency. 2012

b. List of 156 Mandatory Class I Federal 36 Areas. Available at

<http://www.epa.gov/visibility/class1.html> (accessed 20 June 2012). 37 [EPRI] Electric Power Research Initiative. 2011. Mapping and Assessment of the United States 38 Ocean Wave Energy Resource. Available at 39 <http://www1.eere.energy.gov/water/pdfs/mappingandassessment.pdf > (access ed 40 20 June 2012). 41 Environmental Impacts of Alternatives 8-60 [FERC] Federal Energy Regulatory Commission. 2009. A National Assessment of Demand 1 Response Potential. Staff Report. June. Available at <http://www.ferc.gov/legal/staff -reports/06 -2 09-demand-response.pdf> (accessed 25 March 2012). 3 [GEA] Geothermal Energy Association. 2012. Annual Geothermal Power Production and 4 Development Report. Available at 5 <http://www.geo -energy.org/reports/2012AnnualUSGeothermalPowerProductionandDevelopme6 ntReport_Final.pdf> (accessed 25 May 2012). 7 [ICF] ICF, International. 2009. Entergy New Orleans Demand Side Management Potential 8 Study: Summary. Available at 9 <http://www.entergy -neworleans.com/content/irp/Entergy_ENO_Potential_Study_v10_2009_04 10 _28.pdf> (accessed 19 June 2012). 11 [INEEL] Idaho National Engineering and Environmental Laboratory. 1997. U.S. Hydropower 12 Resource Assessment for Mississippi. November. Available at 13 <http://hydropower.inel.gov/resourceassessment/pdfs/states/ms.pdf > (accessed 24 May 2012). 14 [MSCEQ] Mississippi Commission of Environmental Quality. 2005. Regulation SW -2: 15 Nonhazardous Solid Waste Management Regulations and Criteria. Available at: 16 http://www.deq.state.ms.us/newweb/MDEQRegulations.nsf/c70604500020692b86256e1200585 17 8cb/cd70fb66996fc55f86256bd100530dad?OpenDocument (Accessed Nov 2012) 18 [NETL] National Energy Technology Laboratory. 2007. Cost and Performance Baseline for 19 Fossil Energy Plants, Vol. 1, Bituminous Coal and Natural Gas to Electricity. DOE/NETL 20 2007/1281, Final Report, U.S. Department of Energy, Pittsburgh, Pennsylvania. Revision 1, 21 August. Available at <http://www.netl.doe.gov/energy -analyses/baseline_studies.html> 22 (accessed 20 June 2012). 23 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 24 for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG -1437. May 1996. 25 [NRC] U.S. Nuclear Regulatory Commission. 2002. Final Generic Environmental Impact 26 Statement on Decommissioning of Nuclear Facilities Regarding the Decommissioning of 27 Nuclear Power Reactors. Washington, DC: NRC. NUREG -0586, Supplement 1. 28 November 2002. ADAMS Accession Nos. ML023470304 and ML023500295. 29 [NRC] U.S. Nuclear Regulatory Commission. NRC 2012a. Issued Early Site Permit -Grand Gulf 30 Site. Available at <http://www.nrc.gov/reactors/new -reactors/esp/grand -gulf.html> (accessed 31 14 June 2012). 32 [NRC] U.S. Nuclear Regulatory Commission. NRC 2012b. Grand Gulf, Unit 3 Application. 33 Available at <http://www.nrc.gov/reactors/new -reactors/col/grand -gulf.html> (accessed 34 14 June 2012). 35 [NREL] National Renewable Energy Laboratory 1999. The Value of the Benefits of 36 U.S. Biomass Power. Available at <http://www.nrel.gov/docs/fy00osti/27541.pdf > (accessed 37 19 June 2012). 38 [NREL] National Renewable Energy Laboratory. 2003. Biopower Technical Assessment: State 39 of the Industry and Technology. March. Available at <http://www.fs.fed.us/ccrc/topics/urban -40 forests/docs/Biopower_Assessment.pdf> (accessed 19 June 2012). 41 [NREL] National Renewable Energy Laboratory. 2005. A Geographic Perspective on the 42 Current Biomass Resource Availability in the United States. Technical Report 43 NREL/TP-560-39181. 44 Environmental Impacts of Alternatives 8-61 [NREL] National Renewable Energy Laboratory 2010a. The Role of Energy Storage with 1 Renewable Electricity Generation. Available at <http://www.nrel.gov/docs/fy10osti/47187.pdf > 2 (accessed 20 June 2012). 3 [NREL] National Renewable Energy Laboratory. 2010b. Offshore 90 -Meter Wind Maps and 4 Wind Resource Potential. June 2010. Available at 5 <http://www.windpoweringamerica.gov/windmaps/offshore.asp > (accessed 20 June 2012). 6 [NREL] National Renewable Energy Laboratory. 2010c. Large-Scale Offshore Wind Power in 7 the United States: Assessment of Opportunities and Barriers. September. Available at 8 <http://www.nrel.gov/wind/pdfs/40745.pdf > (accessed 24 May 2012). 9 [NREL] National Renewable Energy Laboratory. 2010d. 2008 Solar Technologies Market 10 Report. January. Available at <http://www1.eere.energy.gov/solar/pdfs/46025.pdf> (accessed 11 20 June 2012). 12 [NREL] National Renewable Energy Laboratory. 2012a. "Utility-Scal e Land-Based 80-Meter 13 Wind Maps." Available at <http://www.windpoweringamerica.gov/wind_maps.asp > (accessed 14 24 May 2012). 15 [NREL] National Renewable Energy Laboratory. 2012b. "Wind Resource Potential." Available at 16 <http://www.windpoweringamerica.gov/windmaps/resource_potential.asp> (accessed 17 24 May 2012). 18 [NREL] National Renewable Energy Laboratory. 2012c. "Solar Photovoltaic Technology Basics." 19 Available at <http://www.nrel.gov/learning/re_photovoltaics.html > (accessed 20 June 2012). 20 [NREL] National Renewable Energy Laboratory. 2012d. "Solar Maps." Available at 21 <http://www.nrel.gov/gis/solar.html > (accessed 24 May 2012). 22 Offshorewindfarm.net. "Map of Offshore Wind Energy Activity in North America" (accessed 23 20 June 2012). 24 Reuters. 2012. "Southern Co. Appeals Mississippi's C oal-plant Rate Hike Denial." Available at 25 <http://in.reuters.com/article/2012/07/09/utilities -southern-kemper-idINL2E8I9EOC20120709 > 26 (accessed 31 July 2012). 27 Palmer Renewable Energy, LLC. 2011. 35 MW Biomass -fired Power Plant Conditional 28 Approval. Available at <http://www.mass.gov/dep/public/hearings/precpa_en.pdf > (accessed 29 20 June 2012). 30 [Sandia] Sandia National Laboratories. 2012. Energy Storage Systems: ARRA Energy Storage 31 Demonstrations. Available at <http://www.sandia.gov/ess/docs/ARRA_StorDemos_4 11.pdf> 32 (accessed 20 June 2012). 33 [Siemens] Siemens Power Generation. 2007. Technical Data: Combined Cycle Power Plant 34 Performance Data. Available at 35 <http://www.powergeneration.siemens.com/products -solutions-services/power -plant-36 soln/combined-cycle-power-plants/technical -data> (accessed 20 June 2012). 37 [TEEIC] Tribal Energy and Environmental Information Center. Utility-Scale and Direct Use 38 Geothermal Energy Generation. Available at 39 <http://teeic.anl.gov/er/geothermal/restech/scale/index.cfm > (accessed 20 June 2012). 40 [TCPA] Texas Comptroller of Public Accounts. 2008. The Energy Report 2008. Austin, TX. 41 Available at <http://www.window.state.tx.us/specialrpt/energy/> (accessed 17 October 2011). 42 Environmental Impacts of Alternatives 8-62 [USGS] U.S. Geological Survey. 2008. Assessment of Moderate- and High-Temperature 1 Geothermal Resources of the United States. Available at <http://pubs.usgs.gov/24 2 f s/2008/3082/pdf/fs2008 -3082.pdf> (accessed 24 May 2012). 3 [USOWC] U.S. Offshore Wind Collaborative 2009. U.S Offshore Wind Energy: A Path Forward. 4 A Working Paper of the U.S. Offshore Wind Collaborative. October. Available at 5 <http://www.usowc.org/pdfs/PathForwardfinal.pdf > (accessed 7 June 2012). 6 9-1

9.0 CONCLUSION

1 This draft supplemental environmental impact statement (SEIS) contains the environmental 2 review of Entergy Operations , Inc.'s (Entergy's) application for a renewed operating license for 3 Grand Gulf Nuclear Station , Unit 1 (G G N S), as required by Title 10 of the Code of Federal 4 Regulations Part 51 (10 CFR Part 51), the U.S. Nuclear Regulatory Commission's (NRC 's) 5 regulations that implement the National Environmental Policy Act (NEPA). This chapter 6 presents conclusions and recommendations from the site-specific environmental review of 7 G G N S and summarizes site-specific environmental issues of license renewal that the NRC staff 8 (staff) noted during the review. Section

9.1 summarizes

the environmental impacts of license 9 renewal; Section

9.2 presents

a comparison of the environmental impacts of license renewal 10 and energy alternatives; Section

9.3 discusses

unavoidable impacts of license renewal, energy 11 alternatives, and resource commitments; and Section

9.4 presents

conclusions and staff 12 recommendations . 13 9.1 Environmental Impacts of License Renewal 14 Based on the staff's review of site -specific environmental impacts of license renewal presented 15 in this SEIS, the staff concludes that issuing a renewed license would have SMALL impacts. 16 The site-specific review included applicable Category 2 issues and uncategorized issues. The 17 staff considered mitigation measures for each Category 2 issue, as applicable. The staff 18 concluded that no additional mitigation measure is warranted. 19 The staff also considered cumulative impacts of past, present, and reasonably foreseeable 20 future actions, regardless of what agency (Federal or non -Federal) or person undertakes them. 21 The staff concluded in Section 4.1 2 that cumulative impacts of GGNS's license renewal would 22 be SMALL for all areas , except aquatic and terrestrial resources. For aquatic resources, the 23 staff concluded that the cumulative impact would be MODERATE. For terrestrial resources, the 24 cumulative impacts would be MODERATE . 25 9.2 Comparison of Alternatives 26 In the conclusion to Chapter 8, the staff considered the following alternatives to GGNS license 27 renewal: 28 new nuclear, 29 natural gas -fired combined -cycle (NGCC), 30 supercritical pulverized coal , 31 combination alternative of NGCC, biomass, demand -side management and 32 purchased power , and 33 no-action. 34 The NRC staff concluded that the environmental impacts of renewal of the operating license for 35 GGNS would be smaller than those of feasible and commercially viable alternatives. The 36 no-action alternative would have SMALL environmental impacts in most areas , with the 37 exception of socioeconomic impact

s. Continued operation would have SMALL environmental 38 impacts in all areas. The staff concluded that continued operation of the existing GGNS is the 39 environmentally preferred alternative

. 40 Conclusion 9-2 9.3 Resource Commitments 1 9.3.1 Unavoidable Adverse Environmental Impacts 2 Unavoidable adverse environmental impacts are impacts that would occur after implementation 3 of all workable mitigation measures. Carrying out any of the energy alternatives considered in 4 this SEIS, including the proposed action, would result in some unavoidable adverse 5 environmental impacts. 6 Minor unavoidable adverse impacts on air quality would occur because of emission and release 7 of various chemical and radiological constituents from power plant operations. Nonradiological 8 emissions resulting from power plant operations are expected to comply with 9 U.S. Environmental Protection Agency emissions standards. Chemical and radiological 10 emissions are not expected to exceed the National Emission Standards for hazardous air 11 pollutants. 12 During nuclear power plant operations, workers and members of the public would face 13 unavoidable exposure to radiation and hazardous and toxic chemicals. Workers would be 14 exposed to radiation and chemicals associated with routine plant operations and the handling of 15 nuclear fuel and waste material. Workers would have higher levels of exposure than members 16 of the public, but doses would be administratively controlled and would not exceed standards or 17 administrative control limits. In comparison, the alternatives involving the construction and 18 operation of a non -nuclear power generating facility also would result in unavoidable exposure 19 to hazardous and toxic chemicals to workers and the public. 20 The generation of spent nuclear fuel and waste material, including low -level radioactive waste, 21 hazardous waste, and nonhazardous waste , also would be unavoidable. In comparison, 22 hazardous and nonhazardous wastes also would be generated at non -nuclear power generating 23 facilities. Wastes generated during plant operations would be collected, stored, and shipped for 24 suitable treatment, recycling, or disposal in accordance with applicable Federal and State 25 regulations. Because of the costs of handling these materials, power plant operators would be 26 expected to carry out all activities and optimize all operations in a way that generates the 27 smallest amount of waste possible. 28 9.3.2 Short-Term Versus Long -Term Productivity 29 The operation of power generating facilities would result in short -term uses of the environment, 30 as described in Chapters 4, 5, 6, 7, and

8. "Short-term" is the period of time that continued 31 power generating activities take place.

32 Power plant operations require short -term use of the environment and commitment of resources 33 (e.g., land and energy), indefinitely or permanently. Certain short -term resource commitments 34 are substantially greater under most energy alternatives, including license renewal, than under 35 the no-action alternative because of the continued generation of electrical power and the 36 continued use of generating sites and associated infrastructure. During operations, all energy 37 alternatives require similar relationships between local short -term uses of the environment and 38 the maintenance and enhancement of long -term productivity. 39 Air emissions from power plant operations introduce small amounts of radiological and 40 nonradiological constituents to the region around the plant site. Over time, these emissions 41 would result in increased concentrations and exposure, but they are not expected to impact air 42 quality or radiation exposure to the extent that public health and long -term productivity of the 43 environment would be impaired. 44 Conclusion 9-3 Continued employment, expenditures, and tax revenues generated during power plant 1 operations directly benefit local, regional, and State economies over the shor t term. Local 2 governments investing project -generated tax revenues into infrastructure and other required 3 services could enhance economic productivity over the long term. 4 The management and disposal of spent nuclear fuel, low -level radioactive waste, hazardous 5 waste, and nonhazardous waste requires an increase in energy and consumes space at 6 treatment, storage, or disposal facilities. Regardless of the location, the use of land to meet 7 waste disposal needs would reduce the long -term productivity of the la nd. 8 Power plant facilities are committed to electricity production over the short term. After 9 decommissioning these facilities and restoring the area, the land could be available for other 10 future productive uses. 11 9.3.3 Irreversible and Irretrievable Commitments of Resources 12 This section describes the irreversible and irretrievable commitment of resources that have 13 been noted in this SEIS. Resources are irreversible when primary or secondary impacts limit 14 the future options for a resource. An irretrievable commitment refers to the use or consumption 15 of resources that are neither renewable nor recoverable for future use. Irreversible and 16 irretrievable commitment of resources for electrical power generation include the commitment of 17 land, water, energy, raw materials, and other natural and man made resources required for 18 power plant operations. In general, the commitment of capital, energy, labor, and material 19 resources also are irreversible. 20 The implementation of any of the energy alternatives considered in this SEIS would entail the 21 irreversible and irretrievable commitment of energy, water, chemicals, and -in some cases -22 fossil fuels. These resources would be committed during the license renewal term and over the 23 entire life cycle of the power plant, and they would be unrecoverable. 24 Energy expended would be in the form of fuel for equipment, vehicles, and power plant 25 operations and electricity for equipment and facility operations. Electricity and fuel would be 26 purchased from offsite commercial sources. Water would be obtained from existing water 27 supply systems. These resources are readily available, and the amounts required are not 28 expected to deplete available supplies or exceed available system capacities. 29 9.4 Recommendations 30 The NRC staff's preliminary recommendation is that the adverse environmental impacts of 31 license renewal for G G N S are not great enough to deny the option of license renewal for 32 energy-planning decisionmakers. This recommendation is based on the following: 33 the analysis and findings in NUREG -1437, Volumes 1 and 2, Generic 34 Environmental Impact Statement for License Renewal of Nuclear Plants , 35 the environmental report submitted by E ntergy , 36 consultation with Federal, State, and local agencies, 37 the NRC's environmental review, and 38 consideration of public comments received during the scoping process. 39

10-1 10.0 LIST OF PREPARERS 1 Members of the U.S. Nuclear Regulatory Commission 's (NRC's) Office of Nuclear Reactor 2 Regulation (NRR) prepared this supplemental environmental impact statement (SEIS) with 3 assistance from other NRC organizations and contract support from Argonne National 4 Laboratory (ANL), Pacific Northwest National Laboratory (PNNL), the Center for Nuclear Waste 5 Regulatory Analyses (CNWRA) and a private contractor. Table 10-1 identifies each 6 contributor's name, affiliation, and function or expertise. 7 Table 10-1. List of Preparers 8 Name Affiliation Function or Expertise NRC D. Wrona NRR Management oversight M. Wong NRR Management oversight D. Drucker NRR Project management W. Rautzen NRR Radiological, human health and alternatives S. Klementowicz NRR Radiological, human health and alternatives B. Ford NRR Hydrology and alternatives M. Moser NRR Aquatic ecology and alternatives B. Grange NRR Terrestrial ecology and alternatives E. Larson NRR Cultural resources , cumulative impacts and alternatives J. Rikhoff NRR Socioeconomic, environmental justice, and land use and alternatives E. Keegan NRR Air quality and meteorology (climatology), alternatives and nonradiological waste management N. Martinez NRR Air quality and meteorology (climatology) J. Dozier NRR Severe Accident Mitigation Alternatives Contractor(a)(b)(c) J. Quinn ANL Hydrology and alternatives K. Wescott ANL Cultural resources and alternatives E. Moret ANL Alternatives Y. Chang ANL Air quality and meteorology (climatology) and alternatives D. Anderson PNNL Socioeconomic, environmental justice, and land use R. Benke CNWRA Severe Accident Mitigation Alternatives E. R. Schmidt Contractor Severe Accident Mitigation Alternatives (a) ANL is operated by UChicago Argonne, LLC, for the U.S. Department of Energy . (b) PNNL is operated by Battelle for the U.S. Department of Energy. (c) CNWRA is a federally funded research and development center sponsored by the NRC.

11-1 11.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS 1 TO WHOM COPIES OF THIS SEIS ARE SENT 2 Name and Title Affiliation and Address Chief Phyliss Anderson Tribal Nation -Mississippi Band of Choctaw Indians P.O. Box 6010 Choctaw Branch Choctaw, MS 39350 Principal Chief B. Cheryl Smith Tribal Nation -Jena Band of Choctaw Indians P.O. Box 14 Jena, LA 71342 Chief Gregory Pyle Tribal Nation -Choctaw Nation of Oklahoma P. O. Box 1210 Durant, OK 74702-1210 Chairman Earl J. Barbry, Jr. Tribal Nation -Tunica-Biloxi Tribe of Louisiana P.O. Box 1589 Marksville, LA 71351 Reid Nelson, Director Advisory Council on Historic Preservation Office of Federal Agency Programs 1100 Pennsylvania Avenue, NW , Suite 803 Washington, DC 20004 David Bernhart, Assistant Regional Administrator National Marine Fisheries Service , Southeast Regional Office 263 13th Avenue, South Saint Petersburg, FL 33701 Stephen Ricks, Field Supervisor U.S. Fish and Wildlife Service , Mississippi Field Office 6578 Dogwood View Parkway, Suite A Jackson, MS 39213 Jeffrey Weller, Field Supervisor U.S. Fish and Wildlife Service, Louisiana Field Office 646 Cajundome Blvd., Suite 400 Lafayette, LA 70506 Andy Sanderson, Ecologist Mississippi, Department of Wildlife, Fisheries and Parks 2148 Riverside Drive Jackson, MS 39202 Amity Bass, Ecologist Louisiana, Department of Wildlife and Fisheries P.O. Box 98000 Baton Rouge, LA 70898-9000 Greg Williamson , Review and Compliance Officer Mississippi State Historic Preservation Office P.O. Box 571 Jackson, MS 39205 Phil Boggan, Deputy Director Louisiana State Historic Preservation Office P.O. Box 44247 Baton Rouge, LA 70804 James Johnston, Administrator Claiborne County, Mississippi, Office of the Administrator P.O. Box 689 510 Main St. Port Gibson, MS 39150 Fred Reeves, Mayor City of Port Gibson, Mississippi 1005 College Street Port Gibson, MS 39150 Debra Chambliss, Deputy City Clerk Office of the Mayor, Port Gibson, Mississippi 1005 College Street Port Gibson, MS 39150 List of Agencies, Organizations, and Persons To Whom Copies of This SEIS Are Sent 11-2 Name and Title Affiliation and Address Bryan Collins, Chief, Energy and Transportation Branch Mississippi Department of Environmental Quality P.O. Box 2261 Jackson, MS 39225 B. J. Smith, Director Mississippi Division of Radiological Health 3150 Lawson St. P.O. Box 1700 Jackson, MS 39215-1700 Cheryl Chubb, Project Manager Louisiana Department of Environmental Quality 602 North Fifth Street Baton Rouge, LA 70802 Patricia Hemphill, Deputy Chief, Programs & Project Management U.S. Army Corps of Engineers, Vicksburg District 4155 East Clay Street Vicksburg, MS 39183 -3435 Jan Hillegas, Acting Chair Green Party of Mississippi 8 Gumtree Drive Oxford, MS 38655 Heinz Mueller, Chief, Environmental Assessment Branch U.S. Environmental Protection Agency, Region 4 Room 9T-25 Office of Environmental Accountability , Atlanta Federal Center, 61 Forsyth Street, SW Atlanta, GA 30303-3104 EIS Filing Section U.S. Environmental Protection Agency 1200 Pennsylvania Ave., NW Washington, D.C. 20004 Also sent via EPA's e-NEPA Web site 12-1 12.0 INDEX 1 A 2 accidents, 2-1, 2-6, 5-1, 5-3, 5-4, 5-5, A-3, F-3, 3 F-6, F-10, F-11, F-12, F-16, F-17, F-33, F-35, 4 F-40, F-41 5 Advisory Council on Historic Preservation 6 (ACHP), 21, 1-7, 4-24, 4-53, 11-1, D-1, E-1 7 aesthetic, 4-26, 8-10, 8-11, 8-20, 8-44, 8-45, 8 8-56 9 alternatives, iii, xviii , 1-6, 4-33, 5-3, 5-12, 5-13, 10 6-3, 6-5, 6-6, 8-1, 8-2, 8-3, 8-9, 8-18, 8-26, 11 8-30, 8-34, 8-40, 8-41, 8-42, 8-43, 8-44, 8-47, 12 8-53, 8-57, 8-58, 9-1, 9-2, 9-3, 10-1, B-10 , F-1, 13 F-2, F-23, F-24, F-44, F-45 14 archaeological resources, xvii , 1-7, 2-78, 15 2-79, 2-81, 2-82, 3-2, 4-21, 4-25, 4-45, 4-46, 16 4-48, 8-11, 8-20, 8-32, 8-45, 8-46, 8-56 , B-9 , 17 D-1 18 B 19 biota, 2-39, 2-40, 2-41, 2-44, 2-46, 4-6, 4-39, 20 8-17, 8-28, B-2 21 boiling water reactor, xxi , 2-1, 3-1 22 burnup, 2-1, 12-1, B-14 23 C 24 Choctaw Nation of Oklahoma, 1-7, 4-24, 4-53, 25 11-1, D-1,D-2, E-1 , E-3 26 chronic effects, 1-3, 4-1, 4-13, 4-18, B-8 27 Clean Air Act (CAA), xx , 2-22, 2-23, 2-85, 28 8-14 , 8-15, 8-25, 8-36, 8-37, C-2 29 closed-cycle cooling, 4-40, 4-41 , 4-47, 8-23, 30 8-28, 8-39, B-5 31 Coastal Zone Management Act (CZMA), xx , 32 C-2 33 cold shock, 4-41 34 cooling system, xvi, xvii , 1-4, 1-6, 2-12, 2-15, 35 2-34, 4-6, 4-8, 4-9, 4-40, 4-41, 4-47, 5-8, 5-9, 36 5-12, 8-3, 8-5, 8-7, 8-8, 8-13, 8-16, 8-17 , 8-23, 37 8-27, 8-28, 8-39, B-1, B-2, B-3, B-4, F-7, F-30, 38 F-32, F-37, F-42, F-43 39 core damage frequency (CDF), xiii, xiv, xx , 40 5-4, 5-5, 5-8, 5-12, F-1, F-2, F-4, F-6, F-7, F-8, 41 F-9, F-10, F-11, F-12, F-13, F-14, F-15, F-16, F-42 20, F-21, F-23, F-24, F-25, F-26, F-27, F-28, F-43 29, F-30, F-31, F-32, F-33, F-34, F-35, F-36, F-44 37, F-38, F-41, F-42, F-43 45 Council on Environmental Quality (CEQ), xx , 46 1-4, 4-26, 4-38, 4-49 47 critical habitat, 2-55, 2-58, 2-59, 2-60, 2-62, 48 2-63, 2-64, 2-84, 4-10, 4-11, 4-13, 4-14, 8-8, 49 8-18, 8-29, 8-40, C-3 50 cultural resources, 2-81, 4-25, 4-45, 8-45, C-1 51 D 52 demography, 2-66 53 design-basis accident, xx , 4-31, 5-1 , 5-2, B-10 54 discharges, 2-9, 2-11, 2-12, 2-22, 2-31, 2-33, 55 2-35, 2-39, 2-40, 2-42, 2-43, 2-45, 2-55, 2-63, 56 2-90, 4-5, 4-6, 4-7, 4-8, 4-12, 4-14, 4-37, 4-41, 57 8-5, 8-7, 8-13, 8-16, 8-17, 8-23, 8-27, 8-39, 58 8-40, 8-55, B-1, B-3, B-8 59 dose, xxvi, xxvii , 2-6, 4-17, 4-18, 4-19, 4-43, 60 4-44, 4-48, 5-6, 5-8, 6-2, B-7 , B-11 , B-12 , F-1, 61 F-3, F-4, F-9, F-18, F-24, F-25, F-40, F-41 62 dredging, 2-33, 2-39, 8-7, 8-16, 8-17, 8-27, 63 8-38, 8-39 64 E 65 education, 2-67, 3-2, 4-21, B-9 66 electromagnetic fields, xxiii , 1-3, 4-1, 4-8, 67 4-20, B-6 , B-8 68 Index 12-2 endangered and threatened species, xvii , 1 1-7, 2-56, 2-83, 3-2, 4-10, 4-40, 4-41, B-7 , D-1 2 Endangered Species Act (ESA), vi, xviii, xxiii , 3 1-7, 1-8, 2-54, 2-55, 2-58, 2-63, 2-65, 2-85, 4 2-89, 4-1, 4-9, 4-10, 4-11, 4-49, 8-7, 8-8, 8-17, 5 8-18 , 8-28, 8-29, 8-39, 8-40, C-3, D-1 6 entrainment, 4-40, 8-28, 8-39, B-2, B-4 7 environmental justice (EJ), xviii , 1-3, 1-6, 8 2-85, 3-2, 4-1, 4-21, 4-26, 4-31, 4-45, 4-48, 9 4-49, 8-11 , 8-21, 8-32, 8-46, 10-1, B-1, B-15 10 EPA, 4-18 11 essential fish habitat (EFH), 2-54, 2-92, C-3, 12 D-1 13 eutrophication , 4-54 14 F 15 Fish and Wildlife Coordination Act (FWCA), 16 C-3 17 G 18 GEIS, 4-17 19 Generic Environmental Impact Statement 20 (GEIS), iii, v, xv, xvi, xvii, xviii, xix, xxiv , 1-3, 1-4, 21 1-5, 1-6, 1-8, 1-9, 2-70, 2-92, 3-1, 3-2, 3-3, 4-1, 22 4-2, 4-3, 4-4, 4-5, 4-6, 4-7, 4-8, 4-9, 4-10, 4-15, 23 4-16, 4-19, 4-20, 4-21, 4-22, 4-23, 4-26, 4-33, 24 4-52, 4-54, 5-1, 5-2, 5-3, 5-14, 6-1, 6-2, 6-3, 25 6-12, 7-1, 7-2, 7-3, 8-1, 8-2, 8-9, 8-12, 8-18, 26 8-19, 8-22, 8-23, 8-25, 8-29, 8-30, 8-31, 8-41, 27 8-42, 8-52, 8-54, 8-62, 9-3, B-1, B-10 28 greenhouse gases, xxiv , 2-22, 2-69, 2-84, 29 4-35, 4-49, 6-3, 6-12, 8-13 30 ground water, 4-17 31 groundwater, xvii , 1-6, 2-15, 2-33, 2-34, 2-35, 32 2-36, 2-37, 2-67, 2-68, 2-86, 3-1, 4-4, 4-5, 4-6, 33 4-17, 4-18, 4-32, 4-38, 4-47, 8-2, 8-7, 8-16, 34 8-26 , 8-27, 8-28, 8-38, 8-55, B-1, B-4, B-5, 35 B-10 , C-1 36 H 37 hazardous waste, 2-8, 9-2, 9-3, C-3 38 heat shock, 4-12, 12-2, B-4 39 high-level waste, xvi , 1-4, 6-1, 6-2, 8-12, 8-57, 40 B-10 , B-11 , B-12 , B-13 , B-14 41 I 42 impingement, 4-40, 8-28, 8-39, B-2, B-4 43 independent spent fuel storage installation 44 (ISFSI), xxiv , 2-6, 2-69, 4-34, 4-44, 4-48, A-2 45 Indian tribes, 2-80, 4-26, 4-31 46 invasive species, 4-43 47 J 48 Jena Band of Choctaw Indians, 1-7, 4-24, 49 4-54, 11-1, D-1, D-2, E-1 , E-2 50 L 51 long-term dose, F-41 52 Louisiana Division of Historic Preservation, 53 1-7 54 Louisiana Natural Heritage Program, 1-7, 55 4-51, 4-53, D-1, D-2, E-2 56 low-level waste, 6-1, 8-12, A-2, A-3, B-13 57 M 58 Magnuson-Stevens Fishery Conservation 59 and Management Act (MSA), xxvi , 1-7, 8-7, 60 8-17, 8-28, C-3 61 Marine Mammal Protection Act (MMPA), xxv , 62 C-3 63 maximum occupational doses, 4-16, B-8 64 Mississippi Band of Choctaw Indians, 1-7, 65 4-24, 4-53, 11-1, D-1, E-1 , E-2 66 Mississippi Department of Archives and 67 History, xxv , 1-7 , 2-79, 2-85, 2-89, 2-94, 4-25, 68 4-51, 4-53 69 Index 12-3 Mississippi Natural Heritage Program, xxv , 1 1-7, 2-55 , 2-90, 2-91, 4-52, 4-53, D-1, E-2 2 mitigation, xvi , 1-4, 1-6, 4-15, 4-17, 4-20, 4-37, 3 4-46, 5-3, 7-1, 7-2, 8-6, 8-8, 8-11, 8-14, 8-17, 4 8-18, 8-21, 8-24, 8-28, 8-29, 8-32, 8-35, 8-40, 5 8-45, 9-1, 9-2, E-3 6 mixed waste, 2-7, 8-12, 8-57, B-14 7 N 8 National Environmental Policy Act (NEPA), 9 xv, xvi, xvii, xxvi , 1-1, 1-5, 1-6, 1-8, 2-82, 2-91, 10 2-92, 3-3, 4-10, 4-24, 4-26, 4-38, 4-49, 4-50, 11 4-52, 5-2, 6-2, 6-3, 6-12, 7-3, 8-1, 9-1, 11-2, 12 B-1, B-11 , B-13 13 National Marine Fisheries Service (NMFS), 14 xxvi , 1-7, 2-54, 2-55, 2-56, 2-83, 2-92, 4-10, 15 4-52, 4-53, 11-1, C-3, D-1, D-2, E-2 , E-3 16 National Pollutant Discharge Elimination 17 System (NPDES), xxvi , 2-9, 2-11, 2-31, 2-33, 18 2-90, 4-12, 4-14, 4-37, 4-41, 8-7, 8-16, 8-17, 19 8-27, 8-39, B-2, C-1, C-2, C-4 20 Native American tribes, 2-80, 4-31 21 no-action alternative, iii, xviii, xix , 4-9, 4-38, 22 4-42, 8-2, 8-54, 8-55, 8-57, 8-58, 9-1, 9-2 23 nonattainment, 2-24, 3-2, 4-35, 4-47, 8-6, 24 8-14, 8-24, 8-29, 8-35, B-7 25 O 26 once-through cooling, 2-15, B-2, B-3, B-4 27 P 28 peak dose, B-12 29 postulated accidents, 4-31, 5-1, 5-2, 5-3, A-4 30 power uprate, xxiii , 4-44, 5-4, 5-5, A-3, F-2, F-3 31 pressurized water reactor, 3-1 32 R 33 radon, 4-17, 12-3, B-10 , B-11 34 Ranney wells, 2-11, 2-12, 2-33, 2-34, 2-35, 35 4-4, 4-5, 4-41, 4-47, 8-4, 8-5, 8-7, 8-16, 8-17, 36 B-5 37 reactor, xv, xvi, xxviii , 1-5, 2-1, 2-6, 2-9, 2-11, 38 2-12, 2-15, 2-25, 2-26, 2-27, 2-36, 2-82, 4-5, 39 4-6, 4-22, 4-34, 4-37, 4-38, 4-40, 4-41, 4-44, 40 4-48, 5-1, 5-2, 5-3, 5-4, 5-5, 5-8, 5-13, 6-2, 6-5, 41 6-11, 7-1, 8-5, 8-6, 8-8, 8-10, 8-29, 8-55, A-2, 42 A-3, A-4, B-5 , B-11 , F-1, F-2, F-3, F-6, F-7, F-43 12, F-14, F-16, F-23, F-24, F-29, F-30, F-31, F-44 33, F-37, F-39, F-42, F-44 45 refurbishment, xviii , 3-1, 3-2, 3-3, 4-2, 4-3, 4-9, 46 4-11, 4-13, 4-19, 4-22, 4-26, 4-36, B-1, B-2, B-47 4, B-7 , B-8 , B-9 , F-41 48 replacement power, xxviii , 5-11, 8-1, 8-9, 8-11, 49 8-18 , 8-30, 8-42, 8-43, 8-55, F-39, F-41, F-42 50 S 51 salinity gradients, 4-3, B-1 52 scoping, iii, xv, xvii, xix , 1-2, 1-3, 1-6, 4-2, 4-3, 53 4-4, 4-6, 4-7, 4-8, 4-15, 4-16, 4-17, 4-21, 4-25, 54 4-34, 6-2, 7-2, 9-4, A-1, E-1 , E-2 55 seismic, xxviii , 2-26, 5-7, F-1, F-10, F-11, F-15, 56 F-21, F-23, F-24 57 severe accident mitigation alternative 58 (SAMA), vii, xiii, xiv, xviii, xxviii , 5-3, 5-4, 5-7, 59 5-8, 5-9, 5-10, 5-11, 5-12, 5-13, 5-14, 9-1, E-3 , 60 F-1, F-2, F-3, F-6, F-8, F-9, F-10, F-11, F-15, 61 F-17, F-18, F-19, F-20, F-21, F-22, F-23, F-24, 62 F-25, F-26, F-27, F-28, F-29, F-30, F-31, F-32, 63 F-33, F-34, F-35, F-36, F-37, F-38, F-39, F-40, 64 F-42, F-43, F-44, F-45, F-46 65 severe accidents, xviii , 4-31, 5-1, 5-2, 5-3, 66 B-10 , E-3 , F-1, F-6, F-11, F-15, F-17, F-23, 67 F-41, F-42 68 solid waste, xviii , 2-7, 2-8, 6-1, 6-2, 7-2, 8-52, 69 B-15 , C-1, C-3 70 Index 12-4 spent fuel, xvi , 1-4, 2-6, 4-44, 6-1, 6-2, 6-11, 1 8-13 , 8-22, 8-34, 8-48, 8-57, A-1, A-2, A-3, 2 B-10 , B-11 , B-12 , B-13 , B-14 3 State Historic Preservation Office (SHPO), 4 xxviii , 2-81, 2-93, 4-24, 4-25, 4-46, 11-1, B-9 , 5 C-3, D-1, D-2, E-2 6 State Pollutant Discharge Elimination 7 System (SPDES), C-1 8 stormwater, 8-8, 8-17, 8-28, 8-40, C-4 9 surface runoff, 2-39, 2-45, 4-39, 4-40, 4-41, 10 4-42, 4-43, 4-48 11 surface water, 2-11, 2-15, 2-31, 3-1, 4-3, 4-17, 12 4-31, 4-32, 4-37, 4-41, 4-47, 8-2, 8-7, 8-8, 8-16, 13 8-17, 8-27, 8-28, 8-38, 8-39, 8-55, B-1, B-5, 14 C-1, C-2 15 T 16 taxes, 2-75, 2-77, 4-24, 8-31, 8-43 17 transmission line corridors, 2-10, 2-54, 2-55, 18 2-64, 2-65, 4-9, 4-10, 4-13, 4-14, 4-25, 4-42 19 transmission lines, 2-10, 2-18, 2-47, 2-54, 20 2-55, 2-57, 2-64, 2-81, 4-1, 4-2, 4-8, 4-9, 4-13, 21 4-14, 4-19, 4-20, 4-21, 4-25, 4-42, 8-4, 8-5, 8-8, 22 8-17, 8-18, 8-23 , 8-28, 8-42, 8-45, 8-55, B-6 , 23 B-7 , B-10 24 tritium, 2-36, 4-5, 4-6 25 Tunica-Biloxi Tribe of Louisiana, 1-7 , 4-24, 26 4-54, 11-1, E-1 27 U 28 U.S. Department of Energy (DOE), xx , 4-20, 29 8-2, 8-49, 8-50, 8-51 , 8-60, 8-61, 8-62, 10-2, 30 B-12 31 U.S. Environmental Protection Agency 32 (EPA), xv, xxiii , 1-1, 2-7, 2-8, 2-9, 2-10, 2-22, 33 2-23, 2-24, 2-25, 2-33, 2-35, 2-36, 2-67, 2-68, 34 2-70, 2-84, 2-86, 2-87, 4-5, 4-10, 4-12, 4-14, 35 4-18, 4-35, 4-38, 4-39, 4-42, 4-43, 4-48, 4-49, 36 4-50, 6-2, 8-1, 8-2, 8-6, 8-14, 8-15, 8-16, 8-24, 37 8-25, 8-26, 8-29, 8-36, 8-37, 8-41, 8-60, 8-61, 38 9-1, 9-2, 11-2, B-1, B-13 , C-1, C-2, C-3 39 U.S. Fish and Wildlife Service (FWS), xxiii , 40 1-7, 2-25, 2-54, 2-55, 2-56, 2-57, 2-58, 2-59, 41 2-60, 2-61, 2-62, 2-63, 2-65, 2-83, 2-84, 2-87, 42 2-88, 2-93, 4-10, 4-11, 4-12, 4-13, 4-15, 4-50, 43 4-51, 4-53, 8-8 , 8-18, 8-29, 8-40, 11-1, C-3 44 U.S. Fish and Wildlife Servi ce (FWS), 45 Louisiana Field Office, 1-7, 11-1 46 U.S. Fish and Wildlife Service (FWS), 47 Mississippi Field Office, 1-7 48 uranium, xxvi , 2-1, 2-6, 4-43, 6-1, 6-2, 6-4, 6-5, 49 6-7, 6-8, 6-9, 6-10, 8-4, 8-8, 8-9, 8-19, 8-29, 50 8-30, 8-42, B-10 , B-13 , B-14 51 W 52 wastewater, 2-8, 2-9, 2-31, 2-33, 2-90, 4-3, 53 8-27, 8-52, B-2 54 Y 55 Yucca Mountain, B-12 , B-13 , B-14 56 APPENDIX A 1 COMMENTS RECEIVED ON THE GGNS ENVIRONMENTAL REVIEW 2

A-1 A. COMMENTS RECEIVED ON THE GGNS ENVIRONMENTAL REVIEW 1 A.1 Comments Received During the Scoping Period 2 The scoping process began on December 29, 2011, with the publication of the U.S. Nuclear 3 Regulatory Commission's (NRC's) Notice of Intent to conduct scoping in the Federal Register 4 (76 FRN 81996). The scoping process included two public meetings held at the Port Gibson 5 City Hall, Port Gibson, Mississippi, on January 31, 2012. Approximately 30 people attended the 6 meetings. After the NRC's prepared statements pertaining to the license renewal process, the 7 meetings were open for public comments. Attendees provided oral statements that were 8 recorded and transcribed by a certified court reporter. Transcripts of the two meetings are 9 available using the NRC's Agencywide Documents Access and Management System (ADAMS). 10 ADAMS Public Electronic Reading Room is accessible at http://www.nrc.gov/reading -11 rm/adams.html. Transcripts for the afternoon and evening meetings are listed under Accession 12 Numbers ML12037A222 and ML12037A223, respectively. 13 Table A-1 identifies the individuals who provided comments and an accession number to 14 identify the source document of the comments in ADAMS. 15 Table A-1. Individuals Who Provided Comments During the Scoping Comment Period 16 Commenter Affiliation (If Stated) Comment Source ADAMS Accession Number Jan Hillegas Green Party of Mississippi Regulations.gov ML12060A334 Fred Reeves Mayor of Port Gibson Evening transcript ML12037A223 Debra Chambliss City of Port Gibson Evening transcript ML12037A223 Note - No comments were received during the afternoon meeting. 17 Comments received during the scoping comment period applicable to this environmental review 18 are presented in this section along with the NRC response. The comments that are general or 19 outside the scope of the environmental review for Grand Gulf Nuclear Station (GGNS) license 20 renewal are not included here but can be found in the Scoping Summary Report (ADAMS 21 Accession No. ML12201A623). Unless otherwise identified, comments presented in this section 22 are from Ms. Jan Hillegas. 23 A.1.1 Waste Management 24 Comment: I did not receive an answer to my question (Transcript, p. 35) about "the 25 approximate square footage or cubic yards" of radioactive waste now on site and "how much 26 more accumulates every year." Mr. Smith's answer (Transcript, pp. 36 -38) in terms of bundles, 27 canisters, and so on, gave no dimensions. Please provide the dimensions and capacities of the 28 containers and of the stored waste. And the NRC's Environmental Review needs to calculate 29 and evaluate the onsite storage of spent fuel under current and other possible conditions 30 through at least 2044. 31 Appendix A A-2 Response: There are two broad classifications of radioactive waste generated at GGNS

1 high-level and low

-level waste. High-level radioactive waste results primarily from the fuel that 2 has been used in a nuclear power reactor and is "spent" or is no longer efficient in generating 3 power to the reactor to produce electricity. Low -level radioactive waste results from reactor 4 operations and typically consists contaminated protective shoe covers and clothing, wiping rags, 5 mops, filters, reactor water treatment residues, equipment, and tools. 6 GGNS does not permanently store low -level radioactive waste on site. As stated on page 3 -16 7 of the applicant's Environmental Report (ADAMS Accession No. ML11308A234): GGNS 8 transports low level radioactive waste to a licensed processing facility in Tennessee where the 9 wastes are further processed prior to being sent to a facility such as EnergySolutions in Clive, 10 Utah. 11 GGNS stores its spent nuclear fuel in its spent fuel pool and in dry casks. The spent fuel pool is 12 a strong structure, constructed of steel -reinforced concrete walls with a stainless steel liner, and 13 filled with water. The spent fuel pool is located inside the plant's protected area. The NRC 14 regularly inspects GGNS's spent fuel storage program to ensure the safety of the spent fuel 15 stored in the spent fuel pool. 16 GGNS also stores spent nuclear fuel in NRC approved dry cask canisters made of leak-tight 17 welded and bolted steel. These containers are approximately 16 feet high with an approximate 18 exterior diameter of 6 feet. A canister with spent fuel is placed in a concrete cask forming a dry 19 cask storage system. A typical dry cask storage system is detailed at the following website: 20 http://www.nrc.gov/waste/spent -fuel-storage/diagram -typical-dry-cask-system.html. The 21 concrete casks used at GGNS are approximately 20 feet high with an exterior diameter of 22 11 feet and are stored on a concrete pad within a secure area . The NRC regularly inspects 23 GGNS's dry cask storage system to ensure it complies with NRC requirements. The latest NRC 24 inspection report of the GGNS ISFSI is available at ADAMS Accession No. ML12303A002. 25 As reported on page 5 of the GGNS ISFSI Inspection Report 05000416/2012009 (ADAMS 26 Accession No. ML12303A002) dated October 26, 2012:

"The current ISFSI pad can hold 40 27 casks with provisions for four additional spaces to allow for cask unloading, if required. Future 28 plans are to add a second pad that will increase the capacity of the ISFSI to 88 storage 29 locations with 4 spare locations."

Currently, 17 GGNS ISFSI storage locations are occupied. 30 Every other year, GGNS adds five to seven casks to the ISFSI. 31 The existing license expiration date for GGNS is November 1, 2024. The requested renewal 32 would extend the license expiration date to November 1, 2044. The NRC's safety requirements 33 for the storage of spent nuclear fuel during licensed operations ensures that the expected 34 increase in the volume of spent fuel during the license renewal term can be safely stored on site 35 with small environmental effects. 36 Determining the square feet, cubic yards, and bundles of GGNS spent fuel is n ot necessary for 37 the license renewal environmental review decision -making process. 38 High-level radioactive waste is discussed in Section 6.1 of this SEIS. 39 A.1.2 Extended Power Uprate 40 Comment: Mayor Fred Reeves asked "what effect would the current upgrade at Grand Gulf 41 have to do with the process?" (Transcript, p. 39) The only answer he was given was that "The 42 EPU process that [is] currently ongoing is its own independent process. There are aspect[s] of 43 the plant modifications that are going on that could impact our review, but we have processes in 44 place to account for that." (Transcript, pp. 39 -40) Please provide Mayor Reeves and me with 45 an actual answer to his question: What effect will the upgrade have on the processing of the 46 Appendix A A-3 application for license renewal? The NRC's Environmental Review needs to evaluate all 1 aspects of the upgraded plant, after it has been operating at the upgraded capacity, before 2 being able to make a credible report on the environmental impacts of consuming more land and 3 water, having more personnel on -site, storing more spent fuel, transporting low -level waste, etc. 4 Comment from Mayor Reeves: My other question is what effect would the current upgrade at 5 Grand Gulf have to do with the process? Would that have an impact on the process? 6 Response: This comment expresses concern that the NRC's license renewal review should 7 consider the impacts of the GGNS extended power uprate (EPU) license amendment request. 8 The NRC granted the EPU license amendment request for GGNS on July 18, 2012 (ADAMS 9 Accession No. ML 121210020). In accordance with 10 CFR 51.21, the NRC prepared an 10 Environmental Assessment (EA) with a Finding of No Significant Impact (FONSI) for the EPU. 11 The EA w as published in the Federal Register (77 FR 41814) on July 16, 2012, and can be 12 found at ADAMS Accession No. ML12167A257. 13 The license renewal environmental review process for GGNS considers environmental impacts 14 based on the reactor power level requested in the EPU license amendment request. The 15 impacts on land use are discussed in Section 4.1 of this SEIS. The impacts on water are 16 discussed in Sections 4.4 and 4.5. A discussion of the number of employees at the site during 17 the license renewal term is provided in Section 4.10.2 of this SEIS. The impacts of spent fuel , 18 low-level waste, and transportation of radioactive materials are discussed in Section 6.1 of th is 19 SEIS. 20 A.1.3 Extended Power Uprate/Process 21 Comment: I asked about the date of the announcement of what turns out to have been a 22 "license amendment request" (Transcript, p. 61) to increase the capacity of Grand Gulf, which 23 was granted without general public knowledge, and the expansion is now under construction. 24 Please provide the date of that request and the steps in the process between the filing of the 25 request and the commencement of expansion, including any required public notices, meetings 26 or comment periods, and whether those included any news releases in addition to Federal 27 Register publication or legal ads. The NRC's Environmental Review needs to evaluate all 28 aspects of the impacts of the additional capacity on Grand Gulf, the Mississippi River, and all 29 people and properties possibly affected by any catastrophic events at the expanded plant. 30 Response: This comment incorrectly asserts that an extended power uprate (EPU) license 31 amendment request to increase the maximum reactor core power operating limit at GGNS was 32 granted on or before February 27, 2012. This comment was received on February 27, 2012, 33 and at that time a decision to grant or deny the EPU request had not been made. 34 Entergy Operations, Inc., et al., submitted an EPU license amendment request (ADAMS 35 Accession No. ML1002660403) on September 8, 2010, supplemented by 47 letters, dated from 36 November 18, 2010 to June 12, 2012. 37 The NRC published a Notice of Consideration of Issuance of Amendments to Facility Operating 38 Licenses, Proposed No Significant Hazards Consideration Determination, and Opportunity for a 39 Hearing in the Federal Register (76 FR 1464) on January 11, 2011, regarding the GGNS EPU 40 license amendment request with a 60 -day public comment period. The NRC made a proposed 41 determination that the GGNS EPU amendment request involved no significant hazards 42 consideration. Under the NRC regulations in 10 CFR 50.92, this means that operation of the 43 facility in accordance with the proposed amendment would not (1) involve a significant increase 44 in the probability or consequences of an accident previously evaluated; or (2) create the 45 possibility of a new or different kind of accident from any accident previously evaluated; or 46 Appendix A A-4 (3) involve a significant reduction in a margin of safety. No comments were received on this 1 notice. 2 In addition, in accordance with 10 CFR 51.21, the NRC prepared a draft Environmental 3 Assessment (EA) with a preliminary Finding of No Significant Impact (FONSI) for the proposed 4 action. The draft EA was published in the Federal Register (77 FR 27804) with a 30 -day public 5 comment period that ended on June 11, 2012. No comments were received on this draft EA. 6 The final EA was published in the Federal Register (77 FR 41814) on July 16, 2012, and can be 7 found at ADAMS Accession No. ML12167A257. The EPU license amendment request was 8 granted on July 18, 2012, and can be found at ADAMS Accession No. ML121210020 . 9 The license renewal environmental review process for GGNS considers environmental impacts 10 based on the reactor power level requested in the EPU license amendment request. The 11 environmental impacts on GGNS and vicinity are discussed in Chapter 4 and the environmental 12 impacts of postulated accidents are discussed in Chapter 5 of this SEIS . 13 APPENDIX B 1 NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE 2 RENEWAL OF NUCLEAR POWER PLANTS 3

B-1 B. NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE 1 RENEWAL OF NUCLEAR POWER PLANTS 2 The table in this appendix summarizes the National Environmental Policy Act (NEPA) issues 3 that the applicant was required to consider for potential environmental impacts in developing its 4 license renewal application environmental report submitted to the U.S. Nuclear Regulatory 5 Commission (NRC) on November 1, 2011. On June 20, 2013, the NRC published a final rule 6 (78 FR 37282) revising the list of issues requiring consideration. 7 In addition to the issues listed in the table in this appendix, the NRC also considered the new 8 issues contained in the June 20, 2013, final rule. The new Category 1 (generic) issues include 9 geology and soils, exposure of terrestrial organisms to radionuclides, exposure of aquatic 10 organisms to radionuclides, human health impact from chemicals, and physical occupational 11 hazards. Radionuclides released to groundwater, effects on terrestrial resources (non -cooling 12 system impacts), minority and low -income populations (i.e., environmental justice), and 13 cumulative impacts were added as new Category 2 (site-specific) issues. The June 20, 2013, 14 final rule revised list of NEPA issues is found in Table B-1 in Append ix B, Subpart A, to Title 10 15 of the Code of Federal Regulations, Part 51, "Environmental Protection Regulations for 16 Domestic Licensing and Related Regulatory Functions,"

(10 CFR Part 51). Data supporting this 17 revised list are contained in NUREG

-1437, Generic Environmental Impact Statement for 18 License Renewal of Nuclear Plants. 19 Table B-1. Summary of Issues and Findings 20 Issue Type of Issue Findings Surface Water Quality, Hydrology, and Use Impacts of refurbishment on surface water quality Generic SMALL. Impacts are expected to be negligible during refurbishment because best management practices are expected to be employed to control soil erosion and spills. Impacts of refurbishment on surface water use Generic SMALL. Water use during refurbishment will not increase appreciably or will be reduced during plant outage. Altered current patterns at intake and discharge structures Generic SMALL. Altered current patterns have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Altered salinity gradients Generic SMALL. Salinity gradients have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Altered thermal stratification of lakes Generic SMALL. Generally, lake stratification has not been found to be a problem at operating nuclear power plants and is not expected to be a problem during the license renewal term. Temperature effects on sediment transport capacity Generic SMALL. These effects have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term.

Appendix B B-2 Issue Type of Issue Findings Scouring caused by discharged cooling water Generic SMALL. Scouring has not been found to be a problem at most operating nuclear power plants and has caused only localized effects at a few plants. It is not expected to be a problem during the license renewal term. Eutrophication Generic SMALL. Eutrophication has not been found to be a problem at operating nuclear power plants and is not expected to be a problem during the license renewal term. Discharge of chlorine or other biocides Generic SMALL. Effects are not a concern among regulatory and resource agencies, and are not expected to be a problem during the license renewal term. Discharge of sanitary wastes and minor chemical spills Generic SMALL. Effects are readily controlled through a National Pollutant Discharge Elimination System (NPDES) permit and periodic modifications, if needed, and are not expected to be a problem during the license renewal term. Discharge of other metals in wastewater Generic SMALL. These discharges have not been found to be a problem at operating nuclear power plants with cooling-tower-based heat dissipation systems and have been satisfactorily mitigated at other plants. They are not expected to be a problem during the license renewal term. Water use conflicts (plants with once -through cooling systems) Generic SMALL. These conflicts have not been found to be a problem at operating nuclear power plants with once-through heat dissipation systems. Water use conflicts (plants with cooling ponds or cooling towers using makeup water from a small river with low flow) Site-Specific SMALL OR MODERATE. The issue has been a concern at nuclear power plants with cooling ponds and at plants with cooling towers. Impacts on in -stream and riparian communities near these plants could be of moderate significance in some situations. See 10 CFR 51.53(c)(3)(ii)(A). Aquatic Ecology (all plants) Refurbishment Generic SMALL. During plant shutdown and refurbishment there will be negligible effects on aquatic biota because of a reduction of entrainment and impingement of organisms or a reduced release of chemicals. Accumulation of contaminants in sediments or biota Generic SMALL. Accumulation of contaminants has been a concern at a few nuclear power plants but has bee n satisfactorily mitigated by replacing copper alloy condenser tubes with those of another metal. It is not expected to be a problem during the license renewal term. Entrainment of phytoplankton and zooplankton Generic SMALL. Entrainment of phytoplankton and zooplankton has not been found to be a problem at operating nuclear power plants and is not expected to be a problem during the license renewal term.

Appendix B B-3 Issue Type of Issue Findings Cold shock Generic SMALL. Cold shock has been satisfactorily mitigated at operating nuclear plants with once -through cooling systems, has not endangered fish populations, or been found to be a problem at operating nuclear power plants with cooling towers or cooling ponds, and is not expected to be a problem during the license renewal term. Thermal plume barrier to migrating fish Generic SMALL. Thermal plumes have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Distribution of aquatic organisms Generic SMALL. Thermal discharge may have localized effects but is not expected to affect the larger geographical distribution of aquatic organisms. Premature emergence of aquatic insects Generic SMALL. Premature emergence has been found to be a localized effect at some operating nuclear power plants but has not been a problem and is not expected to be a problem during the license renewal term. Gas supersaturation (gas bubble disease) Generic SMALL. Gas supersaturation was a concern at a small number of operating nuclear power plants with once-through cooling systems but has been satisfactorily mitigated. It has not been found to be a problem at operating nuclear power plants with cooling towers or cooling ponds and is not expected to be a problem during the license renewal term. Low dissolved oxygen in the discharge Generic SMALL. Low dissolved oxygen has been a concern at one nuclear power plant with a once -through cooling system but has been effectively mitigated. It has not been found to be a problem at operating nuclear power plants with cooling towers or cooling ponds and is not expected to be a problem during the license renewal term. Losses from predation, parasitism, and disease among organisms exposed to sublethal stresses Generic SMALL. These types of losses have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Stimulation of nuisance organisms (e.g., shipworms) Generic SMALL. Stimulation of nuisance organisms has been satisfactorily mitigated at the single nuclear power plant with a once -through cooling system where previously it was a problem. It has not been found to be a problem at operating nuclear power plants with cooling towers or cooling ponds and is not expected to be a problem during the license renewal term.

Appendix B B-4 Issue Type of Issue Findings Aquatic Ecology (for plants with once -through and cooling pond heat dissipation systems) Entrainment of fish and shellfish in early life stages Site-Specific SMALL, MODERATE, OR LARGE. The impacts of entrainment are small at many plants but may be moderate or even large at a few plants with once -through and cooling -pond cooling systems. Further, ongoing efforts in the vicinity of these plants to restore fish populations may increase the numbers of fish susceptible to intake effects during the license renewal period, such that entrainment studies conducted in support of the original license may no longer be valid. See 10 CFR 51.53(c)(3)(ii)(B). Impingement of fish and shellfish Site-Specific SMALL, MODERATE, OR LARGE. The impacts of impingement are small at many plants but may be moderate or even large at a few plants with once -through and cooling -pond cooling systems. See 10 CFR 51.53(c)(3)(ii)(B). Heat shock Site-Specific SMALL, MODERATE, OR LARGE. Because of continuing concerns about heat shock and the possible need to modify thermal discharges in response to changing environmental conditions, the impacts may be of moderate or large significance at some plants. See

10 CFR 51.53(c)(3)(ii)(B). Aquatic Ecology (for plants with cooling-tower-based heat dissipation systems) Entrainment of fish and shellfish in early life stages Generic SMALL. Entrainment of fish has not been found to be a problem at operating nuclear power plants with this type of cooling system and is not expected to be a problem during the license renewal term. Impingement of fish and shellfish Generic SMALL. The impacts of impingement have not been found to be a problem at operating nuclear power plants with this type of cooling system and are not expected to be a problem during the license renewal term. Heat shock Generic SMALL. Heat shock has not been found to be a problem at operating nuclear power plants with this type of cooling system and is not expected to be a problem during the license renewal term. Impacts of refurbishment on groundwater use and quality Generic SMALL. Extensive dewatering during the original construction on some sites will not be repeated during refurbishment on any sites. Any plant wastes produced during refurbishment will be handled in the same manner as in current operating practices and are not expected to be a problem during the license renewal term.

Appendix B B-5 Issue Type of Issue Findings Groundwater use conflicts (potable and service water; plants that use <100 gallons per minute [gpm]) Generic SMALL. Plants using less than 100 gpm are not expected to cause any groundwater use conflicts. Groundwater use conflicts (potable and service water, and dewatering plants that use >100 gpm) Site-Specific SMALL, MODERATE, OR LARGE. Plants that use more than 100 gpm may cause groundwater use conflicts with nearby groundwater users. See 10 CFR 51.53(c)(3)(ii)(C). Groundwater use conflicts (plants using cooling towers withdrawing makeup water from a small river) Site-Specific SMALL, MODERATE, OR LARGE. Water use conflicts may result from surface water withdrawals from small water bodies during low flow conditions which may affect aquifer recharge, especially if other groundwater or upstream surface water users come on line before the time of license renewal. See 10 CFR 51.53(c)(3)(ii)(A). Groundwater use conflicts (Ranney wells) Site-Specific SMALL, MODERATE, OR LARGE. Ranney wells can result in potential groundwater depression beyond the site boundary. Impacts of large groundwater withdrawal for cooling tower makeup at nuclear power plants using Ranney wells must be evaluated at the time of application for license renewal. See 10 CFR 51.53(c)(3)(ii)(C). Groundwater quality degradation (Ranney wells) Generic SMALL. Groundwater quality at river sites may be degraded by induced infiltration of poor -quality river water into an aquifer that supplies large quantities of reactor cooling water. However, the lower quality infiltrating water would not preclude the current uses of groundwater and is not expected to be a problem during the license renewal term. Groundwater quality degradation (saltwater intrusion) Generic SMALL. Nuclear power plants do not contribute significantly to saltwater intrusion. Groundwater quality degradation (cooling ponds in salt marshes) Generic SMALL. Sites with closed -cycle cooling ponds may degrade groundwater quality. Because water in salt marshes is brackish, this is not a concern for plants located in salt marshes. Groundwater quality degradation (cooling ponds at inland sites) Site-Specific SMALL, MODERATE, OR LARGE. Sites with closed-cycle cooling ponds may degrade groundwater quality. For plants located inland, the quality of the groundwater in the vicinity of the ponds must be shown to be adequate to allow continuation of current uses. See 10CFR 51.53(c)(3)(ii)(D).

Appendix B B-6 Issue Type of Issue Findings Terrestrial Ecology Refurbishment impacts Site-Specific SMALL, MODERATE, OR LARGE. Refurbishment impacts are insignificant if no loss of important plant and animal habitat occurs. However, it cannot be known whether important plant and animal communities may be affected until the specific proposal is presented with the license renewal application. See 10 CFR 51.53(c)(3)(ii)(E). Cooling tower impacts on crops and ornamental vegetation Generic SMALL. Impacts from salt drift, icing, fogging, or increased humidity associated with cooling tower operation have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Cooling tower impacts on native plants Generic SMALL. Impacts from salt drift, icing, fogging, or increased humidity associated with cooling tower operation have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Bird collisions with cooling towers Generic SMALL. These collisions have not been found to be a problem at operating nuclear power plants and are not expected to be a problem during the license renewal term. Cooling pond impacts on terrestrial resources Generic SMALL. Impacts of cooling ponds on terrestrial ecological resources are considered to be of small significance at all sites. Power line right -of-way management (cutting and herbicide application) Generic SMALL. The impacts of right -of-way maintenance on wildlife are expected to be of small significance at all sites. Bird collisions with power lines Generic SMALL. Impacts are expected to be of small significance at all sites. Impacts of electromagnetic fields on flora and fauna Generic SMALL. No significant impacts of electromagnetic fields on terrestrial flora and fauna have been identified. Such effects are not expected to be a problem during the license renewal term. Floodplains and wetland on power line right-of-way Generic SMALL. Periodic vegetation control is necessary in forested wetlands underneath power lines and can be achieved with minimal damage to the wetland. No significant impact is expected at any nuclear power plant during the license renewal term.

Appendix B B-7 Issue Type of Issue Findings Threatened or Endangered Species Threatened or endangered species Site-Specific SMALL, MODERATE, OR LARGE. Generally, plant refurbishment and continued operation are not expected to adversely affect threatened or endangered species. However, consultation with appropriate agencies would be needed at the time of license renewal to determine whether threatened or endangered species are present and whether they would be adversely affected. See 10 CFR 51.53(c)(3)(ii)(E). Air Quality Air quality during refurbishment (nonattainment and maintenance areas) Site-Specific SMALL, MODERATE, OR LARGE. Air quality impacts from plant refurbishment associated with license renewal are expected to be small. However, vehicle exhaust emissions could be cause for concern at locations in or near nonattainment or maintenance areas. The significance of the potential impact cannot be determined without considering the compliance status of each site and the numbers of workers expected to be employed during the outage. See 10CFR 51.53(c)(3)(ii)(F). Air quality effects of transmission lines Generic SMALL. Production of ozone and oxides of nitrogen is insignificant and does not contribute measurably to ambient levels of these gases. Land Use Onsite land use Generic SMALL. Projected onsite land use changes required during refurbishment and the renewal period would be a small fraction of any nuclear power plant site and would involve land that is controlled by the applicant. Power line right -of-way Generic SMALL. Ongoing use of power line rights -of-way would continue with no change in restrictions. The effects of these restrictions are of small significance. Human Health Radiation exposures to the public during refurbishment Generic SMALL. During refurbishment, the gaseous effluents would result in doses that are similar to those from current operation. Applicable regulatory dose limits to the public are not expected to be exceeded. Occupational radiation exposures during refurbishment Generic SMALL. Occupational doses from refurbishment are expected to be within the range of annual average collective doses experienced for pressurized -water reactors and boiling -water reactors. Occupational mortality risk from all causes, including radiation, is in the mid-range for industrial settings.

Appendix B B-8 Issue Type of Issue Findings Microbiological organisms (occupational health) Generic SMALL. Occupational health impacts are expected to be controlled by the continued application of accepted industrial hygiene practices to minimize worker exposures. Microbiological organisms (public health)(plants using lakes or canals, or cooling towers or cooling ponds that discharge to a small river) Site-Specific SMALL, MODERATE, OR LARGE. These organisms are not expected to be a problem at most operating plants, except possibly at plants using cooling ponds, lakes, or canals that discharge to small rivers. Without site -specific data, it is not possible to predict the effects generically. See 10 CFR 51.53(c)(3)(ii)(G). Noise Generic SMALL. Noise has not been found to be a problem at operating plants and is not expected to be a problem at any plant during the license renewal term. Electromagnetic fields -acute effects (electric shock) Site-Specific SMALL, MODERATE, OR LARGE. Electric shock resulting from direct access to energized conductors or from induced charges in metallic structures has not been found to be a problem at most operating plants and generally is not expected to be a problem during the license renewal term. However, site -specific review is required to determine the significance of the electric shock potential at the site. See 10 CFR 51.53(c)(3)(ii)(H). Electromagnetic fields -chronic effects Uncategorized UNCERTAIN. Biological and physical studies of 60 -Hz electromagnetic fields have not found consistent evidence linking harmful effects with field exposures. However, research is continuing in this area and a consensus scientific view has not been reached. Radiation exposures to public (license renewal term) Generic SMALL. Radiation doses to the public will continue at current levels associated with normal operations. Occupational radiation exposures (license renewal term) Generic SMALL. Projected maximum occupational doses during the license renewal term are within the range of doses experienced during normal operations and normal maintenance outages, and would be well below regulatory limits. Socioeconomic Impacts Housing impacts Site-Specific SMALL, MODERATE, OR LARGE. Housing impacts are expected to be of small significance at plants located in a medium- or high-population area and not in an area where growth control measures, that limit housing development, are in effect. Moderate or large housing impacts of the workforce, associated with refurbishment, may be associated with plants located in sparsely populated areas or in areas with growth control measures that limit housing development. See 10 CFR 51.53(c)(3)(ii)(I).

Appendix B B-9 Issue Type of Issue Findings Public services: public safety, social services, and tourism and recreation Generic SMALL. Impacts to public safety, social services, and tourism and recreation are expected to be of small significance at all sites. Public services: public utilities Site-Specific SMALL OR MODERATE. An increased problem with water shortages at some sites may lead to impacts of moderate significance on public water supply availability. See 10 CFR 51.53(c)(3)(ii)(I). Public services: education (refurbishment) Site-Specific SMALL, MODERATE, OR LARGE. Most sites would experience impacts of small significance but larger impacts are possible depending on site- and project -specific factors. See 10 CFR 51.53(c)(3)(ii)(I). Public services: education (license renewal term) Generic SMALL. Only impacts of small significance are expected Offsite land use (refurbishment) Site-Specific SMALL OR MODERATE. Impacts may be of moderate significance at plants in low population areas. See 10 CFR 51.53(c)(3)(ii)(I). Offsite land use (license renewal term) Site-Specific SMALL, MODERATE, OR LARGE. Significant changes in land use may be associated with population and tax revenue changes resulting from license renewal. See 10 CFR 51.53(c)(3)(ii)(I). Public services: transportation Site-Specific SMALL, MODERATE, OR LARGE. Transportation impacts (level of service) of highway traffic generated during plant refurbishment and during the term of the renewed license are generally expected to be of small significance. However, the increase in traffic associated with the additional workers and the local road and traffic control conditions may lead to impacts of moderate or large significance at some sites. See 10 CFR 51.53(c)(3)(ii)(J). Historic and archaeological resources Site-Specific SMALL, MODERATE, OR LARGE. Generally, plant refurbishment and continued operation are expected to have no more than small adverse impacts on historic and archaeological resources. However, the National Historic Preservation Act requires the Federal agency to consult with the State Historic Preservation Officer to determine whether there are properties present that require protection. See 10 CFR 51.53(c)(3)(ii)(K). Aesthetic impacts (refurbishment) Generic SMALL. No significant impacts are expected during refurbishment. Aesthetic impacts (license renewal term) Generic SMALL. No significant impacts are expected during the license renewal term.

Appendix B B-10 Issue Type of Issue Findings Aesthetic impacts of transmission lines (license renewal term) Generic SMALL. No significant impacts are expected during the license renewal term. Postulated Accidents Design-basis accidents Generic SMALL. The NRC staff has concluded that the environmental impacts of design -basis accidents are of small significance for all plants. Severe accidents Site-Specific SMALL. The probability weighted consequences of atmospheric releases, fallout onto open bodies of water, releases to groundwater, and societal and economic impacts from severe accidents are small for all plants. However, alternatives to mitigate severe accidents must be considered for all plants that have not considered such alternatives. See 10 CFR 51.53(c)(3)(ii)(L). Uranium Fuel Cycle and Waste Management (impacts discussed further in Chapter 6 of this SEIS) Offsite radiological impacts (individual effects from other than the disposal of spent fuel and high-level waste) Generic SMALL. Offsite impacts of the uranium fuel cycle have been considered by the Commission in Table S -3 of this part. Based on information in the GEIS, impacts on individuals from radioactive gaseous and liquid releases, including radon -222 and technetium -99, are small. Appendix B B-11 Issue Type of Issue Findings Offsite radiological impacts (collective effects) Generic The 100-year environmental dose commitment to the U.S. population from the fuel cycle, high -level waste, and spent fuel disposal is calculated to be about 14,800 person-rem, or 12 cancer fatalities, for each additional 20 -year power reactor operating term. Much of this, especially the contribution of radon releases from mines and tailing piles, consists of tiny doses summe d over large populations. This same dose calculation can theoretically be extended to include many tiny doses over additional thousands of years, as well as doses outside the United States. The result of such a calculation would be thousands of cancer fatalities from the fuel cycle, but this result assumes that even tiny doses have some statistical adverse health effects which will not ever be mitigated (for example, no cancer cure in the next thousand years), and that these doses projected over thousands of years are meaningful. However, these assumptions are questionable. In particular, science cannot rule out the possibility that there will be no cancer fatalities from these tiny doses. For perspective, the doses are very small fractions of regulatory limits, and even smaller fractions of natural background exposure to the same populations. Nevertheless, despite all the uncertainty, some judgment as to the regulatory NEPA implications of these matters should be made and it makes no sense to repeat the same judgment in every case. Even taking the uncertainties into account, the Commission concludes that these impacts are acceptable in that these impacts would not be sufficiently large to require the NEPA conclusion, for any plant, that the option of extended operation under 10 CFR Part 54 should be eliminated. Accordingly, while the Commission has not assigned a single level of significance for the collective effects of the fuel cycle, this issue is considered Category 1 (Generic).

Appendix B B-12 Issue Type of Issue Findings Offsite radiological impacts (spent fuel and high-level waste disposal) Generic For the high -level waste and spent fuel disposal component of the fuel cycle, there are no current regulatory limits for offsite releases of radionuclides for the current candidate repository site. However, if it is assumed that limits are developed along the lines of the 1995 National Academy of Sciences (NAS) report, "Technical Bases for Yucca Mountain Standards," and that in accordance with the Commission's Waste Confidence Decision, 10 CFR 51.23, a repository can and likely will be developed at some site which will comply with such limits, peak doses to virtually all individuals will be 100 milliroentgen equivalent man (millirem) per year or less. However, while the Commission has reasonable confidence that these assumptions will prove correct, there is considerable uncertainty since the limits are yet to be developed, no repository application has been completed or reviewed, and uncertainty is inherent in the models used to evaluate possible pathways to the human environment. The NAS report indicated that 100 millirem per year should be considered as a starting point for limits for individual doses, but notes that some measure of consensus exists among national and international bodies that the limits should be a fraction of the 100 millirem per year. The lifetime individual risk from 100 millirem annual dose limit is about 3 x 10-3. Estimating cumulative doses to populations over thousands of years is more problematic. The likelihood and consequences of events that could seriously compromise the integrity of a deep geologic repository were evaluated by the U.S. Department of Energy in the "Final Environmental Impact Statement: Management of Commercially Generated Radioactive Waste," October 1980. The evaluation estimated the 70 -year whole-body dose commitment to the maximum individual and to the regional population resulting from several modes of breaching a reference repository in the year of closure, after 1,000 years, after 100,000 years, and after 100,000,000 years. Subsequently, the NRC and other Federal agencies have expended considerable effort to develop models for the design and for the licensing of a high-level waste repository, especially for the candidate repository at Yucca Mountain. More meaningful estimates of doses to the population may be possible in the future as more is understood about the performance of the proposed Yucca Mountain repository. Such estimates would involve great uncertainty, especially with respect to cumulative population doses over thousands of years. The standard proposed by the NAS is a limit on maximum individual dose. The relationship of potential new regulatory requirements, based on the NAS report, and

Appendix B B-13 Issue Type of Issue Findings Offsite radiological impacts (spent fuel and high-level waste disposal) [continued from previous page] Generic cumulative population impacts has not been determined, although the report articulates the view that protection of individuals will adequately protect the population for a repository at Yucca Mountain. However, the U.S. Environmental Protection Agency's (EPA) generic repository standards in 40 CFR Part 191 generally provide an indication of the order of magnitude of cumulative risk to the population that could result from the licensing of a Yucca Mountain repository, assuming the ultimate standards will be within the range of standards now under consideration. The standards in 40 CFR Part 191 protect the population by imposing the amount of radioactive material released over 10,000 years. The cumulative release limits are based on the EPA's population impact goal of 1,000 premature cancer deaths worldwide for a 100,000-metric ton (MTHM)repository. Nevertheless, despite all the uncertainty, some judgment as to the regulatory NEPA implications of these matters should be made and it makes no sense to repeat the same judgment in every case. Even taking the uncertainties into account, the Commission concludes that these impacts are acceptable in that these impacts would not be sufficiently large to require the NEPA conclusion, for any plant, that the option of extended operation under 10 CFR Part 54 should be eliminated. Accordingly, while the Commission has not assigned a single level of significance for the impacts of spent fuel and high-level waste disposal, this issue is considered in Category 1 (Generic). Nonradiological impacts of the uranium fuel cycle Generic SMALL. The nonradiological impacts of the uranium fuel cycle resulting from the renewal of an operating license for any plant are found to be small. Low-level waste storage and disposal Generic SMALL. The comprehensive regulatory controls that are in place and the low public doses being achieved at reactors ensure that the radiological impacts to the environment will remain small during the term of a renewed license. The maximum additional onsite land that may be required for low -level waste storage during the term of a renewed license and associated impacts will be small. Nonradiological impacts on air and water will be negligible. The radiological and nonradiologica l environmental impacts of long -term disposal of low-level waste from any individual plant at licensed sites are small. In addition, the Commission concludes that there is reasonable assurance that sufficient low -level waste disposal capacity will be made available when needed for facilities to be decommissioned consistent with NRC decommissioning requirements.

Appendix B B-14 Issue Type of Issue Findings Mixed waste storage and disposal Generic SMALL. The comprehensive regulatory controls and the facilities and procedures that are in place ensure proper handling and storage, as well as negligible doses and exposure to toxic materials for the public and the environment at all plants. License renewal will not increase the small, continuing risk to human health and the environment posed by mixed waste at all plants. The radiological and nonradiological environmental impacts of long-term disposal of mixed waste from any individual plant at licensed sites are small. In addition, the Commission concludes that there is reasonable assurance that sufficient mixed waste disposal capacity will be made available when needed for facilities to be decommissioned consistent with NRC decommissioning requirements. Onsite spent fuel Generic SMALL. The expected increase in the volume of spent fuel from an additional 20 years of operation can be safely accommodated on site with small environmental effects through dry or pool storage at all plants if a permanent repository or monitored retrievable storage is not available. Nonradiological waste Generic SMALL. No changes to generating systems are anticipated for license renewal. Facilities and procedures are in place to ensure continued proper handling and disposal at all plants. Transportation Generic SMALL. The impacts of transporting spent fuel enriched up to 5 percent uranium -235 with average burnup for the peak rod to current levels approved by the NRC up to 62,000 megawatt days per metric ton uranium (MWd/MTU) and the cumulative impacts of transporting high-level waste to a single repository, such as Yucca Mountain, Nevada are found to be consistent with the impact values contained in 10 CFR 51.52(c), Summary Table S-4, "Environmental Impact of Transportation of Fuel and Waste to and from One Light -Water-Cooled Nuclear Power Reactor." If fuel enrichment or burnup conditions are not met, the applicant must submit an assessment of the implications for the environmental impact values reported in 10 CFR 51.52. Appendix B B-15 Issue Type of Issue Findings Decommissioning Radiation doses Generic SMALL. Doses to the public will be well below applicable regulatory standards regardless of which decommissioning method is used. Occupational doses would increase no more than 1 man-rem caused by the buildup of long -lived radionuclides during the license renewal term. Waste management Generic SMALL. Decommissioning at the end of a 20 -year license renewal period would generate no more solid wastes than at the end of the current license term. No increase in the quantities of Class C or greater than Class C wastes would be expected. Air quality Generic SMALL. Air quality impacts of decommissioning are expected to be negligible either at the end of the current operating term or at the end of the license renewal term. Water quality Generic SMALL. The potential for significant water quality impacts from erosion or spills is no greater whether decommissioning occurs after a 20 -year license renewal period or after the original 40 -year operation period, and measures are readily available to avoid such impacts. Ecological resources Generic SMALL. Decommissioning after either the initial operating period or after a 20 -year license renewal period is not expected to have any direct ecological impacts. Socioeconomic impacts Generic SMALL. Decommissioning would have some short -term socioeconomic impacts. The impacts would not be increased by delaying decommissioning until the end of a 20-year license renewal period, but they might be decreased by population and economic growth. Environmental Justice Environmental justice Uncategorized NONE. The need for and the content of an analysis of environmental justice will be addressed in plant -specific reviews. Table source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51

APPENDIX C 1 APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS 2

C-1 C. APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS 1 The Atomic Energy Act of 1954, as amended (42 USC § 2011 et seq.), authorizes the 2 U.S. Nuclear Regulatory Commission (NRC) to enter into agreement with any State to assume 3 regulatory authority for certain activities (see 42 USC § 2012 et seq.). For example, through the 4 Agreement State Program, Mississippi assumed regulatory responsibility over certain 5 byproduct, source, and quantities of special nuclear materials not sufficient to form a critical 6 mass. The Division of Radiological Health, Mississippi Department of Health, administers the 7 Mississippi State Agreement Program. 8 In addition to carrying out some Federal programs, State legislatures develop their own laws. 9 State statutes supplement, as well as implement, Federal laws for protection of air, water 10 quality, and groundwater. State legislation may address solid waste management programs, 11 locally rare and endangered species, and historic and cultural resource

s. 12 The Clean Water Act (33 USC

§ 1251 et seq., herein referred to as CWA) allows for primary 13 enforcement and administration through State agencies, given that the State program is at least 14 as stringent as the Federal program. The State program must conform to the CWA and to the 15 delegation of authority for the Federal National Pollutant Discharge Elimination System 16 (NPDES) program from the U.S. Environmental Protection Agency (EPA) to the State. The 17 primary mechanism to control water pollution is the requirement for direct dischargers to obtain 18 an NPDES permit, or in the case of States where the authority has been delegated from the 19 EPA, a State Pollutant Discharge Elimination System permit, under the CWA. In Mississippi, 20 the Mississippi Department of Environmental Quality issues and enforces NPDES permits. 21 One important difference between Federal regulations and certain State regulations is the 22 definition of waters that the State regulates. Certain State regulations may include underground 23 waters, whereas the CWA only regulates surface waters. The Mississippi Department of 24 Environmental Quality is charged with conserving, managing and protecting the surface water 25 and groundwater resources of Mississippi (MDEQ 2013). 26 C.1 Federal and State Environmental Requirements 27 Grand Gulf Nuclear Station (GGNS) is subject to Federal and State requirements for its 28 environmental program. 29 Table C-1 lists the principle Federal and State environmental regulations and laws associated 30 with the environmental review of the GGNS license renewal application. 31 Table C-1. Federal and State Environmental Requirements 32 Law/regulation Requirements Current operating license and license renewal Atomic Energy Act (42 U.S.C. § 2011 et seq.) This Act is the fundamental U.S. law on both the civilian and the military uses of nuclear materials. On the civilian side, it provides for both the development and the regulation of the uses of nuclear materials and facilities in the United States. The Act requires that civilian uses of nuclear materials and facilities be licensed, and it empowers the NRC to establish by rule or order, and to enforce, such standards to govern these uses as "the Commission may deem necessary or desirable in order to protect health and safety and minimize danger to life or property."

Appendix C C-2 Law/regulation Requirements 10 CFR Part 51. Title 10 Code of Federal Regulations (10 CFR) Part 51 , Energy "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions." This part contains environmental protection regulations applicable to the NRC's domestic licensing and related regulatory functions. 10 CFR Part 54 "Requirements for Renewal of Operating Licenses for Nuclear Power Plants." This part focuses on managing adverse effects of aging rather than noting all aging mechanisms. The rule is intended to ensure that important systems, structures, and components will maintain their intended function during the period of extended operation. 10 CFR Part 50 "Domestic Licensing of Production and Utilization Facilities. " Regulations that the NRC issues under the Atomic Energy Act of 1954, as amended (68 Stat. 919), and Title II of the Energy Reorganization Act of 1974 (88 Stat. 1242), provide for the licensing of production and utilization facilities. This part also gives notice to all persons who knowingly supply-to any licensee, applicant, contractor, or subcontractor -components, equipment, materials, or other goods or services that relate to a licensee 's or applicant 's activities subject to this part, that they may be individually subject to NRC enforcement action for violation of § 50.5. Air quality protection Clean Air Act (CAA) (42 USC § 7401 et seq.) The Clean Air Act (CAA) is a comprehensive Federal law that regulates air emissions. Among other things, this law authorizes EPA to establish National Ambient Air Quality Standards (NAAQS) to protect public health and public welfare and to regulate emissions of hazardous air pollutants. EPA has promulgated NAAQS for six criteria pollutants: sulfur dioxide, nitrogen dioxide, carbon monoxide (CO), ozone, lead, and particulate matter. All areas of the United States must maintain ambient levels of these pollutants below the ceilings established by the NAAQS. Mississippi Air and Water Pollution Control Act (Mississippi Code

§§ 49-17-1 to 49-17-43) The Mississippi Air and Water Pollution Control Act authorizes the setting of ambient air quality standards as necessary to protect the public health and welfare and emission standards for the purpose of controlling air contamination, air pollution, and the sources of air pollution.

Land use resources protection Coastal Zone Management Act (16 USC § 1451 et seq.) The Coastal Zone Management Act (CZMA) was established to preserve, protect, develop and where possible, restore or enhance, the resources of the Nation's coastal zone. Water resources protection Clean Water Act (CWA) (33 USC § 1251 et seq.) and the NPDES (40 CFR 122) The Clean Water Act (C WA) establishes the basic structure for regulating discharges of pollutants into the waters of the United States and regulating quality standards for surface waters. Wild and Scenic River Act (16 USC § 1271 et seq.) The Wild and Scenic River Act created the National Wild and Scenic Rivers System, which was established to protect the environmental values of free flowing streams from degradation by affecting activities, including water resources projects. Safe Drinking Water Act (42 USC § 300f et seq.) The Safe Drinking Water Act (SDWA) is the principal Federal law that ensures safe drinking water for the public. Under the SDWA, EPA is required to set standards for drinking water quality and oversees all states, localities, and water suppliers that implement these standards. Mississippi Department of Environmental Quality Regulation WPC-1 Wastewater Regulations for National Pollutant Discharge Elimination System (NPDES) Permits, Underground Injection Control (UIC) Permits, State Permits, Water Quality Based Effluent Limitations and Water Quality Certification

Appendix C C-3 Law/regulation Requirements Waste management and pollution prevention Resource Conservation and Recovery Act (RCRA) (42 USC § 6901 et seq.) RCRA gives EPA authority to control hazardous waste. Before a material can be classified as a hazardous waste, it first must be a solid waste as defined under the Resource Conservation and Recovery Act (RCRA). Hazardous waste is classified under Subtitle C of the RCRA. Parts 261 , "Identification and Listing of Hazardous Waste," and 262, "Standards Applicable to Generators of Hazardous Waste," of 40 CFR contain all applicable generators of hazardous waste regulations. Pollution Prevention Act (42 USC § 13101 et seq.) The Pollution Prevention Act formally established a national policy to prevent or reduce pollution at its source whenever feasible. The Act supplies funds for state and local pollution prevention programs through a grant program to promote the use of pollution prevention techniques by business. Protected species Endangered Species Act (ESA) (16 USC § 1531 et seq.) The Endangered Species Act (ESA) forbids any government agency, corporation, or citizen from taking (e.g., harming or killing) endangered animals without an Endangered Species Permit. The ESA also requires Federal agencies to consult with the U.S. Fish and Wildlife Service or National Marine Fisheries Service if any Federal action may adversely affect any listed species or designated critical habitat. Magnuson-Stevens Fishery Conservation and Management Act (MSA)

(P.L. 94-265), as amended through January 12, 2007 The Magnuson-Stevens Fishery Conservation and Management Act (MSA) includes requirements for Federal agencies to consider the impact of Federal actions on essential fish habitat and to consult with the National Marine Fisheries Service if any activities may adversely affect essential fish habitat.

Marine Mammal Protection Act (MMPA) (16 USC § 1361 et seq.) The Marine Mammal Protection Act (MMPA) prohibits the take of marine mammals in U.S. waters or by U.S. citizens on the high seas without an MMPA Take Permit issued by the National Marine Fisheries Service . MMPA also prohibits importation of marine mammals and marine mammal products into the United States. Fish and Wildlife Coordination Act (16 USC § 661 et seq.) To minimize adverse impacts of proposed actions on fish and wildlife resources and habitat, the Fish and Wildlife Coordination Act requires that Federal agencies consult Government agencies regarding activities that affect, control, or modify waters of any stream or bodies of water. It also requires that justifiable means and measures be used in modifying plans to protect fish and wildlife in these waters. Historic preservation National Historic Preservation Act (NHPA) (16 USC § 470 et seq.) The National Historic Preservation Act (NHPA) directs Federal agencies to consider the impact of their actions on historic properties. To comply with NHPA, Federal agencies must consult with State Historic Preservation Officers and, when applicable, tribal historic preservations officers. NHPA also encourages state and local preservation societies. C.2 Operating Permits and Other Requirements 1 Table C-2 lists the permits and licenses issued by Federal, State, and local authorities for 2 activities at GGNS. 3 Appendix C C-4 Table C-2. Licenses and Permits 1 Permit Number Dates Responsible Agency Operating license NPF-2 9 Issued: 11/1/198 4 Expires: 1 1/1/2024 NRC 401 Water Quality Certification None Issued: 2/5/19 74 Expires: None Mississippi Air and Water Pollution Control Commission NPDES Permit MS0029521 Expires: 0 8/31/201 6 Mississippi Department of Environmental Quality (M DE Q) Baseline Stormwater General NPDES Permit MSR000883 Expires: 09/28/15 M DE Q Large Construction General Permit - Discharge of stormwater to waters of the State MSR10-5946 Expires: 12/31/15 M DE Q Air Permit - Operation of air emission sources (emergency diesel generators, diesel engines and pumps, diesel fueled outage equipment, and cooling towers) 0420-00023 Expires: 05/31/09 Timely renewal application was submitted; therefore, permit has been administratively continued. M DEQ Hazardous waste generator identification MSD000644617 Expires: N/A M DE Q Groundwater withdrawal MS-GW-02972 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-02971 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-02970 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-02969 Expires: 09/25/2016 M DE Q Groundwater withdrawal MS-GW-00371 Expires: 09/25/20 1 6 M DE Q Groundwater withdrawal MS-GW-16714 Expires: 03/10/20 20 MDEQ Groundwater withdrawal MS-GW-02967 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-14989 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-15026 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-02979 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-02978 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-02977 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-02976 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-02975 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-02974 Expires: 09/25/2016 MDEQ Groundwater withdrawal MS-GW-02973 Expires: 09/25/2016 MDEQ Underground diesel fuel storage 5913 Expires: 06/30/2014 M DE Q Transportation of radioactive waste through Mississippi 4600 Expires: 06/30/2014 Mississippi Emergency Management Agency Radioactive and hazardous materials shipments 061013550003V Expires: 06/30/2014 U.S. Department of Transportation Taking of migratory birds MB798276-0 Expires: 03/31/2014 U.S. Fish & Wildlife Service Shipment of radioactive material into Tennessee to a disposal/processing facility T-MS002-L13 Expires: 12/31/2013 Tennessee Department of Environmental Conservation Source: Entergy 2011 Appendix C C-5 C.3 References 1 [Entergy] Entergy Operations, Inc. 2011. Grand Gulf Nuclear Station, Unit 1, License Renewal 2 Application. Appendix E, Applicant's Environmental Report. October 2011. ADAMS Accession 3 No. ML11308A234 4 [MDEQ] Mississippi Department of Environmental Quality. 201

3. Home - The Office of Land 5 and Water Resources. Available at http://www.deq.state.ms.us/mdeq.nsf/page/l%26w_home 6 (accessed 8 January 201 3). 7

APPENDIX D 1 CONSULTATION CORRESPONDENCE 2

D-1 D. CONSULTATION CORRESPONDENCE 1 D.1 Background 2 The Endangered Species Act of 1973, as amended; the Magnuson Stevens Fisheries 3 Management Act of 1996, as amended; and the National Historic Preservation Act of 1966 4 (NHPA) require that Federal agencies consult with applicable State and Federal agencies and 5 groups before taking action that may affect threatened or endangered species, essential fish 6 habitat, or historic and archaeological resources, respectively. Table D-1 contains a list of 7 correspondence between the U. S. Nuclear Regulatory Commission (NRC) and other agencies 8 pursuant to compliance with these Federal acts. 9 Table D-1. Consultation Correspondence 10 Author Recipient Date of Letter/Email NRC (D. Wrona) Advisory Council on Historic Preservation (R. Nelson) January 19, 2012 (ML11348A088 ) NRC (D. Wrona) Tribal Nation - Mississippi Band of Choctaw Indians (P. Anderson) January 19, 2012 (ML11342A121) NRC (D. Wrona) Tribal Nation - Jena Band of Choctaw Indians (B. Smith) January 19, 2012 (ML11342A121) NRC (D. Wrona) Tribal Nation - Choctaw Nation of Oklahoma (G. Pyle) January 19, 2012 (ML11342A121) NRC (D. Wrona) Tribal Nation - Tunica -Biloxi Tribe of Louisiana (E. Barbry) January 19, 2012 (ML11342A121) NRC (D. Wrona) National Marine Fisheries Service (D. Bernhart) January 19, 2012 (ML11350A173) NRC (D. Wrona) U.S. Fish & Wildlife Service (USFWS), Louisiana Field Office (R. Watson) January 19, 2012 (ML11349A001) NRC (D. Wrona) Mississippi State Historic Preservation Office (SHPO) January 19, 2012 (ML11348A090 ) NRC (D. Wrona) Mississippi Natural Heritage Program (S. Surrette) January 20, 2012 (ML11349A003) NRC (D. Wrona) USFWS, Mississippi Field Office (S. Ricks) January 20, 2012 (ML11348A354) NRC (D. Wrona) Louisiana SHPO (P. Boggan) January 20, 2012 (ML11348A353 ) USFWS Mississippi Field Office (S. Ricks) NRC (D. Drucker) February 3, 2012 (ML12047A113) NRC (D. Wrona) Louisiana Natural Heritage Program (C. Michon) February 6, 201 2 (ML12005A163 ) Mississippi Natural Heritage Program (A. Sanderson) NRC (D. Wrona) February 13, 2012 (ML12055A312) Tribal Nation - Mississippi Band of Choctaw Indians (C. Wallace) NRC (D. Wrona) February 13, 2012 (ML12047A127) Appendix D D-2 Author Recipient Date of Letter/Email Louisiana Natural Heritage Program (C. Michon) NRC (D. Wrona) February 16, 2012 (ML12060A098) Mississippi SH PO (G. Williamson ) NRC (D. Wrona) February 28, 20 12 (ML12073A084 ) USFWS Louisiana Field Office (J. Weller) NRC (D. Wrona) February 29, 20 12 (ML12082A141) Jena Band of Choctaw Indians (D. Master s) NRC (Chief, Rules, Announcements, & Directives Branch) March 1, 2012 (ML12089A020) National Marine Fisheries Service (D. Bernhart) NRC (D. Wrona) March 1, 2012 (ML12065A167) Choctaw Nation of Oklahoma (J. Jacobs) NRC (D. Wrona) March 26, 2012 (ML12101A124) CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDEN CE APPENDIX E1 CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE 2

E-1 E. CHRONOLOGY OF ENVIRONMENTAL REVIEW 1 CORRESPONDENCE 2 This appendix contains a chronological listing of correspondence between the U.S. Nuclear 3 Regulatory Commission (NRC) and external parties as part of its environmental review for 4 Grand Gulf Nuclear Station (GGNS). All documents are available electronically from the NRC's 5 Public Electronic Reading Room found on the Internet at the following Web address: 6 http://www.nrc.gov/reading -rm.html. From this site, the public can gain access to the NRC's 7 Agencywide Documents Access and Management System (ADAMS), which provides text and 8 image files of the NRC's public documents in ADAMS. The ADAMS accession number for each 9 document is included in the following list. 10 E.1 Environmental Review Correspondence 11 Table E-1 lists the environmental review correspondence, by date, beginning with the request 12 by Entergy to renew the operating license for GGNS. 13 Table E-1. Environmental Review Correspondence 14 Date Correspondence Description ADAMS No. October 28, 2011 Transmittal of license renewal application (LRA) for GGNS, Unit 1 ML11308A052 November 9, 2011 Receipt and availability of GGNS, Unit 1 LRA ML11293A013 December 16, 2011 Determination of acceptability and sufficiency for docketing, proposed review schedule, and opportunity for a hearing regarding the application from Entergy Operations, Inc. (Entergy), for renewal of the operating license for GGNS, Unit 1 ML11335A340 December 22, 2011 Notice of intent to prepare an environmental impact statement (EIS) and conduct scoping process for license renewal for GGNS, Unit 1 ML11342A073 January 6, 2012 Forthcoming meeting to discuss the license renewal process and environmental scoping for GGNS, Unit 1, LRA review ML11362A433 January 19, 2012 GGNS LRA review Advisory Council on Historic Preservation ML11348A088 January 19, 2012 Mississippi Band of Choctaw Indians -request for comments concerning GGNS LRA review ML11342A121 January 19, 2012 Choctaw Nation of Oklahoma -request for comments concerning GGNS LRA review ML11342A121 January 19, 2012 Tunica-Biloxi Tribe of Louisiana -request for comments concerning GGNS LRA review ML11342A121 January 19, 2012 Jena Band of Choctaw Indians -request for comments concerning GGNS LRA review ML11342A121

Appendix E E-2 Date Correspondence Description ADAMS No. January 19, 2012 Request for list of protected species within the area under evaluation for the GGNS, Unit 1, license renewal review application, U.S. Fish & Wildlife Service (USFWS), Louisiana Field Office ML11349A001 January 19, 2012 GGNS LRA review, Mississippi State Historic Preservation Office (SHPO) ML11348A090 January 19, 2012 GGNS LRA review, National Marine Fisheries Service (NMFS) ML11350A173 January 20, 2012 GGNS LRA review Louisiana SHPO ML11348A353 January 20, 2012 Request for list of protected species within the area under evaluation for GGNS license renewal review application, Mississippi Natural Heritage Program ML11349A003 January 20, 2012 Request for list of protected species within the area under evaluation for GGNS license renewal review application, USFWS, Mississippi Field Office ML11348A354 January 31, 20 12 Transcript from afternoon public scoping meeting ML12037A222 January 31, 20 12 Transcript from evening public scoping meeting ML12037A223 February 3, 20 12 Response from USFWS, Mississippi Field Office, to NRC request for list of protected species within the area under evaluation for GGNS LRA review ML12047A113 February 6, 20 12 Request for list of protected species within the area under evaluation for GGNS, Unit 1, license renewal review application, Louisiana Natural Heritage Program ML12005A163 February 1 3, 20 12 Response from Mississippi Natural Heritage Program to NRC request for list of protected species within the area under evaluation for GGNS LRA review ML12055A312 February 1 3, 20 12 Response from Mississippi Band of Choctaw Indians to NRC request for comments on GGNS LRA review ML12047A127 February 1 3, 20 12 Scoping comment from the National Park Service referencing the GGNS LRA review ML12048A674 February 16, 20 12 Response from Louisiana Natural Heritage Program to NRC request for list of protected species within the area under evaluation for GGNS LRA review ML12060A098 February 27, 20 12 Scoping comments from J. Hil legas, Green Party of Mississippi ML12060A334 February 28, 20 12 Mississippi SHPO response to NRC letter referencing GGNS LRA review ML12073A084 February 29, 20 12 Response from USFWS, Louisiana Field Office, to NRC request for list of protected species within the area under evaluation for GGNS LRA review ML12082A141 March 1, 2012 Response from Jena Band of Choctaw Indians to NRC request for comments concerning GGNS LRA review ML12089A020

Appendix E E-3 Date Correspondence Description ADAMS No. March 1, 2012 Response from NMFS to NRC request for comments concerning GGNS LRA review ML12065A167 March 22, 2012 Transmittal of environmental audit plan to Entergy ML12060A112 March 26, 2012 Response from Choctaw Nation of Oklahoma to NRC request for comments concerning GGNS LRA review ML12101A124 April 23, 20 12 Transmittal of environmental requests for additional information (RAIs) ML12083A188 May 8, 2012 Transmittal of air RAIs ML12123A081 May 21, 2012 Transmittal of severe accident mitigation alterative (SAMA) RAI s ML12115A101 May 23, 2012 Entergy response to environmental RAIs ML12157A173 June 6, 2012 Entergy response to air RAIs ML12158A445 July 19, 2012 Entergy response to SAMA RAIs ML12202A056 August 23, 2012 Transmittal of 2 nd round SAMA RAIs ML12227A735 September 7, 2012 Schedule change letter ML12242A545 October 10, 2012 Entergy partial response to 2 nd round SAMA RAIs ML12277A082 November 19, 2012 Entergy complete response to 2 nd round SAMA RAIs ML12325A174 December 19, 2012 Entergy response to SAMA clarification questions ML12359A038 February 26, 2013 Schedule change letter ML13002A430 April 16, 2013 Scoping Summary Report ML12201A623 August 15, 2013 Schedule change letter ML13207A156

APPENDIX F1 U.S. NUCLEAR REGULATORY COMMISSION STAFF EVALUATION OF 2 SEVERE ACCIDENT MITIGATION ALTERNATIVES FOR 3 GRAND GULF NUCLEAR STATION IN SUPPORT OF 4 LICENSE RENEWAL APPLICATION REVIEW 5

Appendix F F-1 F. U.S. NUCLEAR REGULATORY COMMISSION STAFF EVALUATION 1 OF SEVERE ACCIDENT MITIGATION ALTERNATIVES FOR GRAND 2 GULF NUCLEAR STATION IN SUPPORT OF LICENSE RENEWAL 3 APPLICATION REVIEW 4 F.1 Introduction 5 Entergy Operations, Inc. (Entergy or the applicant) submitted an assessment of severe accident 6 mitigation alternatives (SAMAs) for Grand Gulf Nuclear Station, Unit 1 (GGNS), in Section 4.21 7 and Attachment E of the Environmental Report (ER) (Entergy 2011). This assessment was 8 based on the most recent revision to the GGNS probabilistic risk assessment (PRA), including 9 an internal events model and a plant -specific offsite consequence analysis performed using the 10 MELCOR Accident Consequence Code System 2 (MACCS2) computer code, as well as 11 insights from the GGNS individual plant examination (IPE) (Entergy 1992) and individual plant 12 examination of external events (IPEEE) (Entergy 1995). In identifying and evaluating potential 13 SAMAs, Entergy considered SAMAs that addressed the major contributors to core damage 14 frequency (CDF) and population dose at GGNS, as well as insights and SAMA candidates 15 found to be potentially cost beneficial from the analysis of nine other boiling-water reactor 16 (BWR) nuclear power generating stations. Entergy initially identified a list of 2 49 potential 17 SAMAs. This list was reduced to 63 unique SAMA candidates by eliminating SAMAs that 18 (a) were not applicable to GGNS, (b) had already been implemented at GGNS, or (c) were 19 combined into a more comprehensive or plant -specific SAMA. Entergy concluded in the ER that 20 th ree candidate SAMAs are potentially cost beneficial. 21 As a result of the review of the SAMA assessment, the U.S. Nuclear Regulatory Commission 22 (NRC) staff issued request s for additional information (RAI s) to Entergy by letters dated 23 May 21, 2012, (NRC 2012a) and August 23, 2012 (NRC 2012b). Key questions concerned: 24 changes and updates to Level 1 and Level 2 PRA models that most affect 25 CDF, 26 differences in CDF values and importance measures reported in the ER, 27 the impact of open items and issues from the peer review of the PRA, 28 the process used to assign release categories to containment event tree 29 (CET) end states for incorporating Level 1 results into the Level 2 analysis, 30 selection of representative sequences for each release category in the 31 Level 2 analysis, 32 the impact of new information on fire and seismic initiated sequences, and 33 further information on the cost -benefit analysis of several specific candidate 34 SAMAs and low -cost alternatives. 35 Entergy submitted additional information by letters dated July 19, 2012 (Entergy 2012a), 36 October 2, 2012 (Entergy 2012b), November 19, 2012 (Entergy 2012c), and 37 December 19, 2 012 (Entergy 2012d). In response to the staff RAIs, Entergy provided further 38 information on: 39 the history and key changes to PRA models, 40 the resolution of peer review comments, 41 Appendix F F-2 the development of the Level 2 containment release model, 1 the reasons for differences between CDF values given in the submittal, 2 the results of an updated cost -benefit analysis based on resolution of CDF 3 differences, 4 the impact of new information on external events, and 5 the cost of various SAMAs and potential low -cost alternatives. 6 Entergy's responses addressed the staff's concerns and resulted in the identification of one 7 additional potentially cost -beneficial SAMA. 8 An assessment of the SAMAs for GGNS is presented below. 9 F.2 Estimate of Risk for GGNS 10 Section F.2.1 summarizes Entergy's estimates of offsite risk at GGNS. The summary is 11 followed by the staff's review of Entergy's risk estimates in Section F.2.2. 12 F.2.1 Entergy's Risk Estimates 13 Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA 14 analysis:

(1) the GGNS Level 1 and 2 PRA model, which is an updated version of the IPE 15 (Entergy 1992), and (2) a supplemental analysis of offsite consequences and economic impacts 16 (essentially a Level 3 PRA model) developed specifically for the SAMA analysis. The original 17 SAMA analysis was based on the most recent GGNS Level 1 and Level 2 PRA model available 18 at the time of the ER, referred to as the 2010 extended power uprate (EPU) model 19 (Entergy 2011). Subsequent to the original submittal, errors were found in the interpretation o f 20 the results of the Level 2 model that led Entergy to change the Level 2 model and cost

-benefit 21 analysis (Entergy 2012b, 2012c, 2012d). The results discussed in this appendix are for the 22 updated analysis. The corrections to the model are discussed in Section F.2.2. The scope of 23 the current GGNS PRA does not include external events. 24 The GGNS CDF is approximately 2.9 x 106 per reactor -year as determined from quantification 25 of the Level 1 PRA model with the revised Level 2 model. This value was used as the baseline 26 CDF in the SAMA evaluations (Entergy 2012c, 2012d). The CDF is based on the risk 27 assessment for internally initiated events, which includes internal flooding. Entergy did not 28 explicitly include the contribution from external events within the GGNS risk estimates; however, 29 it did account for the potential risk reduction benefits associated with external events by 30 multiplying the estimated benefits for internal events by a factor of

11. This is discussed further 31 in Sections F.2.2 and F.6.2. 32 The breakdown of CDF by initiating event is provided in Table F-1. As shown in this table, loss 33 of offsite power and power conversion system available transient are the dominant contributors 34 to the CDF. While not listed explicitly in Table F-1 because they can occur as a result of 35 multiple initiators, Entergy stated that station blackout s contribute about 37 percent 36 (1.1 x 106 per reactor

-year) of the total CDF; anticipated transients without scram contribute 37 about 0.2 percent (4.4 x 109 per reactor -year) to the total CDF (Entergy 2012c). 38 The Level 2 GGNS PRA model that forms the basis for the SAMA evaluation is essentially a 39 new model and reflects power uprate conditions. The Level 2 model uses CETs containing both 40 phenomenological and systemic events. The Level 1 core damage sequences are binned into 41 accident classes (or plant damage states) that provide the interface between the Level 1 and 42 Appendix F F-3 Level 2 CET analysis. The CETs are linked directly to the Level 1 event trees and CET nodes 1 are evaluated using subordinate trees and logic rules. 2 The CET considers the influence of physical and chemical processes on the integrity of the 3 containment and on the release of fission products once core damage has occurred. The 4 quantified CET sequences are binned into a set of end states that are subsequently grouped 5 into 13 release categories (or release modes) that provide the input to the Level 3 consequence 6 analysis. The frequency of each release category was obtained by summing the frequency of 7 the individual accident progression CET endpoints binned into the release category. Source 8 terms were developed for the release categories using the results of Modular Accident Analysis 9 Program (MAAP 4.0.6) computer code calculations. From these results, source terms were 10 chosen to be representative of the release categories. The results of this analysis for GGNS 11 are provided in the revised Table E.1-9 of ER Attachme nt E (Entergy 2012c). 12 Entergy computed offsite consequences for potential releases of radiological material using the 13 MACCS2 Version 1.13.1 code and analyzed exposure and economic impacts from its 14 determination of offsite and onsite risks. Inputs for these analyses include plant -specific and 15 site-specific input values for core radionuclide inventory, source term and release 16 characteristics, site meteorological data, projected population distribution and growth within a 17 50-mi le (mi) (80-kilometer (km)) radius, emergency response evacuation modeling, and local 18 economic data. Radionuclide inventory in the reactor core is based on a plant -specific 19 evaluation and corresponds to that for the EPU power of 4,408 megawatts thermal (MWt) 20 (Entergy 2011, Attachment E). The estimation of onsite impacts (in terms of clean -up and 21 decontamination costs and occupational dose) is based on guidance in NUREG/BR -0184 , 22 Regulatory Analysis Technical Evaluation Handbook (NRC 1997a). Additional details on the 23 input parameter assumptions are discussed below. 24 Appendix F F-4 Table F-1. Grand Gulf Nuclear Station Core Damage Frequency (CDF) for Internal Events 1 Initiating Event CDF (per year)

% CDF Contribution Loss of Offsite Power Initiator 1.2 x 106  40 Power Conversion System Available Transient 5.9 x 107  20 Loss of Power Conversion System Initiator 2.5 x 107   8 Loss of Condensate Feed Water Pumps 2.3 x 107   8 Loss of Instrument Air 1.4 x 107   5 Closure of Main Steam Isolation Valves (Initiator) 1.2 x 107   4 Loss of Service Transformer 21 1.2 x 107   4 Large Loss of Coolant Accident (LOCA) 9.7 x 108   3 Loss of Service Transformer 11 8.3 x 108   3 Loss of Alternating Current Division 2 Initiator 6.2 x 108   2 Other Initiating Events1 3.3 x 108   1 Loss of Alternating Current Division 1 Initiator 2.7 x 108   1 Intermediate LOCA 1.4 x 108   1 Total Core Damage Frequency (Internal Events) 2.9 x 106 100 1 Multiple initiating events with each contributing 0.3 percent or less In the E R, the applicant estimated the dose risk to the population within 80 km (50 mi) of the 2 GGNS site to be 0.00609 person-sieverts (Sv) per year (0.609 person-roentgen equivalent in 3 man (rem) per year) (Entergy 2012c). The breakdown of the population dose risk by 4 containment release mode is summarized in Table F-2. Medium releases provide the greatest 5 contribution, totaling approximately 67 percent of the population dose risk and 75 percent of the 6 offsite economic cost risk for all timings. High early (H/E) releases alone contribute only about 7 10 percent, and high releases for all timings contribute 17 percent of the population dose risk.

8 F.2.2 Review of Entergy's Risk Estimates 9 Entergy's determination of offsite risk at GGNS is based on three major elements of analysis: 10 the Level 1 and 2 risk models that form the bases for the 1992 IPE submittal 11 (Entergy 1992), and the external event analyses of the 1995 IPEEE submittal 12 (Entergy 1995); 13 the major modifications to the IPE model that have been incorporated in the 14 GGNS 2010 EPU PRA; and 15 the combination of offsite consequence measures from MACCS2 analyses 16 with release frequencies and radionuclide source terms from the Level 2 PRA 17 model. 18 Appendix F F-5 Table F-2. Base Case Mean Population Dose Risk and Offsite Economic Cost Risk 1 for Internal Events 2 Each analysis element was reviewed to determine the acceptability of Entergy's risk estimates 3 for the SAMA analysis, as summarized further in this section. 4 F.2.2.1 Internal Events CDF Model 5 The staff's review of the GGNS IPE is described in an NRC letter dated March 7, 1996 6 (NRC 1996). From its review of the IPE submittal, the staff concluded that the IPE process is 7 capable of identifying the most likely severe accidents and severe accident vulnerabilities, and 8 Release Mode Population Dose Risk 1 Offsite Economic Cost Risk ID 2 Frequency (per year) person-rem/yr % Contribution

$/yr % Contribution H/E 1.0 x 107 6.2 x 102   10 1.7 x 10+2   11 H/I 1.2 x 108 6.2 x 103   1 1.7 x 10+1   1 H/L 9.2 x 108 3.8 x 102   6 9.6 x 10+1   6 M/E 3.7 x 107 1.7 x 101   28 4.8 x 10+2   32 M/I 1.8 x 107 1.2 x 101   20 3.3 x 10+2   22 M/L 3.0 x 107 1.2 x 101   19 3.2 x 10+2   21 L/E 4.1 x 109 4.0 x 104   <0.1 3.0 x 101   <0.1 L/I 3.6 x 108 1.2 x 102   2 2.7 x 10+1   2 L/L 4.4 x 107 7.8 x 102   13 7.4 x 10+1   5 LL/E 2.2 x 109 7.9 x 107   <0.1 1.0 x 103   <0.1 LL/I 2.1 x 109 3.8 x 107   <0.1 9.7 x 104   <0.1 LL/L 7.1 x 109 2.0 x 103   <1 3.4 x 10+0   <1 NCF 1.4 x 106 5.0 x 104   <0.1 6.4 x 101   <0.1 Total 2.9 x 106 6.1 x 101   100 1.5 x 10+3   100 1 Unit Conversion Factor:  1 Sv = 100 rem 2 Release Mode Nomenclature (Magnitude/Timing)

Magnitude: High (H) - Greater than 10 percent release fraction for Cesium Iodide Medium (M) - 1 to 10 percent release fraction for Cesium Iodide Low (L) - 0.1 to 1 percent release fraction for Cesium Iodide Low-Low (LL) - Less than 0.1 percent release fraction for Cesium Iodide No containment failure (NCF) - Much less than 0.1 percent release fraction for Cesium Iodide Timing: Early (E) - Less than 4 hours Intermediate (I) - 4 to 24 hours Late (L) - Greater than 24 hours Appendix F F-6 therefore, that the GGNS IPE has met the intent of Generic Letter (GL) 88-20 (N RC 1988). 1 Although no vulnerabilities were identified in the IPE, 11 improvements were identified by 2 Entergy. The ER stated that five of these improvements have been implemented, one was 3 considered to be no longer applicable, and five were retained as potential SAMAs. 4 The internal events CDF value from the 1992 IPE (1.7 x 105 per reactor -year) is near the 5 average of the values reported for other General Electric (GE) BWR 5/6 units. Figure 11.2 of 6 NUREG-1560, Volume 2, Individual Plant Examination Program: Perspectives on Reactor 7 Safety and Plant Performance Parts 2 -5, Final Report (NRC 1997b) shows that the IPE -based 8 total internal events CDF for GE BWR 5/6 plants ranges from 1 x 106 per year to 4 x 104 per 9 year, with an average CDF for the group of 2 x 105 per year. Other plants have updated the 10 values for CDF subsequent to the IPE submittals to reflect modeling and hardware changes. 11 The internal events CDF result for GGNS used for the SAMA analysis (2.9 x 106 per year) is 12 somewhat lower than that for other plants of similar vintage. 13 GGNS was one of the units analyzed in considerable detail in the analysis of the risk of five 14 nuclear power plants found in NUREG -1150, Severe Accident Risks: An Assessment for Five 15 U.S. Nuclear Power Plants (NRC 1990). NUREG -1150 stated that the mean internal events 16 CDF for GGNS was 4 x 106 per year, which is very similar to the current Entergy estimate. 17 There have been four revisions to the IPE Level 1 model since the 1992 IPE submittal. A listing 18 of the changes made to the GGNS PRA since the original IPE submittal was provided in the ER 19 (Entergy 2011) and is summarized in Table F-3, including information requested by the NRC 20 (Entergy 2012a, 2012d). A comparison of internal events CDF between the 1992 IPE and the 21 current PRA model indicates a decrease of about a factor of six in the total CDF (from 22 1.7 x 105 per reactor -year to 2.9 x 106 per reactor -year). This reduction can be attributed to 23 incorporation of plant -specific data, improved modeling details, and removal of conservatism. 24 Appendix F F-7 Table F-3. Major GGNS Probabilistic Safety Assessment (PSA) Models 1 PSA Model Summary of Significant Changes from Prior Model CDF (per year) LERF (per year) 1992 (IPE) 1.7 x 105 5.2 x 107 1997 (R1) Incorporation of updated plant -specific data for system maintenance and testing unavailability Incorporation of updated plant -specific data for initiating event frequencies Incorporation of updated plant -specific data for certain important components (i.e., diesel generators, high pressure core spray, and reactor core isolation cooling pumps) Various modeling changes to system models to correct minor modeling errors and incorporate modifications since the original IPE 5.5 x 106 Not Updated 2002 (R2) Modeling changes to reflect installation of new type of plant service water radial well pumps and support systems Addition of heating, ventilation, and air conditioning (HVAC) systems to the model, including addition of the new standby service water pump -house high temperature alarm Modeling of changes to the backup scram valves and logic in the anticipated transient without scram portion of the fault tree Use of more comprehensive human reliability analysis methods Us e of the convolution method for recovery of loss of offsite power (LOSP) Addition of an interfacing systems LOCA initiator Inclusion of operating data through December 31 , 2000 4.3 x 106 2.0 x 107 2010 (R3) Update of plant-specific data and initiator frequencies (through August 2006) and generic initiator frequencies New initiators: loss of service transformer, reactor vessel rupture, Loss of control rod drive, and Break (LOCA) outside of containment Major changes to LOSP modeling Inclusion of modeling for loss of emergency core cooling system pumps due to containment failure Revision of instrument air system modeling to incorporate new plant air compressors Revision of modeling of control rod drive -less credit for control rod drive 2.7 x 106 1.4 x 107 2010 (EPU) Power level change (13 percent EPU) Hardware changes Procedural changes Operational changes 2.9 x 106 1.5 x 107 (Note 1) Note 1. This LERF value is from the Revision 3 EPU LERF model and is different from the Table F-2 value for the High Early (H/E) release category, which was obtained from the full Level 2 model (Entergy 2012d). Refer to additional discussion in Section F.2.2. Appendix F F-8 The GGNS 2010 EPU model reflects GGNS design, component failure, and unavailability data 1 as of August 2006, modified to reflect the EPU configuration. Entergy states that there have 2 been no major plant hardware changes or procedural modifications since August 2006 that 3 would have a significant impact on the results of the SAMA analysis. In response to the staff 4 RAIs, Entergy (2012a) clarified what was meant by "significant" and also stated that a review of 5 plant equipment performance since August 2006 indicated no degradation issues that would 6 impair the SAMA analysis (Entergy 2011). A change that would have a significant impact is 7 described as a grade A (extremely important and necessary to assure the technical adequacy or 8 quality of the PRA) or grade B (important and necessary to address, but may be deferred until 9 the next model update) model change request (MCR). The MCR database is used to track 10 plant changes, procedure revisions, nuclear licensing revisions, and model improvements that 11 impact the PRA models. The RAI response stated that there were one grade A and 12 grade B 12 MCRs. The single grade A MCR involved modeling for the temporary condition when a 13 low-pressure feedwater heater is taken out of service and would not impact the SAMA analysis; 14 the grade B MCRs either impacted the fire model and not the SAMA model, involved systems 15 that are not risk -significant, or would result in a decrease in risk (Entergy 2012a). The staff 16 concludes that there have been no major plant hardware changes or procedural modifications 17 since August 2006 that would have a significant impact on the results of the SAMA analysis. 18 In response to a staff RAI, Entergy explained that the maintenance rule system health reports 19 indicated no equipment reliability issues that would impair the SAMA analysis and that the plant 20 data issues identified during the expert panel reviews of the model updates or during the expert 21 panel review of the Level 2 cutsets were resolved in the model used for the SAMA analysis 22 (Entergy 2012b). 23 Although Entergy suggested the unavailability of the high-pressure core spray (HPCS) system 24 and the B diesel -driven fire pump had increased recently, Entergy also stated that the 25 unavailability for these systems remains within the error band of the unavailability distribution 26 (Entergy 2012b). Based on this response and the staff's review of the GGNS SAMA analysis, 27 the staff concludes that, while the inclusion of more recent plant data might increase the CDF 28 contribution for these two systems, it would not be expected to change the conclusions related 29 to cost-beneficial SAMAs. 30 The staff considered the peer reviews and other assessments performed for the GGNS PRA 31 and the potential impact of the review findings on the SAMA evaluation. The most relevant of 32 these are the peer review of the GGNS 1997, Revision 1 model and the staff review of the 33 GGNS 2010 EPU model as part Entergy's EPU application. 34 The 1997 (Revision

1) Level 1 and large early release frequency (LERF) model was 35 peer-reviewed before the 2002 PRA, Revision 2, using the BWR Owners Group (BWROG) 36 process. The review team used the BWROG Probabilistic Safety Assessment (PSA) Peer 37 Review Certification Implementation Guidelines, Revision 3, January 1997. Entergy stated that 38 all of the "A" priority (extremely important and necessary to address to ensure the technical 39 adequacy of the PSA) PRA peer review comments have been addressed and incorporated into 40 the GGNS PRA model, as appropriate. It also stated that all of the "B" priority (important and 41 necessary to address but may be deferred until the next PSA update) comments have been 42 addressed, except for one documentation item related to the internal flood modeling.

43 In response to a staff RAI concerning A and B priority comments addressed by internal reviews 44 in which Entergy concluded that changes to the model were not needed or the fact and 45 observation was incorrect, Entergy stated that (a) those which were considered incorrect 46 involved documentation issues that would not impact the SAMA PRA, (b) involved comments on 47 the Level 2 model, which has since been completely updated, or (c) for the other observations 48 Appendix F F-9 for which no change was considered necessary, provided a discussion of additional information 1 concerning the issues and confi rmed that the disposition remained valid at the EPU power and 2 the SAMA assessment (Entergy 2012a, 2012b). Entergy (2012b) provided clarification for 3 Observation 85 concerning the Level 1 general transient event tree. Despite a disposition 4 statement that no changes were necessary, Entergy stated that the structure of the event tree 5 was changed subsequent to the peer review, and that the changes addressed the concern 6 raised in the observation. 7 The staff review of Entergy 's EPU application is documented in a safety evaluation report (SER) 8 (NRC 2012c). In Section 2.13.1 of t he EPU SER, the technical evaluation of the EPU focused 9 on the impact on CDF and LERF while operating at EPU conditions. In its review of PRA 10 quality, the staff noted the disposition of an additional nine findings on the Level 2 model. The 11 internal flooding issue was determined to be solely a documentation issue, while eight of the 12 nine Level 2 issues were resolved in the Level 2 model used for the SAMA analysis. In 13 response to an RAI concerning the impact on the SAMA analysis, Entergy stated that vacuum 14 breaker failures and low suppression pool level were incorporated in the SAMA Level 2 model 15 and that personnel hatch seal failure was negligible when compared with hatch failure due to 16 either overpressurization or buckling (Entergy 2012a). The staff found that the Level 2 issue s 17 were acceptably addressed and concluded that failure to model vacuum breakers, low 18 suppression pool level, and personnel hatch seal would not significantly impact the delta risk 19 results for the EPU application. 20 The EPU SER states: 21 Based on its evaluation, the NRC staff concludes that the GGNS PRA models 22 used to support the risk evaluation for this application have sufficient scope, level 23 of detail, and technical adequacy to support the evaluation of the EPU. 24 The SER further states: 25 The NRC staff concludes that the licensee 's evaluation of the impact of the 26 proposed EPU on at -power risk from internal events is reasonable and concludes 27 that the base risk due to the proposed EPU is acceptable and that there are no 28 issues that rebut the presumption of adequate protection provided by the 29 licensee meeting the currently specified regulatory requirements. 30 The staff concludes that, while the EPU application is focused on delta CDF and LERF as 31 opposed to absolute values, these conclusions do lend support for the adequacy for the SAMA 32 application. 33 The staff noted that the LERF value of 1.48 x 107 per year (rounded to 1.5 x 107 per year in 34 Table F-3) given in the ER for the EPU model is different from the value of 1.04 x 107 per year 35 (rounded to 1.0 x 107 per year in Table F-2) for the H/E release category. In response to an 36 RAI, Entergy (2012d) stated that the value of 1.48 x 107 per year is from a separate Revision 3 37 EPU LERF model and the value of 1.04 x 107 per year is from the full Level 2 model. In the 38 analysis for GGNS, LERF is not a dominant contributor to the population dose risk or economic 39 cost risk. The staff concludes that the H/E release category frequency obtained from the full 40 Level 2 analysis (along with the other release category frequencies) is appropriate for use in the 41 SAMA consequence analysis. 42 In the ER, Entergy describes two internal expert panel reviews of the Revision 2 and Revision 3 43 models before their finalization. Various departments (Training, Operations, Engineering, and 44 Nuclear Safety) within the GGNS organization were invited to participate. Each of the top 100 45 cutsets was reviewed individually. In addition, cutsets from accident sequences representing 46 approximately 99 percent of the total CDF also were reviewed if there were no cutsets from 47 these sequences in the top 100. The focus of the review was to identify poor assumptions, 48 Appendix F F-10 over-simplifications, incorrect credit for human actions, sequence timing errors, system 1 modeling errors, and incorrect event probabilities. The reviews resulted in modifications to the 2 model and to the credit given for human actions. 3 In response to an RAI, Entergy briefly described the process and procedures for assuring 4 technical quality of PRA updates since the peer review. The PRA maintenance and update 5 procedure describes the process for maintaining the PRA models current with the as -built and 6 as operated plants and gives specific instructions for identifying model change requests, 7 documenting those requests, and incorporating those requests into the PRA model. The PRA 8 analysts performing model updates are experienced, trained professionals, and each change is 9 reviewed by a second, experienced, trained PRA analyst. In addition, as described above, 10 expert panel reviews are used to enhance the technical quality of the PRA updates. Changes 11 from the expert panel review for an update are immediately incorporated into that update of 12 the model (Entergy 2012a). 13 In the original SAMA submittal (Entergy 2011), Entergy took the internal events CDF to be the 14 sum of all the Level 2 release categories including the no containment failure (NCF) sequences. 15 This summation resulted in a CDF value of 2.05 x 106 per year compared to the CDF from the 16 Level 1 analysis value of 2.92 x 106 per year. In response to a staff RAI to explain this 17 difference, Entergy stated that the Level 2 results were misinterpreted because it was assumed 18 that the NCF sequences were adequately modeled and the resulting frequencies were valid. 19 From investigating the reasons for the difference, Entergy found the assumption to be invalid, 20 and it subsequently used the CDF value from the Level 1 model in a reanalysis of the SAMAs. 21 Additionally, Entergy identified and addressed a number of discrepancies in the Level 2 22 recovery rule file. Typically, Level 2 model changes would not be expected to impact the 23 Level 1 result; however, incorporated changes led to the CDF value of 2.93 x 106 per year 24 used in the revised SAMA analysis (Entergy 2012b, 2012c, 2012d). 25 Given that the GGNS internal events PRA model has been peer -reviewed and the peer review 26 findings were all addressed, that the model has been reviewed by the staff as part of the EPU 27 application approval, that Entergy has satisfactorily addressed staff questions regarding the 28 PRA, and that the misinterpretation of Level 2 results discussed above has been corrected in 29 the revised SAMA analysis, the staff concludes that the internal events Level 1 PRA model is of 30 sufficient quality to support the SAMA evaluation. 31 F.2.2.2 External Events 32 As stated above, the GGNS PRA does not include external events. The SAMA submittals cite 33 the GGNS IPEEE to assess the impact of seismic, internal events and other external events. 34 The final GGNS IPEEE was submitted in 1995 (Entergy 1995), in response to Supplement 4 of 35 GL 88-20 (NRC 1991a). Except for one potential seismic vulnerability, no fundamental 36 weaknesses or vulnerabilities to severe accident risk in regard to the external events were 37 identified in the GGNS IPEEE. In a letter dated March 16, 2001 (NRC 2001), the staff stated 38 that, on the basis of its review of the PRA and IPEEE submittal, the staff concludes that the 39 GGNS IPEEE process is capable of identifying the most likely severe accidents and severe 40 accident vulnerabilities and, therefore, the GGNS IPEEE has met the intent of Supplement 4 to 41 GL 88-20. 42 Seismic Events 43 The GGNS IPEEE seismic analysis was a reduced scope seismic margins assessment (SMA) 44 following NRC guidance (NRC 1991a, 1991b). The SMA was performed using a Safe 45 Shutdown Equipment List with plant walkdowns in accordance with the guidelines and 46 procedures in Electrical Power Research Institute (EPRI) Report NP-6041-SL (EPRI 1991). 47 Appendix F F-11 Since GGNS is a reduced scope SMA plant, the original design -basis safe shutdown 1 earthquake (SSE) ground response spectra and corresponding in -structure response spectra 2 were used as the review level earthquake (RLE) input for the walkdown and evaluation. The 3 SMA approach is deterministic in nature and does not result in probabilistic risk information. As 4 a reduced scope plant, the determination of high confidence of low probability of failure values 5 also is not required. 6 The IPEEE submittal (Entergy 1995) concludes that GGNS is seismically rugged and that all 7 components identified in the Safe Shutdown Path meet the seismic requirements. All 8 anchorage to these components was found to be rugged. One potential vulnerability to a 9 seismic event was identified, which has been corrected. The potential vulnerability involved the 10 standby service water (SSW) piping in the Control Building where the grouted condition of 11 several penetrations into the building were not accounted for in the stress analysis of the piping 12 systems. To correct the situation and to meet design requirements, the grout was removed and 13 a design change was issued to repair the penetration. The as-found grouted condition was 14 evaluated for operability considerations and was determined not to be an operability concern. In 15 addition, a number of "design enhancements " were implemented, including issuance of a new 16 standard to address seismic housekeeping problems, securing of "S" hooks on lighting fixtures, 17 installation of missing clips and screws on several items, and revision to several design -basis 18 calculations (NRC 200 1). 19 Based on the results of the IPEEE seismic assessment as described above, Entergy stated in 20 the ER that since seismic events are not dominant contributors to external event risk and 21 quantitative analysis of these events is not practical, they are assumed negligible in estimation 22 of the external events multiplier. An August 2010 NRC report, "Generic Issue 199 (GI -199), 23 Implications of Updated Probabilistic Seismic Hazard Estimates in Central and Eastern United 24 States on Existing Plants" (NRC 2010) shows a decrease in GGNS seismic CDF, using 2008 25 U.S. Geological Survey (USGS) seismic hazards curve when compared against 1994 Lawrence 26 Livermore National Lab Hazard Curves, but an increase compared to the seismic CDF based on 27 the EPRI hazard curves . Based on a simplified approach to estimate CDF from a seismic 28 margins analysis and using the latest published USGS seismic hazards information, the staff 29 estimates the GGNS seismic CDF is about 1 x 105 per year and is not negligible. In response 30 to a staff RAI (Entergy 2012a), Entergy discussed the impact of this seismic CDF on the SAMA 31 analysis. This topic is discussed further in Section F.3.2 and in the subsection on high winds, 32 floods, and other external events of this section. 33 Fire Events 34 The GGNS IPEEE fire assessment is a fire PRA that uses key assumptions and the general 35 approach specified in the EPRI Fire PRA Implementation Guide (EPRI 1994) and the 36 Fire-Induced Vulnerability Evaluation (FIVE) methodology (EPRI 1992). Additionally, the fire 37 PRA incorporates information from the GGNS Fire Hazards Analysis. 38 The overall approach involved four tasks: develop fire -induced sequences, develop fire 39 scenarios , evaluate fire damage sequences and their uncertainties, and document and verify 40 the analysis. In implementing these tasks, four levels of fire area screening were employed: 41 (1) screen fire compartments inside containment 42 (2) screen compartments with no safe shutdown o r PRA equipment 43 (3) screen assuming all equipment i n compartment fails 44 (4) credit detailed recovery 45 Fires inside containment were screened out because there are few combustible loads to ignite a 46 fire inside containment and a fire in containment would have a minor impact on the ability to 47 Appendix F F-12 safely shutdown the plant because of the limited safe shutdown equipment and cables located 1 inside containment. For the other screening steps, conditional core damage probabilities 2 (CCDPs) were determined using the IPE internal events PRA with increasing refinements 3 concerning the extent of fire damage and recovery actions and a screening CDF criteria of 4 1 x 106 per year. Thirteen fire areas not screened out after the last screening step were 5 subjected to a more detailed analysis incorporating fire modeling to support fire propagation and 6 suppression analyses, location of critical targets, definition of accident scenarios, evaluation of 7 CCDPs for the scenarios, apportioning the compartment fire frequency among the scenarios, 8 and evaluation of the probability of suppression before damage occurs. The estimated fire CDF 9 for the unscreened areas is 8.9 x 106 per reactor-year. 10 The GGNS IPEEE fire PRA was reviewed by Sandia National Laboratory (SNL). The SNL 11 review concluded that: 12 Based on the GGNS IPEEE submittal and the response to RAIs on the submittal, 13 the reviewers recommend that a sufficient level of documentation and 14 appropriate bases for analysis have been established to conclude that the 15 subject licensee submittal has met the intent of GL 88-20 (NRC 200 1). 16 While no vulnerabilities with respect to fire were identified, the IPEEE submittal identifies one 17 plant improvement related to reducing the impact of fires. The licensee stated that upgrades of 18 existing thermo-lag barriers were scheduled to be completed by the end of 1996 (Entergy 1995). 19 In a subsequent response to an IPEEE RAI, Entergy stated that the upgrades had been 20 completed (Entergy 1998). 21 The ER includes a listing of all fire areas, screened and unscreened, in Table E.1-10. The CDF 22 for the unscreened fire areas is provided below in Table F-4. In response to an RA I 23 (Entergy 2012a), Entergy confirmed that these fire zone CDFs are directly from the IPEEE and 24 are based on the IPE internal events model. Given that the current EPU internal events CDF is 25 considerably lower than that from the IPE, the staff concludes that if the EPU PRA had been 26 used to determine the CCDPs, the fire CDF would most likely be reduced. In response to a staff 27 RAI to assess recent fire research and guidance in NUREG/CR -6850 , EPRI/NRC-RES Fire 28 PRA Methodology for Nuclear Power Facilities (NRC 2005), Entergy (2012a) cited a 29 December 2010 industry assessment (NEI 2010) that concluded: 30 Based on the results and insights from industry fire PRAs, it has been identified 31 that the methods described in NUREG/CR -6850/EPRI TR -1011989 contain 32 excess conservatisms that bias the results and skew insights. While the prior 33 frequently asked question process made some incremental progress in 34 addressing areas of excessive conservatism, many more remain in need of 35 enhancement. 36 In the staff's view, it is not clear if applying the new guidance to the GGNS fire assessment 37 would result in excessive conservatism or not. The staff, however, notes the GGNS fire PRA 38 makes use of CCDPs from the IPE internal events PRA to assess the impact of a fire. Based 39 on the NRC review of existing information, the staff expects that the CCDPs using the EPU 40 model would be lower than the CCDPs from the IPE model and, thus, would result in a lower fire 41 CDF. Therefore, any increase in fire risk to using NUREG/CR -6850/EPRI TR -1011989, would 42 be at least partially offset by the expected reduction in fire risk associated with using the EPU 43 internal events models rather than the IPE models. 44 Considering that the GGNS fire PRA model has been reviewed by the staff for the IPEEE, and 45 that Entergy has addressed staff RAIs regarding the fire PRA, the staff concludes that the fire 46 PRA model, as discussed above, provides an acceptable basis for identifying and evaluating the 47 benefits of SAMAs. 48 Appendix F F-13 Table F-4. GGNS Fire IPEEE Core Damage Frequency (CDF) Results for 1 Unscreened Compartments 2 High Winds, Floods, and Other External Events 3 The GGNS IPEEE analysis of high winds, floods, and other external events followed the 4 recommendations in GL 88-20, Supplement

4. The methodology employed a screening 5 approach following the criteria of the 1975 Standard Review Plan (SRP). 6 The GGNS IPEEE submittal states that the plant's current licensing basis conforms with the 7 1975 SRP criteria for high winds, tornado loads, and tornado

-generated missiles. The submittal 8 notes that all safety -related structures and components, except the SSW system components, 9 are protected against high winds, tornado wind loads, and tornado -generated missiles. For 10 these components, a walkdown by Entergy confirmed that damage from high winds or tornado 11 wind loads are not a concern and a frequency assessment of tornado -generated missiles was 12 performed. This frequency was estimated to be 7.7 x 109 per reactor-year, an acceptably low 13 value (NRC 200 1). 14 With regard to external flooding, the IPEEE submittal states that the plant's current licensing 15 basis for flood protection meets the 1975 SRP criteria. Therefore, in accordance with the 16 guidance in NUREG -1407, Procedural and Submittal Guidance for the Individual Plant 17 Examination of External Events (IPEEE) for Severe Accident Vulnerabilities, external floods can 18 Fire Compartment Fire Compartment Description Compartment CDF (per year)

% Contribution to Unscreened Fire CDF CC502 Control Room 3.9 x 106 43 CC202 Division 1 Switchgear Room 9.4 x 107 11 CA301 Auxiliary Building Corridors.

139'-0" Elevation A422, 1A324 6.7 x 107 8 CA201 Auxiliary Building Corridors. 119'-0" Elevation 6.4 x 107 7 CC210 Division 3 (HPCS) Switchgear Room 6.1 x 107 7 CA101 Auxiliary Building Corridors. 93'-0" Elevation 5.7 x 107 7 CC215 Division 2 Switchgear Room 4.1 x 107 5 CT100 Turbine Building Floor, 93'-0" Elevation 3.2 x 107 4 CC402 Cable Spreading Room 2.8 x 107 3 CC104 Hot Machine Shop 2.4 x 107 3 CC302 HVAC Equipment Room 2.1 x 107 2 CD306 Division 3 (HPCS) Diesel Generator Room 1.7 x 107 2 CT200 Turbine Building Floor, 113'-0" Elevation 7.1 x 109 <1 Total 8.9 x 106 100 a a Column values may not total 100 percent because of rounding.

Appendix F F-14 be screened out as a significant hazard (NRC 1991b). In addition, the licensee performed 1 reevaluations of the potential flooding from the Mississippi River and the probable maximum 2 precipitation (PMP) induced flood (for site watershed). As part of their response to GL 89-22, 3 the licensee also addressed Generic Safety Issue (GSI) 103, Design for Probable Maximum 4 Precipitation, and made use of the latest rainfall data (Hydro Meteorological Reports (HMR) 5 No. 51 and 52). While the roof drains and overflows were found adequate, GGNS implemented 6 several improvements including: increase d maintenance on drainage structures, revised 7 procedures to explicitly include at -grade former Unit 2 doors, and revised procedures to 8 periodically inspect roof drains and overflows to ensure they are not blocked. In addition, 9 consideration of the new PMP led to the identification of five further improvements in local 10 drainage and flood prevention provisions. These improvements were not implemented at the 11 time of the IPEEE and, while listed in Table E.2-1 of the ER, are stated to not be cost beneficial 12 due to the minor risk from external flooding. The response to a staff RAI to provide further 13 support for this disposition is discussed below in Section F.3.2. 14 A review of transportation and nearby facility accidents confirmed that there were no severe 15 accident vulnerabilities from these accidents. The licensee found that the plant 's current 16 licensing basis for these events meets the 1975 SRP criteria. 17 As stated in the ER (Entergy 2011), a multiplier of 11 was used to adjust the internal event risk 18 benefit associated with a SAMA to account for external events. This multiplier was based on a 19 fire CDF equal to the sum of the screened and unscreened fire zone CDF values or 20 approximately 2.74 x 105 per year and the assumption that seismic and other external events 21 are negligible. Using the original Level 1 internal event CDF of 2.92 x 106 per year the ratio of 22 external to internal event CDFs is 9.4, which leads to a multiplier of 10.4 which was rounded up 23 to 11. In response to an RAI concerning the impact of the GI -199 (NRC 2010) estimated 24 seismic CDF, Entergy states that use of the GI -199 estimate of approximately 1 x 105 per year 25 along with the IPEEE fire CDF for unscreened fire zones of 8.9 x 106 per year results in an 26 external events multiplier of 7 using the 2.93 x 106 per year internal event CDF and the 27 continued use of the multiplier of 11 more than compensates for the impact of the seismic CDF 28 (Entergy 2012c). The staff agrees that the use of the unscreened fire CDF is valid and that the 29 use of the multiplier of 11 appropriately incorporates the impact of seismic risk. 30 Given that the GGNS IPEEE external events assessments has been reviewed by the staff, and 31 that Entergy has satisfactorily addressed staff questions regarding the assessment, the staff 32 concludes that the external events assessments, combined with the results of the analysis of 33 the impacts of new fire and seismic information, is of sufficient quality to support the SAMA 34 evaluation. 35 F.2.2.3 Level 2 Fission Product Release Analysis 36 The staff reviewed the general process used by Entergy to translate the results of the Level 1 37 PRA into containment releases, as well as the results of the Level 2 analysis, as described in 38 the ER and in responses to staff RAIs (Entergy 2012a, 2012b, 2012c). Plant damage states 39 (PDSs) provide the link between the Level 1 and Level 2 CET analyses. In the PDS analyses, 40 Level 1 results are grouped together according to characteristics that define the status of the 41 reactor, containment, core cooling and heat removal systems at the time of core damage. The 42 PDSs identify which CET the Level 1 results are to be transferred. The information specifically 43 transferred through the PDSs and the direct linking of the Level 1 model with the Level 2 model 44 is: 45 Equipment failures in Level 1. The repair or recovery of failed equipment is 46 not allowed unless an explicit evaluation has been performed as part of the 47 Level 2 analysis. 48 Appendix F F-15 Reactor pressure vessel (RPV) status. The RPV pressure condition is 1 explicitly transferred from the Level 1 analysis to the CET. 2 Containment status. The containment status is explicitly transferred from the 3 Level 1 analysis to the CET. 4 Differences in accident sequence timing are transferred with the Level 1 5 sequences. Timing affects such sequences as: station blackout, internal 6 flooding, and containment bypass (interfacing systems LOCA). 7 The Level 2 analysis is linked to the Level 1 model by extending the model to include the CET, 8 which characterizes the accident phenomena. The CET considers the influence of physical and 9 chemical processes on the integrity of the containment and on the release of fission products. 10 The ER lists and describes 15 functional nodes incorporated in the GGNS Level 2 CETs. These 11 nodes (or branches or questions) address events occurring before vessel breach (including post 12 core damage depressurization and the potential for in -vessel recovery), the phenomena 13 associated ex -vessel accident progression (including early drywell and containment failure 14 caused by hydrogen ignition, high pressure melt ejection, steam explosions, and vapor 15 suppression failure) and the impact of mitigating systems on containment integrity including 16 containment sprays, containment heat removal, and containment venting. 17 The CET end points represent the outcomes of possible containment accident progression 18 sequences with each end point representing a complete sequence from initiator to release to 19 the environment. Associated with each CET end point or end state is an atmospheric 20 radionuclide source term including the timing, magnitude, and other conditions associated with 21 the release. Because of the large number of CET end points, they are grouped into release 22 categories (RCs). Entergy has established 13 RCs based on magnitude of release (four levels) 23 and timing of containment failure relative to the time of the declaration of a general emergency 24 (three time groups) with one RC for NCF. In response to a staff RAI, Entergy states that the 25 CET end points were assigned to the appropriate RC based on consideration of several 26 fundamental variables, including Level 1 accident sequence, initial containment failure mode, 27 RPV pressure at RPV breach, water availability for containment spray or flooding, and auxiliary 28 building effectiveness (Entergy 2012a). As previously stated for the updated analysis, the 29 frequency of the NCF release category was determined from the difference between the Level 1 30 CDF and the sum of frequencies for the other release categories (Entergy 2012c). 31 In developing the response to the staff RAI concerning the difference between the Level 1 and 32 Level 2 results, Entergy discovered and corrected a number of discrepancies in the Level 2 33 analysis. Despite having a relatively minor impact on the release category frequencies, these 34 corrections were described and incorporated in the updated analysis (Entergy 2012c, 2012d). 35 The release characteristic for each RC was determined from the results of MAAP 4.0.6 36 calculations for representative sequences selected for the RC. In response to staff RAIs 37 concerning the selection of representative sequences and the resulting release magnitude and 38 timings, Entergy identified the representative sequence for each RC and described the basis for 39 the selection. The predominant accident class (based on frequency) that contributes to each of 40 the radionuclide release categories was first identified. Once the accident class was identified, 41 the timings and magnitudes of the releases from the results of the various Level 2 MAAP runs 42 for that accident class were reviewed to select an appropriate sequence to represent the 43 release category (Entergy 2012a). 44 In response to a staff RAI to justify the representative sequence as the sequence with the 45 highest frequency versus selecting a sequence with a higher source term and a lower but still 46 important frequency, Entergy, in its updated analysis, revised the Level 3 consequence analysis 47 Appendix F F-16 to use the sequence with the highest source term (in terms of cesium iodide release fraction) to 1 represent each release category (Entergy 2012b, 2012c). 2 In the original ER Figure E.1-1, the NCF or negligible release category accounted for 44 percent 3 of the total release frequency, yet the offsite consequences from this release category were not 4 provided. In response to a staff RAI, Entergy revised the consequence analysis to incorporate 5 releases appropriate for the no -containment -failure category (Entergy 2012c). 6 As stated above, the current GGNS Level 2 PRA model is a complete revision of that used in 7 the IPE. No vulnerabilities were identified in the IPE back -end (i.e., Level 2) analysis performed 8 by the applicant. Risk related insights and improvements discussed in the IPE submittal were 9 discussed previously. The staff and contractor review of the IPE Level 2 analysis concluded 10 that the applicant has made reasonable use of the PRA techniques in performing the back -end 11 analysis and that the techniques employed are capable of identifying severe accident 12 vulnerabilities (NRC 1996). 13 In response to a staff RAI regarding the steps taken to assure the technical adequacy of the 14 new Level 2 model, Entergy stated that: 15 The developing contractor performed a self assessment of the Level 2 model 16 against the American Society of Mechanical Engineering (ASME)/American 17 Nuclear Society (ANS) PRA Standard implemented in accordance with 18 Regulatory Guide 1.200 (NRC 2009). 19 A technical acceptance review was performed by Entergy, with comments 20 resolved by the contractor. 21 An expert panel review of the Level 2 cutsets was performed as further 22 assurance of the quality of the Level 2 PRA. The expert panel consisted of 23 members of the Grand Gulf engineering, PRA, and operations departments. 24 From its review of the Level 2 methodology, Entergy's responses to staff RAIs, and the 25 subjection of the Level 2 model to an internal self -assessment and expert panel review, the staff 26 concludes that the Level 2 PRA, as used in the revised SAMA analysis, provides an acceptable 27 basis for evaluating the benefits associated with various SAMAs. 28 F.2.2.4 Level 3 Consequence Analysis 29 Entergy used the MACCS2 Version 1.13.1 code and a core inventory from a plant-specific 30 calculation to determine the offsite consequences from potential releases of radioactive material 31 (Entergy 2011). Using the ORIGEN 2.1 code, Entergy calculated the core inventory for 32 4 ,408 MWt, which is consistent with the EPU to 115 percent of the originally licensed 33 thermal power that was approved in July 2012. 34 The staff reviewed the process used by Entergy to extend the containment performance 35 (Level 2) portion of the PRA to an assessment of offsite consequences (Level 3 PRA model). 36 Source terms used to characterize fission product releases for the applicable containment 37 release categories and the major input assumptions used in the offsite consequence analyses 38 were considered. In response to a staff RAI on radionuclides from the core inventory used in 39 the radiological dose calculation, the applicant confirmed that all radionuclides listed in 40 Table E.1-12 of Attachment E to the ER (Entergy 2011) were included in the Level 3 analysis 41 (Entergy 2012a). Entergy clarified that consideration was given to the 24 -month refueling cycles 42 in the core radionuclide inventory determination and confirmed that no additional changes are 43 planned or being considered that would affect the core radionuclide inventory (Entergy 2012a). 44 Plant-specific input to the assessment includes the core release fractions and source terms for 45 each release category (Entergy 2011, Table E.1-9), site-specific meteorological data, projected 46 Appendix F F-17 population distribution and expected growth out to the year 2044 within an 80 -km (50-mi) radius, 1 emergency evacuation modeling, and economic data. This information is provided in 2 Section E.1.5 of Attachment E to the ER (Entergy 2011). Because the staff review determined 3 Entergy's source term information is consistent with NRC guidance (NEI 2005) and includes 4 satisfactory responses to NRC questions, the staff concludes that Entergy's source term 5 estimates are acceptable for use in the SAMA analysis. 6 Entergy considered site -specific meteorological data for the calendar years 2005 through 2009 7 and selected meteorological data from 2009 for the analysis as input to the MACCS2 code 8 because they resulted in the highest release quantities (Entergy 2011). Meteorological data 9 was acquired from the meteorological monitoring system at GGNS and regional National 10 Weather Service stations. Meteorological data included wind speed, wind direction, 11 atmospheric stability class, precipitation, and atmospheric mixing heights. In response to an 12 NRC RAI on the source of precipitation data, modeling of precipitation events, and precipitation 13 influence on calculated doses, Entergy stated that the total population dose and offsite 14 economic cost were calculated in determining the meteorological dataset for use in the SAMA 15 analysis (Entergy 2012a). 16 Missing meteorological data were estimated by data substitution using valid data from the 17 previous hour and other elevations on the meteorological tower. In response to questions on 18 the amount of missing data, Entergy clarified that 1 hour of precipitation data and 95 hours of 19 lower wind data were missing in the 8,760 -hour data set for 2009. When missing temperature 20 data were included, data substitution for missing data was applied to less than 3 percent of the 21 meteorological records (Entergy 2012a). The sources of data and models for atmospheric 22 dispersion used by the applicant are consistent with standard industry practice and acceptable 23 for calculating consequences from potential airborne releases of radioactive material. Because 24 multiple years of meteorological data were considered by the applicant and the annual data set 25 that resulted in the largest total population dose and offsite economic cost was selected for the 26 SAMA analysis, the staff finds that the data selection was performed in accordance with NRC 27 guidance (NEI 2005) and, thus, the meteorological data are appropriate for use in the SAMA 28 analysis. 29 Entergy projected population distribution and expected growth within a radius of 80 km (50 mi) 30 out to the year 2044 to account for an anticipated 33 -year period of remaining plant life for 31 13 years remaining on the original operating license plus a 20 -year license renewal period 32 (Entergy 2011). For counties or parishes with declining population projections, census data 33 from earlier years were used to avoid underestimating future population and estimated 34 population doses. The Entergy assessment incorporated U.S. Census 2010 data 35 (Enercon 2011). Entergy also used data on Louisiana and Mississippi state tourism to calculate 36 a transient to permanent population ratio to increase the projected population to account for 37 visitors (Entergy 2011). The applicant provided additional information on the incorporation of 38 transient population into the SAMA analysis (Entergy 2012a). Transient population was 39 determined from annual visitor numbers for the state and an average stay duration. The ratio of 40 transient additions to the permanent population was assumed to be the same for each county or 41 parish in the state. The staff considers the methods and assumptions for estimating population 42 reasonable and acceptable for purposes of the SAMA evaluation because its review of 43 Entergy's assessment determined that Entergy considered appropriate data sources, used a 44 reasonable approach for applying data, followed NRC guidance (NEI 2005), and added 45 conservatism by not accounting for projected population decline. 46 Entergy analyzed evacuation travel times for the Mississippi and Louisiana sides of the 47 Mississippi River within the 16-km (10-mi) emergency planning zone (Entergy 2011). The 48 analysis stated that 100 percent of the population would be prepared to begin evacuation within 49 Appendix F F-18 195 minutes from emergency notification for evacuation and 100 percent of the population could 1 be evacuated in 250 minutes or less following an evacuation order. The applicant concluded 2 that use of this information is still relevant because population within the emergency planning 3 zone has declined since the analysis in 2006. Entergy performed sensitivity analyses on 4 MACCS2 input parameters for an increased evacuation time delay and for a slower evacuation 5 speed. Consequence deviations were found to be less than 1 percent (Entergy 2011). 6 The staff notes that the percentage of population evacuated within the emergency planning 7 zone used by Entergy in the SAMA analysis exceeded the generic value of 99.5 percent 8 (NRC 1997 a, Section 5.7.1). However, the staff finds the applicant's value to be acceptable 9 because, based on the staff's review of the applicant's analysis, the staff determined that the 10 value was derived from a recent site -specific analysis that adequately considered the spatial 11 distribution of individuals in the two counties and one parish included within the emergency 12 planning zone, accounted for response differences due to the time of the week when the 13 evacuation order could be given, and addressed the influence of potential inclement weather 14 conditions. Given that the applicant performed a site -specific analysis to determine evacuation 15 assumptions and parameters, showed radiological consequence results were insensitive to 16 changes to certain evacuation parameters in a sensitivity study, and furnished a rationale for the 17 current appropriateness of the previously collected site -specific data, the staff concludes that 18 the evacuation assumptions and analysis are reasonable and acceptable for the purposes of the 19 SAMA analysis at GGNS. 20 Entergy used regional economic data from the 2007 U.S. Census of Agriculture, the 21 U.S. Department of Commerce, the U.S. Bureau of Labor Statistics, and the Consumer Price 22 Index for estimating farm and nonfarm values. County representation within a spatial element 23 was based on the county with the greatest area contribution. Data for certain counties and 24 parishes were not incorporated into the analysis because of small area contributions within a 25 spatial element. Regional crop values, obtained from 2007 U.S. Census of Agriculture data, 26 were summed with the 80 -km (50-mi) area and applied to the MACCS2 crop categories. 27 The staff considers these data sources used by the applicant to be current and finds them 28 acceptable for the SAMA analysis. Entergy estimated present dollar values based on the 29 internal events PRA at GGNS. Onsite economic costs provided the greatest contribution, about 30 70 percent of the total dollar value. Offsite economic costs contributed about 16 percent to the 31 total dollar value (Entergy 2012c, Table 4.21-1) for a discount rate of 7 percent, 20 -year license 32 renewal period, and updated CDF of 2.9 x 106 per year. Offsite population doses and onsite 33 doses contributed 13 and 1 percent of the total dollar value, respectively. Section F.6 provides 34 more detailed information on the cost -benefit calculation and its evaluation. 35 In summary, the staff reviewed Entergy's assessments of the source term, radionuclide 36 releases, meteorological data , projected population distribution, emergency response, and 37 regional economic data and evaluated Entergy's responses to the staff's requests for additional 38 information, as previously described in this subsection. Based on the staff's review, the staff 39 concludes that Entergy's consequence analysis is acceptable and Entergy's methodology to 40 estimate offsite consequences for GGNS and consideration of parameter sensitivities provide 41 an acceptable basis to assess the risk reduction potential for candidate SAMAs. Accordingly, 42 the staff based its assessment of offsite risk on the CDFs, population doses, and offsite 43 economic costs reported by Entergy. 44 F.3 Potential Plant Improvements 45 The process for identifying potential plant improvements (SAMAs), an evaluation of that 46 process, and the improvements evaluated in detail by Entergy are discussed in this section. 47 Appendix F F-19 F.3.1 Process for Identifying Potential Plant Improvements 1 Entergy's process for identifying potential plant improvements consisted of the following 2 elements: 3 review of industry documents and consideration of other plant-specific 4 enhancements not identified in published industry documents, 5 review of potential plant improvements identified in the GGNS IPE and 6 IPEEE, and 7 review of the risk -significant events in the current GGNS PRA Levels 1 and 2 8 models modifications for inclusion in the comprehensive list of SAMA 9 candidates. 10 Based on this process, Entergy identified an initial set of 249 candidate SAMAs, referred to as 11 Phase I SAMAs. In Phase I of the evaluation, Entergy performed a qualitative screening of the 12 initial list of SAMAs and eliminated SAMAs from further consideration using the following 13 criteria: 14 the SAMA modified features not applicable to GGNS, 15 the SAMA has already been implemented at GGNS, or 16 the SAMA is similar in nature and could be combined with another SAMA 17 candidate. 18 Based on this screening, 60 of the Phase I SAMA candidates were screened out because they 19 were not applicable to GGNS, 98 were screened out because they had already been 20 implemented at GGNS, and 28 were screened out because they were similar in nature and 21 could be combined with another SAMA candidate. Thus, a total of 186 SAMAs were eliminated, 22 leaving 63 for further evaluation. The results of the Phase I screening analysis for each SAMA 23 candidate were provided in a response to a staff RAI (Entergy 2012 a). The remaining SAMAs, 24 referred to as Phase II SAMAs, are listed in Table E.2-2 of Attachment E to the ER in the 25 original submittal (Entergy 2011) and in the revised analysis (Entergy 2012c). In Phase II, a 26 detailed evaluation was performed for each of the 63 remaining SAMA candidates, as discussed 27 in Sections F.4 and F.6 below. 28 F.3.2 Review of Entergy's Process 29 Entergy's efforts to identify potential SAMAs included explicit consideration of potential SAMAs 30 primarily for internal events because the current GGNS PRA does not include external events. 31 Potential SAMAs for external events were included based on the GGNS IPEEE probabilistic 32 analysis of internal fires and deterministic analysis of seismic and other external events. 33 The initial SAMA list was developed primarily from the review of generic industry SAMAs 34 (NEI 2005), as well as SAMAs from nine previous BWR license renewal applications. To this 35 list, a number of SAMAs were added based on improvements identified in the IPE and IPEEE. 36 Finally, SAMAs were added based on the review of the GGNS PRA Level 1 and Level 2 37 LERF results. 38 Entergy provided a tabular listing of the Level 1 PRA basic event CDF importances, down to a 39 risk reduction worth (RRW) of 1.005. SAMAs affecting these basic events would have the 40 greatest potential for reducing risk. An RRW of 1.005 corresponds to a reduction in CDF of 41 approximately 0.5 percent, given 100 percent reliability of the SAMA. Based on the maximum 42 averted cost risk including external events and uncertainty (see Section F.6.1 below), this 43 Appendix F F-20 equates to a benefit of approximately $17,000. This is well below the minimum implementation 1 cost associated with a procedure change given by Entergy of $25,000 (refer to Section F.5) and 2 is not cost beneficial. All basic events in the Level 1 listing were reviewed to identify potential 3 SAMAs and the listing annotated to indicate the Phase II SAMAs mitigating the failure 4 associated with the basic event. All basic events, except flag events, which do not represent 5 failures, were addressed by one or more Phase II SAMAs either from the list based on the 6 generic industry SAMAs or GGNS specific SAMAs (Entergy 2011). 7 Entergy also provided and reviewed the basic events with large early release frequency RRWs 8 down to 1.005. All basic events in the Level 2 LERF (or release category H/E) listing were 9 reviewed to identify potential SAMAs and all were addressed by one or more Phase II SAMAs, 10 except those that are flag or split fractions for which no SAMA would be appropriate 11 (Entergy 2011). The staff notes that because LERF makes up only about 10 percent of the CDF 12 and cost risk, LERF basic events with RRW less than about 1.1 would not be expected to be 13 cost beneficial unless they are also important to CDF. 14 As a result of the review of the Level 1 and Level 2 LERF basic events, four additional SAMAs 15 were identified as most of the basic events were addressed by SAMAs in the generic list. 16 Entergy also considered the potential plant improvements described in the GGNS IPE and 17 IPEEE in the identification of plant -specific candidate SAMAs. As a result of the review of the 18 IPE, 11 improvements were identified and are listed in Table E.2-1 of Attachment E of the ER. 19 The ER stated that five of these improvements have been implemented, one considered no 20 longer applicable and five retained as potential SAMAs. 21 As a result of the IPEEE, eight potential improvements concerning external flooding were 22 identified and are listed in Table E.2-1 of Attachment E of the ER. The ER stated that three of 23 these improvements have been implemented, but five are stated to not be cost beneficial 24 because of the minor risk from external flooding. They are: 25 Remove the wooden foot bridge crossing the northwest ditch near its 26 upstream end. 27 Remove the 38-cm (15-inch) corrugated metal pipe located in the small 28 auxiliary ditch parallel to the northwest ditch. 29 Re-hang the security fence gates west of the control building. 30 Grade down and remove the access road, the raised berm parallel to the 31 access road, and curbs adjacent to the access road. 32 Replace the C8 x 1.5 channel forming the flood barrier across the SSW A 33 equipment hatch opening. 34 In response to a staff RAI to provide further support for this disposition, Entergy stated that site 35 topography has changed considerably since the time of the IPEEE, and it addressed the current 36 status of the items listed above. All were either no longer applicable or otherwise adequately 37 addressed. Although the channel identified in the last bullet has not been replaced, Entergy 38 described features of the interior of the pump house, which minimize the impact of flooding, and 39 it stated that contingency actions are available to place sand bags in front of the doors 40 (Entergy 2012b). 41 In addition, Entergy stated it had re-evaluated the site during the 2011 Mississippi River fl ood 42 and determined it to be adequately protected against external flooding. The NRC resident and 43 region inspectors performed a review of the flooding procedures and site actions for seasonal 44 extreme flooding of the Mississippi River. Additionally, the inspectors performed an inspection 45 Appendix F F-21 of the protected area to identify any modifications to the site that would inhibit site drainage or 1 that would allow ingress past a barrier during a probable maximum precipitation event. No 2 recommendations for improved flo od protection were identified. Further, Entergy provided an 3 estimate of $2 , 300 in the original response (Entergy 2012a) and $2 ,200 in the revised analysis 4 (Entergy 2012c) for the benefit associated with the above probable maximum pr ecipitation 5 flooding modifications assuming they would eliminate the potential for core damage. This was 6 based on the IPEEE -assessed frequency of the probable maximum participation with coincident 7 wind wave activity. Based on the disposition of the cited improvements, the results of the recent 8 inspection and the low benefit associated with the modifications, the staff agrees with the 9 Entergy treatment of external flooding for the SAMA analysis. 10 Entergy also considered SAMAs for the two largest fire risk contributors based on the IPEEE 11 evaluation whose results are summarized in Table F-4. 12 The staff review of the Phase I SAMA screening identified a number of questions concerning the 13 adequacy of the basis for not considering the SAMA in the Phase II analysis. In response to an 14 RAI, Entergy (Entergy 2012b, 2012c, 2012d) stated that: 15 The Division 3 direct current (DC) system used for the HPCS is independent 16 of the other DC buses; hence, a SAMA to reduce the DC dependence 17 between high -pressure injection and the automatic depressurization system 18 has essentially been implemented at GGNS. 19 GGNS does not have another security or other emergency generator beyond 20 the three now installed that could be used for providing DC power through 21 direct connections to necessary loads following a station blackout. Therefore, 22 providing a procedure for this connection is not feasible. Also, for 23 nonstation -blackout situations, the benefit is less than the potential cost. 24 GGNS SAMA No. 6, improve 4.16 -kV bus cross-tie ability, already includes 25 installing key-locked control switches to enable alternating current bus 26 cross-ties; hence, a separate, new SAMA is not necessary. 27 The benefit of a SAMA to provide capability for alternate injection via the 28 react or water cleanup system was evaluated and found to be less than the 29 associated cost. Extensive modifications would be required to use the 30 reactor water cleanup system for alternate injection. Piping modifications and 31 a source of water would be needed because the only existing reactor water 32 cleanup suction source is the reactor pressure vessel itself. Key-locked 33 switches would have to be installed to permit bypassing existing reactor water 34 cleanup interlocks to permit use for injection. Also, the system has power 35 dependencies with the other alternate injection systems which would have to 36 be modified to obtain a significant benefit. 37 The severe accident guidelines implemented at GGNS included 38 considerations of flooding the reactor pressure vessel and/or containment to 39 various levels relative to the core and/or core debris and the impact on the 40 need for containment venting. No further restrictions are deemed 41 appropriate. 42 Simulator training at GGNS includes training on severe accident scenarios. 43 The staff review of the identification of SAMAs from the Level 1 and Level 2 importance analysis 44 identified several basic events for which the associated SAMA required further explanation or 45 justification. For several human error basic events with high failure probabilities, Entergy was 46 Appendix F F-22 asked to consider improvements in procedures or training. In response, Entergy described 1 each of the events as being combined with other human error basic events in the recovery rule 2 application process so that the combined failure rate was lower and supported by procedures 3 and training already in place. For several significant valve failures for high-pressure injection 4 systems, Entergy was asked to consider the potential for lower cost alternatives than the 5 SAMAs originally considered. In response, Entergy described the valves and stated that review 6 of generic SAMAs did not identify any feasible lower cost alternative. The potential for manually 7 opening the HPCS minimum flow isolation valve was considered and determined not to be 8 feasible in the time available (Entergy 2012a, 2012b). 9 As stated above, the GGNS IPEEE used a seismic margins assessment, which neither provided 10 quantitative risk information nor deterministic seismic capacities for specific GGNS systems, 11 structures, or components. It is thus not possible to identify and evaluate GGNS-specific 12 SAMAs to mitigate seismic risk. Based on the conclusions of the IPEEE seismic assessment 13 "-that Grand Gulf Nuclear Station is seismically rugged and that all components identified in 14 the Safe Shutdown Path have adequately considered the seismic input. All anchorage to these 15 components was found to be rugged ," the low GGNS internal events CDF, and the staff 16 observation that SAMAs to mitigate the impact of seismic events are expected to be relatively 17 costly and therefore are not likely to be cost beneficial, the staff concludes that the exclusion of 18 seismic-specific SAMAs from the evaluation is acceptable. 19 On the basis of its review of the foregoing information, the staff concludes that the set of SAMAs 20 evaluated in the ER, together with those identified in response to staff RAIs, addresses the 21 major contributors to both internal and external event CDF. 22 The staff questioned the applicant about additional potentially lower cost alternatives to some of 23 the SAMAs evaluated (NRC 2012a), including: 24 Revise procedures for operators to manually initiate emergency diesel 25 generator (EDG) heating, ventilation, and HVAC if the existing automatic logic 26 fails and/or procedures for the plant auxiliary operators to check on any 27 automatic start of the EDG could allow HVAC failures to be discovered and 28 might eliminate the need for alarms. 29 Provide directions to use jumpers to bypass the low reactor pressure interlock 30 instead of installing a bypass switch to allow operators to bypass interlock 31 circuitry. 32 Consider using other air compressors (service air) that might be connected to 33 the instrument air system instead of providing new compressors. 34 Consider improving control room fire -detection system response for a limited 35 number of key cabinets. 36 In response to the RAIs, the applicant addressed the suggested lower cost alternatives 37 (Entergy 2012a), which are discussed further in Section F.6.2. 38 The staff notes that the set of SAMAs submitted is not all -inclusive because additional, possibly 39 even less expensive, design alternatives can always be proposed. However, the staff 40 concludes that the benefits of any additional modifications are unlikely to exceed the benefits of 41 the modifications evaluated and that the alternative improvements likely would not cost less 42 than the least expensive alternatives evaluated, when the subsidiary costs associated with 43 maintenance, procedures, and training are considered. 44 The staff concludes that Entergy used a systematic and comprehensive process for identifying 45 potential plant improvements for GGNS, and that the set of SAMAs evaluated in the ER, 46 Appendix F F-23 together with those evaluated in response to staff inquiries, is reasonably comprehensive and, 1 therefore, acceptable. This search included reviewing insights from the GGNS plant-specific 2 risk studies that included internal initiating events as well as fire, seismic and other externa l 3 initiated events, and reviewing plant improvements considered in previous SAMA analyses. 4 F.4 Risk Reduction Potential of Plant Improvements 5 In the ER, the applicant evaluated the risk -reduction potential of the 63 SAMAs that were not 6 screened out in the Phase I analysis and retained for the Phase II evaluation. The SAMA 7 evaluations were performed using generally conservative assumptions. 8 Except for two SAMAs associated with internal fires, Entergy used model re -quantification to 9 determine the potential benefits for each SAMA. The CDF, population dose, and offsite 10 economic cost reductions were estimated using the GGNS 2010 EPU PRA model for the 11 non-fire SAMAs. The changes made to the model to quantify the impact of SAMAs are detailed 12 in Section E.2.3 of Attachment E to the ER (Entergy 2011). Bounding evaluations (or analysis 13 cases) were performed to address specific SAMA candidates or groups of similar SAMA 14 candidates. For the two fire -related SAMAs (SAMA Nos. 54 and 55), the benefit was 15 determined by assuming the CDF contribution for the fire area impacted by the SAMA was 16 reduced to zero and that the resulting benefit was determined by the product of the fraction of 17 the internal events total CDF represented by the fire area CDF and the maximum total internal 18 events benefit. 19 Table F-5 lists the assumptions considered to estimate the risk reduction for each of the 20 evaluated SAMAs, the estimated risk reduction in terms of percent reduction in CDF, population 21 dose risk and offsite economic cost risk, and the estimated total benefit (present value) of the 22 averted risk. The estimated benefits reported in Table F-5 reflect the combined benefit in both 23 internal and external events. The determination of the benefits for the various SAMAs is further 24 discussed in Section F.6. 25 Phase II evaluation, Cases 6 and 10, were used to evaluate SAMA No. 7 (install an additional, 26 buried offsite power source) and SAMA No. 18 (protect transformers from fire), respectively. 27 Entergy stated that for these cases, loss of offsite power (LOSP) initiating event frequencies 28 were multiplied by the ratios of 19/24 and 9/24 to account for severe weather and plant -centered 29 causes of LOSP, respectively. In response to a staff RAI concerning the source of these 30 values, Entergy stated that of the 24 LOSP events applicable to GGNS, 5 were weather -related, 31 15 were plant- or switchyard -related, and 4 were grid -related (Entergy 2012a). The ratio 19/24 32 then represents the fraction of LOSP frequency if severe weather causes are eliminated. 33 The ratio 9/24 then represents the fraction of LOSP frequency if the plant -centered causes 34 are eliminated. The staff concludes that this approach is valid for the assessment of 35 these SAMAs. 36 Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk 1 Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk 2 (OECR) 3 Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

% Risk Reduction Internal and External Benefit Internal and External Benefit with Uncertainty CDF PDR OECR Case 1. Direct Current Power Assumption:  Eliminates all cutsets for station blackout (Analysis Case for SAMA Nos. 1, 2, 11, 12, & 15) 1-Provide additional direct current battery capacity
$2,131,000 2-Replace lead

-acid batteries with fuel cells

$4,080,000 11-Portable generator for direct current power:  This SAMA involves the use of a portable generator to supply direct current power to the battery chargers during a station blackout.
$1,278,000 12-Portable generator for direct current power:  This SAMA involves the use of a portable generator to supply direct current power to the individual panels during a station blackout.
$1,278,000 15-Use direct current generators to provide power to operate the switchyard power control breakers while a 480

-V alternating current generator could supply the air compressors for breaker support

$1,428,000 37.1% 27.3% 21.3% $374,000 $1,121,000 Case 2. Improve Charger Reliability Assumption:  Failure of chargers contribution at zero (Analysis Case for SAMA Nos. 3 & 13) 3-Add battery charger to existing direct current system
$90,000  13-Proceduralize battery charger high

-voltage shutdown circuit inhibit $50,000 0.7% 2.0% 2.1% $1 2 , 100 $36 , 200 Case 3. Add Direct Current System Cross -Ties Assumption: Eliminates failure of direct current power gates (Analysis Case for SAMA No. 4) 4-Provide direct current bus cross -ties $300,000 3.6% 8.4% 9.0% $57,000 $171 ,000 F-24 Appendix F

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued) Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

% Risk Reduction CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 4. Increase Availability of Onsite Alternating Current Power Assumption:  Eliminates failure of diesel generators 11, 12, and 13 to their alternating current buses (Analysis Case for SAMA Nos. 5 & 8) 5-Provide an additional diesel generator
$20,000,000 8-Install a gas turbine generator with tornado protection
$2,000,000 42.1% 31.4% 25.6% $427 ,000 $1,282 ,000 Case 5. Improve Alternating Current Power Assumption:  Eliminates the loss of the most important 4.16-kV bus (Analysis Case for SAMA Nos. 6 & 17) 6-Improve 4.16

-kV bus cross-tie ability

$656,000  17-Provide alternate feeds to essential loads directly from an alternate emergency bus
$656,000  7.5% 29.5% 23.5% $145,000 $434,000 Case 6. Reduce Loss of Offsite Power During Severe Weather Assumption:  Eliminates the weather centered loss of offsite power initiating event (Analysis Case for SAMA No. 7) 7-Install an additional, buried offsite power source
$2,485,000 8.4% 6.0% 4.8% $84,200 $253,000 Case 7. Provide Backup Emergency Diesel Generator Cooling Assumption:  Eliminates failure of service water cooling to the emergency diesel generators (Analysis Case for SAMA Nos. 9 & 10) 9-Use fire water system as backup source for diesel cooling
$1,344,000 10-Add new backup source of diesel cooling
$2,000,000 7.6% 6.4% 4.6% $77,800 $234 ,000 Case 8. Increase Emergency Diesel Generator Reliability Assumption:  Eliminates failure of emergency diesel generators to run (Analysis Case for SAMA No. 14) 14-Provide a portable emergency diesel generator fuel oil transfer pump
$1,477,000 4.0% 4.3% 4.0% $45,500 $137 ,0 00   Appendix F F-25 Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued)

Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

 % Risk Reduction CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 9. Improve Diesel Generator Reliability Assumption:  Eliminates the common cause failure contribution of failure to start emergency diesel generators (Analysis Case for SAMA No. 16) 16-Provide a diverse swing diesel generator air start compressor
$100,000  0.8% 0.6% 0.4% $7, 8 50 $23 , 600 Case 10. Reduce Plant

-Centered Loss of Offsite Power Assumption: Removes contribution of plant- and switchyard -centered events (Analysis Case for SAMA No. 18) 18-Protect transformers from failure

$780,000  25.0% 17.6% 13.9% $250 ,000 $749,000 Case 11. Redundant Power to Torus Hard Pipe Vent Valves Assumption:  Eliminates failure of power to containment vents (Analysis Case for SAMA No. 19) 19-Provide redundant power to direct torus hard pipe vent valves to improve the reliability of the direct torus vent valves and enhance the containment heat removal capability.
$714,000  <0.1% 5.4% 6.0% $1 8 , 600 $55 , 700 Case 12. High Pressure Injection System Assumption:  Eliminates failure of the high pressure core spray (Analysis Case for SAMA Nos. 20 & 61) 20-Install an independent active or passive high

-pressure injection system

$8,800,000 61-Install a backup water supply and pumping capability that is independent of normal and emergency alternating current power $6,410,000 53.7% 6 2.2% 58.0% $622,000 $1,867,000   F-26 Appendix F

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued) Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

 % Risk Reduction CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 13. Extend Reactor Core Isolation Cooling Operation Assumption:  Eliminates failure of trip due to pressure (Analysis Case for SAMA No. 21) 21-Raise backpressure trip set points for high

-pressure coolant injection/reactor core isolation cooling [High -pressure coolant injection backpressure trip set point has already been raised. This SAMA evaluates raising the reactor core isolation cooling backpressure trip set point.]

$200,000  <0.1% <0.1% <0.1% <$1 <$1 Case 14. Improve Automatic Depressurization System Assumption:  Eliminates failure of automatic depressurization system valves (Analysis Case for SAMA No. 22) 22-Modify automatic depressurization system components to improve reliability [This SAMA will add larger accumulators thus increasing reliability during station blackouts].
$1,177,000 33.6% 12.7% 13.1% $310 ,000 $930 ,000 Case 15. Improve Automatic Depressurization System Signals Assumption:  Eliminates failure of the safety relief valve failing to open (Analysis Case for SAMA No. 23) 23-Add signals to open safety relief valves automatically in a main steam isolation valve closure transient.
$1,500,000 6.0% 4.5% 4.2% $61 , 900 $186 ,000 Case 16. Low Pressure Injection System Assumption:  Eliminates failure of the low pressure coolant injection and low pressure core spray (Analysis Case for SAMA No. 24) 24-Add a diverse low

-pressure injection system.

$8,800,000 11.4% 45.4% 40.5% $229,000 $687,000   F-27 Appendix F

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued) Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

 % Risk Reduction CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 17. Emergency Core Cooling System Low-Pressure Interlock Assumption:  Eliminates emergency core cooling system permissives and interlock failure (Analysis Case for SAMA No. 25) 25-Install a bypass switch to allow operators to bypass the low reactor pressure interlock circuitry that inhibits opening the low-pressure coolant injection or core spray injection valves following sensor or logic failures that prevent all low pressure injection valves from opening. $1,000,000 
 <0.1% <0.1% <0.1% $0 $0 Case 18. Residual Heat Removal Heat Exchangers Assumption:  Eliminates failure of standby service water to provide cooling to the residual heat removal heat exchangers (Analysis Case for SAMA No. 26) 26-Implement modifications to allow manual alignment of the fire water system to residual heat removal heat exchangers.
$1,950,000 12.5% 30.9% 34.1% $205,000 $616,000 Case 19. Emergency Service Water System Reliability Assumption:  Eliminates failure of service water pumps (Analysis Case for SAMA No. 27) 27-Add service water pump to increase availability of cooling water $5,900,000 3.5% 6.0% 6.3% $4 7, 200 $142,000 Case 20. Main Feedwater System Reliability Assumption:  Eliminates failure to inject from feedwater (Analysis Case for SAMA No. 28) 28-Add a motor-driven feed water pump
$1,650,000 7.5% 22.2% 23.7% $134 ,000 $402 ,000 Case 21. Increase Availability of Room Cooling Assumption:  Eliminates failure of room cooling to low

-pressure core spray, high -pressure core spray, standby service water and safeguard switchgear battery rooms (Analysis Case for SAMA No. 29) 29-Provide a redundant train or means of ventilation

$2,203,000 17.9% 15.1% 16.0% $1 93 ,000 $5 80 ,000 F-28 Appendix F

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued) Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

 % Risk Reduction CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 22. Increase Availability of the Diesel Generator System through HVAC Improvements Assumption:  Eliminates failure of HVAC  for diesel generator rooms (Analysis Case for SAMA Nos. 30, 32, & 33) 30-Add a diesel building high temperature alarm or redundant louver and thermostat
$1,305,000 32-Diverse emergency diesel generator HVAC logic $1,148,000 33-Install additional fan and louver pair for emergency diesel generator HVAC $6,000,000 23.9% 16.6% 12.3% $237,000 $711,000 Case 23. Increased Reliability of Room Cooling for High

-Pressure Coolant injection and Reactor Core Isolation Cooling Assumption: Eliminates failure of power to the high -pressure core spray pump room cooler (Reactor core isolation cooling pump continued operation is not dependent on room cooling.)

(Analysis Case for SAMA No. 31) 31-Create ability to switch high

-pressure coolant injection and reactor core isolation cooling room fan power supply to direct current in an station blackout event

$300,000  <0.1% <0.1% <0.1% $0 $0 Case 24. Increase Reliability of Instrument Air Assumption:  Eliminates failure of the instrument air (Analysis Case for SAMA Nos. 34 & 35) 34-Modify procedure/hardware to provide ability to align diesel power to more air compressors
$1,200,000 35-Replace service and instrument air compressors with more reliable compressors which have self

-contained air cooling by shaft-driven fans

$1,395,000 10.6% 17.1% 18.7% $143,000 $428,000  F-29 Appendix F

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued) Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

 % Risk Reduction CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 25. Backup Nitrogen to Safety Relief Valve   Assumption:  Eliminates operator failure to install air bottles (Analysis Case for SAMA No. 36) 36-Install nitrogen bottles as backup gas supply for safety relief valves
$1,723,000 5.9% 0.1% 0.0% $46, 900 $141,000 Case 26. Improve Availability of Safety Relief Valves and Main Steam Isolation Valves  Assumption:  Eliminates failure of non

-automatic-depressurization -system safety relief valves (Analysis Case for SAMA No. 37) 37-Improve safety relief valve and main steam isolation valve pneumatic components

$1,500,000 33.7% 12.9% 13.3% $312,000 $935,000 Case 27. Improve Suppression Pool Cooling Assumption:  Eliminates the failure of flow to the residual heat removal heat exchangers (Analysis Case for SAMA No. 38) 38-Install an independent method of suppression pool cooling
$5,800,000 1 2.5% 3 0.9% 3 4.1% $20 6 ,000 $617,000 Case 28. Increase Availability of Containment Heat Removal Assumption:  Eliminates failure of cooled flow from residual heat removal pump A and B (Analysis Case for SAMA Nos. 39 & 41) 39-Procedural change to cross

-tie open cycle cooling system to enhance containment spray system

$25,000 41-Use the fire water system as a backup source for the drywell spray system
$1,950,000 17.8% 45.6% 50.2% $297 ,000 $892 ,000 F-30 Appendix F

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued) Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

 % Risk Reduction CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 29. Decay Heat Removal Capability - Drywell Spray Assumption:  Eliminates failure of residual heat removal spray (Analysis Case for SAMA No. 40)  17.8% 45.6% 50.2% $297,000 $892,000 40-Install a passive drywell spray system to provide redundant drywell spray method
$5,800,000 Case 30. Increase Availability of the Condensate Storage Tank Assumption:  Eliminates failure of high

-pressure core spray and reactor core isolation cooling suction (Analysis Case for SAMA No. 42) 42 - Enhance procedures to refill condensate storage tank from demineralized water or service water system

$200,000  4.4% 12.6% 13.5% $77,000 $231,000 Case 31. Filtered Vent to Increase Heat Removal Capacity for Non-Anticipated Transient without Scram Events Assumption:  Reduces the baseline accident progression source terms by a factor of 2 (Analysis Case for SAMA No. 43) 43-Install a filtered containment vent to provide fission product scrubbing
$1,500,000 0.0% 31.6% 40.6% $118,000 $354,000 Case 32. Reduce Hydrogen Ignition Assumption:  Eliminates failure of hydrogen igniters (Analysis Case for SAMA Nos. 44 & 45) 44-Provide post

-accident containment inerting capability

$2,665,000 45-Install a passive hydrogen control system
$760,000  0.0% 18.8% 19.9% $6 2, 500 $188 ,000 F-31 Appendix F

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued) Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

 % Risk Reduction CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 33. Controlled Containment Venting Assumption:  Eliminates failure of air

-operated valves to open (Analysis Case for SAMA Nos. 46 & 47) 46-Provide passive overpressure relief by changing the containment vent valves to fail open and improving the strength of the rupture disk

$1,000,000 47-Enable manual operation of all containment vent valves via local controls
$150,000  1.3% 3.1% 3.5% $21,200 $63,600 Case 34. Interfacing Systems Loss of Coolant Accident Assumption:  Removes all interfacing systems LOCA initiators (Analysis Case for SAMA Nos. 48, 50, & 51) 48-Increase frequency of valve leak testing to reduce interfacing systems LOCA frequency $100,000 50-Revise emergency operating procedures to improve interfacing systems LOCA identification
$50,000 51-Improve operator training on interfacing systems LOCA coping $112,000  0.0% 0.1% 0.1% $128 $385 Case 35. Main Steam Isolation Valve Design Assumption:  Eliminates failure of the main steam isolation valves to close or remain closed (Analysis Case for SAMA No. 49) 49-Improve main steam isolation valve design to decrease the likelihood of containment bypass scenarios
$1,000,000 0.0% 0.1% 0.0% $5 $15    F-32 Appendix F

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued) Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

 % Risk Reduction   CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 36. Standby Liquid Control System Assumption:  Eliminates failure to initiate standby liquid control and failures of alternate boron injection (Analysis Case for SAMA No. 52) 52-Increase boron concentration in the standby liquid control system [Reduced time required to achieve shutdown provides increased margin in the accident timeline for successful initiation of standby liquid control]
$50,000  0.1% 0.1% 0.1% $590 $1,771 Case 37. Safety Relief Valve Reseat Assumption:  Eliminates the initiator for safety relief valves inadvertently being open and basic events for stuck open safety relief valves (Analysis Case for SAMA No. 53) 53-Increase safety relief valve reseat reliability to address the risk associated with dilution of boron caused by the failure of the safety relief valves to reseat after standby liquid control injection
$2,200,000 4.2% 3.9% 4.1% $46 , 500 $139 ,000 Case 38. Add Fire Suppression a  Assumption:  Eliminates fire CDF from the critical switchgear rooms (Analysis Case for SAMA No. 54) 54-Add automatic fire suppression systems to the dominant fire zones $375,000  n/a n/a n/a $32,600 $97 , 800 Case 39. Reduce Risk from Fires that Require Control Room Evacuation a Assumption:  Eliminates fire CDF from the main control room (Analysis Case for SAMA No. 55) 55-Upgrade the alternate shutdown system panel to include additional system controls for opposite division
$787,000  n/a n/a n/a $134 ,000 $4 0 2,000  F-33 Appendix F

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued) Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

 % Risk Reduction CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 40. Large Break Loss of Coolant Accident Assumption:  Eliminates large break LOCA (Analysis Case for SAMA No. 56) 56-Provide digital large break LOCA protection to identify symptoms and/or precursors of a large break LOCA (a leak before break) $2,000,000 3.3% 13.3% 14.5% $71 , 300 $214 ,000 Case 41. Trip/Shutdown Risk Assumption:  Reduces all initiating events except pipe breaks, floods,  and loss of offsite power by 10 percent (Analysis Case for SAMA No. 57) 57-Generation risk assessment implementation into plant activities (trip/shutdown risk modeling)
$500,000  5.7% 6.1% 6.5% $65 , 800 $19 7,000 Case 42. Increase Availability of Pump House Ventilation System for Standby Service Water Assumption:  Eliminates failure of standby service water pump house ventilation (Analysis Case for SAMA No. 58) 58-Increase the training emphasis and provide additional control room indication on the operational status of standby service water pump house ventilation system
$100,000  1.5% 1.6% 1.6% $16 , 800 $50,400  F-34 Appendix F

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Analysis for Grand Gulf Nuclear Station. Percentage Risk Reductions are Presented for Core Damage Frequency (CDF), Population Dose Risk (PDR), and Offsite Economic Cost Risk (OECR) (continued) Analysis Case, Analysis Assumption, Individual SAMAs, and Cost Estimates

 % Risk Reduction CDF    PDR    OECR Internal and External Benefit Internal and External Benefit with Uncertainty Case 43. Increase Recovery Time of Emergency Core Cooling System Upon Loss of Standby Service Water Assumption:  Eliminates failure of standby service water to the low pressure core spray room cooler (Analysis Case for SAMA No. 59) 59-Increase operator training for alternating operation of the low-pressure emergency core cooling system pumps (low-pressure coolant injection and low

-pressure core spray) for loss of standby service water scenarios

$50,000  4.5% 5.2% 5.5% $53,300 $160 ,000 Case 44. Additional Containment Heat Removal Assumption:  Eliminates failure of suppression pool cooling and containment spray systems (Analysis Case for SAMA No. 60) 60-Install an additional method of heat removal from containment
$4,352,000 17.8% 47.1% 51.9% $302 ,000 $907 ,000 Case 45. Improve Heat Exchanger Availability for Residual Heat Removal Assumption:  Eliminates failure of residual heat removal heat exchanger cooler inlet and outlet valves (Analysis Case for SAMA No. 62) 62-Add a bypass around the residual heat removal heat exchanger inlet and outlet valves
$2,832,000 2.0% 6.4% 7.0% $37,800 $1 13 ,0 00 Case 46. Improve Lube Oil Cooling for Reactor Core Isolation Cooling Assumption:  Eliminates failure to cool lube oil for reactor core isolation cooling (Analysis Case for SAMA No. 63) 63-Add a redundant reactor core isolation cooling lube oil cooling path $1,803,000 7.4% 3.1% 2.5% $68,200 $205,000 a These analysis cases only affected external events and were evaluated differently.

b Clarified by the applicant to be reduced by 10 percent in response to a request for additional information. F-35 Appendix F

Appendix F F-36 Case 8, used to evaluate the benefit of SAMA No. 14 (provide a portable EDG fuel oil transfer 1 pump), assumed that the EDGs ' failure to run was eliminated. In its review, the staff noted that 2 the failure to run of the Division 3, HPCS diesel was not eliminated. In response to an RAI, 3 Entergy stated that the Division 3 diesel did not have a common fuel oil transfer pump with the 4 other two EDGs and i f the Division 3 diesel were included in the assessment, either two portable 5 fuel transfer pumps would be needed, or the pump would have to be moved to fill the additional 6 day tank. Entergy stated this would increase implementation costs and would not change the 7 results of the cost -benefit assessment (Entergy 2012a). While the staff disagrees that the 8 added cost of moving the portable transfer pump would be appreciable, in considering the 9 conservatism in the assumption that all failures to run would be eliminated by having a portable 10 pump, the staff concludes that the assessment of the benefit of SAMA No. 14 is acceptable. 11 Case 32, used to evaluate the benefit of SAMAs Nos. 44 and 45 (both changes to eliminate 12 hydrogen ignition containment failures), was evaluated by eliminating failures of the hydrogen 13 igniter system. A staff RAI on the original ER submittal (NRC 2012a) noted that Entergy results 14 indicated the assumption would lead to a 16 percent reduction in CDF, whereas it should have 15 no impact on CDF. In response, Entergy stated that the elimination of igniter failures in the 16 Level 2 analysis was done by setting a gate to TRUE, which eliminated all hydrogen igniter 17 failure cut sets from the Level 2 results, and therefore, led to the reduction in CDF in the original 18 analysis (Entergy 2012a). This inconsistency was resolved in the revised SAMA analysis. In 19 the revised analysis, there is no reduction in CDF for Case 32 (Entergy 2012c). The staff 20 concludes that the revised evaluation, as described, is appropriate for the SAMA analysis. 21 In the description of the updated analysis, Entergy stated that the assumptions for evaluating 22 the benefit for Case 5 used for SAMA No. 6 (Improve 4.16 -kV bus cross -tie ability) and SAMA 23 No. 17 (Provide alternate feeds to essential loads directly from an alternate emergency bus) 24 were revised to remove some of the excess conservatism in the prior evaluation 25 (Entergy 2012c). Because the applicant's additional information addressed the questions raised 26 by the staff and provided a sufficient basis for justifying the cost -benefit conclusions, the staff 27 concludes that the revised evaluation, as described, is appropriate for the SAMA analysis. 28 F.5 Cost Impacts of Candidate Plant Improvements 29 Entergy estimated the costs of implementing the 63 Phase II SAMAs through the use of other 30 licensees' estimates for similar improvements and the development of site -specific cost 31 estimates where appropriate. 32 Entergy stated that the following cost ranges were used based on the review of previous 33 SAMA applications. 34 Table F-6. Estimated Cost Ranges for SAMA Applications 35 Type of Change Estimated Cost Range Procedural only

$25K-$50K Procedural change with engineering or training required
$50K-$200K Procedural change with engineering and testing or training required $200K-$300K Hardware modification
$100K to > $1000K

Appendix F F-37 Entergy stated that the GGNS site -specific cost estimates were based on the engineering 1 judgment of project engineers experienced in performing design changes at the facility. 2 The detailed cost estimates considered engineering, labor, materials, and support functions, 3 such as planning, scheduling, health physics, quality assurance, security, safety, and fire watch. 4 The estimates included a 20 percent contingency on the design and installation costs but did not 5 account for inflation, replacement power during extended outages necessary for SAMA 6 implementation, or increased maintenance or operation costs following SAMA implementation. 7 In response to a staff RAI for more information concerning the applicability of cost estimates 8 taken directly from previous SAMA applications, Entergy stated that engineering judgment by 9 project engineers familiar with the costs of modifications at Entergy plants was used to 10 determine if the cited cost estimates from other SAMA analyses were valid for GGNS. If the 11 GGNS project engineers' rough conceptual cost estimate of the modification was larger than the 12 other plant's cost estimate, the other plant 's estimate was adopted without further detailed cost 13 analysis (Entergy 2012a). 14 The staff reviewed the applicant's cost estimates, presented in Table E.2-2 of Attachment E to 15 the ER in the original submittal (Entergy 2011) and in response s to staff RAIs 16 (Entergy 2012a, 2012c). For certain improvements, the staff also compared the cost estimates 17 to estimates developed elsewhere for similar improvements, including estimates developed as 18 part of other licensees' analyses of SAMAs for operating reactors. 19 The staff noted that the new plant -specific cost estimates incorporated into the revised 20 cost-benefit analysis for a number of SAMAs are considerably greater than those previously 21 given and appear large compared to that implied by the SAMA description. In response to an 22 RAI, Entergy provide d more details on what is specifically included in the new cost estimates for 23 SAMA Nos. 1, 9, 11, 14, and 63 to justify those estimates (Entergy 2012d). Based on the 24 additional information provided, comparison of the costs with those provided in other SAMA 25 submittals, conservatisms in the determination of the benefit, and consideration of the margins 26 between the cost and the benefit, the staff concludes that the applicant's cost estimates are 27 acceptable for determining the cost -benefit ratio of these SAMAs. 28 In the revised cost -benefit analysis, Entergy stated that the cost estimate for SAMA No. 6 29 (Improve 4.16 -kV bus cross-tie ability) and SAMA No. 17 (Provide alternate feeds to essential 30 loads directly from an alternate emergency bus) of $656,000 was taken from the Susquehanna 31 SAMA analysis. In response to a staff RAI that pointed out the value used from Susquehanna 32 was for two reactor units, Entergy described the basis for concluding that the cost for these 33 SAMAs at GGNS would exceed the $656,000 value and justified use of this value for the GGNS 34 SAMA analysis (Entergy 2012d) on the basis of extensive changes to the electrical bus control 35 scheme, supporting calculations, documentation changes, required hardware, installation, and 36 testing. Based on the information provided for implementing these SAMAs at GGNS, the staff 37 concludes that Entergy's cost estimates are acceptable for determining the cost -benefit ratio of 38 these SAMAs. 39 The staff concludes that, with the above clarifications, the cost estimates provided by Entergy 40 are sufficient and appropriate for use in the SAMA evaluation. 41 Appendix F F-38 F.6 Cost-Benefit Comparison 1 Entergy's cost-benefit analysis and the staff's review are described in the following sections. 2 F.6.1 Entergy's Evaluation 3 The methodology used by Entergy was based primarily on NRC's guidance for performing 4 cost-benefit analysis; i.e., NUREG/BR-0184 (NRC 1997a). As described in Section 4.21.5.4 of 5 the ER (Entergy 2011), the net value was determined for each SAMA according to the 6 following formula: 7 Net Value = (APE + AOC + AOE + AOSC) - COE 8 where 9 APE (averted public exposure) = present value of APE costs ($) 10 AOC (averted offsite property damage costs) = present value of AOC costs ($) 11 AOE (averted occupational exposure) = present value of AOE costs ($) 12 AOSC (averted onsite costs) = present value of AOSC ($) 13 COE = cost of enhancement ($) 14 If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the 15 benefit associated with the SAMA, and it is not considered to be cost beneficial. Entergy's 16 derivation of each of the associated costs is summarized next. 17 NEI guidance states that two sets of estimates should be developed for discount rates of 18 7 percent and 3 percent (NEI 2005). Entergy provided a base set of results using a discount 19 rate of 7 percent and a 20-year license renewal period. Two sensitivity cases were developed 20 by Entergy

one used a discount rate of 7 percent with a 33-year period for remaining plant life 21 and another used a more conservative discount rate of 3 percent with a 20-year license 22 renewal period. 23 F.6.1.1 Averted Public Exposure (APE) Costs 24 Entergy defined APE cost as the monetary value of accident risk avoided from population doses 25 after discounting (Entergy 2011). The APE costs were calculated using the following formula:

26 APE = -rem per year) 27 x monetary equivalent of unit dose

($2 ,000 per person

-rem) 28 x present value conversion corresponding to NRC (1997a, Equation on p. 5.27 29 for C when a facility is already operating) 30 The annual reduction in public exposure was calculated according to the following formula: 31 Annual reduction in public exposure = (Accident frequency without modification 32 accident population dose without modification) - (Accident frequency with 33 modification x accident population dose with modification) 34 As stated in NUREG/BR -0184 (NRC 1997a), it is important to note that the monetary value of 35 the public health risk after discounting does not represent the expected reduction in public 36 health risk due to a single accident. Rather, it is the present value of a stream of potential 37 losses extending over the remaining lifetime (in this case, the 20 -year renewal period) of the 38 facility. Thus, it reflects the expected annual loss due to a single accident, the possibility that 39 such an accident could occur at any time over the renewal period, and the effect of discounting 40 Appendix F F-39 these potential future losses to present value. As previously stated, Entergy also considered an 1 extended period of 33 years for the remaining facility lifetime as a sensitivity case. For a 2 discount rate of 7 percent and a 20 -year license renewal period in the revised analysis with a 3 CDF of 2.93 x 106 per year, the applicant calculated an APE cost of $13,116 for internal events 4 (Entergy 2012c). 5 F.6.1.2 Averted Offsite Property Damage Costs (AOC) 6 Entergy defined AOC as the monetary value of risk avoided from offsite property damage after 7 discounting (Entergy 2011). The AOC values were calculated using the following formula: 8 AOC = Annual reduction in offsite property damage x present value conversion 9 corresponding to NRC (1997a, Equation for C on p. 5.27 for an operational 10 facility). 11 The annual reduction in offsite property damage was calculated according to the 12 following formula: 13 Annual reduction in offsite property damage = (Accident frequency without 14 modification x accident property damage without modification) - (Accident frequency 15 with modification x accident property damage with modification) 16 For a discount rate of 7 percent and a 20-year license renewal period in the revised analysis 17 with a CDF of 2.93 x 106 per year, the applicant calculated an AOC of $16,264 for internal 18 events (Entergy 2012c). 19 F.6.1.3 Averted Occupational Exposure (AOE) Costs 20 Entergy defined AOE as the avoided onsite exposure (Entergy 2011). Similar to the APE 21 calculations, the applicant calculated costs for immediate onsite exposure. Long -term onsite 22 exposure costs were calculated consistent with guidance in NUREG/BR -0184 (NRC 1997a), 23 which included an additional term for accrual of long -term dose s. 24 Entergy derived the values for averted occupational exposure from information provided in 25 Section 5.7.3 of NUREG/BR -0184 (NRC 1997a). Best estimate values provided for immediate 26 occupational dose (3,300 person-rem) and long -term occupational dose (20,000 person-rem 27 over a 10-year clean -up period) were used. The present value of these doses was calculated 28 using the equations provided in the handbook in conjunction with a monetary equivalent of unit 29 dose of $2,000 per person -rem, a real discount rate of 7 percent, and a time period of 20 years 30 to represent the license renewal period. Entergy assumed an accident frequency with 31 modification of zero to overestimate and bound the long -term onsite exposure costs. Immediate 32 and long-term onsite exposure costs were summed to determine AOE cost. For a CDF of 33 2.93 x 106 per year in its revised analysis, the applicant calculated an AOE cost of $1,115 for 34 internal events (Entergy 2012c). 35 F.6.1.4 Averted Onsite Costs (AOSC) 36 AOSC include averted cleanup and decontamination costs and averted power replacement 37 costs. Repair and refurbishment costs are considered for recoverable accidents only and not 38 for severe accidents. The applicant derived the values for AOSC based on information provided 39 in Section 5.7.6 of NUREG/BR -0184 (NRC 1997a). This cost element was divided into two 40 parts: the onsite cleanup and decontamination cost, also commonly referred to as averted 41 cleanup and decontamination costs; and the replacement power cost (RPC). 42 Appendix F F-40 Averted cleanup and decontamination costs (ACC) were calculated using the following formula: 1 ACC = Annual CDF reduction 2 x present value of clean -up costs per core damage event 3 x present value conversion factor 4 The total cost of clean -up and decontamination subsequent to a severe accident is estimated in 5 NUREG/BR-0184 to be $1.5 x 10 9 (undiscounted). This value was converted to present costs 6 over a 10-year clean -up period and integrated over the term of the proposed license extension. 7 Long-term RPC s were calculated using the following formula: 8 RPC = Annual CDF reduction 9 x present value of replacement power for a single event 10 x factor to account for remaining service years for which replacement power 11 is required 12 x reactor power scaling factor 13 Accounting for the GGNS EPU, the applicant based its calculations on a net electric output of 14 1, 475 megawatt s-electric (MWe) and scaled up from the 910 MWe reference plant in 15 NUREG/BR-0184 (NRC 1997a). Therefore, the applicant applied a power -scaling factor of 16 1.62 (1475 / 910 = 1.62) to determine the RPCs. For a CDF of 2.93 x 106 per year in its 17 revised analysis, Entergy calculated an AOSC of $71,500 from internal events for the 20-year 18 license renewal period (Entergy 2012c). 19 Using the above equations, Entergy estimated the total present dollar value equivalent 20 associated with completely eliminating severe accidents due to internal events at GGNS to be 21 about $101,995 (Entergy 2012c, Table 4.21-1). The applicant multiplied the internal events 22 estimated benefit by 11 to account for the risk contributions from external events and yield the 23 internal and external benefit. Additionally, internal and external benefits were multiplied by a 24 factor of 3 to account for uncertainties in the CDF calculation (Entergy 2011). In total, a 25 multiplication factor of 33 was applied to the estimated benefit from internal events to obtain the 26 total estimated benefit for internal and external events with uncertainty, which was used in 27 Entergy's cost -benefit comparisons. 28 F.6.1.5 Entergy's Results 29 If the implementation costs for a candidate SAMA exceeded the calculated benefit, the SAMA 30 was determined to be not cost beneficial. If the benefit exceeded the estimated cost, the SAMA 31 candidate was considered to be cost beneficial. In Entergy's original submittal and revised 32 analysis, three SAMA candidates were found to be potentially cost beneficial (Entergy 2011, 33 Section 4.21.6; Entergy 2012c, Table 4.21-2). Results of the cost -benefit evaluation are 34 presented in Table F-5. 35 The potentially cost -beneficial SAMAs are: 36 SAMA No. 39-Change procedure to cross tie open cycle cooling system to 37 enhance containment spray system, 38 SAMA No. 42-Enhance procedures to refill condensate storage tank from 39 demineralized water or service water system), and 40 SAMA No. 59-Increase operator training for alternating operation of the 41 low-pressure emergency core cooling system pumps (low -pressure coolant 42 Appendix F F-41 injection and low -pressure core spray) for loss of standby service water 1 scenarios. 2 Entergy stated that a condition report to implement these potentially cost -beneficial SAMAs has 3 been initiated within the corrective action process. 4 A sensitivity analysis considered two cases: a discount rate of 7 percent with a 33 -year period 5 for remaining plant life and a more conservative discount rate of 3 percent with a 20 -year 6 license renewal period (Entergy 2011, Section 4.21.5 and Table E.2-3; Entergy 2012c, 2012d). 7 Based on its sensitivity analysis in the original submittal and revised analysis, Entergy did not 8 identify any additional cost -beneficial SAMAs. 9 F.6.2 Review of Entergy's Cost-Benefit Evaluation 10 Based primarily on NUREG/BR -0184 (NRC 1997a) and NEI guidelines on discount rate s 11 (NEI 200 5), the staff determined the cost-benefit analysis performed by Entergy was consistent 12 with the guidance. Three SAMA candidates were found to be potentially cost beneficial. 13 The applicant considered possible increases in benefits from analysis uncertainties on the 14 results of the SAMA assessment. In the ER (Entergy 2011), Entergy stated that the 15 95 th percentile value of the GGNS CDF was a factor of 2.38 greater than the mean CDF. 16 A multiplication factor of 3 was conservatively selected by the applicant to account for 17 uncertainty. This multiplication factor was applied in addition to a separate multiplication factor 18 of 11 for CDF increases due to external events. Entergy's assessment accounted for the 19 potential risk -reduction benefits associated with both internal and external events. The staff 20 considers the multipliers of 3 for uncertainty and 11 for external events provide adequate margin 21 and are acceptable for the SAMA analysis. 22 At the staff's request, Entergy provided further information on the uncertainty analysis that 23 indicated the 95 th percentile CDF was 7.14 x 106/yr for a cutset truncation of 1 x 1011/yr. The 24 point estimate and mean values for CDF were 2.82 x 106/yr and 3.00 x 106/yr 25 (Entergy 2012a). The ratio of the 95 th percentile to the point estimate, which should be used in 26 determining the uncertainty multiplier, is therefore 2.53 versus the 2.38 discussed above. 27 Because a multiplier of 3 was conservatively used in the assessment, the results of the SAMA 28 assessment are not affected by this correction. 29 Sensitivity to the discount rate and time period for remaining plant life was analyzed by the 30 applicant. Compared to Entergy's baseline benefits in the original submittal (Entergy 2011, 31 Table E.2-3), benefit increases for individual SAMAs ranged from 20 to 59 percent and from 32 20 to 40 percent for the first and second sensitivity cases, respectively. Additional sensitivity 33 analyses were performed on MACCS2 input parameters for an increased evacuation time delay 34 and for a slower evacuation speed. The applicant indicated consequence deviations of less 35 than 1 percent to the sensitivity case results for the MACCS2 parameters (Entergy 2011). 36 The staff requested additional information related to costs for a few SAMAs within $10,000 of 37 estimated benefits in the sensitivity analysis. Entergy provided additional information that the 38 margin between the cost benefit and actual implementation cost would be greater than $10,000 39 (Entergy 2012a, 2012c). For SAMA No. 13 on a procedure change to inhibit high -voltage circuit 40 shutdown for battery charging, Entergy explained that the cost -benefit ratio in the SAMA 41 analysis is an overestimate because other failure mechanisms, not precluded by the procedure 42 change, were included into the benefit calculation. The implementation cost selected by 43 Entergy was the minimum value from the typical range for procedure changes with engineering 44 or training required. For SAMA Nos. 14 and 63 (provide portable EDG fuel oil transfer pump 45 and adding a redundant path for reactor core isolation cooling lube oil cooling), Entergy 46 Appendix F F-42 provided refined, pl ant-specific cost estimates of $1,477,000 and $1,803,000, respectively, for 1 these modifications that involve piping changes to safety -related systems. Based on this 2 additional information, additional cost -beneficial SAMAs were not identified. 3 Sensitivity analysis results were recast in the SAMA reanalysis (Entergy 2012c). In response to 4 an NRC clarification question on the unexpected large increase in the sensitivity to the discount 5 rate shown in the revised results, Entergy described that the sensitivity calculation for the lower 6 discount rate of 3 percent inadvertently included the cumulative effect of both the longer time 7 period of remaining plant life of 33 years and the lower discount rate (Entergy 2012d). Without 8 the additional effect from a longer time period, increases in the benefit solely due to a lower 9 discount rate would be smaller than those results reported in Entergy (2012c). Individual (as 10 well as cumulative) increases in the estimated benefits from the sensitivity parameters were 11 smaller than the factor of 3 applied by the applicant to account for uncertainty. In the revised 12 analysis, neither individual nor cumulative sensitivity effects resulted in benefit estimates for 13 individual SAMAs that exceeded GGNS implementation costs beyond the three SAMAs 14 previously identified by Entergy to be potentially cost beneficial. 15 The staff asked the applicant to evaluate potentially lower cost alternatives to several 16 candidates SAMAs, as summarized below: 17 Revising procedures for operators to manually initiate EDG HVAC if the 18 existing automatic logic fails or procedures for the plant auxiliary operators to 19 check on any automatic start of the EDG that could allow HVAC failures to be 20 discovered and might eliminate the need for alarms. 21 Providing directions to use jumpers to bypass the low reactor pressure 22 interlock instead of installing a bypass switch to allow operators to bypass 23 interlock circuitry. 24 Using other air compressors (service air) that might be connected to the 25 instrument air system instead of providing new compressors. 26 Improving control room fire -detection system response for a limited number of 27 key cabinets. 28 Concerning the first alternative, Entergy agreed that a procedure revision to direct that the 29 operator monitoring a running diesel ensure the ventilation system is running, or take action to 30 open doors or use portable fans, would be potentially cost beneficial. Entergy stated that a 31 condition report to implement this potentially cost -beneficial SAMA has been initiated within the 32 corrective action process (Entergy 2012a). 33 Concerning the second alternative, Entergy concluded that because of system design and the 34 number of failures that would initiate the need for this action, the likelihood of performing this 35 action successfully would be low and the benefit small. Thus, this alternative was not 36 considered cost beneficial (Entergy 2012a). 37 Concerning the third alternative, Entergy stated that a modification to connect service air with 38 instrument air has already been implemented (Entergy 2012a). 39 Concerning the fourth alternative, Entergy stated that the control room is already protected by 40 smoke detectors in the underfloor area and in every cabinet except P680 (i.e., the console at 41 which the operator sits). Since the control room is continuously occupied and, thus, provides 42 the capability of prompt detection and suppression, the use of "very early warning" or "incipient" 43 detection is not expected to provide a significant improvement and would not be cost beneficial 44 (Entergy 2012a). 45 Appendix F F-43 The staff agrees with the Entergy disposition of the above lower -cost alternatives. 1 F.7 Conclusions 2 Entergy considered 249 candidate SAMAs based on risk -significant contributors at GGNS from 3 updated probabilistic safety assessment models, its review of SAMA analyses from other BWR 4 plants, NRC and industry documentation of potential plant improvements, and GGNS individual 5 plant examination of internal and external events including available updates. Phase I 6 screening reduced the list to 63 unique SAMA candidates by eliminating SAMAs that were not 7 applicable to GGNS, had already been implemented at GGNS, or were combined into a more 8 comprehensive or plant-specific SAMA. 9 For the remaining SAMA candidates, Entergy performed a cost -benefit analysis with results 10 shown in Table F-5. The cost -benefit analysis identified three potentially cost -beneficial SAMAs 11 (Phase II SAMA Nos. 39, 42, and 59). Sensitivity cases were analyzed for the present value 12 discount rate and time period for remaining plant life. No additional SAMAs were identified as 13 potentially cost beneficial from the sensitivity analysis. In response to a staff RAI concerning 14 potential low -cost alternatives, Entergy determined that a procedure revision to direct that the 15 operator monitoring a running diesel ensure the ventilation system is running, or take action to 16 open doors, or use portable fans would be potentially cost beneficial. 17 The staff reviewed the Entergy SAMA analysis and concludes that, subject to the discussion 18 in this appendix, the methods used and implementation of the methods were sound. On the 19 basis of the applicant's treatment of SAMA benefits and costs, the staff finds that the 20 SAMA evaluations performed by Entergy are reasonable and sufficient for the license 21 renewal submittal. 22 The staff agrees with Entergy's conclusion that the four candidate SAMAs discussed in this 23 section are potentially cost beneficial, which was based on generally conservative treatment of 24 costs, benefits, and uncertainties. This conclusion of a small number of potentially 25 cost-beneficial SAMAs is consistent with the low residual level of risk indicated in the GGNS 26 PRA and the fact that Entergy has already implemented the plant improvements identified from 27 the IPE and IPEEE. Because the potentially cost -beneficial SAMAs do not relate to aging 28 management during the period of extended operation, they do not need to be implemented as 29 part of license renewal in accordance with Title 10 of the Code of Federal Regulations, Part 54. 30 Nevertheless, Entergy issued a condition report under the corrective action process to consider 31 implementation of these potentially cost -beneficial SAMAs. The staff accepts this course of 32 action. 33 F.8 References 34 Electric Power Research Institute (EPRI). 1991. "A Methodology for Assessment of Nuclear 35 Power Plant Seismic Margin." NP-6041-SL, Rev. 1. Jack R. Benjamin and Associates, 36 Inc., et al. Palo Alto, CA. August 1991. 37 Electric Power Research Institute (EPRI). 1992. "Fire -Induced Vulnerability Evaluation (FIVE)," 38 TR-100370. Professional Loss Control, Inc. Palo Alto, CA. April 1992. 39 Electric Power Research Institute (EPRI). 1994. "EPRI Fire PRA Implementation Guide." 40 EPRI Report Project 3385 -01. Draft, Parkinson, W.J., et al. Palo Alto, CA. January 1994. 41 Enercon Services, Inc. (Enercon). 2011. Permanent, Transient, and Total Population Projection 42 in Sectors. Calc. No. ENTGGG084-CALC-001, Revision

1. Oklahoma City, OK. May 27, 2011. 43 Appendix F F-44 Entergy Operations, Inc. (Entergy). 1992. "Individual Plant Examination (IPE) for Grand Gulf 1 Nuclear Station Unit 1." December 1992. Accessible at Agencywide Documents Access 2 Management System (ADAMS) No.

ML080090496 (nonpublic document ). 3 Entergy Operations, Inc. (Entergy). 1995. Letter from M.J. Meisner, Entergy, to U.S. NRC 4 Document Control Desk.

Subject:

"Grand Gulf Nuclear Station Docket No.

50-416 License 5 No. NPF-29 Individual Plant Examination of External Events (IPEEE) Schedule Final 6 Submittal." November 15, 1995 (nonpublic document ). 7 Entergy Operations, Inc. (Entergy). 1998. Letter from W. K. Hughey, Entergy, to U.S. NRC 8 Document Control Desk.

Subject:

"Grand Gulf Nuclear Station Unit 1 Docket No.

50-416 9 License No. NPF-29 Response to Request for Additional Information Related to Individual Plant 10 Examination of External Events ." February 10, 1998 (nonpublic documen t). 11 Entergy Operations, Inc. (Entergy). 2011. "Applicant's Environmental Report Operating License 12 Renewal Stage Grand Gulf Nuclear Generating Station." Appendix E to Grand Gulf Nuclear 13 Station (GGNS) License Renewal Application (LRA). Port Gibson, MS. October 2011. 14 Accessible at ADAMS No. ML11308A234. 15 Entergy Operations, Inc. (Entergy). 2012a. Letter from Michael Perito, Entergy, to U.S. Nuclear 16 Regulatory Commission Document Control Desk.

Subject:

"Response to Request for Additional 17 Information (RAI) on Severe Accident Mitigation Alternatives dated May 21, 2012, Grand Gulf 18 Nuclear Station, Unit 1, Docket No. 50-416, License No. NPF -29." Port Gibson, MS. 19 July 19, 2012. Accessible at ADAMS No. ML12202A056. 20 Entergy Operations, Inc. (Entergy). 2012b. Letter from Michael Perito, Entergy, to U.S. Nuclear 21 Regulatory Commission Document Control Desk.

Subject:

 "Response to Request for Additional 22 Information (RAI) on Severe Accident Mitigation Alternatives dated August 23, 2012, Grand Gulf 23 Nuclear Station, Unit 1, Docket No. 50

-416, License No. NPF -29." Port Gibson, M S. 24 October 2, 2012. Accessible at ADAMS No. ML12277A082. 25 Entergy Operations, Inc. (Entergy). 2012c. Letter from Michael Perito, Entergy, to U.S. Nuclear 26 Regulatory Commission Document Control Desk.

Subject:

 "Reanalysis of Severe Accident 27 Mitigation Alternatives, Grand Gulf Nuclear Station, Unit 1, Docket No.

50-416, License 28 No. NPF-29." Port Gibson, MS. November 19, 2012. Accessible at ADAMS No. ML12325A174. 29 Entergy Operations, Inc. (Entergy). 2012d. Letter from Kevin J. Mulligan, Entergy, to 30 U.S. Nuclear Regulatory Commission Document Control Desk.

Subject:

"Response to 31 Clarification Questions on Reanalysis of Severe Accident Mitigation Alternatives (SAMA) Letter 32 dated November 19, 2012, Grand Gulf Nuclear Station, Unit 1, Docket No. 50-416, License 33 No. NPF-29." Port Gibson, MS. December 19, 2012. Accessible at ADAMS No. ML12359A038. 34 Nuclear Energy Institute (NEI). 2005. "Severe Accident Mitigation Alternative (SAMA) Analysis 35 Guidance Document." NEI 05-01, Rev. A. Washington, DC. November 2005. 36 Nuclear Energy Institute (NEI). 2010. "Roadmap for Attaining Realism in Fire PRA." 37 Washington, DC. December 2010. Accessible at ADAMS No. ML110210990. 38 U.S. Nuclear Regulatory Commission (NRC). 1988. "Individual Plant Examination for Severe 39 Accident Vulnerabilities." Generic Letter 88-20. November 23, 1988. Accessible at ADAMS 40 No. ML031470299. 41 U.S. Nuclear Regulatory Commission (NRC). 1990. Severe Accident Risks: An Assessment for 42 Five U.S. Nuclear Power Plants. NUREG-1150. Washington, DC. Accessible at ADAMS 43 Nos. ML040140729 and ML120960691. 44 Appendix F F-45 U.S. Nuclear Regulatory Commission (NRC). 1991a. "Individual Plant Examination of External 1 Events (IPEEE) for Severe Accident Vulnerabilities." Generic Letter 88-20, Supplement

4. 2 Washington, DC. June 28, 1991. Accessible at ADAMS No.

ML031150485. 3 U.S. Nuclear Regulatory Commission (NRC). 1991b. Procedural and Submittal Guidance for the 4 Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities. 5 NUREG-1407. Washington, DC. May 1991. Accessible at ADAMS No. ML063550238. 6 U.S. Nuclear Regulatory Commission (NRC). 1996. U.S. NRC to R. Hutchinson (GGNS). 7 "Individual Plant Examination (IPE) -Internal Events -Grand Gulf Nuclear Station (TAC 8 No. M74415)." Generic Letter 88-20. Correspondence No. GNRI-96/00067. March 7, 1996. 9 Available via the NRC Public Document Room by e-mail to pdr.resource@nrc.gov. 10 U.S. Nuclear Regulatory Commission (NRC). 1997a. Regulatory Analysis Technical Evaluation 11 Handbook. NUREG/BR -0184. Washington, DC. Accessible at ADAMS No. ML050190193. 12 U.S. Nuclear Regulatory Commission (NRC). 1997b. Individual Plant Examination Program: 13 Perspectives on Reactor Safety and Plant Performance Parts 2 -5, Final Report." 14 NUREG-1560, Vol.

2. Washington, DC. December 31, 1997. Accessible at ADAMS 15 No. ML0635550228 (nonpublic document

). 16 U.S. Nuclear Regulatory Commission (NRC). 2001. Letter from S.P. Sekerak, NRC, to William 17 A. Eaton, Entergy.

Subject:

 "Grand Gulf Nuclear Station, Unit 1 - Re:  Staff Evaluation of 18 Licensee Response to Generic Letter 88-20, Supplement 4, 'Individual Plant Examination for 19 Severe Accident Vulnerabilities,' (TAC No.

M83625)." March 16, 2001 (nonpublic document ). 20 U.S. Nuclear Regulatory Commission (NRC). 2005. EPRI/NRC-RES Fire PRA Methodology 21 for Nuclear Power Facilities. NUREG/CR -6850. Vols. 1 and 2. Washington, DC. 22 September 2005. Accessible at ADAMS Nos. ML052580075 and ML052580118. 23 U.S. Nuclear Regulatory Commission (NRC). 2009. "An Approach for Determining the Technical 24 Adequacy of Probabilistic Risk Assessment Results for Risk -Informed Activities." Regulatory 25 Guide 1.200, Revision

2. March 2009. Accessible at ADAMS No.

ML090410014. 26 U.S. Nuclear Regulatory Commission (NRC). 2010. "NRC Information Notice 2010 -18: Generic 27 Issue 199, Implications of Updated Probabilistic Seismic Hazard Estimates in Central and 28 Eastern United States on Existing Plants." Washington, DC. September 2, 2010. Accessible at 29 ADAMS No. ML101970221. 30 U.S. Nuclear Regulatory Commission (NRC). 2012a. Letter from David Drucker, NRC, to 31 Michael Perito, Entergy.

Subject:

 "Request for Additional Information on Severe Accident 32 Mitigation Alternatives for the Review of the Grand Gulf Nuclear Station, Unit 1, License 33 Renewal Application." May 21, 2012. Accessible at ADAMS No.

ML12115A101. 34 U.S. Nuclear Regulatory Commission (NRC). 2012b. Letter from David Drucker, NRC, to 35 Michael Perito, Entergy.

Subject:

 "Request for Additional Information on Severe Accident 36 Mitigation Alternatives for the Review of the Grand Gulf Nuclear Station, Unit 1, License 37 Renewal Application." August 23, 2012. Accessible at ADAMS No.

ML12227A735. 38 U.S. Nuclear Regulatory Commission (NRC). 2012c. Letter from Alan Wang, NRC, to Vice 39 President, Operations, Entergy.

Subject:

 "Grand Gulf Nuclear Station, Unit 1 - Issuance of 40 Amendment Re:  Extended Power Uprate (TAC No.

ME4679)." Enclosure 2, Safety Evaluation 41 by the Office of Nuclear Reactor Regulation Related to Amendment No. 191 to Facility 42 Operating License No. NPF -29, Entergy Operations, Inc., Grand Gulf Nuclear Station, Unit 1, 43 Docket No. 50-416. July 18, 2012. Accessible at ADAMS No. ML121210020. 44}}