ML11266A062

Davis-Besse, Unit 1 - License Renewal Application Amendment No. 16, Supplemental Information for the Review of the License Renewal Application Environmental Report

ML11266A062
Person / Time
Site:	Davis Besse
Issue date:	09/19/2011
From:	Byrd K W FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-11-289, TAC ME4613
Download: ML11266A062 (176)

Text

{{#Wiki_filter:FENOC Davis-Besse Nuclear Power StationS5501 N. State Route 2FirstEnergy Nuclear Operating Company Oak Harbor, Ohio 43449September 19, 2011L-1 1-289 10 CFR 54ATTN: Document Control DeskU. S. Nuclear Regulatory CommissionWashington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit No. 1Docket No. 50-346, License Number NPF-3License Renewal Application Amendment No. 16, Supplemental Information for theReview of the Davis-Besse Nuclear Power Station, Unit No. 1, License RenewalApplication Environmental Report (TAC No. ME4613)By letter dated August 27, 2010 (Agencywide Documents Access and ManagementSystem (ADAMS) Accession No. ML102450565), FirstEnergy Nuclear OperatingCompany (FENOC) submitted an application pursuant to Title 10 of the Code of FederalRegulations, Part 54 for renewal of Operating License NPF-3 for the Davis-BesseNuclear Power Station, Unit No. 1 (DBNPS).Amendment 16 to the DBNPS License Renewal Application, which provides updatedinformation for the Davis-Besse Nuclear Power Station, Unit No. 1, License RenewalApplication, Appendix E, "Applicant's Environmental Report, Operating LicenseRenewal Stage," Chapters 7 and 8, is provided as Enclosure A. Enclosure B provides acopy of the Amendment that shows the changes in redline (or tracked-changes) formatto facilitate NRC review.There are no regulatory commitments contained in this letter. If there are any questionsor if additional information is required, please contact Mr. Clifford I. Custer, FleetLicense Renewal Project Manager, at 724-682-7139. Davis-Besse Nuclear Power Station, Unit No. 1L-1 1-289Page 2I declare under penalty of perjury that the foregoing is true and correct. Executed onSeptember __, 2011.Sincerely,Kendall W. BDirector, Site Performance ImprovementEnclosure-:A. Amendment No. 16 to the DBNPS License Renewal ApplicationB. FENOC Annotation of Amendment No. 16 to the DBNPS License RenewalApplication to Facilitate NRC Reviewcc: NRC DLR Project ManagerNRC DLR Environmental Project ManagerNRC Region III Administratorcc: w/o EnclosureNRC DLR DirectorNRR DORL Project ManagerNRC Resident InspectorUtility Radiological Safety Board Enclosure ADavis-Besse Nuclear Power Station, Unit No. 1 (DBNPS)Letter L-11-289Amendment No. 16 to theDBNPS License Renewal Application86 Pages(not including this cover page)License Renewal ApplicationSections AffectedAppendix E, Chapter 7Appendix E, Chapter 8This Enclosure provides updated information for the Davis-Besse Nuclear PowerStation, Unit No. 1, License Renewal Application, Appendix E, "Applicant'sEnvironmental Report, Operating License Renewal Stage," Chapters 7 and 8, thatare to be replaced, in their entirety, with the attached. Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report7.0 ALTERNATIVES TO THE PROPOSED ACTIONRegulatory Requirement: 10 CFR 51.45(b)(3)The environmental report shall discuss "Alternatives to the proposed action."[adopted by reference at 10 CFR 51.53(c)(2)].7.0.1 OVERVIEWThis chapter assesses alternatives to the proposed renewal of the Davis-Besseoperating license. It includes discussions of the no-action alternative and alternativesthat meet system generating needs. Descriptions are provided in sufficient detail tofacilitate comparison of the impacts of the alternatives to those of the proposed action.In considering the level of detail and analysis that it should provide for each category,FENOC relied on the NRC decision-making standard for license renewal:... the NRC staff, adjudicatory officers, and Commission shall determine whether or notthe adverse environmental impacts of license renewal are so great that preserving theoption of license renewal for energy planning decision makers would be unreasonable.[10 CFR 51.95(c)(4)]As noted in 10 CFR 51.53(c)(2), a discussion is not required of need for power oreconomic costs and benefits of the proposed action or of alternatives to the proposedaction except insofar as such costs and benefits are either essential for a determinationregarding the inclusion of an alternative in the range of alternatives considered orrelevant to mitigation.Section 7.1 addresses the "no-action" alternative in terms of the potential environmentalimpacts of not renewing the Davis-Besse operating license, independent of any actionstaken to replace or compensate for the loss of generating capacity. Section 7.2describes feasible alternative actions that could be taken, which FENOC also considersto be elements of the no-action alternative, and presents other alternatives that FENOCdoes not consider to be reasonable. Section 7.3 presents the environmental impacts forthe reasonable alternatives.The environmental impact evaluations of alternatives presented are intended to provideenough information to support NRC decision-making by demonstrating whether analternative would have a smaller, comparable, or greater enyironmental impact than theproposed action. Additional detail or analysis was not considered useful or necessary ifit would identify only additional adverse impacts of license renewal alternatives; i.e.,information beyond that necessary for a decision. This approach is consistent with theCEQ regulations, which provide that the consideration of alternatives (including theAlternatives to the Proposed ActionPage 7.0-1September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportproposed action) be adequately addressed so reviewers may evaluate theircomparative merits (40 CFR 1502.14(b)).The characterization of environmental impacts in this chapter applies the samedefinitions of "SMALL," "MODERATE," and "LARGE" used in Chapter 4 of this ER andby the NRC in the GElS (NRC 1996). Chapter 8 presents a summary comparison ofenvironmental impacts of the proposed action and alternatives.7.0.2 REGION OF INTERESTNRC environmental guidance for siting new reactors defines the "Region of interest"(ROI) as "the geographic area considered in searching for candidate sites."NUREG-1555, at 9.3-1 (1999). That definition is not directly applicable to this licenserenewal action because Davis-Besse is already sited as an operating reactor in Ohio.The application here is for license renewal, and not for initial plant siting, construction,or operation. However, that same environmental guidance explains that "the basis foran ROI is the State in which the proposed site is located or the relevant service area forthe proposed plant." NUREG-1555, at 9.3-2. This explanation, or basis for selectingthe ROI for siting new reactors, is applicable for defining the ROI for purposes of licenserenewal. Accordingly, FENOC is adopting an ROI for this Environmental Report as theState in which Davis-Besse is located: Ohio. The second portion of the explanation inNUREG-1555-"the relevant service area for the proposed plant"-is not applicable toDavis-Besse, because the electricity that Davis-Besse generates is sold on thewholesale power market. Accordingly, there is no "relevant service area" for the plant.Alternatives to the Proposed Action Page 7.0-2 September 2011Alternatives to the Proposed ActionPage 7.0-2September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report7.1 NO-ACTION ALTERNATIVEFENOC considers the no-action alternative is not to renew the Davis-Besse operatinglicense. With this alternative, FENOC expects Davis-Besse would continue to operateuntil the expiration of the existing operating license in 2017, at which time plantoperations would cease, decommissioning would begin, and FirstEnergy or otherswould take the appropriate actions to meet system-generating needs created bydiscontinued operation of the plant.Section 7.1.1 addresses the impacts of terminating operations and decommissioning,whereas Section 7.1.2 discusses the actions to replace power from Davis-Besse.7.1.1 TERMINATING OPERATIONS AND DECOMMISSIONINGIn the event the NRC does not renew the Davis-Besse operating license, FENOCassumes for this ER that it would operate the plant until the current license expires, thenterminate operations and initiate decommissioning activities in accordance with NRCrequirements. For purposes of this discussion, terminating operations includes thoseactions directly associated with permanent cessation of operations, which may result inmore or less immediate environmental impacts (e.g., socioeconomic impacts fromreduction in employment and tax revenues).Decommissioning, as defined in the GELS, is the safe removal of a nuclear facility fromservice and the reduction of residual radioactivity to a level that permits release of theproperty for unrestricted use and termination of the license (NRC 1996, Section 7.1).The two decommissioning options typically selected for United States reactors are rapiddecontamination and dismantlement (DECON), and safe storage of the stabilized andde-fueled facility (SAFSTOR), followed by final decontamination and dismantlement(NRC 1996, Section 7.2.2). Under the DECON option, radioactively contaminatedportions of the facility and site are decontaminated or removed promptly after cessationof operations to a level that permits termination of the license; these activities requireseveral years for large light-water reactors like Davis-Besse (NRC 1996, Table 7.8).The SAFSTOR option involves safe storage of the stabilized and defueled facility for aperiod of time followed by decontamination to levels that permit license termination.Regardless of the option selected, decommissioning typically must be completed within60 years after operations cease in accordance with NRC requirements at 10 CFR 50.82(NRC 1996, Section 7.2.2).FENOC has not selected a decommissioning method for Davis-Besse. Thedecommissioning method for Davis-Besse would be described in post-shutdowndecommissioning plans for the plant, which must be submitted to NRC within two yearsfollowing cessation of operations. For purposes of the present analysis, FENOCassumes that the DECON option would be employed upon license termination.No-action AlternativePage 7.1-1September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportThe NRC presents in Chapter 7 and Section 8.4 of the GElS a summary of genericenvironmental impacts of the decommissioning process and an evaluation of potentialchanges in impact that could result from deferring the decommissioning process for upto 20 years (NRC 1996). For a pressurized water reactor decommissioning, NRC useda 1,175 MWe reference reactor. Although larger than Davis-Besse (910 MWe), FENOCconsiders the reference reactor to be representative of Davis-Besse. As a result,FENOC believes the decommissioning activities described in the GElS to berepresentative of activities FENOC would perform for decommissioning at Davis-Besse.The NRC concluded from its evaluation that decommissioning impacts would not besignificantly greater as a result of the proposed action, assumed to result in20 additional years of operation (NRC 1996, Sections 7.3 and 8.4). The NRCconclusions also indicate that the impacts of the decommissioning process itself,addressed in this ER as part of the no-action alternative, would have SMALL impactswith respect to radiation dose, waste management, air quality, water quality, andecological resources (see 10 CFR Part 51, Subpart A, Appendix B, Table B-i). FENOCconsiders this generic evaluation and associated conclusions applicable to Davis-Besseas well.The NRC has provided additional analysis of the environmental impacts associated withdecommissioning in the Final Generic Environmental Impact Statement onDecommissioning of Nuclear Facilities (NRC 2002). Except for issues that requiresite-specific evaluation, environmental impacts, including radiological releases anddoses from decommissioning activities, were assessed to be SMALL (NRC 2002,Sections 4.3 and 6.1).Regardless of the NRC decision on license renewal, FENOC will have to decommissionDavis-Besse; license renewal would only postpone decommissioning for an additional20 years. In the GELS, the NRC concludes that there should be little difference betweenthe environmental impacts from decommissioning at the end of 40 years of operationversus those associated with decommissioning after an additional 20 years of operationunder a renewed license (NRC 1996, Section 7.4).By reference, FENOC adopts the NRC findings regarding environmental impacts ofdecommissioning in the license renewal GElS (NRC 1996) and in the decommissioningGElS (NRC 2002), and concludes that environmental impacts under the no-actionalternative would be similar to those that occur following license renewal. Further,FENOC believes that decommissioning activities would not involve significant land-usedisturbance offsite or significant activities beyond current operational areas that wouldoffer potential for impacts on land use, ecological resources, or cultural resources.Decommissioning impacts would be temporary and occur at the same time as thoseassociated with the operation of replacement generating sources.No-action AlternativePage 7.1-2September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report7.1.2 REPLACEMENT CAPACITYDavis-Besse is a base-load generator of electric power, with a net generating capabilityof 908 MWe (Section 3.1.2). In 2008, Davis-Besse generated approximately 8.3% ofFirstEnergy's total base-load electricity generation (FirstEnergy 2008a, Page 7;USDOE 2010). The power produced by Davis-Besse, which represents a significantportion of the electricity FirstEnergy supplies to 2.1 million customers in its serviceterritories located in Ohio (FirstEnergy 2009a, Page 81), would be unavailable in theevent the Davis-Besse operating license is not renewed.As provided in 10 CFR 51.53(c)(2), FENOC does not consider the need for power fromDavis-Besse in this analysis, but does consider the potential impact of alternatives forreplacing this power. Replacement options considered include building new base-loadgenerating capacity, purchasing power, delaying retirement of non-nuclear assets, andreducing power requirements through demand reduction, as discussed in Section 7.2.No-action Alternative Page 7.1-3 September 2011No-action AlternativePage 7.1-3September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report[This page intentionally blank]No-action AlternativePage 7.1-4September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report7.2 ALTERNATIVES THAT MEET SYSTEM GENERATING NEEDSIf the Davis-Besse operating license is not renewed, then the State of Ohio, FirstEnergyCorp. and its subsidiary companies, and other participants in the wholesale powermarket would lose approximately 910 MWe* of base-load capacity. Renewal wouldpreserve the option of relying on Davis-Besse to meet future electric power needsthrough the period of extended operation.While many methods are available to generate electricity, the GElS indicates that a"reasonable set of alternatives should be limited to analysis of single, discrete electricgeneration sources and only electric generation sources that are technically feasibleand commercially viable" (NRC 1996, Section 8.1). Considering that Davis-Besseserves as a large base-load generator, FENOC considers reasonable alternatives to bethose that would also be able to generate base-load power. FENOC believes that anyalternative would be unreasonable if it did not consider replacement of the energyresource.7.2.1 ALTERNATIVES CONSIDERED AS REASONABLEFossil-Fuel Alternatives SummaryFENOC believes that coal-fired and gas-fired generation capacity are feasiblealternatives to nuclear power generating capacity, based on current (and expected)technological and cost factors, as compared to the other alternatives listed in the GElS(NRC 1996, Section 8.1). FENOC considers the coal-fired and gas-fired technologiesreasonable alternatives for purposes of this analysis to replace Davis-Besse generatingcapacity in the event its operating license is not renewed. The GElS further notes thatnatural gas combined-cycle plants are particularly efficient and are used as base-loadfacilities (NRC 1996, Section 8.3.10). The specific coal-generating technologies thatwould represent viable alternatives are less certain, particularly in view of potentiallyhigher air emissions compared to natural gas firing. For example, large-capacityintegrated gasification combined-cycle (IGCC) and fluidized-bed-combustion (FBC)technologies (atmospheric and pressurized) are at or near commercial viability andcould prove to be appropriate replacements. However, modern pulverized coal plantswith advanced, clean-coal technology air emission controls represent currently proventechnology and are economically competitive and commercially available in large-capacity unit sizes that could effectively replace Davis-Besse. Therefore, FENOC usesa representative plant of this type for purposes of impact evaluation, noting that airemission impacts of IGCC and FBC options may be lower than modern pulverized coal,but would be higher than the gas-fired combined-cycle alternative (USDOE 1999,Pages 5-7)."910 MWe is used for calculation convenience instead of 908 Mwe, as noted in Section 3.1.2.Alternatives that Meet System Page 7.2-1 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportRenewable Energy Alternatives SummaryOn April 26, 2011, an NRC Atomic Safety and Licensing Board (Board) presiding overthe license renewal proceeding for Davis-Besse issued a Memorandum and Order(LBP-1 1-13) admitting a contention alleging that the FENOC analysis of renewableenergy alternatives in the Environmental Report was not adequate. As admitted by theBoard, the contention states:[FENOC's ER] fails to adequately evaluate the full potential for renewableenergy sources, specifically wind power in the form of interconnected windfarms and/or solar photovoltaic power, in combination with compressed airenergy storage, to offset the loss of energy production from Davis-Besse,and to make the requested license renewal action unnecessary. TheFENOC Environmental Report (Section 7.2) treats all of the alternatives tolicense renewal except for natural gas and coal plants as unreasonableand does not provide a substantial analysis of the potential for significantalternatives in the Region of Interest.The Board's phrasing of the contention, as admitted, arguably includes the followingrenewable energy alternatives: 1) wind power in the form of interconnected wind farms;2) wind power in the form of interconnected wind farms with compressed air energystorage (CAES); 3) solar (photovoltaic) power combined with CAES; or 4) a combinationof interconnected wind farms and solar (photovoltaic) power with CAES.FENOC does not believe that any of these are "reasonable" alternatives under NEPA.However, in order to resolve the issues raised in the admitted contention, FENOC hasrevised this ER to evaluate the renewable energy alternatives listed above as analternative to replace the rated electrical output of Davis-Besse by 2017.FENOC considers the other technologies listed in the GElS as not reasonablealternatives for the reasons discussed in Section 7.2.2.DisclaimerThroughout Chapters 7 & 8, FENOC presents information about renewable energyresources compiled by others. FENOC has not independently confirmed the accuracyof these statements, nor does FENOC agree with them.Additionally, FENOC does not agree that the renewable energy alternatives listed abovecan provide base-load generation or that the existing and any interstate transmissionsystem available by 2017 could accommodate such renewable energy.Finally, even if such a group of renewable resources were built, there is no way toassure that the power generated by those resources would be available to the CAESfacility to create the alternative that Joint Petitioners envision. There are a number ofAlternatives that Meet System Page 7.2-2 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportconsiderations for the development of a solar or wind resource including the availabilityof sufficient sun or wind, the availability of land, grid access, cost of interconnection(which may be economically prohibitive in some cases), and sufficient transmissionresources to assure the CAES's ability to interact with the resource.The NRC has noted that, while there are many methods available for generatingelectricity and many combinations of alternative power generation sources that couldprovide base-load capacity, such an expansive consideration of alternatives would betoo unwieldy (NRC 1996, Section 8.1).7.2.1.1 Coal-Fired GenerationFor purposes of this analysis, FENOC assumed development of a modern pulverizedcoal-fired power plant with state-of-the-art emission controls similar to that described inits license renewal application, Appendix E (Environmental Report), for the BeaverValley Power Station (FENOC 2007, Section 7.2.2.2). In defining the Davis-Besse coal-fired alternative, FENOC has used site-specific input as appropriate.The representative plant would consist of commercially available standard-sized units,with a nominal net output of approximately 910 MWe, and would be designed to meetapplicable standards with respect to control of air and wastewater emissions. As aminimum, FENOC assumed that the plant would feature low nitrogen oxide burners withoverfire air to minimize formation of nitrogen oxides, and selective catalytic reduction forpost-combustion nitrogen oxide control. Emissions of particulate matter and mercurywould be limited by use of a fabric filter (baghouse), and sulfur oxide emissions wouldbe controlled using a wet scrubber using limestone as the reagent.Table 7.2-1 lists the basic specifications for the representative plant.The Davis-Besse site would not be a viable location for the representative plant as aresult of space limitations (see Section 7.3.1, Land Use). Land area requirements for acoal-fired plant of similar capacity to Davis-Besse would be approximately 1.7 acres perMWe (NRC 1996, Section 8.3.9), or 1,547 acres for a 910 MWe plant. The needed landarea, therefore, far exceeds the 954-acre Davis-Besse site, most of which is occupiedby marshland that is leased to the U.S. Government as a national wildlife refuge(Section 2.1).Therefore, FENOC assumed for the analysis that the representative coal-fired plantwould be located elsewhere at a greenfield or (preferably) brownfield site close to acommercially, navigable waterway or existing railway. A navigable waterway locationwould be highly desirable from a technical and economic perspective, considering therelative abundance of cooling water and low fuel cost afforded by barge transportationof coal and limestone. FENOC further assumed for the analysis that the representativecoal-fired plant would use closed-cycle cooling with a natural draft cooling tower.Alternatives that Meet System Page 7.2-3 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportLastly, FENOC assumed for the analysis that the environmental impacts associatedwith siting, design, and operation of the plant would be subject to comprehensive reviewunder Ohio Power Siting Board (OPSB) rules or a comparable process.7.2.1.2 Gas-Fired GenerationFor purposes of this analysis, FENOC assumed development of a modern natural gas-fired combined-cycle plant based on a commercially available design similar to thatdescribed in its license renewal application, Appendix E (Environmental Report), for theBeaver Valley Power Station (FENOC 2007, Section 7.2.2.1). In defining theDavis-Besse gas-fired alternative, FENOC has used site-specific input as appropriate.The representative plant would consist of commercially available standard-sized units,with a nominal net output of approximately 910 MWe, and would be designed to meetapplicable standards with respect to control of air and wastewater emissions. As aminimum, FENOC assumed that the plant would use natural gas as its only fuel andfeature dry low-NOx burners to minimize formation of nitrogen oxides during combustionand selective catalytic reduction for post-combustion nitrogen oxide control. Emissionsof particulate matter and carbon monoxide would be limited through proper combustioncontrols.Table 7.2-2 lists the basic specifications for the representative plant.The Davis-Besse site is uncertain as a viable location for the representative plant due tospace limitations. Land area requirements for a gas-fired plant of similar capacity toDavis-Besse, for example, would be approximately 0.11 acres per MWe (NRC 1996,Table 8.1), or 100 for a 910 MWe plant. Of the 954 acres of land occupied by theDavis-Besse site, 733 acres is occupied by marshland that is leased to the U.S.Government as a national wildlife refuge (Section 2.1). The remaining 221 acres ismostly occupied by Davis-Besse structures. Therefore, FENOC assumed for theanalysis that the representative gas-fired plant would be located elsewhere at agreenfield or (preferably) brownfield site, but has not identified a specific site. However,primary considerations for a cost-competitive site include close proximity to adequatenatural gas supply, transmission infrastructure, cooling water, and sufficient landsuitable for development. For this analysis, FENOC assumed, based on FirstEnergyexperience in gas-fired plant siting, that northwestern Ohio would be a realistic generalarea to locate the new plant (FENOC 2007, Section 7.2.2.1). FENOC further assumedfor the analysis that the representative gas-fired plant would use closed-cycle coolingwith mechanical draft cooling towers.Lastly, FENOC assumed for the analysis that the environmental impacts associatedwith siting, design, and operation of the plant would be subject to comprehensive reviewunder Ohio Power Siting Board (OPSB) rules or a comparable process.Alternatives that Meet System Page 7.2-4 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report7.2.1.3 Renewable Energy GenerationAs explained above in Section 7.2.1, and subject to the disclaimers in that Section,FENOC is evaluating for the sole purpose of this NEPA analysis certain renewableenergy alternatives. These alternatives are discussed in more detail below. Otherrenewable energy alternatives were rejected for the reasons explained below inSection 7.2.2.Interconnected Wind FarmsWind energy facilities use wind turbines to harness the kinetic energy of wind andtransform it into electrical power. Output depends on a turbine's size and the wind'sspeed through the rotor as well as the availability of wind itself. Wind turbinesmanufactured today range from 250 watts (AWEA 2002) to 10 megawatts (MW) (SWAY2010), and wind farms can range in capacity from a few megawatts to the 781+megawatt Roscoe Wind Complex in Texas. (CBS 2010) Wind availability, speed andturbine height are critical factors for wind farm generating capacity. The stronger andmore consistent the wind, and the taller the turbines, the higher potential capacityexists. Multiple land uses are often possible on wind farms. For example, a wind farmmay generate electricity while cattle graze or corn grows on the land surrounding theturbines. (AWEA 2002)Neither a single wind turbine nor interconnected wind farms currently provide baseloadpower anywhere in the United States. However, the theory that multiple wind farmslocated throughout a region and interconnected via the grid could provide for moreconsistent power generation due to the reduced likelihood that all sites wouldexperience the same wind patterns at any given time, has been studied.In one study, the benefits of interconnecting wind farms were evaluated for 19 siteslocated in the midwestern United States with annual average wind speeds greater than6.9 meters per second (m/s) (class 3 or greater) at 80 m above ground, the hub heightof modern wind turbines. The study reported that, on average, only 33% and amaximum of 47% of yearly-averaged wind power from interconnected wind farms couldtheoretically be relied upon to produce electricity. And there were days when noelectricity was produced from these wind farms. (JACM 2007)Additionally, delays in the implementation of interconnected wind technology can be dueto transmission line construction difficulties, as the North American Electric ReliabilityCorporation (NERC) explains in its 2009 Long-Term Reliability Assessment. The NERCpoints out that siting of new bulk power transmission lines brings with it uniquechallenges due to the high visibility, their span through multiple states/provinces and,potentially, the amount of coordination/cooperation required among multiple regulatingagencies and authorities. Lack of consistent and agreed-upon cost allocationAlternatives that Meet System Page 7.2-5 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportapproaches, coupled with public opposition due to land-use and property valuationconcerns, have, at times, resulted in long delays in transmission line construction. Newtransmission, including transmission in the DOE's designated "National Interest ElectricTransmission Corridors" can be delayed or halted by individual states, increasing thedifficulty to site bulk transmission, including those projects focused on unlockinglocation-constrained renewable generation. These siting issues create a potentialcongestion issue and challenge the economic viability of new generation projects.(NERC 2009)In the specific case of wind power, a wind project must be located where it wouldproduce economical generation, and that location may be far removed from the nearestpossible connection to the transmission system. A location far removed from the powertransmission grid might not be economical, as new transmission lines would be requiredto connect the wind farm to the distribution system, and the question of who pays for thetransmission upgrade would be at issue. Existing transmission infrastructure may needto be upgraded to handle the additional supply. Soil conditions and the terrain must besuitable for the construction of the towers' foundations. Finally, the choice of a locationmay be limited by land use regulations and the ability to obtain the required permitsfrom local, regional, and national authorities.Jacobs and Archer completed a study of interconnected wind farms with consisting ofup to 19 wind farm sites, and concluded that maximum capacity factors ofapproximately 45% could theoretically be obtained (JACM 2007). Davis-Besse's recentcapacity factor has been in excess of 90%, which would generate approximately7,158,672 MWh over a full year. To achieve a similar annual average at a 45% capacityfactor, interconnected wind farms with a minimum of 1210 GE 1.5 MW turbines wouldbe required, and would not be guaranteed due to the uncontrollability of the windavailability. It must be noted, however, that the studies by Jacobs and Archer werebased on areas with higher annual average wind speeds (over 8 m/s). Thus, in Ohio, itwould be expected that the GE 1.5-MW turbines might not operate as efficiently andthus the number of turbines required for replacement power generation would be higher.And there would still be times when reserve capacity from traditional generation orenergy storage would be required. Using larger turbines could be used if wind speedssupported their economical use, especially in offshore locations (discussed below),which would reduce land use.Since 1998-99, average turbine nameplate capacity has increased by 151%, but growthin this metric has slowed in recent years due to the dominance of GE's 1.5 MW turbineand as a result of the logistical challenges associated with transporting larger turbines toproject sites. (USDOE 2011) There are several land based wind farms underconstruction or planned in Ohio. These wind farms will utilize wind turbines ranging from1.8 MW (Timber Ridge Wind Farm) to 2.0 MW (Blue Creek Wind Farm). (WAG 2011and TBM 2011)Alternatives that Meet System Page 7.2-6 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportFENOC reviewed several recent documents describing studies conducted by theNational Renewable Energy Laboratory (NREL) related to wind integration andtransmission studies for both land-based and offshore wind generating facilities (NREL2011, NREL 2010, NREL 2010a). Based on the findings in these documents, aland-based interconnected transmission system in the central and eastern United Statesis likely to be completed by 2024. For the sole purpose of this NEPA analysis, however,FENOC evaluates renewable energy alternatives as if an interconnected grid systemwould be available by 2017.FENOC also evaluated the potential for offshore wind generation and integrating thatpower into the transmission system. Although both Lake Erie and Lake Michigan havesignificant wind resources, no offshore wind turbines have been sited in freshwater,particularly a potable water source such as the Great Lakes. (USDOE 2011)Offshore wind power project and policy developments continued in 2010; however, todate no offshore projects have been installed in the United States and the emergence ofan offshore wind power market still faces many challenges. Nonetheless, interest existsin developing offshore wind energy in several parts of the country, with nine projectstotaling 2322 MW of unstated capacity factors primarily located in the Northeast andMid-Atlantic, though proposed projects also exist in the Great Lakes and Gulf of Mexico.(USDOE 2011) Many of these projects have advanced significantly in the permittingand development process, including three that have signed power purchaseagreements with terms and details that have been made public. Notably, the CapeWind project was granted approval by the Department of Interior in 2010; severalsignificant strides relating to offshore wind energy have been made recently in thefederal arena; and a variety of other recent project and state policy announcementsdemonstrate continued activity in the offshore wind energy sector. (USDOE 2011)In August 2009, Lake Erie Energy Development Corporation (LEEDCo) was created bythe Great Lakes Energy Development Task Force (GLEDTF), then developed andlaunched by NorTech Energy Enterprise, the Cleveland Foundation, City of Cleveland,Cuyahoga and Lorain Counties (Ohio). It was founded as a private, non-profit regionalcorporation to initially build wind turbines in Lake Erie, and eventually help stimulate anentire offshore freshwater wind industry. Initially LEEDCo plans to build and install a 20-30 megawatt (MW) wind energy pilot project seven miles offshore of downtownCleveland which would be the first offshore freshwater wind energy project in NorthAmerica. LEEDco then plans to use the initial project as a road map to develop thepermitting process and catalyze future offshore wind projects by commissioning the first20-to-30 MW, five-to-seven turbines by 2013, with a long-term vision of generating1000 MW of wind energy by 2020. (LEEDCo 2011)Despite the unlikely development of sufficient offshore wind generation as outlinedabove, FENOC evaluates-for the sole purpose of this NEPA analysis-wind energyAlternatives that Meet System Page 7.2-7 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportfrom interconnected wind farms as if such energy was available by 2017. Therefore,FENOC evaluated the potential environmental impacts for offshore wind generation andintegrating that power into the transmission system as a replacement for Davis-Besse'srated electrical output.Solar FarmsElectric power generation from photovoltaic (PV) cells has been commerciallydemonstrated. However, because the sun only shines during the day, solar PV arrayscannot by themselves consistently produce electricity. There is currently only oneoperational solar energy facility in Ohio greater than 10 MW-the 12-MWe WyandotSolar Farm in Upper Sandusky, OH (PSEG 2010). The 49.9 MWe Turning Point Solarproject near Cumberland, OH, is projected to be completed in 2015 (AEP 2011).FENOC is not aware of other planned solar energy facilities greater than 10 MW in Ohiothat would be operational by 2017, and whose output is not already dedicated to anexisting commercial or industrial facility.A solar project would have to be located where the project would produce economicalgeneration, and that location may be far removed from the nearest possible connectionto the transmission system. A location far removed from the power transmission gridmight require construction of new transmission lines to connect the solar farm to thedistribution system, and the question of who pays for the transmission upgrade would beat issue. Existing transmission infrastructure may need to be upgraded to handle theadditional supply. Soil conditions and the terrain must be suitable for the construction ofthe solar farms. Finally, the choice of a location may be limited by land use regulationsand the ability to obtain the required permits from local, regional, and national authorities.Although solar resources are limited in Ohio, FENOC evaluates-for the sole purpose ofthis NEPA analysis-solar energy combined with CAES, and combined withinterconnected wind farms and CAES, as alternatives to replace the rated electricaloutput of Davis-Besse by 2017.Compressed Air Energy StorageFENOC is presenting the following information about CAES technology as backgroundfor the discussion that follows about CAES combined with interconnected wind farms orsolar energy facilities.CAES can be linked with renewable energy by offering one way to supplement andback-up the electricity produced by intermittent resources such as wind and solar. Thisenergy storage method enhances the ability of these resources to provide the electricitythat customer's need, when they need it.Alternatives that Meet System Page 7.2-8 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportHowever, CAES facilities are generally operated as peaking plants with energy placedinto storage during the less expensive, non-peak demand hours and generated from thestorage units during the higher-priced, peak demand hours. CAES involves usingcompressors powered by the generation source to pump air into a storage facility, suchas an underground cavern. During peak demand hours, the compressed air is used incombination with a heat source, such as natural gas, to drive turbines and generateelectricity. To generate electricity from CAES, natural gas usage is between one-thirdand one-half that needed to generate the same amount of electricity at a natural gasgenerating plant (USDOE 2009). Due to the cost differential between peak and non-peak hours and the reduction in the volume of natural gas used to generate a specificamount of power, a CAES facility can be an economically and environmentally attractivemethod of producing peaking power (RES 2005; PEI 2008).These economic benefits evaporate if the energy source used to pump air into thestorage facility is solar power, or wind power available during the day. Since solar is aresource mostly available during the onpeak daytime hours, storage offers little economicbenefit when evaluating solar (or daytime wind power) with CAES. FENOC is not awareof any existing CAES facilities that are combined solely with wind or solar power.The Iowa Stored Energy Park (ISEP) was proposed to be a 270 MW CAES facilityintegrated with a wind farm in Iowa. However, testing and analysis of the site geologyconcluded that the ability to store the air underground at the ISEP site near DallasCenter, Iowa was unfeasible. (ISEP 2011)Two CAES facilities combined with natural gas power plants, a 110-MW facility inAlabama and a 290-MW plant in Germany, have been built and are in operation (PEI2008). A CAES facility powered with energy from generation facilities already on thepower grid is proposed for Norton, Ohio. This facility, which is still in the projectdevelopment stage, is planned to eventually-i.e., after 2017-provide 2700 MW ofpeaking power generation (PEI 2008). The Norton CAES project is somewhat differentfrom the other CAES projects in that a pre-existing mine on a brownfield site would beutilized. The size and the mining engineered construction of the pre-existing mineallows a much greater planned capacity for the Norton facility as compared to otherexisting or proposed CAES projects.Norton Energy StorageIn 2009, FirstEnergy Generation Corp., a subsidiary of FirstEnergy Corp., purchased therights to develop the Norton Energy Storage (NES) facility. The facility is located on a92-acre site in Norton, Ohio. The compressed air would be stored in a 600-acreunderground cavern, formerly operated as a limestone mine, which is ideal for energystorage technology. The facility would generate electricity during on-peak andintermediate periods, which would enable the more efficient operation of large, base-Alternatives that Meet System Page 7.2-9 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportload power plants. FirstEnergy is currently developing the NES facility and it would beconstructed in phases. The initial phase is designed to produce 268 MW of generation,220 MW of compression, and 373 hours of storage using two 134 MW generators.FirstEnergy estimates that up to four units or 536 MW of generation could be online by2017. The existing air permit for the NES facility authorizes FirstEnergy GenerationCorp to expand the facility to a capacity of 804 MW (see Table 7.2-3). (NES 2010) Thisproject has two major components: the above-ground equipment and the subsurfaceabandoned limestone mine used to store compressed air. The size of the cavern couldeventually allow the project to provide up to 2700 MW of generation if the current airpermit could be modified.The NES facility would include two power generation units designed specifically for theCAES application. Each unit would consist of an air compressor, a motor, an expander,an associated combustor and a generator. The facility would be designed to operate onnatural gas only; no fuel oil would be combusted in the turbines or in-line burners. Themajor ancillary support equipment would consist of an emergency generator, a backupdiesel fire pump, and wet cooling towers to cool compressor air to be injected intostorage and provide other equipment cooling. Other support equipment would includecooling water treatment systems, acid/caustic or neutralization tanks, instrument aircompressors, electric driven fuel compressors, sumps, and oil/water separators.Available Alternatives for Renewable Energy Generation in Combination withEnergy StorageThe potential for using renewable power sources as an alternative to license renewalcan be enhanced if the generation source is combined with an energy storagetechnology, thus increasing the availability, reliability, and predictability of the delivery ofpower. The two renewable power generation sources evaluated in this ER areinterconnected wind farms and photovoltaic solar facilities.The theory behind the combination of renewable power generation with energy storageis that when the generation capacity is available, the amount of power produced could,at times, exceed the demand for power at that time. Excess energy could be stored andreturned later to the electrical grid when the renewable power generation resource iseither not available or is available at a diminished level that is insufficient to satisfy thedemand for power.Therefore, in order for this combination of technologies to function, the renewableenergy source would have to be sized larger than the base-load power level in this casefor Davis-Besse, 910 MW. The need to have generation capacity greater thanbase-load requirements in order to place energy into storage would cause greaterenvironmental impacts than a generation source rated at the base-load value alone.For example, a solar or wind generation source assumed to be available for 12 hoursAlternatives that Meet System Page 7.2-10 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportevery day, and a CAES facility assumed to be available to generate electricity theremaining 12 hours in the day, would require that generation source to be rated at, andconsistently produce 1820 MW in order to provide 24-hours of continuous electricity(i.e., 12 hours to provide 910 MW of generation onto the grid, and the same 12 hours toprovide 910 MW to recharge the CAES facility, so that the CAES facility could feed thegrid the remainder of the day).As explained in Section 7.2.1, FENOC evaluates-for the sole purpose of this NEPAanalysis-renewable energy sources combined with energy storage as an alternative toreplace the rated electrical output of Davis-Besse.Wind Energy Generation Combined with CAESAs of 2011, there is currently 11 MWe of wind generation in Ohio with another 406 MWeunder construction. (AWEA 2011) However, Ohio has a potential wind generationcapacity of nearly 55,000 MW according to the NREL (AWEA 2011 and NREL 2011a),which at a 30% capacity factor would be more than sufficient to provide power tooperate a CAES facility. The 30% capacity factor is derived from PJM Interconnection(a regional transmission organization) and the U.S. Department of Energy (USDOE)(PJM 2011 and USDOE 2011. The environmental impacts of developing this type ofgeneration alternative are evaluated in Section 7.3.3.For this combination, FENOC evaluated wind energy generating electricity for both 910MW to replace Davis-Besse's rated output and 910 MW of storage capacity, for a totalof 1820 MWe. Sufficient energy must be put into storage when the wind resources areavailable to account for the lack of power generation capabilities for the periods of timewhen adequate wind resources are unavailable. Under this alternative, natural gaswould be needed to recover the energy captured in the CAES process, but would not beused as a source of supplemental power generation if wind generation or generationfrom the storage facility is not available for extended periods of time.Photovoltaic Power Combined with CAESAs stated previously, there is currently only one operational solar energy facility in Ohiogreater than 10 MW: the 12-MWe Wyandot Solar Farm in Upper Sandusky, OH. (PSEG2010) The 49.9-MWe Turning Point Solar project near Cumberland, OH, is projected tobe completed in 2015. (AEP 2011) FENOC is not aware of other planned solar energyfacilities greater than 10 MW in Ohio that would be operational by 2017, and whoseoutput is not already dedicated to an existing commercial or industrial facility. As withwind, FENOC evaluated solar farms as if they were interconnected with CAES toprovide electricity to the grid.Alternatives that Meet System Page 7.2-11 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportCombinations of Wind and Solar with CAESAs referenced above, approximately 1820 MWe of base-load power would be requiredfrom renewable energy generation plus storage to account for the lack of powergeneration capabilities for the periods of time when adequate wind and solar resourcesare unavailable.FENOC evaluates-for the sole purpose of this NEPA analysis-the following acombined alternative to replace the rated electrical output of Davis-Besse by 2017:sufficient interconnected wind farms and solar (PV) facilities available with high reliability,and connected to an operating CAES facility; an operating CAES facility expanded to acapacity similar to Davis-Besse; and an interconnected grid system. The potentialenvironmental impacts related to this scenario are presented in Section 7.3.3.3.7.2.2 ALTERNATIVES CONSIDERED AS NOT REASONABLEThe following alternatives were considered as not reasonable replacement base-loadpower generation for one or more reasons as listed in Section 7.2.2.1 andSection 7.2.2.2. Although several of the alternatives could be considered incombination for replacement power generation at multiple sites, they do not generallyprovide base-load generation, and would entail greater environmental impacts.7.2.2.1 Alternatives Not Requiring New Generating CapacityThis section discusses the economic and technical feasibility of supplying replacementenergy without constructing new base-load generating capacity. Specific alternativesinclude:* Conservation measures (including implementing demand side management (DSM)actions);" Delayed retirement of existing non-nuclear plants; and" Purchased power from other utilities equivalent to the output of Davis-Besse (i.e.,eliminating the need for license renewal).Conservation ProgramsThere is a variety of conservation technologies (e.g., DSM) that could be considered aspotential alternatives to generating electricity at Davis-Besse. Examples include:* Conservation Programs-homeowner agreements to limit energy consumption;educational programs that encourage the wise use of electricity.Alternatives that Meet System Page 7.2-12 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report" Energy Efficiency Programs- discounted residential rates for homes that meetspecific energy efficiency standards; programs providing residential energy auditsand encouraging efficiency upgrades; incentive programs used to encouragecustomers to replace older inefficient appliances or equipment with newer versionsthat are more efficient.* Load Management Programs -programs that encourage customers to switch loadto customer-owned standby generators during periods of peak demand; programsthat encourage customers to allow a portion of their load to be interrupted duringperiods of peak demand.On a national basis, DSM has shown great potential in reducing peak demand(maximum power requirement of a system at a given time). In 2008, a peak loadreduction of 32,741 MWe was achieved nationally, which is an increase of 8.2% from2007; however, since these DSM costs increased by 47.4%. DSM costs can varysignificantly from year to year because of business cycle fluctuations and regulatorychanges. Since costs are reported as they occur, while program effects may appear infuture years, DSM costs and effects may not always show a direct relationship. Since2003, nominal DSM expenditures have increased at 22.9% average annual growth rate.During the same period, actual peak load reductions have grown at a 6.2% averageannual rate from, 22,904 MW to 32,741 MW (EIA 2010, Page 9).In Ohio, as part of Senate Bill 221, utilities must implement energy efficiency programsthat, beginning in 2009, achieve energy savings of at least 0.3% of the utility's three-year average annual kilowatt-hour (kWh) sales, with energy savings increasing to22.5% by the end of 2025. Peak demand reductions of 1% in 2009 and increasing to7.75% by the end of 2018 are also required. (FirstEnergy 2009a, Page 100) However,since these DSM-induced load reductions typically are considered in load forecasts, thereductions do not offset the projected power demands that are expected to be suppliedwith the power generated by Davis-Besse.Although FENOC believes that energy generation savings can increase from DSMpractices, it would be unrealistic to increase those energy savings to completely andconsistently replace the Davis-Besse generating capability. The variability in associatedcosts also makes DSM a less desirable option. Consequently, FENOC does not seeDSM as a practicable offset for the base-load capacity of Davis-Besse.Delayed RetirementExtending the lives of existing non-nuclear generating plants beyond the time they wereoriginally scheduled to be retired, as described in the GElS (NRC 1996, Section 8.3.13),does not represent a realistic option with respect to FirstEnergy's generating assets.Alternatives that Meet System Page 7.2-13 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportApproximately 56% of FirstEnergy's generating capacity consists of coal-fired plantswhich, due to a lower cost of generation, are used at capacity factors higher than otherfossil-fuel generating units (FirstEnergy 2008b). Virtually all of FirstEnergy's non-nuclear base-load generating capability is from coal firing. These coal-fired plants weredeveloped in the 1980s or earlier and represent the only plants in FirstEnergy's portfoliothat would have any potential for continued operation to replace the base-loadgeneration represented by Davis-Besse. However, older plants that do becomecandidates for retirement generally represent less efficient generation and pollutioncontrol technologies than are available in more modern plants, and continued operationtypically would require substantial upgrades to be economically competitive and meetapplicable environmental standards. In many cases, it is unlikely that such upgradeswould be economically viable. FENOC believes that the environmental impacts ofimplementing such upgrades and operating the upgraded plants are bounded by theassessments presented in Section 7.3 for the gas-fired and coal-fired alternatives.For these reasons, the delayed retirement of non-nuclear generating units is notconsidered by FENOC as a reasonable alternative to the renewal of Davis-Besse'slicense.Purchased PowerEach of the states (Ohio, Pennsylvania, and New Jersey) in which FirstEnergy servesload have undertaken electric industry restructuring initiatives that promote competitionin retail energy markets by allowing participation of non-utility suppliers. Retailcustomers historically served by the regulated operating subsidiaries of FirstEnergy nowhave the option to choose between FirstEnergy-affiliated suppliers and other state-qualified energy suppliers. (FENOC 2007, Section 7.2.3.2)In theory, purchased power is a feasible alternative to Davis-Besse license renewal.There is no assurance, however, that sufficient capacity or energy would be availableduring the entire license renewal time frame to replace the approximately 910 MWe ofbase-load generation. In addition, even if power to replace Davis-Besse capacity wereto be purchased, FENOC assumes that the generating technology used to produce thepurchased power would be one of those described in the GELS. Thus, theenvironmental impacts of purchased power would still occur, but would be locatedelsewhere within the region.As a result, FENOC has determined that purchased power would not be a reasonablealternative to replace power lost in the event the Davis-Besse operating license is notrenewed.Alternatives that Meet System Page 7.2-14 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report7.2.2.2 Alternatives Requiring New Generating CapacityThe following conventional power plant types are evaluated in this section as potentialalternatives to license renewal:* New Nuclear Reactor* Petroleum Liquids (Oil)In addition, with the passage of Ohio's Senate Bill 221 in 2008, at least 25% ofelectricity supply for retail customers must come from renewable and advanced energyresources by 2025 OHPUCO 2009, Pages 3 and 4). Accordingly, the followingalternative energy sources are evaluated." Hydropower" Solar* Geothermal* Biomass (Wood Waste)* Municipal Solid Waste* Other Biomass-Derived Fuels (Energy Crops)* Fuel CellsCriteria used to determine if the potential energy alternatives represent a reasonablealternative include whether the alternative is developed and proven, can providegeneration of approximately 910 MWe of electricity as a base-load supply, iseconomically feasible, and does not impact the environment more than Davis-Besse.New Nuclear ReactorIncreased interest in the development of advanced reactor technology has beenexpressed by members of both industry and government. With energy demandsforecasted to increase and public opposition to new carbon-fueled power plants, somecompanies are pursuing permits and licenses to build and operate new nuclear reactorsto meet the country's future energy needs. As of June 2010, for example, 18applications, for 28 units, for combined licenses have been submitted to the NRC forreview (NRC 2010).Nonetheless, there is ongoing uncertainty with respect to future electric demand due tothe potential impacts of policy changes that could be enacted to limit or reducegreenhouse gas emissions. The downturn in the world economy also has had asignificant impact on energy demand as well. The recovery of the world's financialmarkets is especially important for the energy supply outlook, because the capital-intensive nature of most large energy projects makes access to financing a criticalnecessity. (EIA 2010, Pages 5). Moreover, the economics of new nuclear plantsAlternatives that Meet System Page 7.2-15 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportremain uncertain with escalating fuel and construction costs emerging as forces whichcould affect this option.In consideration of the extended schedule for construction of a new nuclear reactor,access to capital, and the schedule for the new reactor licensing process, constructionof a new nuclear reactor at the Davis-Besse site or at an alternative site is not feasibleprior to the period of extended operation for Davis-Besse, i.e., in this case, 2017.Therefore, a new nuclear reactor is not considered a reasonable alternative to renewalof Davis-Besse's operating license..Petroleum Liquids (Oil)Oil-fired generation has experienced a significant decline since the early 1970s.Increases in world oil prices have forced utilities to use less expensive fuels (NRC 1996,Section 8.3.11). From 2002 to 2008, for example, the average cost of petroleum forpower generation increased by more than a factor of three (EIA 2010, Table 3.5).This high cost of oil has prompted a steady decline in its use for electricity generation.Within Ohio, for example, oil-fired units produce only 0.2% of power generation(NEI 2008). Increasing domestic concerns over oil security also will intensify the moveaway from oil-fired electricity generation.Therefore, FENOC does not consider oil-fired generation a viable alternative to renewalof Davis-Besse's operating license.HydropowerConsidering the FirstEnergy transmission and distribution territory, Ohio andPennsylvania have a combined potential for 1,758 MWe of additional undevelopedhydroelectric capacity, with Ohio contributing 57 MWe (INEEL 1998, Table 4). Thus,hydropower is a feasible alternative to Davis-Besse license renewal in theory.However, as noted in the GElS, hydropower's percentage of United States generatingcapacity is expected to decline because the facilities have become difficult to site as aresult of public concern about flooding, destruction of natural habitat, and alteration ofnatural river courses (NRC 1996, Section 8.3.4). For example, the GElS estimated thatland requirements for hydroelectric power are approximately 1 million acres per1,000 MWe. Replacement of the Davis-Besse generating capacity would thereforerequire flooding a substantial amount of land (910,000 acres). Consequently, even ifthe capacity for development were available in Ohio-Pennsylvania, there would be largeland-use and related environmental and ecological resource impacts associated withsiting hydroelectric facilities large enough to replace Davis-Besse.Alternatives that Meet System Page 7.2-16 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportAs a result, developing a hydropower base-load capacity of approximately 910 MWe isnot considered by FENOC to be a reasonable alternative to renewal of Davis-Besse'soperating license.Solar PowerSolar power technologies, both thermal and photovoltaic (PV), have been commerciallydemonstrated. However, because the sun only shines during the day, solar arrayscannot, by themselves, provide consistent electrical output. Therefore, solar arraysalone are not considered in this ER as a reasonable alternative to the license renewal ofDavis-Besse. Solar energy in combination with interconnected wind farms and CAES isdiscussed in Section 7.2.1.3.Geothermal EnergqyGeothermal energy has an average capacity factor of 90 percent and can be used forbase-load power where available (NRC 2009b Section 8.2.5.5). However, geothermalelectric generation is limited by the geographical availability of geothermal resources.As illustrated by Figure 8.4 in the GELS, no feasible eastern location for geothermalcapacity exists to serve as an alternative to Davis-Besse (NRC 1996, Section 8.3.5). Asa result, FENOC does not consider geothermal energy to be a reasonable alternative torenewal of the Davis-Besse operating license.Biomass EnergyBiomass is any organic material made from plants or animals. Agricultural and woodwastes such as forestry residues, particularly paper mill residues, are the most commonbiomass resources used for generating electricity. Regionally, eastern Ohio and mostof Pennsylvania provide the largest biomass resources (EERE 2009a, b). The costs ofthese fuels, however, are highly variable and very site specific (NRC 1996,Section 8.3.6).Most biomass plants use direct-fired systems by burning biomass feedstocks to producesteam directly for conventional steam turbine conversion technology. Although thetechnology is relatively simple to operate, it is expensive and inefficient. Conversionefficiencies of wood-fired power plants are typically 20-25%, with capacity factors ofaround 70-80%. As a result, biomass plants at modest scales (550 MWe) makeeconomic sense if there is a readily available supply of low-cost wood wastes andresidues nearby so that feedstock delivery costs are minimal. (NRC 1996,Section 8.3.6)The construction impacts of a wood-fired plant would be similar to those for a coal-firedplant, although most facilities using wood waste for fuel would be built on smallerscales. Like coal-fired plants, biomass and wood-waste plants require large areas forAlternatives that Meet System Page 7.2-17 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportfuel storage and processing. They also create impacts to land and water resources,primarily associated with soil disturbance and runoff, in addition to air emissions whichmust be managed. However, unlike coal-fired plants, biomass and wood-waste plantshave very low levels of sulfur oxide emissions. (NRC 1996, Section 8.3.6)Due to the relatively small scale of potential projects and uncertainties in securinglong-term fuel supplies, biomass is not considered by FENOC to be a reasonablealternative to replace Davis-Besse's base-load power generation.Municipal Solid WasteMunicipal solid waste (MSW) facilities that convert waste to energy use technologycomparable to steam-turbine technology for wood waste plants, although the capitalcosts are greater due to the need for specialized separation and handling equipment(NRC 1996, Section 8.3.7). The decision to burn MSW for energy is typically made dueto insufficient landfill space, rather than energy considerations.There are 89 operational MSW energy conversion plants in the United States(USEPA 2009a), none of which were located in Ohio as of 2007 (WTE 2007). Theseplants generate approximately 2,500 MWe, or about 0.3% of total national powergeneration (USEPA 2009a). At an average capacity of about 28 MWe, numerousMSW-fired power plants would be needed to replace the base-load capacity ofDavis-Besse.Construction impacts for a waste-to-energy plant are estimated to be similar to those fora coal-fired plant. Air emissions are potentially harmful. Increased construction costs fornew plants and economic factors (i.e., strict regulations and public opposition) may limitthe growth of MSW energy generation (NRC 1996, Section 8.3.7; USEPA 2009a).For reasons stated, MSW is not considered by FENOC to be a reasonable alternative torenewal of Davis-Besse's operating license.Other Biomass-Derived FuelsIn addition to biomass energy such as wood and municipal solid-waste fuels, there areother concepts for biomass-fired electric generators, including direct burning of energycrops, conversion to liquid biofuels, and biomass gasification. The GElS indicated thatnone of these technologies had progressed to the point of being competitive on a largescale or of being reliable enough to replace a base-load plant (NRC 1996,Section 8.3.8). After recently re-evaluating current technologies, the NRC staff believesother biomass-fired alternatives are still unable to reliably replace base-load capacity(NRC 2009b, Section 8.2.5.8). For this reason, FENOC does not consider biomass-derived fuels to be a reasonable alternative to renewal of Davis-Besse's operatinglicense.Alternatives that Meet System Page 7.2-18 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportFuel CellsFuel cells are electrochemical devices that generate electricity without combustion andwithout water and air pollution. Fuel cells began supplying electric power for the spaceprogram in the 1960s. Today, they are being developed for more commercialapplications. The U.S. Department of Energy (USDOE) is currently partnering withseveral fuel cell manufacturers to develop more practical and affordable designs for thestationary power generation sector. If successful, fuel cell power generation shouldprove to be efficient, reliable, and virtually pollution free. At present, progress has beenslow and costs are high. The most widely marketed fuel cell is currently about $4,500per kilowatt (kW) compared to $800 to $1,500 per kW for a diesel generator and about$400 per kW or less for a natural gas turbine. By the end of this decade, the USDOEgoal is to reduce costs to as low as $400 per kW. (USDOE 2009b)However, fuel cells presently are not economically or technologically competitive withother alternatives for base-load capacity. Therefore, FENOC does not consider fuelcells to be a reasonable alternative to renewal of Davis-Besse's operating license.Alternatives that Meet SystemGenerating NeedsPage 7.2-19September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 7.2-1 Coal-Fired Alternative Emission Control CharacteristicsCharacteristic BasisNet capacity = 910 MW Equivalent to Davis-Besse.Capacity factor = 80% From FENOC 2007, Table 7.2-2Firing mode: subcritical, tangential, dry-bottom Widely demonstrated, reliable, economical;pulverized coal tangential firing minimizes NOx emissions(FENOC 2007, Table 7.2-2)Fuel type = bituminous coal Type used in FirstEnergy Ohio River plants(FENOC 2007, Table 7.2-2)Fuel heating value = 12,285 Btu/lb FirstEnergy Bruce Mansfield Plant average(FENOC 2007, Table 7.2-2)Heat rate = 9,800 Btu/kWh at full load FirstEnergy experience (FENOC 2007, Table 7.2-2)Fuel sulfur content = 3.52 wt% ; 2.86 lb/MMBtu FirstEnergy Bruce Mansfield Plant average(FENOC 2007, Table 7.2-2)Fuel ash content = 11.88 wt% FirstEnergy Bruce Mansfield Plant average(FENOC 2007, Table 7.2-2)Uncontrolled SOx emissions = 130 lb/ton coal USEPA estimate calculated as 38 x wt% sulfur incoal (FENOC 2007, Table 7.2-2)Uncontrolled NOx emissions = 10 lb/ton coal USEPA estimate (FENOC 2007, Table 7.2-2)Uncontrolled CO emission = 0.5 lb/ton coal USEPA estimate (FENOC 2007, Table 7.2-2)Uncontrolled PM emission = 120 lb/ton coal USEPA estimate calculated as 10 x wt% ash in coal(FENOC 2007, Table 7.2-2)Uncontrolled PM10 emission = 27 lb/ton coal USEPA estimate calculated as 2.3 x wt% of ash incoal (FENOC 2007, Table 7.2-2)CO2 emissions = 6,000 lb/ton Approximate average for bituminous coalcombustion (FENOC 2007, Table 7.2-2)SOx control = wet limestone flue gas Best available technology for minimizing SOxdesulphurization (95% removal) emissions (FENOC 2007, Table 7.2-2)NOX control = low NOX burners, overfire air, Best available technology for minimizing NOxselective catalytic reduction (95% reduction) emissions (FENOC 2007, Table 7.2-2)Particulate control = fabric filters Best available technology for minimizing particulate(99.9% removal) emissions (FENOC 2007, Table 7.2-2)Btu = British thermal unit MW = megawattCO = carbon monoxide NOx = nitrogen oxidesCO2 = carbon dioxide PM = particulate matterft3 = cubic feet PM10 = PM with diameter less than 10 micronskWh = kilowatt-hour SOx = sulfur oxideslb = pound USEPA = U.S. Environmental Protection AgencyMMBtu = million Btu wt% = percent by weightAlternatives that Meet SystemGenerating NeedsPage 7.2-20September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 7.2-2: Gas-Fired Alternative Emission Control CharacteristicsCharacteristic BasisNet capacity = 910 MW Equivalent to Davis-Besse.Capacity factor = 80% From FENOC 2007, Table 7.2-1Fuel type = natural gas AssumedHeat rate = 6,500 Btu/kWh FENOC Estimate (FENOC 2007, Table 7.2-1)Fuel heating value = 1,025 Btu/ft3 From FENOC 2007, Table 7.2-1Fuel sulfur content = 0.2 grains/100 scf From FENOC 2007, Table 7.2-1(0.00068 wt%)SO2 emissions = 0.00064 lb/MMBtu USEPA estimate for natural gas-fired turbines(0.94 x wt% sulfur in fuel) (FENOC 2007, Table 7.2-1)NOx emissions (assuming dry low-NOx USEPA estimate for best available NOx combustioncombustors) = 0.099 lb/MMBtu control (FENOC 2007, Table 7.2-1)NOx post-combustion control: selective USEPA estimate for best available NOx post-catalytic reduction (90% reduction) combustion control (FENOC 2007, Table 7.2-1)CO emissions (assuming dry low-NOx USEPA estimate (FENOC 2007, Table 7.2-1)combustors) = 0.015 lb/MMBtuPM emissions (all PM10) = 0.0019 lb/MMBtu USEPA estimate (FENOC 2007, Table 7.2-1)CO2 emissions = 110 lb/MMBtu USEPA estimate (FENOC 2007, Table 7.2-1)Btu = British thermal unit MW = megawattCO = carbon monoxide NOx = nitrogen oxidesCO, = carbon dioxide PM = particulate matterft = cubic feet PM10 = PM with diameter less than 10 micronskWh = kilowatt-hour scf = standard cubic feetlb = pound SOx = sulfur oxidesMMBtu = million Btu USEPA = U.S. Environmental Protection Agencywt% = percent by weightAlternatives that Meet SystemGenerating NeedsPage 7.2-21September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 7.2-3: CAES Alternative Emission Control CharacteristicsCharacteristic BasisSix trains at 134 MW per trainNet capacity = 804 MW (maximum authorized under existing air permit,although only 536 MW could be online by 2017)Within typical range of base-load plant; results inCapacity factor = 80% approximate annual output near that of Davis-Besse.Fuel type = natural gas AssumedHeat rate (HHV) = 4,395 Btu/kWh From OEPA Air Permit P0106714; Norton CAESFuel heating value = 1,025 Btu/ft3 From FENOC 2007, Table 7.2-1Fuel sulfur content = 2 grains/100 scf From QEPA Air Permit P0106714; Norton CAES(0.0066 wt%)SO2 emissions = 0.006 lb/MMBtu From OEPA Air Permit P0106714; Norton CAESNOx emissions (assuming water injection &selective catalytic reduction) = 3.0 ppmvd @ From OEPA Air Permit P0106714; Norton CAES15% oxygen and 43.08 lbs/hr(6 units at 7.18 lbs/hr each)CO emissions (assuming dry low-NOxcombustors & CO catalytic oxidation) = From OEPA Air Permit P0106714; Norton CAES5 ppmvd @ 15% oxygen and 43.68 lbs/hr(6 units at 7.28 lbs/hr each)PM emissions (all PM10) = 0.0066 Ib/MMBtuPM eissons(al PM0) =0.066 b/M~tu From OEPA Air Permit P0106714; Norton CAESand 23.34 lbs/hr (6 units at 3.89 lbs/hr each)CO2 emissions = 110 lb/MMBtu USEPA estimate (FENOC 2007, Table 7.2-1)VOC emissions = 13.2 lbs/hr(6 unit sions at 3.2 lbs/hr eaFrom OEPA Air Permit P0106714; Norton CAES(6 units at 2.2 Ibs/hr each)Btu = British thermal unit MW = megawattCO = carbon monoxide NOx = nitrogen oxidesCO2 = carbon dioxide OEPA = Ohio Environmental Protection AgencyCAES = compressed air energy storage PM = particulate matterft3 = cubic feet PM10 = PM with diameter less than 10 micronsHHV = higher heating value ppmvd = parts per million volumetric drykWh = kilowatt-hour scf = standard cubic feetlb = pound SOx = sulfur oxideslbs/hr = pounds per hour USEPA = U.S. Environmental Protection AgencyMMBtu = million Btu wt% = percent by weightVOC = volatile organic compoundAlternatives that Meet SystemGenerating NeedsPage 7.2-22September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report7.3 ENVIRONMENTAL IMPACTS OF ALTERNATIVESEnvironmental impacts are evaluated in this section for the coal- and gas-firedgeneration alternatives determined by FENOC to be reasonable in Section 7.2.1compared to renewal of Davis-Besse's operating license.The impacts are characterized as being SMALL, MODERATE, or LARGE. Thedefinitions of these impact descriptions are the same as presented in the introduction toChapter 4, which in turn are consistent with the criteria established in 10 CFR Part 51,Appendix B to Subpart A, Table B-i, Footnote 3. FENOC believes the environmentalimpacts associated with the construction and operation of new generating capacity at agreenfield site would exceed those for the same type plants located at Davis-Besse orat another existing disturbed site, i.e., brownfield site.The new generating plants addressed in Section 7.2.1 would not be constructed only tooperate for the period of extended operation of Davis-Besse. Therefore, FENOCassumes for this analysis a typical design life of 40 years for the coal-fired plant,30 years for the combined-cycle natural gas-fired plant, and considers impactsassociated with operation for the entire design life of the units in this analysis. The lifespan of a wind turbine is 20 years (REN 2005); however, turbines can be replaced andthe tower would likely be in service for at least 40 years. The life span of a solar plant isestimated to be at least 30 years (TEP 2005).Chapter 8 presents a summary comparison of the environmental impacts of licenserenewal and the alternatives discussed in this section.7.3.1 COAL-FIRED GENERATIONThis section presents the impact evaluation for the representative coal-fired generationalternative. As discussed in Section 7.2.1.1, FENOC assumed for purposes of thisanalysis that the representative plant would be located at a greenfield or (preferably)brownfield site along commercially navigable waterway or existing rail way. Thisassumption is a result of the space limitation at the Davis-Besse site.Land UseLand area requirements for a coal-fired plant of similar capacity to Davis-Besse, forexample, would be approximately 1.7 acres per MWe (NRC 1996, Table 8.1), or1,547 acres for a 910 MWe plant. This amount of land use will include plant structuresand associated infrastructure. Additional acres would be needed offsite for transmissionlines and possibly rail lines, depending on the location of the site relative to the nearestinter-tie connection or rail spur. This acreage could amount to a considerable loss ofnatural habitat or agricultural land for the plant site alone dependent upon whether aEnvironmental Impacts of AlternativesPage 7.3-1September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportgreenfield or brownfield site was used, excluding that required for mining and other fuel-cycle impacts. Some portion of the impacts could be mitigated by constructing newtransmission line in existing rights-of-way (ROW) to as great an extent as possible.Land-use changes also would occur offsite in an undetermined coal-mining area tosupply coal for the plant. For example, the GElS estimated that approximately 22 acresof land per MWe would be affected for mining the coal and disposing of the waste tosupport a coal-fired plant during its operational life (NRC 1996, Section 8.3.9).Therefore, for the 910 MWe plant used in this analysis, approximately 20,020 acres ofland would be needed. Partially offsetting this offsite land use would be the eliminationof the need for uranium mining and processing to supply fuel for Davis-Besse. TheGElS estimated that approximately one acre per MWe would be affected for mining andprocessing the uranium during the operating life of a nuclear power plant (NRC 1996,Section 8.3.12). Therefore, for Davis-Besse uranium mining and processing,approximately 910 acres of land would be required, resulting in offsite mining net landuse of 19,110 acres for the representative coal-fired generation alternative.In consideration of the above, FENOC considers that land use impacts associated witha coal-fired plant at an alternate site would depend on the location of the plant and beMODERATE to LARGE.Water Use and Quality -Surface WaterConstruction-phase impacts on water quality of greatest potential concern includeerosion and sedimentation associated with land clearing and grading operations at theplant site and waste disposal site, and suspension of bottom sediments duringconstruction of cooling water intake and discharge structures and facilities for bargedelivery of coal and limestone. However, land clearing and grading activities would besubject to stormwater protections in accordance with the NPDES program, and work inwaterways would be regulated by the USACE under the CWA Section 404 andSection 10 of the Rivers and Harbors Act. These activities would also be subject tocorresponding state and local regulatory controls, as applicable. In addition, theseadverse effects would be localized and temporary. As a result, FENOC considers thatimpacts on surface water quality associated with construction of the representative plantat an alternative site would be SMALL.FENOC expects that potential impacts on water quality and use associated withoperation of the representative plant would be similar to impacts associated withDavis-Besse operation. Cooling water and other wastewater discharges would beregulated by an NPDES permit, regardless of location. Cooling water intake,evaporative losses, and discharge flows for the representative coal-fired plant, assumedto use a closed-cycle cooling system, would be similar to or lower than those resultingfrom Davis-Besse operation (see Chapter 4). As a result, FENOC considers thatEnvironmental Impacts of AlternativesPage 7.3-2September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportimpacts on surface water quality associated with operation of the representative plant atan alternative site would be SMALL.In view of the environmental review afforded under OPSB rules or a similar program,FENOC considers the impacts of surface water use and quality from construction andoperation of the representative plant at an alternative site would be SMALL.Water Use and Quality -Ground WaterImpacts will depend on whether the plant will use ground water for any purposes, aswell as the characteristics of local aquifers. Effects to ground water quality can alsodepend on waste-management and coal-storage practices, although proper disposaland material handling should reduce the likelihood of an effect, as would recycling agreater percentage of waste products. Regardless of location, FENOC believes it highlyunlikely that a coal-fired power plant at an alternate site will rely on ground water forplant cooling, and that ground water and waste-management regulations will limitimpacts to SMALL.Air QualityAir quality impacts of coal-fired generation differ considerably from those of nucleargeneration. A coal-fired plant emits sulfur oxides (SO,), nitrogen oxides (NO.),particulate matter (PM), and carbon monoxide (CO), all of which are regulatedpollutants. Additionally, there are substantial emissions of carbon dioxide (CO2), agreenhouse gas, although future developments such as carbon capture and storageand co-firing with biomass have the potential to reduce the carbon footprint of coal-firedelectricity generation (POST 2006). Coal also contains other constituents (e.g.,mercury, beryllium) that are potentially emitted as hazardous air pollutants, which arealso of concern from a human health standpoint. (NRC 1996, Section 8.3.9)As noted in Section 7.2.1.1, FENOC has assumed a plant design that includes controlsto minimize emissions of regulated air pollutants effectively. Based on emission factors,estimated efficiencies for emission controls, and assumed design parameters listed inTable 7.2-1, operation of the plant would result in the following annual air emissions forcriteria pollutants:* Sulfur dioxide = 8,267 tons* Nitrogen oxides = 5,087 tons" Carbon monoxide = 636 tons* Total filterable particulates = 153 tons* PM10 = 34.3 tons.The annual emissions of carbon dioxide, which is currently unregulated, would beapproximately 7.63 million tons. See Table 7.3-1 for details.Environmental Impacts of AlternativesPage 7.3-3September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportFENOC expects that these emissions would result in a decrease in local air qualitycompared to operation of a nuclear plant. However, FENOC anticipates that both sulfurdioxide and nitrogen oxide emissions will be subject to cap and trade programs(FENOC 2007, Section 7.2.1.3). As a result, the plant would not be expected to add toregional sulfur dioxide emissions and may not add to regional nitrogen oxide emissions,at least during the ozone season (FENOC 2007, Section 7.3.2, Air Quality). Therepresentative plant would add to regional concentrations of other pollutants, includingthe criteria pollutants carbon monoxide and particulates; hazardous air pollutants; andcarbon dioxide, which is a greenhouse gas.Subject to regulatory controls, FENOC anticipates that the overall air quality would benoticeable, but not destabilizing. As a result, FENOC considers that the impacts to airquality from operation of the representative plant at an alternative site would beMODERATE.Ecological ResourcesOnsite and offsite land disturbances form the basis for impacts to terrestrial ecology.Constructing a coal-fired plant at an alternate site could alter onsite ecologicalresources because of the need to convert about 1,547 acres of land at the site toindustrial use for the plant, coal storage, and ash and scrubber sludge disposal (see theLand Use subsection above). Coal-mining operations will also affect terrestrial ecologyin offsite mining areas, although some of this land is likely already disturbed by miningoperations.Impacts could include wildlife habitat loss, reduced productivity, habitat fragmentation,and a local reduction in biological diversity. Impacts, however, will vary based on thedegree to which the proposed plant site is already disturbed. On a previous industrialsite, impacts to terrestrial ecology will be minor, unless substantial transmission lineROWs, a lengthy rail spur, or additional roads need to be constructed throughundisturbed or less-disturbed areas. Any onsite or offsite waste disposal by landfillingwill also affect terrestrial ecology at least through the time period when the disposalarea is reclaimed.During construction, impacts to aquatic ecology are likely. Regardless of where theplant is constructed, site disturbance will likely increase erosion and sedimentationrunoff into nearby waterways, increasing turbidity. While site procedures andmanagement practices may limit this effect, the impact will likely be noticeable. This isparticularly true when intake and outfall structures are constructed alongside or in thebody of water, as well as when any ROWs, roads, or rail lines require in-streamstructures to support stream crossings. Noise and disturbance from construction, inaddition to increased turbidity, may have a noticeable effect. Required regulatorypermits, however, will help to mitigate these impacts.Environmental Impacts of AlternativesPage 7.3-4September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportDuring operations, the cooling water system would have a potential impact to aquaticcommunities. However, this system would be designed and operated in compliancewith the CWA, including NPDES limitations to ensure appropriate protection of aquaticcommunities from thermal discharges and cooling water intakes. The cooling waterintake and discharge flows would be comparable to or less than for Davis-Besse, theimpact from which is considered to be SMALL (see Chapter 4). Therefore, associatedimpacts at a comparable site on commercially navigable waterway would also beexpected to be SMALL.Management of runoff from coal piles will also be necessary. However, subject toregulatory oversight, as afforded under OPSB rules or a similar program, FENOCconsiders the impacts to ecological resources from construction and operation of therepresentative plant at an alternative site may be noticeable, but not destabilizing.On this basis, FENOC considers that the overall impact to ecological resources ofconstructing a coal-fired plant with a closed-cycle cooling system at an alternate sitewould be MODERATE.Human HealthCoal-fired power generation introduces worker risk from coal and limestone mining,worker and public risk from coal and lime/limestone transportation, worker and publicrisk from disposal of coal combustion wastes, and public risk from inhalation of stackemissions. For example, the GElS noted that there could be human health impacts(cancer and emphysema) from inhalation of toxins and particulates from a coal-firedplant, but the GElS does not identify the significance of these impacts (NRC 1996,Section 8.3.9). In addition, the coal-fired alternative also introduces the risk of coal pilefires and attendant inhalation risks, though these types of events are relatively rare.(NRC 2009b, Section 8.2.1, Human Health)Regulatory agencies, including the USEPA, USOSHA, and state agencies, set airemission standards requirements for workers and the public based on human healthimpacts. These agencies also impose site-specific emission limits as needed to protecthuman health.Given these extensive health-based regulatory controls, FENOC considers thatoperating the representative coal-fired plant at an alternate site would be SMALL.SocioeconomicsThe peak workforce during construction of the coal-fired plant alternative is estimated torange between 1.2 to 2.5 workers per MWe and the workforce required during operationis estimated to be 0.25 workers per MWe (NRC 1996, Section 8.3.9, Table 8.1 andEnvironmental impacts of AlternativesPage 7.3-5September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.2). For a plant with a capacity of 910 MWe, workforces of approximately 1,092to 2,275 construction workers and 228 permanent employees would be required.Potential impacts from construction of the coal-fired alternative would be highly locationdependent. As noted in the GElS, socioeconomic impacts are expected to be larger ata rural site than at an urban site, because more of the peak construction work forcewould need to move to the area to work (NRC 1996, Section 8.3.9). Not consideringimpacts of terminating Davis-Besse operations, socioeconomic impacts at a remoterural site could be LARGE, while impacts at a site in the vicinity of a more populatedmetropolitan area (e.g., Toledo) could be SMALL to MODERATE. FENOC assumedthat the OPSB or comparable review process, including application of appropriatemitigation found to be needed as a result, would ensure that these construction impactswould not be destabilizing to local communities.At most alternate sites, coal and lime would be delivered by barge, although delivery isfeasible for a location near a railway. Transportation impacts would depend upon thesite location. Socioeconomic impacts associated with rail transportation would beMODERATE to LARGE. Barge delivery of coal and lime/limestone would have SMALLsocioeconomic impacts.As noted in Section 4.17, communities in Ottawa County, particularly those within thetax jurisdiction of Carroll Township and the Carroll-Benton-Salem School District, wouldexperience losses in both employment and tax revenues due to Davis-Besse closure,assuming the plant is constructed outside the area.Based on the above, FENOC considers that the overall socioeconomic impacts ofconstruction and operation of the representative coal-fired plant at an alternate sitewould be MODERATE.Waste ManagementThe representative coal-fired plant would produce substantial solid waste, especially flyash and scrubber sludge. Based on emission factors and controls scaled from BeaverValley (FENOC 2007, Section 7.3.2 and Table 7.2-2)*, the plant annual wastegeneration amounts would be approximately 300,000 tons/year of ash and 470,100 tonsof flue gas desulphurization waste (dry basis), consisting primarily of hydrated calciumsulfate (gypsum) and excess limestone reactant. Although these wastes representpotentially usable products, FENOC assumed the total waste generated would bedisposed of at an offsite landfill. Based on a fill depth of 30 feet and scaling fromBeaver Valley (FENOC 2007, Section 7.3.2), approximately 644 acres would berequired for the landfill over an assumed plant operating life of 40 years..The scale factor for coal is the ratio of total electric capability, 910 MWe/1 980 Mwe, or 0.460.Environmental Impacts of AlternativesPage 7.3-6September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportDisposal of the waste could noticeably affect land use and ground water quality. Inaddition, the December 2008 failure of the dike used to contain fly ash at the TennesseeValley Authority Kingston Fossil Plant in Roane County, Tennessee, and subsequentcleanup, highlight other waste management issues (USEPA 2009b). However,environmental impacts related to the location, design, and operational aspects of wastedisposal for the plant would be subject to regulatory review under OPSB rules or similarprograms. As a result, FENOC believes that with proper disposal siting, coupled withcurrent waste management and monitoring practices, waste disposal would notdestabilize any resources.On this basis, FENOC considers that waste management impacts from operation of therepresentative coal-fired plant at an alternate site would be MODERATE.AestheticsPotential aesthetic impacts of construction and operation of the representative coal-firedplant include visual impairment resulting from the presence of a large industrial facility,including 500-foot-high stacks, and cooling towers up to approximately 500 feet highwith associated condensate plumes. The stacks and condensate plumes from thecooling towers could be visible some distance from the plant. There would also be anaesthetic impact if construction of a new transmission line or rail spur were needed.Similarly, noise impacts associated with rail delivery of coal and lime/limestone if usedwould be most significant for residents living in the vicinity of the facility and along therail route.These impacts, however, are highly site-specific. Site locations could reduce theaesthetic impact of a coal-fired generation, for example, if siting were in an area thatwas already industrialized versus locating at largely undeveloped sites.In view of the environmental review afforded under OPSB rules or a similar program,FENOC considers that the impacts to aesthetics from construction and operation of therepresentative plant at an alternative site would depend on location and be SMALL toMODERATE.Cultural ResourcesFENOC assumed that the representative coal-fired plant, associated infrastructure (e.g.,roads, transmission corridors, rail lines, or other rights-of-way), and associated wastedisposal site would be located with consideration of cultural resources afforded underOPSB or comparable rules. FENOC further assumed that appropriate measures wouldbe taken to recover or provide other mitigation for loss of any resources discoveredduring onsite or offsite construction.Environmental Impacts of AlternativesPage 7.3-7September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportOn this basis, FENOC considers that the potential impact on cultural resources fromconstruction and operation of the representative plant at an alternative site would beSMALL.7.3.2 GAS-FIRED GENERATIONThis section presents the impact evaluation for the representative gas-fired generationalternative. As discussed in Section 7.2.1.2, FENOC assumed for purposes of thisanalysis that the representative plant would be located at a greenfield or (preferably)brownfield site in northwestern Ohio. This assumption is a result of the space limitationat the Davis-Besse site.Land UseLand-use requirements for gas-fired plants are relatively small, at about 100 acres for a910 MWe plant (Section 7.2.1.2). An estimated 240 -270 additional acres would beneeded offsite at a greenfield location for new gas and electric transmission lines(FENOC 2007, Section 7.3.1, Land Use) and increased land-related impacts, which inturn would be location-specific.Land use in northwestern Ohio is predominantly rural agricultural cropland withscattered rural residences and woodlots. Located in a rural area, the change in landuse would be locally apparent and could include displacement of cropland, which ishighly productive for corn, wheat, and soybeans relative to other areas of the state;however, substantial buffer with respect to highly incompatible land uses (e.g.,residential use) could be provided and destabilization of overall land use would not beexpected. If the plant were located in an area designated for industrial use, associatedland-use impacts would not be significant. Agricultural practices could continue alongmost of the area occupied by offsite rights-of-way. (FENOC 2007, Section 7.3.1, LandUse)Regardless of where the natural gas-fired plant is built, additional land would berequired for natural gas wells and collection stations. Partially offsetting these offsiteland requirements would be the elimination of the need for uranium mining to supplyfuel for Davis-Besse. The GElS estimated that approximately one acre per MWe wouldbe affected for mining and processing the uranium during the operating life of a nuclearpower plant (NRC 1996, Section 8.3.12). Therefore, for Davis-Besse uranium miningand processing, approximately 910 acres of land would be required, resulting in a netgain in reclaimed land for the representative natural gas-fired generation alternative.In view of the environmental review afforded under OPSB rules or a similar program,FENOC considers that the overall impacts of land use from construction and operationof the representative plant at an alternative site would depend on plant location and beSMALL to MODERATE.Environmental Impacts of AlternativesPage 7.3-8September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportWater Use and Quality -Surface WaterCooling water intake, evaporative losses, and discharge flows for the plant would beless than that of Davis-Besse, primarily because less power would be derived from asteam cycle (FENOC 2007, Section 7.2.2.1).During operation, cooling water and wastewater discharges would be regulated underthe federal CWA and corresponding state programs by an NPDES permit. Constructionactivities would be similarly regulated to ensure protection of water resources. Inaddition, impacts on water use and quality would be subject to scrutiny in the planningstage under OPSB or similar governing authority rules.Overall, FENOC considers that the impacts from construction and operation of therepresentative plant at an alternative site on surface water use and quality would beSMALL.Water Use and Quality -Ground WaterImpacts will depend on whether the plant will use ground water for any purposes, aswell as the characteristics of local aquifers. Regardless of location, FENOC assumesthat a gas-fired power plant at an alternate site will not rely on ground water for plantcooling, and that regulations for ground water use for potable water will limit impacts toSMALL.Air QualityNatural gas is a relatively clean-burning fuel with nitrogen oxides being the primaryfocus of combustion emission controls. As noted in the GELS, air quality impacts for allnatural gas technologies are generally less than for fossil technologies of equal capacitybecause fewer pollutants are emitted (NRC 1996, Section 8.3.10).As noted in Section 7.2.1.2, FENOC has assumed a plant design that includes controlsto minimize emissions of regulated air pollutants effectively. Based on emission factors,estimated efficiencies for emission controls, and assumed design parameters listed inTable 7.2-2, operation of the plant would result in the following annual air emissions forcriteria pollutants:" Sulfur dioxide = 13.3 tons* Nitrogen oxides = 205 tons" Carbon monoxide = 311 tons" Total filterable particulates = 39.4 tonsThe annual emissions of carbon dioxide, which is currently unregulated, would beapproximately 2.28 million tons. See Table 7.3-2 for details.Environmental Impacts of AlternativesPage 7.3-9September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportFENOC expects that these emissions may result in a noticeable reduction in local airquality. However, FENOC anticipates that both sulfur dioxide and nitrogen oxideemissions will be subject to cap and trade programs (FENOC 2007, Section 7.2.1.3).As a result, the plant would not be expected to add to regional sulfur dioxide emissionsand may not add to regional nitrogen oxide emissions, at least during the ozone season(FENOC 2007, Section 7.3.1, Air Quality). The representative plant would add toregional concentrations of other pollutants, including the criteria pollutants carbonmonoxide and particulates; hazardous air pollutants such as mercury; and carbondioxide, which is presently unregulated.Subject to regulatory controls, FENOC anticipates that the overall air quality would benoticeable, but not destabilizing. As a result, FENOC considers that the impacts to airquality from operation of the representative plant at an alternative site would beMODERATE, but smaller than those of coal-fired generation.Ecological ResourcesAs noted in the Land Use subsection above, development of the representativecombined-cycle natural gas-fired plant may require approximately 100 acres for theplant site and approximately 240 -270 additional acres for offsite infrastructure.Although the GElS noted that land-dependent ecological impacts from construction fromgas-fired plants would be smaller than for other fossil fuel technologies of equal capacity(NRC 1996, Section 8.3.10), the type and quality of terrestrial habitat that would bedisplaced is location-specific.However, FENOC considers it likely that most of the area required for constructionwould consist of agricultural cropland with relatively low habitat value. Stream crossingsand wetland disturbance, if any, would be subject to provisions of a USACE permit(CWA Section 404) and relevant state and local requirements. (FENOC 2007,Section 7.3.1, Ecology)The most significant potential impacts to aquatic communities relate to operation of thecooling water system. However, the cooling system for the plant would be designedand operated in compliance with the CWA, including NPDES limitations for physical andchemical parameters of potential concern and provisions of CWA Sections 316(a) and316(b), which are respectively established to ensure appropriate protection of aquaticcommunities from thermal discharges and cooling water intakes. Also, the siting,design, and operation of the plant would be subject to the environmental protectionsunder OPSB rules.Overall, FENOC expects that development of the representative natural gas-fired plantwould likely have little noticeable impact on ecological resources of the area. As aresult, FENOC considers that the overall impacts to ecology resources fromEnvironmental Impacts of AlternativesPage 7.3-10September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportconstruction and operation of the representative plant at an alternative site woulddepend on plant location and be SMALL to MODERATE.Human HealthThe GElS cites risk of accidents to workers and public health risks (e.g., cancer, oremphysema) from the inhalation of toxics and particulates associated with air emissionsas potential risks to human health associated with the gas-fired generation alternative(NRC 1996, Table 8.2). However, regulatory requirements imposed on facility design,construction, and operations under the authority of the Occupational Safety and HealthAct, Clean Air Act, and related statutes are designed to provide an appropriate level ofprotection to workers and the public. Additionally, regulatory agencies, including theUSEPA, USOSHA, and state agencies, set air emission standards requirements forworkers and the public based on human health impacts.Given the extensive health-based regulatory control, FENOC considers that operatingthe representative gas-fired plant at an alternate site, regardless of plant location, wouldbe SMALL.SocioeconomicsMajor sources of potential socioeconomic impacts from the representative gas-firedgeneration alternative include temporary increases in jobs, economic activity, anddemand for housing and public services in communities surrounding the site during theconstruction period. Countering these increases are losses in permanent jobs, taxrevenues, and economic activity attributable to gas-fired plant operation and terminationof operations of Davis-Besse.The estimated number of peak construction workers expected to build a gas-fired plantwith a capacity of 910 MWe is 1,092 -2,275 (NRC 1996, Tables 8.1). To operate theplant would require 137 workers (NRC 1996, Tables 8.2). Although northwestern Ohiois predominantly rural, most areas are within commuting distance of the metropolitanareas like Toledo and Cleveland, Ohio. Considering the proximity of these sources oflabor and services, FENOC expects that most of the construction workforce wouldcommute and relatively few would relocate into the area, and associated socioeconomicimpacts during construction would be SMALL.Communities in Ottawa County, however, particularly those within the taxing jurisdictionof Carroll Township and the Benton-Carroll-Salem School District, would experiencelosses in both employment and tax revenues due to Davis-Besse closure that couldconstitute MODERATE impact (see Section 4.17).FENOC believes that these impacts, although noticeable, would not be destabilizing.As a result, FENOC considers that the overall socioeconomic impact of constructionEnvironmental Impacts of AlternativesPage 7.3-11September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportand operation of the representative gas-fired at an alternative site would beMODERATE.Waste ManagementGas-fired generation would result in minimal waste generation, producing minor (if any)impacts (NRC 1996, Section 8.3.10). As a result, FENOC considers wastemanagement impacts from the operation of the representative plant at an alternativesite would be SMALL.AestheticsPotential aesthetic impacts of construction and operation of a gas-fired plant includevisual impairment resulting from the presence of a large industrial facility, includingmultiple exhaust stacks at least 150 feet high, and mechanical-draft cooling towers withassociated condensate plumes. Considering the flat topography in northwestern Ohio,the stacks and condensate plumes would likely be visible for several miles from the site;new transmission lines constructed to connect the plant to the grid would also berelatively visible for the same reason, though would not be out of character for the ruralnorthwestern Ohio landscape. (FENOC 2007, Section 7.3.1, Aesthetics) FENOCexpects that the plant likely would be located in a rural area, and assumed thatadequate buffer and vegetation screens would be provided at the plant site as neededto moderate visual and noise impacts.In view of the environmental review afforded under OPSB rules, FENOC considers thatthe impacts to aesthetics from construction and operation of the representative plant atan alternative site would depend on location and be SMALL to MODERATE.Cultural ResourcesFENOC assumed that the representative gas-fired plant and associated gas-supplypipeline and transmission line would be located with consideration of cultural resourcesunder OPSB or comparable program rules. FENOC further assumed that appropriatemeasures would be taken to avoid, recover, or provide other mitigation for loss of anyresources discovered during onsite or offsite construction.On this basis, FENOC concludes that the potential adverse impact on cultural resourcesof the representative plant at an alternative site, regardless of location, would beSMALL.Environmental Impacts of Alternatives Page 7.3-12 September 2011Environmental Impacts of AlternativesPage 7.3-12September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report7.3.3 RENEWABLE ENERGYThis section presents the impact evaluation for wind power in the form of interconnectedwind farms and/or solar photovoltaic power, in combination with CAES. To be specific,FENOC evaluated for purposes of this NEPA analysis electricity generation comingfrom: wind power in the form of interconnected wind farms; or wind power in the form ofinterconnected wind farms with CAES; or solar (photovoltaic) power with CAES; or acombination of interconnected wind farms and solar power with CAES, as described inSections 7.2.1 and 7.2.1.3.Wind and solar energy are renewable energy sources that produce electricity withoutreleasing air or water pollutants; however, these advantages are offset byenvironmental impacts such as large land requirements (both wind and solar), potentialharm to birds and bats (wind), aesthetic concerns (wind and solar), noise concerns(wind); radar interference (wind), and generation of hazardous waste streams (solar).In addition, there would be environmental impacts associated with the construction andoperation of new transmission lines associated with new renewable energy sources.These impacts are not evaluated as part of this analysis because the scope of newtransmission would not be determined until the energy sources were sited.The environmental impacts related to interconnected wind farms are discussed inSection 7.3.3.1. The environmental impacts of interconnected wind farms with CAESare discussed in Section 7.3.3.2. The environmental impacts of solar PV power withCAES are discussed in Section 7.3.3.3. Finally, a summary of the combinedenvironmental impacts of wind farms, solar PV power, and CAES are provided inSection 7.3.3.4.7.3.3.1 Interconnected Wind EnergyUsing the assumptions and disclaimers in Section 7.2.1, development of a series ofwind farms would be required to provide replacement power for Davis-Besse.Transmission impacts associated with an interconnected grid that would serverenewable energy sources would have to be evaluated once the renewable energysources have been sited.Development of large-scale, land-based wind power facilities could have MODERATEto LARGE impacts on aesthetics, land use, and terrestrial ecology. The environmentalimpacts of a large-scale wind farm are described in the GElS (NRC 1996, Section8.3.1). In summary, the construction of roads and turbine tower supports would result inshort-term impacts, such as increases in noise, erosion, and sedimentation, anddecreases in air quality from fugitive dust and equipment emissions. Construction inundeveloped areas would have the potential to disturb and impact cultural resources orhabitat for sensitive species. During operation, some land near wind turbines could beEnvironmental Impacts of AlternativesPage 7.3-13September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportavailable for compatible uses such as agriculture. There is some continuing noise fromwind turbine operation, light flicker caused by reflection of the sun, and aestheticimpacts, although whether a wind farm improves the landscape is in the eye of thebeholder. Wind farms generate very little waste and pose limited human health riskother than from occupational injuries. There is a potential for bird and bat collisions withturbine blades, which is discussed in this subsection.Although most environmental impacts associated with a single wind farm are SMALL orcan be mitigated, the cumulative impacts from the many wind farms that would beneeded to support an interconnected grid system, such as impacts to sensitive habitatsand endangered species, could be LARGE, depending on the locations.The incorporation of offshore wind resources from Lake Erie could reduce the amount ofland use impacts; however, a new set of impacts related to offshore wind would becreated. Placing wind farms offshore eliminates some of the obstacles encounteredwhen siting wind farms on shore and limits conflicts with other planning interests.However, other impacts are created, including influence on birds, marine life,hydrography, and marine traffic. (IEAWIND 2002)A detailed discussion of impacts is presented below.Land UseThe land use requirement for interconnected wind farms in open and flat terrain is about50 acres per megawatt (MW) of installed capacity. Approximately 5% (2.5 acres) of thisarea is occupied by turbines, access roads, and other equipment. The remaining landarea can be used for compatible activities such as farming or ranching (AWEA 2002),except if the wind farms are located offshore. The Roscoe Wind Farm near Roscoe,Texas has the capacity of 209 MW and is spread-out across 30,000 acres (RWC 2010),or 143 acres per MW. When complete, the entire Roscoe Wind Complex project isexpect to have the capacity of 781 MW on approximately 100,000 acres (CBS 2010) or128 acres per MW.Assuming the use of interconnected wind as the only renewable source to generate theequivalent of Davis-Besse's net output of 910 MWe base-load power plus 910 MWe ofenergy storage to be used when wind power is not available, a series of wind farms with2.0-MWe turbines with an average capacity factor of 30% as specified by PJM andUSDOE (PJM 2011 and USDOE 2011) would require approximately 3030 turbines toproduce 1820 MWe. At 50 acres per MW, the land use potential would be as much as91,000 acres (142 square miles), with about 4550 acres (7.1 square miles) occupied byturbines and support facilities.Land use in Ohio, where additional wind generation would likely be developed, ispredominantly rural agricultural cropland with scattered rural residences and woodlots.Environmental Impacts of AlternativesPage 7.3-14September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportIn such a location, the change in land use would be locally apparent and could includesome initial displacement of highly productive cropland for corn, wheat, and soybeans.However, a substantial buffer with respect to highly incompatible land uses (e.g.,residential use) could be provided, and destabilization of overall land use would not beexpected. Agricultural practices could continue along most of the area occupied byoffsite rights-of-way. (FENOC 2007, Section 7.3.1, Land Use)Offshore impacts have been extensively studied in Europe. An environmental impactreport has been prepared by the Cape Wind Project (CWP) and a feasibility study wasconducted by the Great Lakes Wind Energy Center (GLWEC) for an offshore area inLake Erie near Cleveland, Ohio (GLWEC 2009). Based on the findings in the CWPEnvironmental Impact Report (EIR) (CWP 2007) and the study completed by GLWEC,land use impacts associated with offshore wind generation would be SMALL.Regardless of where the wind generation facilities are built, additional land would berequired for an interconnected grid system as described in Section 7.2.2.3. Partiallyoffsetting these offsite land requirements would be the elimination of the need foruranium mining to supply fuel for Davis-Besse. The GElS estimates that approximatelyone acre per MWe would be affected for mining and processing the uranium during theoperating life of a nuclear power plant (NRC 1996, Section 8.3.12). Therefore, for theuranium mining and processing associated with fuel for Davis-Besse, approximately910 acres of land would be required, resulting in a net avoidance of potentiallydisturbing 3640 (4550-910) acres of land when compared to wind generation land use.Based on these data, FENOC considers that the overall impacts of land use fromconstruction and operation of interconnected wind farms would depend on theirlocations, and be MODERATE to LARGE.Water Use and Quality -Surface WaterWind generation does not require cooling water or intake structures. Therefore, therewould be no impact on water use and the only potential impact on local water qualitywould be erosion or sedimentation issues during construction. These impacts would beminimized by using best management practices during construction activities and areconsidered SMALL.Water Use and Quality -Ground WaterA limited amount of ground water may be used during construction activities if otherpotable water supplies are limited. Minor amounts of water may be needed foroperating wind generation facilities if surface water resources were not available. Thepotential impact to ground water is SMALL.Environmental Impacts of AlternativesPage 7.3-15September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportAir QualityThere are no air quality impacts associated with the operation of onshore or offshoreinterconnected wind farms. The construction of roads and turbine tower supports wouldresult in short-term impacts in air quality from fugitive dust and equipment emissionsand the overall impacts would be SMALL.Ecological ResourcesAs noted in the Land Use subsection above, development of onshore interconnectedwind farms would have a MODERATE to LARGE impact on land resources which couldhave a LARGE impact on the ecological resources, especially during construction.Migratory bird, eagle and raptor, and bat mortality are potential impacts related to windturbines. The deaths of birds and bats at wind farm sites have raised concerns by fishand wildlife agencies and conservation groups. United States Fish and Wildlife Service(USFWS) estimates indicate that wind turbine rotors kill 33,000 birds annually (USFWS2002). Concerns of the potential impacts of wind power deployment have led theUSFWS to release draft guidance that provides agency employees, developers, federalagencies, and state organizations information for reviewing and selecting sites forinterconnected and community-scale wind energy facilities to avoid and minimizenegative impacts to fish, wildlife, plants and their habitats (USDOI 2011). Direct effectsinclude blade strikes, barotrauma, loss of habitat, and "displacement". Indirect effectsoccur later in time and include introduction of invasive vegetation that result in alterationof fire cycles; increase in predators or predation pressure; decreased survival orreproduction of the species; and decreased use of the habitat that may result fromeffects of the project or resulting "habitat fragmentation." (USFWS 2011)Although wind turbine/bird collision studies seem to indicate that wind generatingfacilities in some locations of the United States have a minor impact on birds comparedto other sources of collision mortality, one cannot assume that similar impacts wouldoccur among birds using wind-generating sites built in Ohio or offshore in Lake Erie.Based on a feasibility study conducted by Great Lakes Wind Energy Center (GLWEC)the avian morality rate of this proposed offshore project is expected to be minimal.(GLWEC 2009) FENOC assumed that construction best management practices andawareness of critical habitat during operations would minimize impacts to ecologicalresources. Therefore, impacts to migrating species would depend on the location of thewind farms and could be SMALL to MODERATE.Human HealthThe only major health risk for the construction and operation of a series of wind farms(onshore or offshore) would be accidents. FENOC assumed that all OccupationalEnvironmental Impacts of AlternativesPage 7.3-16September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportSafety and Health Act requirements would be complied with during construction andoperation of these facilities and the impacts should be SMALL.SocioeconomicsMajor sources of potential socioeconomic impacts from interconnected wind farmsinclude temporary increases in jobs, economic activity, and demand for housing andpublic services in communities surrounding the sites during the construction period.These impacts would be spread throughout the region. Countering these increases arelosses in permanent jobs, tax revenues, and economic activity attributable to thetermination of operations of Davis-Besse. Typically, renewable energy sources are notsubject to the tax rate of conventional energy-generating facilities, so the loss ofpermanent jobs and tax revenue could be significant to the communities nearDavis-Besse and thus have a SMALL to MODERATE impact.Communities in Ottawa County, however, particularly those within the taxing jurisdictionof Carroll Township and the Benton-Carroll-Salem School District, would experiencelosses in both employment and tax revenues due to Davis-Besse closure that couldconstitute MODERATE impacts.The number of peak construction workers expected to build the wind farms is unknownat this time; however, it is likely similar to a gas-fired plant with a capacity of 910 MWe,which is 1200 (NRC 1996, Tables 8.1). To operate and maintain the wind farms wouldrequire approximately 150 to 200 workers. FENOC expects that most of theconstruction workforce would commute and relatively few would relocate into the area,and associated socioeconomic impacts during construction would be SMALL.Waste ManagementConstruction of wind farms could result in generation of large amounts of vegetationfrom land clearing activities. If this material is managed correctly (e.g., recycled orcomposted) the impacts should be SMALL. Minor amounts of waste may be generatedduring the operations and maintenance of the wind turbines (onshore or offshore)which, if waste streams are managed correctly, the impacts would likely be SMALL.AestheticsMost wind farms are located in remote areas and may generate large aestheticconcerns, particularly if sited on highlands or in recreational areas and could have someeffect on the local aesthetic quality. The aesthetic impacts from wind farms located inflat-lying rural areas would likely be SMALL.Offshore wind turbines would likely have a lesser aesthetic impact than onshore windturbines and be limited to those individuals who reside close to the shoreline orEnvironmental Impacts of AlternativesPage 7.3-17September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportparticipate in recreational activities close to the wind facilities. There have beenconcerns related to the related to aesthetic impacts. (CA 2011) The overall aestheticimpacts from wind turbines would be SMALL to MODERATE.Cultural ResourcesDue to the large amount of land needed to construct the necessary wind farms, thepotential for impacting cultural resources could be LARGE. To minimize theseimpacts, FENOC assumed construction activities would consider cultural resourcesunder OPSB or comparable program rules. FENOC further assumed that appropriatemeasures for both onshore and offshore construction activities would be taken toavoid, recover, or provide other mitigation for loss of any resources discovered duringonsite or offsite construction.On this basis, FENOC concludes that the potential adverse impact on cultural resourcesof the wind farms, regardless of location, would be SMALL.7.3.3.2 Wind with Compressed Air Energy StorageEnvironmental impacts associated with wind farms are discussed above in Section7.3.3.1, and are not repeated here in detail. Impacts associated with the compressedair energy storage (CAES) facility are discussed below.By combining CAES with interconnected wind farms, the anticipated environmentalimpacts would be greater than the impacts from interconnected wind farms alone.Therefore, wind farms with CAES generating 1820 MW of power are expected tohave greater environmental impacts than Davis-Besse during the proposed 20 yearlicense extension.Land UseThe overall land use impact for wind generation in this energy alternative, as discussedin Section 7.3.3.1, is MODERATE to LARGE.Land use associated with the NES facility would be limited to the facility's 92 surfaceacres. There would be some land impacted during construction, but this site has beenpreviously disturbed so the impact should be SMALL. However, if another site isWind generation source is assumed to be available for 12 hours every day, and a CAES facilityassumed to be 100% efficient (i.e., 910 MWe of energy input from wind and/or solar to the CAES facilityresults in 910 MWe of generation from the CAES facility), would require that generation source to berated at 1820 MW in order to provide 24-hours of baseload electricity when integrated with a 910 MWCAES facility (i.e., 12 hours to provide 910 MW of base-load generation onto the grid, and the same12 hours to provide 910 MW to recharge the CAES facility, so that the CAES facility could feed the gridthe remainder of the day).Environmental Impacts of AlternativesPage 7.3-18September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportchosen for the CAES or an additional CAES facility is needed to meet base-load powerrequirements then there could be a MODERATE to LARGE land use impact.Water Use and Quality -Surface WaterCAES facilities have cooling towers associated with the use of gas turbines to produceelectricity and compressors to recharge the storage structure. These cooling towers aremuch smaller than those typically used for coal and gas generation plants. Coolingmakeup water evaporative losses, and discharge flows for the plant would beconsiderably less than that of Davis-Besse, primarily because less power would bederived from a steam cycle. (FENOC 2007, Section 7.2.2.1)During CAES operation, cooling water and wastewater discharges would be regulatedunder the federal CWA and corresponding state programs by an NPDES permit.Construction activities would be similarly regulated to ensure protection of waterresources. In addition, impacts on water use and quality would be subject to scrutiny inthe planning stage under OPSB or similar governing authority rules.Overall, FENOC considers that the impacts from construction and operation ofinterconnected wind farms (onshore and offshore) combined with a CAES facility onsurface water use and quality would be SMALL.Water Use and Quality -Ground WaterImpacts would depend on whether the plant would use ground water for any purposes,as well as the characteristics of local aquifers. Regardless of location, FENOCassumed that the NES plant or a CAES plant at an alternate site would not rely onground water for plant cooling, and that regulations for ground water use for potablewater would limit impacts to SMALL.Air QualityCAES facilities use natural gas, which is a relatively clean-burning fuel with nitrogenoxides being the primary focus of combustion emission controls. As noted in the GELS,air quality impacts for all natural gas technologies are generally less than for fossiltechnologies of equal capacity because fewer pollutants are emitted (NRC 1996,Section 8.3.10).FirstEnergy Generation Corp. has applied for and received an Air Pollution Permit toInstall and Operate (PTIO) proposed emission units for the Norton CAES facility (FacilityID 1677105001) (see Table 7.2-3). The permit (Number P0106714) was issued onSeptember 7, 2010 by the Ohio EPA. The permit establishes emission limitations, airemission controls, monitoring, reporting, and recordkeeping requirements. Theproposed emission units established in the PTIO are based on the original design of theEnvironmental Impacts of AlternativesPage 7.3-19September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportfacility and include six combustion trains and one cooling tower. Each combustion trainincludes a 589 mmBtu/hr (134 MWe) combustion turbine and a 1 mmBtu/hr in-lineheater to remove moisture from the compressed air. (NES 2010) The combustionturbines and in-line heaters would fire only pipeline-quality natural gas. The only othersources associated with this facility are an emergency generator and a back-upfirewater pump; both of these units would be diesel-fired.The permitted annual air emission limits from this facility with six combustion trains(i.e., 804 Mwe) are as follows:* Sulfur dioxide (SO2) = 42.41 tons* Nitrogen oxides (NOx) = 93.67 tons* Carbon monoxide = 90.36 tons* PM10 = 46.65 tons" Volatile Organic Compounds (VOCs) = 26.40 tonsThe annual emissions of carbon dioxide from all sources would be approximately681,100 tons. These emissions are based on the current air permit for NES and couldchange if different equipment is used during plants operations. A list of air emissions forthe six combustion trains is presented in Table 7.3-4.FENOC anticipates that both sulfur dioxide and nitrogen oxide emissions would besubject to cap and trade programs (FENOC 2007, Section 7.2.1.3). As a result, the plantwould not be expected to add to regional sulfur dioxide emissions and may not add toregional nitrogen oxide emissions, at least during the ozone season (FENOC 2007,Section 7.3.1, Air Quality). The plant would add to regional concentrations of otherpollutants, including the criteria pollutants carbon monoxide and particulates; hazardousair pollutants such as mercury; and carbon dioxide, which is presently unregulated.Subject to regulatory controls, FENOC anticipates that the impacts to air quality fromoperation of the CAES plant at an alternative site would be MODERATE.Ecological ResourcesAs noted in Section 7.3.3.1, development of the interconnected wind farms would havea MODERATE to LARGE impact on land resources which could have a LARGE impacton ecological resources, especially during construction.Since the NES has an existing underground storage space and only has 92 acres ofland use at the surface, the potential impact to ecological resources is SMALL.However, if another CAES site with compressed air storage on the land surface ischosen or needed to provide additional stored energy capacity the ecological impactscould be MODERATE to LARGE.Environmental Impacts of AlternativesPage 7.3-20September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportFor an alternative CAES site, FENOC considers it likely that most of the area requiredfor construction would consist of agricultural cropland with relatively low habitat value.Stream crossings and wetland disturbance, if any, would be subject to provisions of aUSACE permit (CWA Section 404) and relevant state and local requirements.(FENOC 2007, Section 7.3.1, Ecology)The most significant potential impacts to aquatic communities relate to operation of thecooling water system. However, the NES site (or alternative site) cooling system for theplant would be designed and operated in compliance with the CWA, including NPDESlimitations for physical and chemical parameters of potential concern and provisions ofCWA Sections 316(a) and 316(b), which are respectively established to ensureappropriate protection of aquatic communities from thermal discharges and coolingwater intakes. Also, the siting, design, and operation of the plant would be subject tothe environmental protections under OPSB or other state agency's rules.Overall, FENOC expects that development of the CAES plant would likely have littlenoticeable impact on ecological resources of the area. As a result, FENOC considersthat the overall impacts to ecology resources from construction and operation of therepresentative plant at an alternative site would depend on plant location and be SMALLto LARGE.Human HealthThe only major health risk for the construction and operation of a series of wind farms(onshore or offshore) would be accidents. FENOC assumed that all OccupationalSafety and Health Act requirements would be complied with during construction andoperation of these facilities and the impacts should be SMALL.The NES or an alternative CAES facility would use natural gas in its power generationmode. The GElS cites risk of accidents to workers and public health risks (e.g., cancer,or emphysema) from the inhalation of toxics and particulates associated with airemissions as potential risks to human health associated with the gas-fired generationalternative (NRC 1996, Table 8.2). However, regulatory requirements imposed onfacility design, construction, and operations under the authority of the OccupationalSafety and Health Act, Clean Air Act, and related statutes are designed to provide anappropriate level of protection to workers and the public. Additionally, regulatoryagencies, including the USEPA, USOSHA, and state agencies, set air emissionstandards requirements for workers and the public based on human health impacts.Given the extensive health-based regulatory control, FENOC considers that humanhealth impacts from operating a CAES plant at NES or an alternate site, regardless ofplant location, would be SMALL.Environmental Impacts of AlternativesPage 7.3-21September2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportSocioeconomicsMajor sources of potential socioeconomic impacts from interconnected wind farms withCAES would be similar to those discussed in Section 7.3.3.1. The number of peakconstruction workers expected to build the NES facility is unknown at this time;however, it is likely not to exceed the number for a gas-fired plant with a capacity of 910MWe, which is 1200 (NRC 1996, Table 8.1). FENOC expects that most of theconstruction workforce would commute and relatively few would relocate into the area,and associated socioeconomic impacts during construction would be SMALL. Tooperate and maintain the NES plant would require approximately 50 to 100 workers.FENOC believes that the construction impacts, although noticeable, would be spreadthroughout the State and should not impact any one local community over another. Thefinancial impacts from closing Davis-Besse, however, could be significant to the areassurrounding the station. The addition of an operational workforce for the CAES facilityand new tax revenue for the local community near the CAES facility would be abeneficial impact in that local community. As a result, FENOC considers that the overallsocioeconomic impact of construction and operation of the NES or an alternative CAESsite would be SMALL to MODERATE.Waste ManagementConstruction of interconnected wind farms could result in generation of large amounts ofvegetation from land clearing activities. If this material is managed correctly (e.g.recycled or composted) then the impacts should be SMALL. Like gas-fired generation,NES or an alternative CAES site would result in minimal waste generation, producingminor (if any) impacts (NRC 1996, Section 8.3.10). As a result, FENOC considerswaste management impacts from the operation of a CAES plant at an alternative sitewould be SMALL.AestheticsMost wind farms are located in remote areas and may generate large aestheticconcerns, particularly if sited on highlands or in recreational areas and could have someeffect on the aesthetic quality. In general, impact on aesthetic quality for wind farmslocated in flat-lying rural areas would be SMALLPotential aesthetic impacts of construction and operation of NES or an alternative CAESplant may include visual impairment resulting from the presence of a large industrialfacility, including multiple exhaust stacks and mechanical-draft cooling towers withassociated condensate plumes. Considering the flat topography in northwestern Ohioand other areas where an alternative CAES may be placed, the stacks and condensateplumes would likely be visible for several miles from the site; new transmission linesconstructed to connect the plant to the grid would also be relatively visible for the sameEnvironmental Impacts of AlternativesPage 7.3-22September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportreason, though would not be out of character for most rural areas including thenorthwestern Ohio landscape. (FENOC 2007, Section 7.3.1, Aesthetics)The NES site is on a brownfield area located just south of Norton, Ohio. Theconstruction of the facility would cause a minor change in the appearance of the area,but aesthetic impacts would be SMALL. FENOC expects that an alternative CAES plantlikely would be located in a rural area, and assumed that adequate buffer andvegetation screens would be provided at the plant site as needed to moderate visualand noise impacts.In view of the environmental review afforded under OPSB rules, FENOC considersthat the impacts to aesthetics from construction and operation of interconnected windfarms and NES or an alternative CAES site would depend on location and be SMALLto MODERATE.Cultural ResourcesAs discussed in Section 7.3.3.1, FENOC concludes that the potential adverse impacton cultural resources of the interconnected wind farms, regardless of location, wouldbe SMALL.FENOC assumed that the NES facility or alternative CAES plant and associatedgas-supply pipeline and transmission lines would be located with consideration of culturalresources under OPSB or comparable program rules, and the impact would be SMALL.7.3.3.3 Photovoltaic Power Combined with CAESEnvironmental impacts of solar power systems can vary based on site-specificconditions. Land use and aesthetics are the primary environmental impacts of solarpower. Land requirements for PV facilities are large, compared to the land currentlyused by Davis-Besse. During operation, however, PV technologies produce no airpollution, little or no noise, and require no transportable fuels.Land UseAs stated in the GELS, land requirements are high: 35,000 ac (14,000 ha) [i.e.,54.7 square miles] per 1,000 MWe for PV cells (NRC, 1996).An NREL study (for the western United States) has indicated the amount of landrequired depends on the available solar insolation and ranges from about3.8 to 7.6 acres per MW for photovoltaic systems with a capacity factor ranging from 20to 25%. (NREL 2002) Assuming an average capacity factor of 24% from NREL 2002,and 5 acres per MW, plus an additional 910 MWe needed for energy storage, and theestimated required land would be approximately 37,900 acres (59.2 square miles).Environmental Impacts of AlternativesPage 7.3-23September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportUnlike wind power generation, all the land used to construct the solar generationfacilities would be permanently disturbed and could not be used for other purposes.To reduce the amount of land use, the solar facilities could be placed in the samelocations as the wind generation facilities, or brownfield locations assuming these areflat areas with sufficient sunlight. PV arrays are placed on the rooftops of businessesand residential dwellings to generate electricity or to heat water. These units are usuallysmall and are designed to provide energy directly to the facility or residence to whichthey are attached. Only in a few cases are these PV arrays large enough to provideexcess energy to the grid.Based on these data, FENOC considers that the overall impacts of land use fromconstruction and operation of the representative solar power facilities alone wouldbe LARGE.Land use associated with the NES facility would be limited to the facilities' 92 surfaceacres. There would be some land impacted during construction but this site has beenpreviously disturbed so the impact should be SMALL. However, if another site ischosen for the CAES or an additional CAES facility is needed to meet base-loadpower requirements then the potential impacts to land resources could beMODERATE to LARGE.Water Use and Quality -Surface WaterSolar generation using PV technology does not require cooling water or intakestructures. Therefore, there would be no impact on water use and the only potentialimpact on local water quality would be erosion or sedimentation issues duringconstruction. These impacts would be minimized by using best management practicesduring construction activities. Significant amounts of water could be used to keep thesolar panels clean so they remain effective in collecting the maximum amount of sunlightpossible. Since the areas where these solar facilities would be located are not in adesert or semi-arid environment, the demands on water resources should be reduced.Overall, the impacts on water use and quality should be SMALL to MODERATE.Surface water impacts associated with the CAES cooling systems are discussed indetail in Section 7.3.3.2, and are SMALL.Overall, FENOC considers that the impacts from construction and operation of solargeneration facilities and a CAES plant at alternative sites on surface water use andquality would be SMALL to MODERATE.Environmental Impacts of Alternatives Page 7.3-24 September 2011Environmental Impacts of AlternativesPage 7.3-24September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportWater Use and Quality -Ground WaterImpacts would depend on whether the plant would use ground water for any purposes,as well as the characteristics of local aquifers. Regardless of location, FENOCassumed that the NES plant or a CAES plant at an alternate site would not rely onground water for plant cooling, and that regulations for ground water use for potablewater would limit impacts to SMALL.Air QualityThere are no air quality impacts associated with the operation of solar generationfacilities.Potential emissions from NES are discussed in Section 7.3.3.2 and Table 7.3-3.FENOC considers that the impacts to air quality from operation of a CAES facility at analternative site would be MODERATE.Ecological ResourcesAs noted in the Land Use subsection above, development of solar generation facilitieswould have a major impact on land resources, which could have a significant impact onthe ecological resources during construction and operation of these facilities. As statedin the Land Use subsection, approximately 37,900 acres would be permanentlydisturbed, and with the possible loss of important habitat. Although FENOC assumedthat construction best management practices and awareness to critical habitat duringoperations would minimize effects to ecological resources, the potential for significantimpacts would be MODERATE to LARGE.As discussed in Section 7.3.3.2, since the NES is a former underground limestone mineand only has 92 acres of land use at the surface, the potential impact to ecologicalresources is SMALL. However, if another CAES site with compressed air storage onthe land surface is chosen or needed to provide additional stored energy capacity, thenthe ecological impacts could be MODERATE to LARGE.Human HealthThe health risks for the construction and operation of a series of solar generationfacilities would be accidents and potential exposure to hazardous materials. FENOCassumed that all Occupational Safety and Health Act requirements would becomplied with during construction and operation of these facilities and the impactsshould be SMALL.Environmental Impacts of Alternatives Page 7.3-25 September 2011Environmental Impacts of AlternativesPage 7.3-25September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportAs discussed in Section 7.3.3.2, given the extensive health-based regulatory control,FENOC considers that operating the CAES plant at NES or an alternate site, regardlessof plant location, would be SMALL.SocioeconomicsMajor sources of potential socioeconomic impacts from the solar power with associatedNES or CAES facility alternative include temporary increases in jobs, economic activity,and demand for housing and public services in communities surrounding the sitesduring the construction period. These impacts would be spread throughout the stateand should not impact any one local community over another. Countering theseincreases are losses in permanent jobs, tax revenues, and economic activity attributableto operation of the alternative generation facilities and termination of operations ofDavis-Besse. Typically, renewable energy sources are not subject to the tax rate ofconventional energy generating facilities, so the loss of permanent jobs and tax revenuecould be significant to the communities near Davis-Besse and thus the impacts could beSMALL to MODERATE.Communities in Ottawa County, however, particularly those within the taxing jurisdictionof Carroll Township and the Benton-Carroll-Salem School District, would experiencelosses in both employment and tax revenues due to Davis-Besse's closure that couldconstitute MODERATE impacts.The number of peak construction workers expected to build the solar power facilities andthe NES facility is unknown at this time. However, it is likely not to exceed that of a gas-fired plant with a capacity of 910 MWe, which is 1200 (NRC 1996, Table 8.1). Tooperate and maintain the solar facilities and NES plant would require approximately 150to 200 workers. FENOC expects that most of the construction workforce would commuteand relatively few would relocate into the area, and associated socioeconomic impactsduring construction would be SMALL.In summary, FENOC considers that the overall socioeconomic impact of constructionand operation of the representative solar generation combined with CAES generationfacility would be SMALL to MODERATE.Waste ManagementPV technology creates environmental impacts related to manufacture and disposal.Chemicals used in the manufacture of PV cells include cadmium and lead. Potentialhuman health risks also arise from the manufacture and deployment of PV systemsbecause there is a risk of exposure to heavy metals such as selenium and cadmium.The cumulative and long-range impacts from transporting and disposing of hazardouswaste could be SMALL to MODERATE.Environmental Impacts of AlternativesPage 7.3-26September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportAestheticsMost solar facilities are located in remote areas and would likely not generate largeaesthetic concerns and would likely meet minor public resistance. Overall, the impactsfrom the construction and operation of solar power facilities would be SMALL.Cultural ResourcesDue to the large land use to construct the necessary solar generation facilities and forthe CAES facility, the potential for impacting cultural resources could be LARGE. Tominimize these impacts, FENOC assumed construction activities would considercultural resources under OPSB or comparable program rules. FENOC further assumedthat appropriate measures would be taken to avoid, recover, or provide other mitigationfor loss of any resources discovered during onsite or offsite construction.On this basis, FENOC concludes that the potential adverse impact on cultural resourcesof the solar generating facilities, regardless of location, would be SMALL.FENOC assumed that the NES facility or alternative CAES plant and associatedgas-supply pipeline and transmission line would be located considering culturalresources under OPSB or comparable program rules and, therefore, any impacts wouldbe SMALL.7.3.3.4 Combinations of Wind and Solar with CAESAs discussed in Sections 7.2.1 and 7.2.1.3, FENOC evaluated a combination of windand solar generation along with CAES as an alternative to replace the rated electricaloutput of Davis-Besse.The environmental impact results for interconnected wind farms and PV solar andCAES facilities are discussed in detail in Sections 7.3.3.1 through 7.3.3.3. A summaryof these results is described below and listed in Table 8.0-1.Land UseThe amount of territory required for the construction and operation of a series of windfarms and solar PV facilities would result in LARGE land use impacts. Most of this landwould be in greenfield or agricultural areas. Although some land used to develop windfarms could be used to generate solar power, there could be several issues includingagriculture needs, transmission capacity and sunlight duration that may limit themultiuse of this land.Land use associated with the NES facility would be limited to the facility's 92 surfaceacres. There would be some land impacted during construction, but this site has beenEnvironmental Impacts of AlternativesPage 7.3-27September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportpreviously disturbed so the impact should be SMALL. However, if another site ischosen for the CAES or an additional CAES facility is needed to meet base-load powerrequirements, then the land use impact could be MODERATE to LARGE.Water Use and Quality -Surface WaterWind farms and solar generation using PV technology do not require cooling water orintake structures. Therefore, there would be no impact on water use and the onlypotential impact on local water quality would be erosion or sedimentation issues duringconstruction. These impacts would be minimized by using best management practicesduring construction activities.Significant amounts of water could be used to keep the solar panels clean so theyremain effective in collecting the maximum amount of sunlight as possible. Since theareas where these solar facilities would be located are not in a desert or semi-aridenvironment, the demands on water resources should be reduced. Overall, the impactson water use and quality should be SMALL to MODERATE.CAES have cooling towers associated with the use of gas turbines to produce electricityand compressors to recharge the storage structure. These cooling towers are muchsmaller than those typically used for coal and gas generation plants. Cooling makeupwater evaporative losses and discharge flows for the plant would be considerably lessthan that of Davis-Besse, primarily because less power would be derived from a steamcycle. (FENOC 2007, Section 7.2.2.1)During CAES operation, cooling water and wastewater discharges would be regulatedunder the federal CWA and corresponding state programs by an NPDES permit.Construction activities would be similarly regulated to ensure protection of waterresources. In addition, impacts on water use and quality would be subject to scrutiny inthe planning stage under OPSB or similar governing authority rules.Overall, FENOC considers that the impacts from construction and operation of thiscombined energy alternative on surface water use and quality to be SMALL toMODERATE.Water Use and Quality -Ground WaterImpacts would depend on whether the combined energy alternative facilities would useground water for any purposes, as well as the characteristics of local aquifers.Regardless of location, FENOC assumed that the NES plant or a CAES plant at analternate site would not rely on ground water for plant cooling, and that regulations forground water use for potable water would limit impacts to SMALL. FENOC alsoassumed that construction of the facilities would employ best management practices tokeep the impact to groundwater quality SMALL.Environmental Impacts of AlternativesPage 7.3-28September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportAir QualityThe construction of roads and turbine tower supports would result in short-term impactsin air quality from fugitive dust and equipment emissions. There are no air qualityimpacts associated with the operation of wind farms and solar PV facilities, therefore theoverall impacts would be SMALL.CAES facilities use natural gas, which is a relatively clean-burning fuel with nitrogenoxides being the primary focus of combustion emission controls. The NES facility hasbeen issued an air permit by the Ohio EPA, and emission details are discussed inSection 7.3.3.2 and Table 7.3-3. FENOC assumed that best management practiceswould be utilized during construction activities to minimize impacts to air quality. Inaddition, FENOC assumed that the NES or alternate CAES facility would comply with itsair permit, thus impacts to air quality should be MODERATE.Ecological ResourcesAs noted in the Land Use subsection above, development of wind farms and solar PVfacilities and CAES would have a MODERATE to LARGE impact on land resourceswhich could have a MODERATE to LARGE impact on the ecological resources duringconstruction and operation of these facilities. FENOC assumed that construction bestmanagement practices and awareness to critical habitat during operations wouldminimize impacts to ecological resources.Human HealthThe only major health risk for the construction and operation of a series of wind farmsand solar PV facilities, and a CAES plant would be accidents. There may be minorhealth impacts from reduced air quality during construction and the operation of theCAES facility and from handling potential hazardous substances or waste materials.FENOC assumed that all air permits and Occupational Health and Safety Actrequirements would be complied with during construction and operation of thesefacilities, and the impacts should be SMALL.SocioeconomicsMajor sources of potential socioeconomic impacts from wind farms and solar PVsystems with an associated NES or CAES facility include temporary increases in jobs,economic activity, and demand for housing and public services in communitiessurrounding the sites during the construction period. Socioeconomic impacts are similarto those discussed in Sections 7.3.3.1 to 7.3.3.3 and would be SMALL to MODERATE.Environmental Impacts of Alternatives Page 7.3-29 September 2011Environmental Impacts of AlternativesPage 7.3-29September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportWaste ManagementPV technology creates environmental impacts related to manufacture and disposal.Chemicals used in the manufacture of PV cells include cadmium and lead. Potentialhuman health risks also arise from the manufacture and deployment of PV systemsbecause there is a risk of exposure to heavy metals such as selenium and cadmium.The cumulative and long range impacts from transporting and disposing of hazardouswaste could be a MODERATE to LARGE impact. Minimal waste streams should begenerated from the construction and operations of the wind power and CAES facilities.Therefore, the impacts should be SMALL.AestheticsMost wind farms are located in remote areas and may generate large aestheticconcerns, particularly if sited on highlands or in recreational areas. Solar PV generationrequires relatively flat land, which limits the view to the public. However, presence ofoverhead transmission lines may cause some moderate public resistance. To minimizethese impacts, the renewable generation facilities would likely be located in rural areasas much as possible. The proposed NES facility is located in a brownfield area andshould not change the aesthetic view of the area. Overall, the aesthetic impacts fromthese facilities should be SMALL.Cultural ResourcesDue to the large amount of land needed to construct the necessary wind farms and solarPV facilities, and for the CAES facility, the potential for impacting cultural resources couldbe LARGE. To minimize these impacts, FENOC assumed construction activities wouldconsider cultural resources under OPSB or comparable program rules. FENOC furtherassumed that appropriate measures would be taken to avoid, recover, or provide othermitigation for loss of any resources discovered during onsite or offsite construction. Onthis basis, FENOC concludes that the potential adverse impact on cultural resources ofthis combined energy alternative regardless of location would be SMALL.7.3.3.5 Conclusions of Combining New Generation Power Sources with StorageThe use of wind power in the form of interconnected wind farms and/or solarphotovoltaic power, in combination with CAES to provide power to replaceDavis-Besse's output by 2017 has been evaluated and discussed in the subsectionsabove. The environmental impacts associated with renewable sources and CAES wereevaluated in Subsections 7.3.3.1, 7.3.3.2, 7.3.3.3 and 7.3.3.4. The overall conclusionfrom this impact analysis is that the combination of these energy source alternatives hasSMALL to LARGE impacts. These impacts are compared in Section 8.0 to the impactsfrom renewal of the Davis-Besse license for another 20 years as well as those for thealternative coal and natural gas fired plants.Environmental Impacts of AlternativesPage 7.3-30September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 7.3-1: Air Emissions from Coal-Fired AlternativeParameter(1) Calculation ResultHeat RateTotal Gross Capability x x Conversion Factors x Capacity Factor tons/yearAnnual Coal Heat ValueConsumption 910MW x 9,800 Btu lb 1,000 kW 8,760 hr ton xO.80 2,543,644x x ~x -x x08 ,4,4kW x hr 12,285 Btu MW year year 2,000 lbEmissions Coal Consumption x Uncontrolled Emissionsx Conversion Factors x [100 -removal efficiency (%)](2) tons/year2,543,644 tons 130 Ib ton 100 -95 8,267S xx x -- x8,6year ton 2,000 Ib 100NOX 2,543,644 tons 10 lb ton 100-60 5,087year ton 2,000 lb 100CO 2,543,644 tons 0.5 lb ton 636year ton 2,000 lbPM 2,543,644 tons 120 lb ton 100 -99.9152.6PMx x x156year ton 2,000 Ib 100PM10 2,543,644 tons 27 lb ton 100-99.9 3434year ton 2,000 Ib 100CO2 2,543,644 tons 6,000 lb tonyear x ton x 2,630,year ton 2,000 lbBtuCOCO2hrkWlbMWNOxPMPM10Sox= British thermal units= carbon monoxide= carbon dioxide= hour= kilowatt= pound= megawatt= nitrogen oxides= total filterable particulate matter= PM having a diameter less than 10 microns= sulfur oxidesNotes:(1) Source: Table 7.2-1(2) There are no emission controls for CO and CO2.Environmental Impacts of Alternatives Page 7.3-31 September 2011Environmental Impacts of AlternativesPage 7.3-31September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 7.3-2: Air Emissions from Gas-Fired AlternativeParameterO') Calculation ResultGross Capability x Heat Rate x Conversion Factors x Capacity Factor MMBtu/yearAnnual GasHeat Input 910 MW x 6,500 Btu 1,000 kW 8,760 hr 0.80 41,452,320kW -hr MW yearEmissions Annual Gas Heat Input x Uncontrolled Emissionsx Conversion Factors x [100 -removal efficiency (%)] (2) tons/year41,452,320 0.00064 lb tonyear MMBtu 2,000 lb41,452,320 0.099 lb ton 100 -90year MMBtu 2,000 lb 10041,452,320 0.015 lb tonCO x -x --311year MMBtu 2,000 lb41,452,320 0.019 lb tonPM (al - XX 39.4PM (all PMlo) year MMBtu 2,000 lb41,452,320 110 lb tonyear MMBtu 2,000 lbBtu = British thermal unitsCO = carbon monoxideCO2 = carbon dioxidehr = hourkW = kilowattIb/MMBtu = pounds per million British thermal unitsMW = megawattNOx = nitrogen oxidesPM = particulate matterPM1o = PM having a diameter less than 10 micronsSOx = sulfur oxides (mainly SO2)Notes:(1) Source: Table 7.2-2(2) There are no emission controls for SO2, CO, PM, and CO2.Environmental Impacts of Alternatives Page 7.3-32 September 2011Environmental Impacts of AlternativesPage 7.3-32September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 7.3-3 Permitted Air Emissions from theProposed Norton Energy Storage ProjectParameter Quantity VolumeS02 42.41 tons/year*NOx 93.67 tons/year*CO 90.36 tons/year*PM (all PM10) 46.65 tons/year*Volatile Organic 26.40 tons/year*CompoundsCO2 681,100 tons/year*CO = carbon monoxideCO2 = carbon dioxideNOx = nitrogen oxidesPM = particulate matterPM10 = PM having a diameter less than 10 micronsSO2 = sulfur dioxide* Based on rolling, 12-month permitsEmissions are listed based on Permit information, and are from units P001 -P006,combined (including startups/shutdowns), which equates to 804 MW (134 MW x 6 units).Equipment Description: Each Combustion Train -589MMBtu/hr Dresser Rand natural gasfired combustion turbine (134 MW) operating in simple cycle mode with recuperatorcontrolled by catalytic oxidation, water injection, and selective catalytic reduction.As explained in Section 7.2.1.3, FirstEnergy estimates that only up to four units(i.e., 536 MW) could be online by 2017.Source: NES 2010Environmental Impacts of Alternatives Page 7.3-33 September 2011Environmental Impacts of AlternativesPage 7.3-33September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report[This page intentionally blank]Environmental Impacts of Alternatives Page 7.3-34 September 2011Environmental Impacts of AlternativesPage 7.3-34September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report7.4 REFERENCESNote to reader: This list of references identifies web pages and associated URLs wherereference data were obtained. Some of these web pages may likely no longer beavailable or their URL addresses may have changed. FENOC has maintained hardcopies of the information and data obtained from the referenced web pages.AEP 2011. AEP Ohio to Partner with Turning Point Solar on the Development of theTurning Point Solar Generating Facility in MNoble County, Website:http://www.prnewswire.com/ .. partner-with-tturning-point-on-the-development-of-the-turning-point-solar-generation-facility-in-noble-county-125021444.html, accessedSeptember 6, 2011.AWEA 2002. Most Frequently Asked Questions About Wind Energy, American WindEnergy Association, May 2002.AWEA 2011. Wind Energy Facts: Ohio, American Wind Energy Association, July 2011.CA 2011. Machines of the Ocean: The Aesthetics od Wind Farms, ContemporaryAesthetics. Website:http://www.contempaesthetics.org/newvoIume/pages/article. php?articlel D=24 7,accessed September 7, 2011.CBS 2010. World's Largest Wind Farm Churns in Texas, CBS News, Website:cbsnews.com/stories/2009/10/02/tech/livinggreen/main5358287.shtm, accessedSeptember 1, 2011.CWP 2007. Cape wind Energy Project Final Environmental Impact report/Developmentof Regional Impact, Cape wind Project, February 2007.EERE 2009a. Ohio Wind Resource Map, U.S. Department of Energy, Energy Efficiencyand Renewable Energy, available athttp://www.windpoweringamerica.gov/astate_template.asp?stateab=oh, accessedJune 30, 2009.EERE 2009b. Pennsylvania Wind Resource Map, U.S. Department of Energy, EnergyEfficiency and Renewable Energy, available athttp://www.windpoweringamerica.gov/astatetemplate.asp?stateab=pa, accessedJune 30, 2009.EIA 2010. Electric Power Annual 2008, DOE/EIA-0348(2008), U.S. Department ofEnergy, Energy Information Administration, January 2010.ReferencesPage 7.4-1September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportFENOC 2007. FirstEnergy Nuclear Operating Company, Beaver Valley Power StationUnit Nos. 1 and 2, License Renewal Application, Appendix E, Applicant's EnvironmentalReport -Operating License Renewal Stage, Facility Operating License No. DPR-66and NPF-73, Akron, OH, ADAMS Accession No. ML072470523.FirstEnergy 2008a. 2008 Annual Report, FirstEnergy Corp., Akron, Ohio, Website:http://www.firstenergycorp.com/financialreports/index.html, accessed January 12, 2010.FirstEnergy 2008b. FirstEnergy Generation System, 6/25/08, Website:http://www.firstenergycorp.com/corporate/Corporate-Profile/FirstEnergyGeneration-System.html, accessed July 13, 2009.FirstEnergy 2009a. FirstEnergy Boston Investor Meetings, June 11, 2009, Website:http://investors.firstenergycorp.com/phoenix.zhtml?c=1 02230&p=irol-presentations,accessed June 21, 2009.FirstEnergy 2009b. FirstEnergy to Repower R.E. Burger Plant With Biomass, NewsRelease, FirstEnergy Corp., Akron, Ohio, April 1, 2009.GLWEC 2009. Final Feasibility Report, Great Lakes Wind Energy Center, April 2009.IEAWIND 2002. Summary of lEA R&D Wind -Topical Expert Meeting #40,Environmental issues of Offshore Wind Farms, September 2002.INEEL 1998. U.S. Hydropower Resource Assessment Final Report, DocumentDOE/ID-10430.2, Idaho National Engineering and Environmental Laboratory, December1998.NEI 2008. Nuclear Energy in Ohio Fact Sheet, Nuclear Energy Institute, July 2008.ISEP 2011. Iowa Stored Energy Park Project Terminated, Press Release,July 28, 2011.JACM2007. Supplying Baseload Power and Reducing Transmission Requirements byInterconnected Wind Farms, Journal of Applied Meteorology and Climatotology,November 2007.LEEDco 2011. About LEEDco Lake Erie Energy Development Corporation, Website.www.leedco.org/about-us/about-leedco, accessed August 10, 2011.NEI 2008. Nuclear Energy in Ohio Fact Sheet, Nuclear Energy Institute, July 2008.NERC 2009. 2009 Long Tem Reliability Assessment, North American ElectricReliability Corporation, October 2009.ReferencesPage 7.4-2September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportNES 2010. Norton Energy Storage, LLC, Final Air Permit-To-Install and Operate, OhioEPA, September 2010.NRC 1996. Generic Environmental Impact Statement for License Renewal of NuclearPower Plants (GELS), NUREG-1437, Volumes 1 and 2, U.S. Nuclear RegulatoryCommission, Office of Nuclear Regulatory Research, May 1996.NRC 2002. Final Generic Environmental Impact Statement on Decommissioning ofNuclear Facilities, Supplement 1, Regarding the Decommissioning of Nuclear PowerReactors, NUREG-0586 Supplement 1, Volume 1, U.S. Nuclear RegulatoryCommission, Office of Nuclear Reactor Regulation, November 2002.NRC 2009a. Combined License Applications for New Reactors, Website:http://www.nrc.gov/reactors/new-reactors/col.html, accessed July 13, 2009.NRC 2009b. Generic Environmental Impact Statement for License Renewal of NuclearPower Plants (GELS), NUREG-1437, Supplement 36, U.S. Nuclear RegulatoryCommission, Office of Nuclear Regulatory Research, May 2009.NRC 2010. Combined License Applications for New Reactors, Website:http://www.nrc.gov/reactors/new-reactors/col.html, accessed June 18, 2010.NREL 2002. Fuel from the Sky -Solar Power's Potential for Western Energy Supply,National Renewable Energy Laboratory, July 2002.NREL 2010. Large-Scale Offshore Wind Power in the United States, NationalRenewable Energy Laboratory, June 2010.NREL 2010a. Assessment of Offshore Wind Energy for the United States, NationalRenewable Energy Laboratory, September 2010.NREL 2011. Eastern Wind Integration and Transmission Study, National RenewableEnergy Laboratory, February 2011.NREL 2011 a. Estimates of Windy Land Areas and Wind Energy Potential by State,National Renewable Energy Laboratory, Updated April 13, 2011.OHPUCO 2009. Alternative Energy Portfolio Standard, Chapter 4901: 1-40, Ohio PublicUtilities Commission, December 2009.PEI 2008. Compressed Air Energy Storage,: Theory, Resources, and Applications forWind Power Energy Systems Analysis group, Princeton Environmental institute,Princeton University, April 2008.PMJ 2011. State of the Market report for PJM, Monitoring Analytics, LLC, August 2011.ReferencesPage 7.4-3September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportPOST 2006. Carbon Footprint of Electricity Generation, Parliamentary Office ofScience and Technology, October 2006, available athttp://www.parliament.uk/documents/upload/postpn268.pdf, accessed July 8, 2009.PSEG 2010. Governor Strickland Helps Dedicate Ohio's Largest Solar Farm, MediaRelease from Public Service Enterprise Group, August 19, 2010.REN 2005. Assessing the Life Cycle of Wind turbine Production, Renewable EnergyWorld, Website. www.renewableenergyworld.com/rea/news/article/2005/04/assessing -the-life-cycle-of-wind-turbine-production-25113, accessed August 6, 2011.RES 2005. The Economic Impact of CAES on Wind in TX, OK, and NM, Ridge EnergyStorage & Grid Services, L.P., June 2005.RWC 2010. Roscoe Wind Council, Website:http://www.roscoewind.org/roscoewind-farm/php,_ accessed September 11, 2011.SWAY 2010. Norway to Build the World's Largest Wind Turbine, Website.http://inhabitat.com/norway-to-build-the-worlds-largest-wind-tu rbine, accessedSeptember 1,2011.TBM 2011. lberdrola Sells Energy from Blue Creek Wind Farm project, Times BulletinMedia, February 9, 2011, Website:http://www.timesbuiletin.com/main.asp?SectionlD=2&SubsectionlD=4&ArticlelD=1 64339.TEP2006. Photovoltaic Power Experience at Tucson Electric Power, Sandia NationalLaboratories and Tucson Electric Power Company, April 2006.USDOE 1999. Executive Summary, Clean Coal Technology Evaluation Guide -FinalReport, December 1999, available athttp://www.netl.doe.gov/technologies/coalpower/cctc/ccpi/bibliography/program/bibp-ev.html, accessed June 26, 2009.USDOE 2009a. Installed U.S. Wind Capacity and Wind Project Locations, Website:http://www.windpoweringamerica.gov/windinstalledcapacity.asp, accessedJuly 9, 2009.USDOE 2011. A national Offshore Wimd Strategy: Creating an Offshore Wind EnergyIndustry in the United States, U.S. Department of Energy, February 2011.USDO 2011. News Release -Salazar Announces Additional Steps Towards SmarterDevelopment of Renewable Energy on U.S. Public Land, United States Department ofInterior, February 8, 2011.ReferencesPage 7.4-4September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportUSDOE 2009b. Future Fuel Cells R&D, U.S. Department of Energy, Office of Scienceand Technology, Website:http://www.fossil.energy.gov/programs/powersystems/fuelcells/, accessed June 30,2009.USDOE 2010. Monthly Nuclear Generation by State and Reactor, 2008, U.S.Department of Energy, Energy Information Administration, Website:http://www.eia.doe.gov/cneaf/nuclear/page/nucgeneration/gensum.html, accessedJanuary 12, 2010.USEPA 2009a. Electricity from Municipal Solid Waste, U.S. Environmental ProtectionAgency, Website: http://www.epa.gov/cleanenergy/energy-and-you/affect/municipal-sw.html, accessed June 30, 2009.USEPA 2009b. EPA's Response to the TVA Kingston Fossil Fly Ash Release,U.S. Environmental Protection Agency, Region 4, May 11, 2009.USFWS 2002. Migratory Bird Mortality, United States Fish and Wildlife Service,January 2002.USFWS 2011. United States Fish and Wildlife Service -Draft Land-Based WindEnergy Guidelines, February 2011.WGA 2011. Timber Road Wind Farm in Ohio, Wind Action Group, Website.http://wagengin eering. blog spot. com/2011 /05/tim ber-road-wind-fa rm-in-ohio. html,accessed September 1, 2011.WTE 2007. 2007 Directory of Waste-to-Energy Plants in the United States, Waste-to-Energy Resources, Energy Recovery Council, Website: http://www.wte.org/waste-energy-resources-a2985, accessed June 30, 2009.References Page 7.4-5 September 2011ReferencesPage 7.4-5September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report[This page intentionally blank]References Page 7.4-6 September 2011ReferencesPage 7.4-6September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report8.0 COMPARISON OF ENVIRONMENTAL IMPACT OF LICENSERENEWAL WITH THE ALTERNATIVESRegulatory Requirement: 10 CFR 51.45(b)(3)"To the extent practicable, the environmental impacts of the proposal and thealternatives should be presented in comparative form." as adopted by10 CFR 51.53(c)(2)."FENOC presents its evaluations of the environmental impacts of Davis-Besse licenserenewal in Chapter 4 and reasonable alternatives in Chapter 7. In this chapter, FENOCprovides a comparative summary of these impacts.Table 8.0-1 summarizes environmental impacts of the proposed action (licenserenewal) and the alternatives, for comparison purposes. The environmental impactscompared in Table 8.0-2 are those that are either Category 2 issues for the proposedaction or are issues that the GElS (NRC 1996) identified as major considerations in analternatives analysis. For example, although the NRC concluded that air quality impactsfrom the proposed action would be small (Category 1), the GElS identified major humanhealth concerns associated with air emissions from alternatives (Section 7.2.2).Therefore, Table 8.0-1 compares air quality impacts from the proposed action to thealternatives. Table 8.0-2 is a more detailed comparison of the alternatives.As shown in Table 8.0-1 and Table 8.0-2, environmental impacts of the proposed action(Davis-Besse license renewal) are expected to be SMALL for all impact categoriesevaluated. In contrast, FENOC expects that environmental impacts in some impactcategories would be MODERATE or MODERATE to LARGE for the no-actionalternative (NRC decision not to renew Davis-Besse operating license), considered withor without development of replacement generation facilities.As codified in the NRC regulations at 10 C.F.R. § 51.95(c)(4), "the NRC staff,adjudicatory officers, and Commission shall determine whether or not the adverseenvironmental impacts of license renewal are so great that preserving the option oflicense renewal for energy planning decision makers would be unreasonable."The Commission explained this standard as follows:Given the uncertainties involved and the lack of control thatthe NRC has in the choice of energy alternatives in thefuture, the Commission believes that it is reasonable toexercise its NEPA authority to reject license renewalapplications only when it has determined that the impacts ofComparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-1September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportlicense renewal sufficiently exceed the impacts of all oralmost all of the alternatives that preserving the option oflicense renewal for future decision makers would beunreasonable.Environmental Review for Renewal of Nuclear Power Plant Operating Licenses,61 Fed. Reg. 28,467, 28,473 (June 5, 1996).FENOC concludes that the environmental impacts of the continued operation ofDavis-Besse, providing approximately 910 MWe of base-load power generation through2037, when compared to alternatives discussed in Section 7.0 of this EnvironmentalReport, demonstrate that preserving license renewal as an option is not unreasonable.Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-2September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.0-1: Impacts Comparison SummaryNo-Action Alternatives(1)ProposedImpact(') Action Base With With(License (Decommissioning) With Coal-Fired With Gas-Fired Interconnected Renewable &Renewal) Generation Generation Wind CAESGenerationMODERATE to SMALL to MODERATE toLand Use SMALL SMALL LARGE MDRT AG AGLARGE MODERATE LARGEWater Quality SMALL SMALL SMALL SMALL SMALL SMALL toMODERATEAir Quality SMALL SMALL MODERATE MODERATE(3) SMALL MODERATEEcological SMALL SMALL MODERATE MALL to S MALL to LARGE MODERATE toResources MODERATE LARGEHuman Health SMALL SMALL SMALL SMALL SMALL SMALLSocioeconomics SMALL SMALL MODERATE MODERATE SMALL to SMALL toMODERATE MODERATEWasteM agee SMALL SMALL MODERATE SMALL SMALL SMALLManagementSMALL to SMALL to SMALL toAesthetics SMALL SMALL MODERATE MODERATE MODERATE SMALLCultural Resources SMALL SMALL SMALL SMALL SMALL SMALLComparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-3September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportNotes:(1) Environmental impacts associated with the construction and operation of new coal-fired or gas-fired generating capacity at agreenfield site would exceed those for a coal-fired or gas-fired plant located at a brownfield, i.e., existing disturbed site.(2) From 10 CFR Part 51, Subpart A, Appendix B, Table B-i, Footnote 3:-SMALL -Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter anyimportant attribute of the resource.-MODERATE -Environmental effects are sufficient to alter noticeably, but not destabilize, any important attribute of theresource.-LARGE -Environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource.(3) Moderate, but less than with coal-fired generation.Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-4September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.0-2: Impacts Comparison DetailNo-Action Alternativest1)' (2)Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R aeGeneration Generation Wind Generation GCatoGenerattionAlternative DescriptionsDavis-Besse license Decommissioning New construction at New construction at New construction at New constructionrenewal for 20 years, following expiration of greenfield (but greenfield (but greenfield locations, at greenfield (wind,followed by current Davis-Besse preferably brownfield) preferably brownfield) and solar) CAES atdecommissioning license. Adopting by site. site. brownfield site.reference, as bounding Pulverized coal units, Combined-cycle units, Wind generation Assume CAES withDavis-Bessedecommissioning, GElS 910-MW (equivalent 910-MW (equivalent units, 910-MW natural gas units atdescription (NRC 1996, to Davis-Besse); to Davis-Besse); (equivalent to electrical output ofSection 7.1). capacity factor 0.80. capacity factor 0.80. Davis-Besse); 804 MW (6 trains).capacity factor 0.80.Closed-cycle cooling Closed-cycle cooling No cooling required. Closed-cyclewith 500-foot-tall with mechanical-draft cooling withnatural-draft cooling cooling towers. mechanical-drafttowers. cooling towers forCAES.Coal and limestone Delivery of natural gas No fuel delivery Delivery of naturaldelivery via waterway via a new 10-mile- system required. gas via a newor rail. long pipeline. 10-mile-longpipeline for CAES.Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-5September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.0-2: Impacts Comparison Detail (continued)No-Action Alternatives(1)' (2)Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R aeGeneration Generation Wind Generation &CaESGenertionGenerationAir emission controls: Air emission controls: No air emission Air emissionParticulates: fabric Nitrogen oxides: dry controls required. controls: Nitrogenfilter (99.9% removal) low-NOx burners; oxides: dry low-Sulfur oxide: wet selective catalytic NOx burners;limestone scrubber reduction (90% selective catalytic(95% removal) removal). Particulate reduction (90%Nitrogen oxide: matter and carbon removal).low-NOx burners, monoxide emissions Particulate matteroverfire air, selective limited through proper and carboncatalytic reduction combustion controls. monoxide(95% removal), emissions limitedthrough propercombustioncontrols for CAES.Emissions dispersed Exhaust dispersed via No emissions or Exhaust dispersedvia 500-foot-tall 150-foot-tall stacks. heat plume exhaust. via 150-foot-tall (orstacks. less) stacks.825 permanent and Estimated workforce: Estimated workforce: Estimated Estimated60 contract workers Construction: 1,092 -Construction: 1,092 -workforce: workforce:(Section 3.4) 2,275; Operation: 228 2,275; Operation: 137 Construction: 1,200 Construction: 1,200-1,500; Operation: -1,500; Operation:150. 150.Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-6September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.0-2: Impacts Comparison Detail (continued)No-Action Alternativestt1 (2)Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected & CAESGeneration Generation Wind Generation GenerationLand Use ImpactsSMALL -Adopting by SMALL -Adopting by MODERATE to SMALL to MODERATE to LARGE -up toreference Category 1 reference applicable LARGE -1,547 acres MODERATE -100 LARGE -Would be 91,000 acresissue findings NRC impact conclusions required for the acres for facility and dependent on how required for wind(Table A-i, Issues 52, in the GElS Section 8.4 powerblock and 240 to 270 additional many wind farms and 37,900 acres53). and Supplement 1 to associated facilities; acres for gas pipeline onshore verses for solar generationNUREG-0586. assumed 10 miles of and electric offshore and associated345-kV transmission transmission lines (Section 7.3.3). facilities;line on a 150-foot (Section 7.3.2). (Section 7.3.3).right-of-way; 22acres/MW for miningand disposal(Section 7.3.1).Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-7September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.0-2: Impacts Comparison Detail (continued)No-Action Alternatives(11' (2)Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R aeGeneration Generation Wind Generation &CaESGenertionGenerationWater Quality ImpactsSMALL -Adopting by SMALL -Adopting by SMALL -SMALL -SMALL -SMALL toreference Category 1 reference Category 1 Construction impacts Construction impacts Construction MODERATE -issue findings (Table issue finding (Table A-i, minimized by minimized by impacts minimized ConstructionA-i, Issues 1-3, 6-11, Issue 89) in the GElS regulatory controls; regulatory controls; by regulatory impacts minimizedand 31). Five Chapter 7 and operation-phase cooling water and controls by regulatoryCategory 2 water Section 8.4, and in impacts similar to wastewater (Section 7.3.3). controls; coolingquality issues do not Supplement 1 to those of Davis-Besse; discharges subject to water andapply: Section 4.1, NUREG-0586. cooling water and regulatory controls wastewaterIssue 13; Section 4.6, wastewater (Section 7.3.2). discharges subjectIssue 34, Section 4.5, discharges subject to to regulatoryIssue 33; Section 4.7, regulatory controls controlsIssue 35; and (Section 7.3.1). (Section7.3.3).Section 4.8 Issue 39.Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-8September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.0-2: Impacts Comparison Detail (continued)No-Action Alternatives(')' (2)Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R aeGeneration Generation Wind Generation GnatoGenertionGenerationAir Quality ImpactsSMALL -Adopting by SMALL- Adopting by MODERATE -MODERATE -SMALL -MODERATE -reference Category 1 reference Category 1 8,267 tons SOx/year 13.3 tons S02/year Construction 42.41 tonsissue finding issue findings 5,087 tons NOx/year 205 tons NOx/year impacts minimized S02/year(Table A-i, Issue 51). (Table A-i, Issue 88) in 636 tons CO/year 311 tons CO/year by regulatory 93.67 tonsOne Category 2 issue the GElS Chapter 7 and 153 tons PM/year 39.4 tons PM/year controls NOx/yeardoes not apply: Section 8.4, and in 34.3 tons PM10/year 2.28x106 tons (Section 7.3.3). 90.36 tons CO/yearSection 4.11, Supplement 1 to 7.63x106 tons C02/year 46.65 tons PE/yearIssue 50. NUREG-0586. C02/year (Section 7.3.2). 26.40 tons(Section 7.3.1). VOCs/year681.1 x103tons ofC02/year(Section 7.3.3).Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-9September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.0-2: Impacts Comparison Detail (continued)No-Action Alternatives(')' (2)Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected & CAESGeneration Generation Wind Generation GenerationEcological Resource ImpactsSMALL -Adopting by SMALL -Adopting by MODERATE -SMALL to SMALL to MODERATE toreference Category 1 reference Category 1 Potential loss or MODERATE -MODERATE -LARGE- Potentialissue findings issue finding alteration of more Approximately 100 Habitat and loss or alteration of(Table A-i, Issues (Table A-i, Issue 90) in than 1,500 acres of acres onsite and 240 migratory impacts more than 90,00014-24, 28-30, 41-43, the GElS Chapter 7 and habitat (e.g., to 270 acres offsite of would be greater for acres of habitatand 45-48). Three Section 8.4, and in transmission, waste largely agricultural land based wind (e.g., wind andCategory 2 issues do Supplement 1 to disposal landfill); land would be farms then offshore solar facilities,not apply: NUREG-0586. facilities siting would converted to industrial wind farms (e.g., transmission);Section 4.2, Issue 25; be subject to use for plant site and wind facilities, facilities sitingSection 4.3, Issue 26; regulatory controls offsite infrastructure, transmission); would be subject toand Section 4.4, limiting impacts to respectively; facilities facilities siting would regulatory controlsIssue 27. ecological resources, siting would be be subject to limiting impacts toincluding wetlands subject to regulatory regulatory controls ecologicaland threatened or controls limiting limiting impacts to resources,endangered species. impacts to ecological ecological including wetlandsImpact on aquatic resources, including resources, including and threatened orhabitats and biota wetlands and wetlands and endangeredfrom dredging (e.g., threatened or threatened or speciesfor intake and endangered species. endangered species (Section 7.3.3).discharge structures Potential for impacts (Section 7.3.3).and, if applicable, to aquatic resourcesbarge terminal), from construction andcooling water operation (e.g.,withdrawal, and cooling waterdischarge would be withdrawal andComparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-10September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.0-2: Impacts Comparison Detail (continued)No-Action Alternatives(')' (2)Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected & CAESGeneration Generation Wind Generation Generationsubject to regulatory discharge) reduced bycontrols best management(Section 7.3.1). practices andregulatory controls(Section 7.3.2).Threatened or Endangered Species ImpactsSMALL -Federally SMALL -Not an impact SMALL -Federal and SMALL -Federal and SMALL -Federal SMALL -Federaland state threatened evaluated by the GEIS. state laws prohibit state laws prohibit and state laws and state lawsor endangered destroying or destroying or prohibit destroying prohibit destroyingspecies are protected adversely affecting adversely affecting or adversely or adverselythrough company and protected species and protected species and affecting protected affecting protectedplant procedures. their habitats. their habitats. species and their species and their(Section 4.10, habitats. habitats.Issue 49) 1Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-11September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.0-2: Impacts Comparison Detail (continued)No-Action Alternatives(')' (2)Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected & CAESGeneration Generation Wind Generation GenerationHuman Health ImpactsSMALL -Adopting by SMALL- Adopting by SMALL -Some risk of SMALL -Similar to SMALL SMALL -Similar toreference Category 1 reference Category 1 cancer and the coal-fired (Section 7.3.3). the gas-firedissues (Table A-i, issue finding (Table A-i, emphysema from air alternative alternative (CAESIssues 54-56, 58, 61, Issue 86) in the GElS emissions and risk of (Section 7.3.2). plant)62). One Category 2 Chapter 7 and accidents to workers, (Section 7.3.3).issue does not apply: Section 8.4, and in as the NRC notes inSection 4.12, Supplement 1 to the GELS.Issue 57. Risk due to NUREG-0586. Assumed thattransmission-line regulatory controlsinduced currents would reduce risks tominimal due to acceptable levelsconformance with (Section 7.3.1).consensus code(Section 4.13,Issue 59). __1___1_1Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-12September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.0-2: Impacts Comparison Detail (continued)No-Action Alternatives(1)' (2)Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected & CAESGeneration Generation Wind Generation GenerationSocioeconomic ImpactsSMALL -Adopting by SMALL -Adopting by MODERATE to MODERATE -MODERATE -MODERATE -reference Category 1 reference Category 1 Reduction in Reduction in Reduction in Reduction inissue findings issue finding (Table A-i, permanent work force permanent work force permanent work permanent work(Table A-i, Issues 64, Issue 91) in the GElS and tax base at and tax base at force and tax base force and tax base67). Two Category 2 Chapter 7 and Davis-Besse would Davis-Besse would at Davis-Besse at Davis-Besseissues do not apply: Section 8.4, and in adversely affect adversely affect would adversely would adverselySection 4.16, Issue 66 Supplement 1 to surrounding surrounding affect surrounding affect surroundingand Section 4.17.1, NUREG-0586. communities. communities. communities. communities.Issue 68. Location in Construction and Impacts from Impacts from Impacts fromhigh population area operational impacts construction would be construction would construction wouldwith no growth would depend upon mitigated by siting be mitigated by be mitigated bycontrols minimizes the site location. plant within siting renewable siting renewablepotential for housing Regulatory controls commuting distance facilities within facilities withinimpacts (Section 4.14, and appropriate of large metropolitan commuting distance commutingIssue 63). mitigation would areas (Section 7.3.2). of metropolitan distance ofCapacity of public ensure that impacts areas when possible metropolitan areaswater supply as well are not destabilizing (Section 7.3.3). when possibleas education and (Section 7.3.1). (Section 7.3.3).transportationinfrastructuresminimizes potentialfor related impacts(Section 4.15, Issue65; Section 4.16,Issue 66; and SectionComparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-13September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.0-2: Impacts Comparison Detail (continued)No-Action Alternatives(')' (2)Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R aeGeneration Generation Wind Generation &CaESGenertionGeneration4.18, Issue 70).Plant tax paymentsrange from <10% tonearly 20% of localjurisdictions taxrevenues (Section4.17.2, Issue 69). 1 1 1 1Waste Management ImpactsSMALL -Adopting by SMALL -Adopting by MODERATE -Annual SMALL -Solid waste SMALL -Solid SMALL -Solidreference Category 1 reference Category 1 waste of is minimal (Section waste is minimal waste is minimalissue findings issue finding Table A-i, approximately 7.3.2). (Section 7.3.3). (Section 7.3.3).(Table A-i, Issue 87) in the GElS 300,000 tons ash andIssues 77-85). Chapter 7 and 470,000 tons flue gasSection 8.4, and in desulphurizationSupplement 1 to waste, requiringNUREG-0586. disposal offsite in a644-acre landfill overan assumed 40-yearplant life(Section 7.3.1).Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-14September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.0-2: Impacts Comparison Detail (continued)No-Action Alternatives(1)' (2)Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected & CAESGeneration Generation Wind Generation GenerationAesthetic ImpactsSMALL -Adopting by SMALL -Adopting by SMALL to SMALL to SMALL to SMALL -Aestheticreference Category 1 reference conclusions in MODERATE -Highly MODERATE -Highly MODERATE -impacts areissue findings (Table the GElS Section 8.4 dependent on dependent on Highly dependent on minimalA-i, Issues 73, 74). and Supplement 1 to location. Stacks, location. Stacks, location of wind (Section 7.3.3).NUREG-0586. cooling tower plumes cooling tower plumes farmslikely would be visible would be visible (Section 7.3.3).for several miles. offsite (Section 7.3.2).Operation of wastedisposal site wouldhave adverse impactpotential (Section7.3.1).Cultural Resource ImpactsSMALL -License SMALL -Adopting by SMALL -Siting of SMALL -Same as SMALL -Cultural SMALL -Culturalrenewal does not reference conclusions in plant and offsite the coal-fired resource impacts resource impactsrequire additional land the GElS Section 8.4 infrastructure (e.g., alternative (Section are minimal are minimaldisturbance (Section and Supplement 1 to transmission line, 7.3.2). (Section 7.3.2). (Section 7.3.2).4.19, Issue 71). NUREG-0586. natural gas pipeline)would be subject toregulatory review, andmitigation measureswould beimplemented (Section7.3.1).Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-15September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportBtu = British thermal unitCO = carbon monoxideCO2 = carbon dioxideft3 = cubic footGElS = Generic Environmental Impact Statement (NRC 1996)kWh = kilowatt hourlb = poundMM = millionMW = megawattNOx = nitrogen oxidesPM = particulate matterPM10 = particulates having diameter less than 10 micronsNotes:(1) Environmental impacts associated with the construction and operation of new coal-fired or gas-fired generating capacity at agreenfield site would exceed those described in the table for a coal-fired or gas-fired plant located at a brownfield, i.e., existingdisturbed site.(2) From 10 CFR Part 51, Subpart A, Appendix B, Table B-I, Footnote 3:-SMALL -Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter anyimportant attribute of the resource.-MODERATE -Environmental effects are sufficient to alter noticeably, but not to destabilize, any important attribute of theresource.-LARGE -Environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource.Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-16September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report8.1 REFERENCESNES 2010. Norton Energy Storage, LLC, Final Air Permit-To-Install and Operate,Ohio EPA, September 2010.NRC 1996. Generic Environmental Impact Statement for License Renewal of NuclearPower Plants (GELS), NUREG-1437, Volumes 1 and 2, U.S. Nuclear RegulatoryCommission, Office of Nuclear Regulatory Research, May 1996.ReferencesPage 8. 1-1September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report[This page intentionally blank]References Page 8.1-2 September 2011ReferencesPage 8.1-2September 2011 Enclosure BDavis-Besse Nuclear Power Station, Unit No. 1 (DBNPS)Letter L-11-289FENOC Annotation of Amendment No. 16 to theDBNPS License Renewal Applicationto Facilitate NRC Review86 Pages(not including this cover page)License Renewal ApplicationSections AffectedAppendix E, Chapter 7Appendix E, Chapter 8This Enclosure provides a copy of the Amendment provided in Enclosure A (Davis-BesseNuclear Power Station, Unit No. 1, License Renewal Application, Appendix E, "Applicant'sEnvironmental Report, Operating License Renewal Stage," Chapters 7 and 8) that showsthe changes in redline (or tracked-changes) format to facilitate NRC review. Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report7.0 ALTERNATIVES TO THE PROPOSED ACTIONRegulatory Requirement: 10 CFR 51.45(b)(3)The environmental report shall discuss "Alternatives to the proposed action."[adopted by reference at 10 CFR 51.53(c)(2)].7.0.1 OVERVIEWThis chapter assesses alternatives to the proposed renewal of the Davis-Besseoperating license. It includes discussions of the no-action alternative and alternativesthat meet system generating needs. Descriptions are provided in sufficient detail tofacilitate comparison of the impacts of the alternatives to those of the proposed action.In considering the level of detail and analysis that it should provide for each category,FENOC relied on the NRC decision-making standard for license renewal:... the NRC staff, adjudicatory officers, and Commission shall determine whether or notthe adverse environmental impacts of license renewal are so great that preserving theoption of license renewal for energy planning decision makers would be unreasonable.[10 CFR 51.95(c)(4)]As noted in 10 CFR 51.53(c)(2), a discussion is not required of need for power oreconomic costs and benefits of the proposed action or of alternatives to the proposedaction except insofar as such costs and benefits are either essential for a determinationregarding the inclusion of an alternative in the range of alternatives considered orrelevant to mitigation.Section 7.1 addresses the "no-action" alternative in terms of the potential environmentalimpacts of not renewing the Davis-Besse operating license, independent of any actionstaken to replace or compensate for the loss of generating capacity. Section 7.2describes feasible alternative actions that could be taken, which FENOC also considersto be elements of the no-action alternative, and presents other alternatives that FENOCdoes not consider to be reasonable. Section 7.3 presents the environmental impacts forthe reasonable alternatives.The environmental impact evaluations of alternatives presented are intended to provideenough information to support NRC decision-making by demonstrating whether analternative would have a smaller, comparable, or greater environmental impact than theproposed action. Additional detail or analysis was not considered useful or necessary ifit would identify only additional adverse impacts of license renewal alternatives; i.e.,information beyond that necessary for a decision. This approach is consistent with theCEQ regulations, which provide that the consideration of alternatives (including theAlternatives to the Proposed ActionPage 7.0-1September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportproposed action) be adequately addressed so reviewers may evaluate theircomparative merits (40 CFR 1502.14(b)).The characterization of environmental impacts in this chapter applies the samedefinitions of "SMALL," "MODERATE," and "LARGE" used in Chapter 4 of this ER andby the NRC in the GElS (NRC 1996). Chapter 8 presents a summary comparison ofenvironmental impacts of the proposed action and alternatives.7.0.2 REGION OF INTERESTNRC environmental guidance for siting new reactors defines the "Region of interest"(ROI) as "the geographic area considered in searching for candidate sites."NUREG-1 555, at 9.3-1 (1999). That definition is not directly applicable to this licenserenewal action because Davis-Besse is already sited as an operating reactor in Ohio.The application here is for license renewal, and not for initial plant siting, construction.or operation. However, that same environmental guidance explains that "the basis foran ROI is the State in which the proposed site is located or the relevant service area forthe Proposed plant." NUREG-1555, at 9.3-2. This explanation, or basis for selectingthe ROI for siting new reactors, is applicable for defining the ROI for purposes of licenserenewal, Accordingly, FENOC is adopting an ROI for this Environmental Report as theState in which Davis-Besse is located: Ohio. The second portion of the explanation inNUREG-1 555--the relevant service area for the proposed plant"-is not applicable toDavis-Besse, because the electricity that Davis-Besse generates is sold on thewholesale power market. Accordingly, there is no "relevant service area" for the plant.I Alternatives to the Proposed ActionPage 7.0-2September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report7.1 NO-ACTION ALTERNATIVEFENOC considers the no-action alternative is not to renew the Davis-Besse operatinglicense. With this alternative, FENOC expects Davis-Besse would continue to operateuntil the expiration of the existing operating license in 2017, at which time plantoperations would cease, decommissioning would begin, and FirstEnergy or otherswould take the appropriate actions to meet system-generating needs created bydiscontinued operation of the plant.Section 7.1.1 addresses the impacts of terminating operations and decommissioning,whereas Section 7.1.2 discusses the actions to replace power from Davis-Besse.7.1.1 TERMINATING OPERATIONS AND DECOMMISSIONINGIn the event the NRC does not renew the Davis-Besse operating license, FENOCassumes for this ER that it would operate the plant until the current license expires, thenterminate operations and initiate decommissioning activities in accordance with NRCrequirements. For purposes of this discussion, terminating operations includes thoseactions directly associated with permanent cessation of operations, which may result inmore or less immediate environmental impacts (e.g., socioeconomic impacts fromreduction in employment and tax revenues).Decommissioning, as defined in the GELS, is the safe removal of a nuclear facility fromservice and the reduction of residual radioactivity to a level that permits release of theproperty for unrestricted use and termination of the license (NRC 1996, Section 7.1).The two decommissioning options typically selected for United States reactors are rapiddecontamination and dismantlement (DECON), and safe storage of the stabilized andde-fueled facility (SAFSTOR), followed by final decontamination and dismantlement(NRC 1996, Section 7.2.2). Under the DECON option, radioactively contaminatedportions of the facility and site are decontaminated or removed promptly after cessationof operations to a level that permits termination of the license; these activities requireseveral years for large light-water reactors like Davis-Besse (NRC 1996, Table 7.8).The SAFSTOR option involves safe storage of the stabilized and defueled facility for aperiod of time followed by decontamination to levels that permit license termination.Regardless of the option selected, decommissioning typically must be completed within60 years after operations cease in accordance with NRC requirements at 10 CFR 50.82(NRC 1996, Section 7.2.2).FENOC has not selected a decommissioning method for Davis-Besse. Thedecommissioning method for Davis-Besse would be described in post-shutdowndecommissioning plans for the plant, which must be submitted to NRC within two yearsfollowing cessation of operations. For purposes of the present analysis, FENOCassumes that the DECON option would be employed upon license termination.I No-action AlternativePage 7.1-1September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportThe NRC presents in Chapter 7 and Section 8.4 of the GElS a summary of genericenvironmental impacts of the decommissioning process and an evaluation of potentialchanges in impact that could result from deferring the decommissioning process for upto 20 years (NRC 1996). For a pressurized water reactor decommissioning, NRC useda 1,175 MWe reference reactor. Although larger than Davis-Besse (910 MWe), FENOCconsiders the reference reactor to be representative of Davis-Besse. As a result,FENOC believes the decommissioning activities described in the GElS to berepresentative of activities FENOC would perform for decommissioning at Davis-Besse.The NRC concluded from its evaluation that decommissioning impacts would not besignificantly greater as a result of the proposed action, assumed to result in20 additional years of operation (NRC 1996, Sections 7.3 and 8.4). The NRCconclusions also indicate that the impacts of the decommissioning process itself,addressed in this ER as part of the no-action alternative, would have SMALL impactswith respect to radiation dose, waste management, air quality, water quality, andecological resources (see 10 CFR Part 51, Subpart A, Appendix B, Table B-1). FENOCconsiders this generic evaluation and associated conclusions applicable to Davis-Besseas well.The NRC has provided additional analysis of the environmental impacts associated withdecommissioning in the Final Generic Environmental Impact Statement onDecommissioning of Nuclear Facilities (NRC 2002). Except for issues that requiresite-specific evaluation, environmental impacts, including radiological releases anddoses from decommissioning activities, were assessed to be SMALL (NRC 2002,Sections 4.3 and 6.1).Regardless of the NRC decision on license renewal, FENOC will have to decommissionDavis-Besse; license renewal would only postpone decommissioning for an additional20 years. In the GELS, the NRC concludes that there should be little difference betweenthe environmental impacts from decommissioning at the end of 40 years of operationversus those associated with decommissioning after an additional 20 years of operationunder a renewed license (NRC 1996, Section 7.4).By reference, FENOC adopts the NRC findings regarding environmental impacts ofdecommissioning in the license renewal GElS (NRC 1996) and in the decommissioningGElS (NRC 2002), and concludes that environmental impacts under the no-actionalternative would be similar to those that occur following license renewal. Further,FENOC believes that decommissioning activities would not involve significant land-usedisturbance offsite or significant activities beyond current operational areas that wouldoffer potential for impacts on land use, ecological resources, or cultural resources.Decommissioning impacts would be temporary and occur at the same time as thoseassociated with the operation of replacement generating sources.I No-action AlternativePage 7.1-2September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report7.1.2 REPLACEMENT CAPACITYDavis-Besse is a base-load generator of electric power, with a net generating capabilityof 908 MWe (Section 3.1.2). In 2008, Davis-Besse generated approximately 8.3% ofFirstEnergy's total base-load electricity generation (FirstEnergy 2008a, Page 7;USDOE 2010). The power produced by Davis-Besse, which represents a significantportion of the electricity FirstEnergy supplies to 2.1 million customers in its serviceterritories located in Ohio (FirstEnergy 2009a, Page 81), would be unavailable in theevent the Davis-Besse operating license is not renewed.As provided in 10 CFR 51.53(c)(2), FENOC does not consider the need for power fromDavis-Besse in this analysis, but does consider the potential impact of alternatives forreplacing this power. Replacement options considered include building new base-loadgenerating capacity, purchasing power, delaying retirement of non-nuclear assets, andreducing power requirements through demand reduction, as discussed in Section 7.2.I No-action AlternativePage 7.1-3September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report[This page intentionally blank]I No-action AlternativePage 7.1-4September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report7.2 ALTERNATIVES THAT MEET SYSTEM GENERATING NEEDSIf the Davis-Besse operating license is not renewed, then the State of Ohio, FirstEnergyCorp. and its subsidiary companies, and other participants in the wholesale powermarket would lose approximately 910 MWe of base-load capacity. Renewal wouldpreserve the option of relying on Davis-Besse to meet future electric power needsthrough the period of extended operation.While many methods are available to generate electricity, the GElS indicates that a"reasonable set of alternatives should be limited to analysis of single, discrete electricgeneration sources and only electric generation sources that are technically feasibleand commercially viable" (NRC 1996, Section 8.1). Considering that Davis-Besseserves as a large base-load generator, FENOC considers reasonable alternatives to bethose that would also be able to generate base-load power. FENOC believes that anyalternative would be unreasonable if it did not consider replacement of the energyresource.7.2.1 ALTERNATIVES CONSIDERED AS REASONABLEFossil-Fuel Alternatives SummaryFENOC believes that coal-fired and gas-fired generation capacity are feasiblealternatives to nuclear power generating capacity, based on current (and expected)technological and cost factors, as compared to the other alternatives listed in the GElS(NRC 1996, Section 8.1). FENOC considers the coal-fired and gas-fired technologiesreasonable alternatives for purposes of this analysis to replace Davis-Besse generatingcapacity in the event its operating license is not renewed. The GEIS further notes thatnatural gas combined-cycle plants are particularly efficient and are used as base-loadfacilities (NRC 1996, Section 8.3.10). The specific coal-generating technologies thatwould represent viable alternatives are less certain, particularly in view of potentiallyhigher air emissions compared to natural gas firing. For example, large-capacityintegrated gasification combined-cycle (IGCC) and fluidized-bed-combustion (FBC)technologies (atmospheric and pressurized) are at or near commercial viability andcould prove to be appropriate replacements. However, modern pulverized coal plantswith advanced, clean-coal technology air emission controls represent currently proventechnology and are economically competitive and commercially available in large-capacity unit sizes that could effectively replace Davis-Besse. Therefore, FENOC usesa representative plant of this type for purposes of impact evaluation, noting that airemission impacts of IGCC and FBC options may be lower than modern pulverized coal,but would be higher than the gas-fired combined-cycle alternative (USDOE 1999,Pages 5-7)."910 MWe is used for calculation convenience instead of 908 Mwe, as noted in Section 3.1.2.--Deleted: FENOC considers the othertechnologies listed in the GElS as notreasonable alternatives for thereasons discussed in Section 7.2.2.¶,Alternatives that Meet SystemGenerating NeedsPage 7.2-1 September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportRenewable Energy Alternatives SummaryOn April 26, 2011, an NRC Atomic Safety and Licensing Board (Board) presiding overthe license renewal proceeding for Davis-Besse issued a Memorandum and Order(LBP-1 1-13) admitting a contention alleging that the FENOC analysis of renewableenergy alternatives in the Environmental Report was not adequate. As admitted by theBoard, the contention states:[FENOC's ER] fails to adequately evaluate the full potential for renewableenergy sources, specifically wind power in the form of interconnected windfarms and/or solar photovoltaic power, in combination with compressed airenergy storage, to offset the loss of energy production from Davis-Besse.and to make the requested license renewal action unnecessary. TheFENOC Environmental Report (Section 7.2) treats all of the alternatives tolicense renewal except for natural gas and coal plants as unreasonableand does not provide a substantial analysis of the potential for significantalternatives in the Region of Interest.The Board's phrasing of the contention, as admitted, arguably includes the followinqrenewable energy alternatives: 1) wind power in the form of interconnected wind farms:2) wind power in the form of interconnected wind farms with compressed air energystorage (CAES): 3) solar (photovoltaic) power combined with CAES: or 4) a combinationof interconnected wind farms and solar (photovoltaic) power with CAES.FENOC does not believe that any of these are "reasonable" alternatives under NEPA.However, in order to resolve the issues raised in the admitted contention, FENOC hasrevised this ER to evaluate the renewable energy alternatives listed above as analternative to replace the rated electrical output of Davis-Besse by 2017.FENOC considers the other technologies listed in the GElS as not reasonablealternatives for the reasons discussed in Section 7.2.2.DisclaimerThroughout Chapters 7 & 8. FENOC presents information about renewable energyresources compiled by others. FENOC has not independently confirmed the accuracyof these statements, nor does FENOC agree with them.Additionally, FENOC does not agree that the renewable energy alternatives listed abovecan provide base-load generation or that the existing and any interstate transmissionsystem available by 2017 could accommodate such renewable enerqy.Finally, even if such a group of renewable resources were built, there is no way toassure that the power generated by those resources would be available to the CAESfacility to create the alternative that Joint Petitioners envision. There are a number ofAlternatives that Meet SystemGenerating NeedsPage 7.2-2September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportconsiderations for the development of a solar or wind resource including the availabilityof sufficient sun or wind, the availability of land, grid access, cost of interconnection(which may be economically prohibitive in some cases), and sufficient transmissionresources to assure the CAES's ability to interact with the resource.The NRC has noted that, while there are many methods available for generatingelectricity and many combinations of alternative power generation sources that couldprovide base-load capacity, such an expansive consideration of alternatives would betoo unwieldy (NRC 1996, Section 8.1).-{ Deleted: Representative7.2.1.1 Coal-Fired GenerationFor purposes of this analysis, FENOC assumed development of a modern pulverizedcoal-fired power plant with state-of-the-art emission controls similar to that described inits license renewal application, Appendix E (Environmental Report), for the BeaverValley Power Station (FENOC 2007, Section 7.2.2.2). In defining the Davis-Besse coal-fired alternative, FENOC has used site-specific input as appropriate.The representative plant would consist of commercially available standard-sized units,with a nominal net output of approximately 910 MWe, and would be designed to meetapplicable standards with respect to control of air and wastewater emissions. As aminimum, FENOC assumed that the plant would feature low nitrogen oxide burners withoverfire air to minimize formation of nitrogen oxides, and selective catalytic reduction forpost-combustion nitrogen oxide control. Emissions of particulate matter and mercurywould be limited by use of a fabric filter (baghouse), and sulfur oxide emissions wouldbe controlled using a wet scrubber using limestone as the reagent.Table 7.2-1 lists the basic specifications for the representative plant.The Davis-Besse site would not be a viable location for the representative plant as aresult of space limitations (see Section 7.3.1, Land Use). Land area requirements for acoal-fired plant of similar capacity to Davis-Besse would be approximately 1.7 acres perMWe (NRC 1996, Section 8.3.9), or 1,547 acres for a 910 MWe plant. The needed landarea, therefore, far exceeds the 954-acre Davis-Besse site, most of which is occupiedby marshland that is leased to the U.S. Government as a national wildlife refuge(Section 2.1).Therefore, FENOC assumed for the analysis that the representative coal-fired plantwould be located elsewhere at a greenfield or (preferably) brownfield site close to acommercially, navigable waterway or existing railway. A navigable waterway locationwould be highly desirable from a technical and economic perspective, considering therelative abundance of cooling water and low fuel cost afforded by barge transportationof coal and limestone. FENOC further assumed for the analysis that the representativecoal-fired plant would use closed-cycle cooling with a natural draft cooling tower.Alternatives that Meet SystemGenerating NeedsPage 7.2-3 September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportLastly, FENOC assumed for the analysis that the environmental impacts associatedwith siting, design, and operation of the plant would be subject to comprehensive reviewunder Ohio Power Siting Board (OPSB) rules or a comparable process.-{ Deleted: Representative7.2.1.2 Glas-Fired G eneration _-- -- --- -- -- --- -- --- ---......................aivFor purposes of this analysis, FENOC assumed development of a modern natural gas-fired combined-cycle plant based on a commercially available design similar to thatdescribed in its license renewal application, Appendix E (Environmental Report), for theBeaver Valley Power Station (FENOC 2007, Section 7.2.2.1). In defining theDavis-Besse gas-fired alternative, FENOC has used site-specific input as appropriate.The representative plant would consist of commercially available standard-sized units,with a nominal net output of approximately 910 MWe, and would be designed to meetapplicable standards with respect to control of air and wastewater emissions. As aminimum, FENOC assumed that the plant would use natural gas as its only fuel andfeature dry low-NOx burners to minimize formation of nitrogen oxides during combustionand selective catalytic reduction for post-combustion nitrogen oxide control. Emissionsof particulate matter and carbon monoxide would be limited through proper combustioncontrols.Table 7.2-2 lists the basic specifications for the representative plant.The Davis-Besse site is uncertain as a viable location for the representative plant due tospace limitations. Land area requirements for a gas-fired plant of similar capacity toDavis-Besse, for example, would be approximately 0.11 acres per MWe (NRC 1996,Table 8.1), or 100 for a 910 MWe plant. Of the 954 acres of land occupied by theDavis-Besse site, 733 acres is occupied by marshland that is leased to the U.S.Government as a national wildlife refuge (Section 2.1). The remaining 221 acres ismostly occupied by Davis-Besse structures. Therefore, FENOC assumed for theanalysis that the representative gas-fired plant would be located elsewhere at agreenfield or (preferably) brownfield site, but has not identified a specific site. However,primary considerations for a cost-competitive site include close proximity to adequatenatural gas supply, transmission infrastructure, cooling water, and sufficient landsuitable for development. For this analysis, FENOC assumed, based on FirstEnergyexperience in gas-fired plant siting, that northwestern Ohio would be a realistic generalarea to locate the new plant (FENOC 2007, Section 7.2.2.1). FENOC further assumedfor the analysis that the representative gas-fired plant would use closed-cycle coolingwith mechanical draft cooling towers.Lastly, FENOC assumed for the analysis that the environmental impacts associatedwith siting, design, and operation of the plant would be subject to comprehensive reviewunder Ohio Power Siting Board (OPSB) rules or a comparable process.Alternatives that Meet System Page 7.2-4 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report7.2.1.3 Renewable Energy GenerationAs explained above in Section 7.2.1. and subject to the disclaimers in that Section,FENOC is evaluating for the sole purpose of this NEPA analysis certain renewableenergy alternatives. These alternatives are discussed in more detail below. Otherrenewable energy alternatives were rejected for the reasons explained below inSection 7.2.2.Interconnected Wind FarmsWind enerqy facilities use wind turbines to harness the kinetic energy of wind andtransform it into electrical power. Output depends on a turbine's size and the wind'sspeed through the rotor as well as the availability of wind itself. Wind turbinesmanufactured today range from 250 watts (AWEA 2002) to 10 megawatts (MW) (SWAY2010), and wind farms can range in capacity from a few megawatts to the 781+megawatt Roscoe Wind Complex in Texas. (CBS 2010) Wind availability, speed andturbine height are critical factors for wind farm generating capacity. The stronger andmore consistent the wind, and the taller the turbines, the higher potential capacityexists. Multiple land uses are often possible on wind farms. For example, a wind farmmay generate electricity while cattle graze or corn grows on the land surrounding theturbines. (AWEA 2002)Neither a single wind turbine nor interconnected wind farms currently provide baseloadpower anywhere in the United States. However, the theory that multiple wind farmslocated throughout a region and interconnected via the grid could provide for moreconsistent power generation due to the reduced likelihood that all sites wouldexperience the same wind patterns at any given time, has been studied.In one study, the benefits of interconnecting wind farms were evaluated for 19 siteslocated in the midwestern United States with annual average wind speeds greater than6.9 meters per second (mWs) (class 3 or greater) at 80 m above ground, the hub heightof modern wind turbines. The study reported that, on average, only 33% and amaximum of 47% of yearly-averaged wind power from interconnected wind farms couldtheoretically be relied upon to produce electricity. And there were days when noelectricity was produced from these wind farms. (JACM 2007)Additionally, delays in the implementation of interconnected wind technology can be dueto transmission line construction difficulties, as the North American Electric ReliabilityCorporation (NERC) explains in its 2009 Long-Term Reliability Assessment. The NERCpoints out that siting of new bulk power transmission lines brings with it uniquechallenges due to the high visibility, their span through multiple states/provinces and.potentially, the amount of coordination/cooperation required among multiple regulatingagencies and authorities. Lack of consistent and agreed-upon cost allocationI Alternatives that Meet SystemGenerating NeedsPage 7.2-5September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportapproaches, coupled with public opposition due to land-use and property valuationconcerns, have, at times, resulted in long delays in transmission line construction. Newtransmission, including transmission in the DOE's designated "National Interest ElectricTransmission Corridors" can be delayed or halted by individual states, increasing thedifficulty to site bulk transmission, including those projects focused on unlockinglocation-constrained renewable generation. These siting issues create a potentialcongestion issue and challenge the economic viability of new generation proiects.(NERC 2009)In the specific case of wind power, a wind proiect must be located where it wouldproduce economical generation, and that location may be far removed from the nearestpossible connection to the transmission system. A location far removed from the powertransmission grid might not be economical, as new transmission lines would be requiredto connect the wind farm to the distribution system, and the question of who pays for thetransmission upgrade would be at issue. Existing transmission infrastructure may needto be upgraded to handle the additional supply. Soil conditions and the terrain must besuitable for the construction of the towers' foundations. Finally, the choice of a locationmay be limited by land use regulations and the ability to obtain the required permitsfrom local, regional, and national authorities.Jacobs and Archer completed a study of interconnected wind farms with consisting ofup to 19 wind farm sites, and concluded that maximum capacity factors ofapproximately 45% could theoretically be obtained (JACM 2007). Davis-Besse's recentcapacity factor has been in excess of 90%, which would generate approximately7,158,672 MWh over a full year. To achieve a similar annual average at a 45% capacityfactor, interconnected wind farms with a minimum of 1210 GE 1.5 MW turbines wouldbe required, and would not be guaranteed due to the uncontrollability of the windavailability. It must be noted, however, that the studies by Jacobs and Archer werebased on areas with higher annual average wind speeds (over 8 m/s). Thus, in Ohio, itwould be expected that the GE 1.5-MW turbines might not operate as efficiently andthus the number of turbines required for replacement power generation would be higher.And there would still be times when reserve capacity from traditional generation orenergy storage would be required. Using larger turbines could be used if wind speedssupported their economical use, especially in offshore locations (discussed below).which would reduce land use.Since 1998-99, average turbine nameplate capacity has increased by 151%, but growthin this metric has slowed in recent years due to the dominance of GE's 1.5 MW turbineand as a result of the logistical challenges associated with transporting larger turbines toproiect sites. (USDOE 2011) There are several land based wind farms underconstruction or planned in Ohio. These wind farms will utilize wind turbines ranging from1.8 MW (Timber Ridge Wind Farm) to 2.0 MW (Blue Creek Wind Farm). (WAG 2011and TBM 2011)Alternatives that Meet System Page 7.2-6 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportFENOC reviewed several recent documents describing studies conducted by theNational Renewable Energy Laboratory (NREL) related to wind integration andtransmission studies for both land-based and offshore wind generating facilities (NREL2011. NREL 2010. NREL 2010a). Based on the findings in these documents, aland-based interconnected transmission system in the central and eastern United Statesis likely to be completed by 2024. For the sole purpose of this NEPA analysis, however,FENOC evaluates renewable energy alternatives as if an interconnected grid systemwould be available by 2017.FENOC also evaluated the potential for offshore wind generation and integrating thatpower into the transmission system. Although both Lake Erie and Lake Michigan havesignificant wind resources, no offshore wind turbines have been sited in freshwater,particularly a potable water source such as the Great Lakes. (USDOE 2011)Offshore wind power project and policy developments continued in 2010: however, todate no offshore projects have been installed in the United States and the emergence ofan offshore wind power market still faces many challenges. Nonetheless, interest existsin developing offshore wind energy in several parts of the country, with nine projectstotaling 2322 MW of unstated capacity factors primarily located in the Northeast andMid-Atlantic, though proposed projects also exist in the Great Lakes and Gulf of Mexico.(USDOE 2011) Many of these projects have advanced significantly in the permittingand development process, including three that have signed power purchaseagreements with terms and details that have been made public. Notably, the CapeWind project was granted approval by the Department of Interior in 2010; severalsignificant strides relating to offshore wind energy have been made recently in thefederal arena: and a variety of other recent project and state policy announcementsdemonstrate continued activity in the offshore wind energy sector. (USDOE 2011)In August 2009, Lake Erie Energy Development Corporation (LEEDCo) was created bythe Great Lakes Energy Development Task Force (GLEDTF), then developed andlaunched by NorTech Energy Enterprise, the Cleveland Foundation, City of Cleveland,Cuyahoga and Lorain Counties (Ohio). It was founded as a private, non-profit regionalcorporation to initially build wind turbines in Lake Erie, and eventually help stimulate anentire offshore freshwater wind industry. Initially LEEDCo plans to build and install a 20-30 megawatt (MW) wind energy pilot project seven miles offshore of downtownCleveland which would be the first offshore freshwater wind energy project in NorthAmerica. LEEDco then plans to use the initial project as a road map to develop thepermitting process and catalyze future offshore wind projects by commissioning the first20-to-30 MW, five-to-seven turbines by 2013, with a long-term vision of generating1000 MW of wind energy by 2020. (LEEDCo 2011)Despite the unlikely development of sufficient offshore wind generation as outlinedabove, FENOC evaluates-for the sole purpose of this NEPA analysis-wind energyI Alternatives that Meet System Page 7.2-7 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportfrom interconnected wind farms as if such energy was available by 2017. Therefore,FENOC evaluated the potential environmental impacts for offshore wind generation andintegrating that power into the transmission system as a replacement for Davis-Besse'srated electrical output.Solar FarmsElectric power generation from photovoltaic (PV) cells has been commerciallydemonstrated. However, because the sun only shines during the day, solar PV arrayscannot by themselves consistently Produce electricity. There is currently only oneoperational solar energy facility in Ohio greater than 10 MW-the 12-MWe WyandotSolar Farm in Upper Sandusky, OH (PSEG 2010). The 49.9 MWe Turning Point Solarproject near Cumberland, OH, is proiected to be completed in 2015 (AEP 2011).FENOC is not aware of other planned solar energy facilities greater than 10 MW in Ohiothat would be operational by 2017, and whose output is not already dedicated to anexisting commercial or industrial facility.A solar Proiect would have to be located where the proiect would produce economicalgeneration, and that location may be far removed from the nearest possible connectionto the transmission system. A location far removed from the power transmission gridmight require construction of new transmission lines to connect the solar farm to thedistribution system, and the question of who pays for the transmission upgrade would beat issue. Existing transmission infrastructure may need to be upgraded to handle theadditional supply. Soil conditions and the terrain must be suitable for the construction ofthe solar farms. Finally, the choice of a location may be limited by land use requlationsand the ability to obtain the required permits from local, regional, and national authorities.Although solar resources are limited in Ohio, FENOC evaluates-for the sole purpose ofthis NEPA analysis-solar energy combined with CAES, and combined withinterconnected wind farms and CAES, as alternatives to replace the rated electricaloutput of Davis-Besse by 2017.Compressed Air Energy StorageFENOC is presenting the following information about CAES technology as backgroundfor the discussion that follows about CAES combined with interconnected wind farms orsolar enerqy facilities.CAES can be linked with renewable energy by offering one way to supplement andback-up the electricity produced by intermittent resources such as wind and solar. Thisenergy storage method enhances the ability of these resources to provide the electricitythat customer's need, when they need it.I Alternatives that Meet SystemGenerating NeedsPage 7.2-8September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportHowever, CAES facilities are generally operated as peaking plants with energy placedinto storage during the less expensive, non-peak demand hours and generated from thestorage units during the higher-priced, peak demand hours. CAES involves usingcompressors powered by the generation source to pump air into a storage facility, suchas an underground cavern. During peak demand hours, the compressed air is used incombination with a heat source, such as natural gas, to drive turbines and generateelectricity. To generate electricity from CAES, natural gas usage is between one-thirdand one-half that needed to generate the same amount of electricity at a natural gasgenerating plant (USDOE 2009). Due to the cost differential between peak and non-peak hours and the reduction in the volume of natural gas used to generate a specificamount of power, a CAES facility can be an economically and environmentally attractivemethod of producing peaking power (RES 2005; PEI 2008).These economic benefits evaporate if the energy source used to pump air into thestorage facility is solar power, or wind power available during the day. Since solar is aresource mostly available during the onpeak daytime hours, storage offers little economicbenefit when evaluating solar (or daytime wind power) with CAES. FENOC is not awareof any existing CAES facilities that are combined solely with wind or solar power.The Iowa Stored Energy Park (ISEP) was proposed to be a 270 MW CAES facilityintegrated with a wind farm in Iowa. However, testing and analysis of the site geologyconcluded that the ability to store the air underground at the ISEP site near DallasCenter, Iowa was unfeasible. (ISEP 2011)Two CAES facilities combined with natural gas power plants, a 110-MW facility inAlabama and a 290-MW plant in Germany, have been built and are in operation (PEI2008). A CAES facility powered with energy from generation facilities already on thepower grid is proposed for Norton, Ohio. This facility, which is still in the projectdevelopment stage, is planned to eventually-i.e., after 2017-provide 2700 MW ofpeaking power generation (PEI 2008). The Norton CAES project is somewhat differentfrom the other CAES proiects in that a pre-existing mine on a brownfield site would beutilized. The size and the mining engineered construction of the pre-existing mineallows a much greater Planned capacity for the Norton facility as compared to otherexisting or proposed CAES proiects.Norton Energy StorageIn 2009, FirstEnergy Generation Corp., a subsidiary of FirstEnergy Corp., purchased therights to develop the Norton Energy Storage (NES) facility. The facility is located on a92-acre site in Norton, Ohio. The compressed air would be stored in a 600-acreunderground cavern, formerly operated as a limestone mine, which is ideal for energystorage technology. The facility would generate electricity during on-peak andintermediate periods, which would enable the more efficient operation of large, base-I Alternatives that Meet SystemGenerating NeedsPage 7.2-9September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportload power plants. FirstEnergy is currently developing the NES facility and it would beconstructed in phases. The initial phase is designed to produce 268 MW of generation,220 MW of compression, and 373 hours of storage using two 134 MW generators.FirstEnergy estimates that up to four units or 536 MW of generation could be online by2017. The existing air permit for the NES facility authorizes FirstEnergy GenerationCorp to expand the facility to a capacity of 804 MW (see Table 7.2-3). (NES 2010) ThisProject has two maior components: the above-ground equipment and the subsurfaceabandoned limestone mine used to store compressed air. The size of the cavern couldeventually allow the project to provide up to 2700 MW of generation if the current airPermit could be modified.The NES facility would include two power generation units designed specifically for theCAES application. Each unit would consist of an air compressor, a motor, an expander,an associated combustor and a generator. The facility would be designed to operate onnatural gas only: no fuel oil would be combusted in the turbines or in-line burners. Themaior ancillary support eguipment would consist of an emergency generator, a backupdiesel fire pump, and wet cooling towers to cool compressor air to be injected intostorage and provide other equipment cooling. Other support equipment would includecooling water treatment systems, acid/caustic or neutralization tanks, instrument aircompressors, electric driven fuel compressors, sumps, and oil/water separators.Available Alternatives for Renewable Energy Generation in Combination withEnergy StorageThe potential for using renewable power sources as an alternative to license renewalcan be enhanced if the generation source is combined with an energy storagetechnoloqy, thus increasing the availability, reliability, and predictability of the delivery ofpower. The two renewable power generation sources evaluated in this ER areinterconnected wind farms and photovoltaic solar facilities.The theory behind the combination of renewable power generation with energy storageis that when the generation capacity is available, the amount of power produced could,at times, exceed the demand for power at that time. Excess energy could be stored andreturned later to the electrical grid when the renewable power generation resource iseither not available or is available at a diminished level that is insufficient to satisfy thedemand for power.Therefore, in order for this combination of technologies to function, the renewableenergy source would have to be sized larger than the base-load power level in this casefor Davis-Besse, 910 MW. The need to have generation capacity greater thanbase-load requirements in order to place energy into storage would cause greaterenvironmental impacts than a generation source rated at the base-load value alone.For example, a solar or wind generation source assumed to be available for 12 hoursI Alternatives that Meet System Page 7.2-10 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportevery day, and a CAES facility assumed to be available to -generate electricity theremaining 12 hours in the day, would require that generation source to be rated at, andconsistently produce 1820 MW in order to provide 24-hours of continuous electricity(i.e., 12 hours to provide 910 MW of generation onto the grid, and the same 12 hours toprovide 910 MW to recharge the CAES facility, so that the CAES facility could feed thegrid the remainder of the day).As explained in Section 7.2.1. FENOC evaluates-for the sole purpose of this NEPAanalysis-renewable energy sources combined with energy storage as an alternative toreplace the rated electrical output of Davis-Besse.Wind Energy Generation Combined with CAESAs of 2011. there is currently 11 MWe of wind generation in Ohio with another 406 MWeunder construction. (AWEA 2011) However, Ohio has a potential wind generationcapacity of nearly 55,000 MW according to the NREL (AWEA 2011 and NREL 2011a),which at a 30% capacity factor would be more than sufficient to provide power tooperate a CAES facility. The 30% capacity factor is derived from PJM Interconnection(a regional transmission organization) and the U.S. Department of Energy (USDOE)(PJM 2011 and USDOE 2011. The environmental impacts of developing this type ofgeneration alternative are evaluated in Section 7.3.3.For this combination, FENOC evaluated wind energy generating electricity for both 910MW to replace Davis-Besse's rated output and 910 MW of storage capacity, for a totalof 1820 MWe. Sufficient energy must be put into storage when the wind resources areavailable to account for the lack of power generation capabilities for the periods of timewhen adequate wind resources are unavailable. Under this alternative, natural gaswould be needed to recover the energy captured in the CAES process, but would not beused as a source of supplemental power generation if wind generation or generationfrom the storage facility is not available for extended periods of time.Photovoltaic Power Combined with CAESAs stated previously, there is currently only one operational solar energy facility in Ohiogreater than 10 MW: the 12-MWe Wyandot Solar Farm in Upper Sandusky, OH. (PSEG2010) The 49.9-MWe Turning Point Solar proiect near Cumberland, OHR is proiected tobe completed in 2015. (AEP 2011) FENOC is not aware of other planned solar energyfacilities greater than 10 MW in Ohio that would be operational by 2017, and whoseoutput is not already dedicated to an existing commercial or industrial facility. As withwind, FENOC evaluated solar farms as if they were interconnected with CAES toprovide electricitv to the arid.I Alternatives that Meet SystemGenerating NeedsPage 7.2-11September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportCombinations of Wind and Solar with CAESAs referenced above, approximately 1820 MWe of base-load power would be requiredfrom renewable energy generation plus storage to account for the lack of powergeneration capabilities for the periods of time when adequate wind and solar resourcesare unavailable.FENOC evaluates-for the sole purpose of this NEPA analysis-the following acombined alternative to replace the rated electrical output of Davis-Besse by 2017:sufficient interconnected wind farms and solar (PV) facilities available with high reliability,and connected to an operating CAES facility: an operating CAES facility expanded to acapacity similar to Davis-Besse: and an interconnected grid system. The potentialenvironmental impacts related to this scenario are presented in Section 7.3.3.3.7.2.2 ALTERNATIVES CONSIDERED AS NOT REASONABLEThe following alternatives were considered as not reasonable replacement base-loadpower generation for one or more reasons as listed in Section 7.2.2.1 andSection 7.2.2.2. Although several of the alternatives could be considered incombination for replacement power generation at multiple sites, they do not generallyprovide base-load generation, and would entail greater environmental impacts.7.2.2.1 Alternatives Not Requiring New Generating CapacityThis section discusses the economic and technical feasibility of supplying replacementenergy without constructing new base-load generating capacity. Specific alternativesinclude:* Conservation measures (including implementing demand side management (DSM)actions);* Delayed retirement of existing non-nuclear plants; and* Purchased power from other utilities equivalent to the output of Davis-Besse (i.e.,eliminating the need for license renewal).Conservation ProgramsThere is a variety of conservation technologies (e.g., DSM) that could be considered aspotential alternatives to generating electricity at Davis-Besse. Examples include:* Conservation Programs-homeowner agreements to limit energy consumption;educational programs that encourage the wise use of electricity.I Alternatives that Meet System Page 7.2-12 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report* Energy Efficiency Programs- discounted residential rates for homes that meetspecific energy efficiency standards; programs providing residential energy auditsand encouraging efficiency upgrades; incentive programs used to encouragecustomers to replace older inefficient appliances or equipment with newer versionsthat are more efficient.* Load Management Programs -programs that encourage customers to switch loadto customer-owned standby generators during periods of peak demand; programsthat encourage customers to allow a portion of their load to be interrupted duringperiods of peak demand.On a national basis, DSM has shown great potential in reducing peak demand(maximum power requirement of a system at a given time). In 2008, a peak loadreduction of 32,741 MWe was achieved nationally, which is an increase of 8.2% from2007; however, since these DSM costs increased by 47.4%. DSM costs can varysignificantly from year to year because of business cycle fluctuations and regulatorychanges. Since costs are reported as they occur, while program effects may appear infuture years, DSM costs and effects may not always show a direct relationship. Since2003, nominal DSM expenditures have increased at 22.9% average annual growth rate.During the same period, actual peak load reductions have grown at a 6.2% averageannual rate from, 22,904 MW to 32,741 MW (EIA 2010, Page 9).In Ohio, as part of Senate Bill 221, utilities must implement energy efficiency programsthat, beginning in 2009, achieve energy savings of at least 0.3% of the utility's three-year average annual kilowatt-hour (kWh) sales, with energy savings increasing to22.5% by the end of 2025. Peak demand reductions of 1% in 2009 and increasing to7.75% by the end of 2018 are also required. (FirstEnergy 2009a, Page 100) However,since these DSM-induced load reductions typically are considered in load forecasts, thereductions do not offset the projected power demands that are expected to be suppliedwith the power generated by Davis-Besse.Although FENOC believes that energy generation savings can increase from DSMpractices, it would be unrealistic to increase those energy savings to completely andconsistently replace the Davis-Besse generating capability. The variability in associatedcosts also makes DSM a less desirable option. Consequently, FENOC does not seeDSM as a practicable offset for the base-load capacity of Davis-Besse.Delayed RetirementExtending the lives of existing non-nuclear generating plants beyond the time they wereoriginally scheduled to be retired, as described in the GElS (NRC 1996, Section 8.3.13),does not represent a realistic option with respect to FirstEnergy's generating assets. ,_ _Deleted: AJso, FENOC is notknowledgeable of retirement plans ofother regional electric powersuppliers. Even without retiring anygenerating units, FirstEnergy expectsto require additional capacity in thenear future. Therefore, even if asubstantial portion of its capacitywere scheduled for retirement andcould be delayed, some of thedelayed retirement would be neededjust to meet load growth.Alternatives that Meet SystemGenerating NeedsPage 7.2-13 September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportApproximately 56% of FirstEnergy's generating capacity consists of coal-fired plantswhich, due to a lower cost of generation, are used at capacity factors higher than otherfossil-fuel generating units (FirstEnergy 2008b). Virtually all of FirstEnergy's non-nuclear base-load generating capability is from coal firing. These coal-fired plants weredeveloped in the 1980s or earlier and represent the only plants in FirstEnergy's portfoliothat would have any potential for continued operation to replace the base-loadgeneration represented by Davis-Besse. However, older plants that do becomecandidates for retirement generally represent less efficient generation and pollutioncontrol technologies than are available in more modern plants, and continued operationtypically would require substantial upgrades to be economically competitive and meetapplicable environmental standards. In many cases, it is unlikely that such upgradeswould be economically viable. FENOC believes that the environmental impacts ofimplementing such upgrades and operating the upgraded plants are bounded by theassessments presented in Section 7.3 for the gas-fired and coal-fired alternatives.For these reasons, the delayed retirement of non-nuclear generating units is notconsidered by FENOC as a reasonable alternative to the renewal of Davis-Besse'slicense.Purchased PowerEach of the states (Ohio, Pennsylvania, and New Jersey) in which FirstEnergy servesload have undertaken electric industry restructuring initiatives that promote competitionin retail energy markets by allowing participation of non-utility suppliers. Retailcustomers historically served by the regulated operating subsidiaries of FirstEnergy nowhave the option to choose between FirstEnergy-affiliated suppliers and other state-qualified energy suppliers. (FENOC 2007, Section 7.2.3.2)In theory, purchased power is a feasible alternative to Davis-Besse license renewal.There is no assurance, however, that sufficient capacity or energy would be availableduring the entire license renewal time frame to replace the approximately 910 MWe ofbase-load generation. In addition, even if power to replace Davis-Besse capacity wereto be purchased, FENOC assumes that the generating technology used to produce thepurchased power would be one of those described in the GELS. Thus, theenvironmental impacts of purchased power would still occur, but would be locatedelsewhere within the region.As a result, FENOC has determined that purchased power would not be a reasonablealternative to replace power lost in the event the Davis-Besse operating license is notrenewed.Alternatives that Meet SystemGenerating NeedsPage 7.2-14September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report7.2.2.2 Alternatives Requiring New Generating CapacityThe following conventional power plant types are evaluated in this section as potentialalternatives to license renewal:* New Nuclear Reactor* Petroleum Liquids (Oil)In addition, with the passage of Ohio's Senate Bill 221 in 2008, at least 25% ofelectricity supply for retail customers must come from renewable and advanced energyresources by 2025 OHPUCO 2009, Pages 3 and 4). Accordingly, the followingalternative energy sources are evaluated.* HydropowerS ,S* olaar .- -{ Deleted: <#>Windl* Geothermal* Biomass (Wood Waste)* Municipal Solid Waste* Other Biomass-Derived Fuels (Energy Crops)* Fuel CellsCriteria used to determine if the potential energy alternatives represent a reasonablealternative include whether the alternative is developed and proven, can providegeneration of approximately 910 MWe of electricity as a base-load supply, iseconomically feasible, and does not impact the environment more than Davis-Besse.New Nuclear ReactorIncreased interest in the development of advanced reactor technology has beenexpressed by members of both industry and government. With energy demandsforecasted to increase and public opposition to new carbon-fueled power plants, somecompanies are pursuing permits and licenses to build and operate new nuclear reactorsto meet the country's future energy needs. As of June 2010, for example, 18applications, for 28 units, for combined licenses have been submitted to the NRC forreview (NRC 2010).Nonetheless, there is ongoing uncertainty with respect to future electric demand due tothe potential impacts of policy changes that could be enacted to limit or reducegreenhouse gas emissions. The downturn in the world economy also has had asignificant impact on energy demand as well. The recovery of the world's financialmarkets is especially important for the energy supply outlook, because the capital-intensive nature of most large energy projects makes access to financing a criticalnecessity. (EIA 2010, Pages 5). Moreover, the economics of new nuclear plantsI Alternatives that Meet System Page 7.2-15 September 2011Generating Needs Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportremain uncertain with escalating fuel and construction costs emerging as forces whichcould affect this option.In consideration of the extended schedule for construction of a new nuclear reactor,access to capital, and the schedule for the new reactor licensing process, constructionof a new nuclear reactor at the Davis-Besse site or at an alternative site is not feasibleprior to the period of extended operation for Davis-Besse, i.e., in this case, 2017.Therefore, a new nuclear reactor is not considered a reasonable alternative to renewalof Davis-Besse's operating license..Petroleum Liquids (Oil)Oil-fired generation has experienced a significant decline since the early 1970s.Increases in world oil prices have forced utilities to use less expensive fuels (NRC 1996,Section 8.3.11). From 2002 to 2008, for example, the average cost of petroleum forpower generation increased by more than a factor of three (EIA 2010, Table 3.5).This high cost of oil has prompted a steady decline in its use for electricity generation.Within Ohio, for example, oil-fired units produce only 0.2% of power generation(NEI 2008). Increasing domestic concerns over oil security also will intensify the moveaway from oil-fired electricity generation.Therefore, FENOC does not consider oil-fired generation a viable alternative to renewalof Davis-Besse's operating license.HydropowerConsidering the FirstEnergy transmission and distribution territory, Ohio andPennsylvania have a combined potential for 1,758 MWe of additional undevelopedhydroelectric capacity, with Ohio contributing 57 MWe (INEEL 1998, Table 4). Thus,hydropower is a feasible alternative to Davis-Besse license renewal in theory.However, as noted in the GELS, hydropower's percentage of United States generatingcapacity is expected to decline because the facilities have become difficult to site as aresult of public concern about flooding, destruction of natural habitat, and alteration ofnatural river courses (NRC 1996, Section 8.3.4). For example, the GElS estimated thatland requirements for hydroelectric power are approximately 1 million acres per1,000 MWe. Replacement of the Davis-Besse generating capacity would thereforerequire flooding a substantial amount of land (910,000 acres). Consequently, even ifthe capacity for development were available in Ohio-Pennsylvania, there would be largeland-use and related environmental and ecological resource impacts associated withsiting hydroelectric facilities large enough to replace Davis-Besse.Alternatives that Meet SystemGenerating NeedsPage 7.2-16September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportAs a result, developing a hydropower base-load capacity of approximately 910 MWe isnot considered by FENOC to be a reasonable alternative to renewal of Davis-Besse'soperating license.Solar Power .........................................................,Solar power technologies, both thermal and photovoltaic (PV). have been commercially/demonstrated. However, because the sun only shines during the day, solar arrayscannot, by themselves, provide consistent electrical output. Therefore, solar arraysalone are not considered in this ER as a reasonable alternative to the license renewal ofDavis-Besse. Solar energy in combination with interconnected wind farms and CAES isdiscussed in Section 7.2.1.3.Geothermal EnergyGeothermal energy has an average capacity factor of 90 percent and can be used forbase-load power where available (NRC 2009b Section 8.2.5.5). However, geothermalelectric generation is limited by the geographical availability of geothermal resources.As illustrated by Figure 8.4 in the GELS, no feasible eastern location for geothermalcapacity exists to serve as an alternative to Davis-Besse (NRC 1996, Section 8.3.5). Asa result, FENOC does not consider geothermal energy to be a reasonable alternative torenewal of the Davis-Besse operating license.Biomass EnergyBiomass is any organic material made from plants or animals. Agricultural and woodwastes such as forestry residues, particularly paper mill residues, are the most commonbiomass resources used for generating electricity. Regionally, eastern Ohio and mostof Pennsylvania provide the largest biomass resources (EERE 2009a, b). The costs ofthese fuels, however, are highly variable and very site specific (NRC 1996,Section 8.3.6).Most biomass plants use direct-fired systems by burning biomass feedstocks to producesteam directly for conventional steam turbine conversion technology. Although thetechnology is relatively simple to operate, it is expensive and inefficient. Conversionefficiencies of wood-fired power plants are typically 20-25%, with capacity factors ofaround 70-80%. As a result, biomass plants at modest scales (550 MWe) makeeconomic sense if there is a readily available supply of low-cost wood wastes andresidues nearby so that feedstock delivery costs are minimal. (NRC 1996,Section 8.3.6)The construction impacts of a wood-fired plant would be similar to those for a coal-firedI plant, although most facilities using wood waste for fuel would be built on smallerscales. Like coal-fired plants, biomass and wood-waste plants require large areas forDeleted: Wind Power¶JAreas suitable for wind energyapplications must be wind-powerClass 3 or higher (NREL 1986,Chapter 1). Coastal regions alongLake Erie in northwestern Ohio havean estimated wind power of Class 3,increasing to Class 5 over offshoreareas (NREL 1986, Chapter 3) andsome Class 6 areas mid-lake(USDOE 2009a). The rest of thestate, however, is devoid of Class 3or higher wind-power areas.Pennsylvania is mostly a wind powerClass 1 region, although some areas,particularly along ridgelines, mayprovide wind classes ranging from 4to 6. West Virginia is also mostly awind power Class 1 region, with Class2 and higher resources alonghighlands and ridges in the east-central part of the state. The totalwind generation capacity for thethree-state region in 2008 was 698MWe. (USDOE 2009a) ¶Thus, wind power in coastal Ohioalong Lake Erie and along ridgelinesin Pennsylvania and West Virginia isa feasible alternative to Davis-Besselicense renewal in theory. However,wind power by itself is not suitable forlarge base-load capacity. Asdiscussed in the GELS, wind Deleted: Solar power technologies,bothphotovoltaic (PV) and thermal,depend on the availability andstrength of sunlight. As such, it is anintermittent source of energy,requiring energy storage or asupplemental power source toprovide electric power at night. Solarresource availability in Ohio, westernPennsylvania, and northern WestVirginia is low compared to otherparts of the United States. The three-state region, for example, has about3.3 kWh per square meter per day of,solar radiation, which is less than halfof that available in the southwesternUnited States (NRC 1996, Figure8.2). ¶The land requirement for solartechnology is large. As noted in theGElS, it requires 14 to 35 acres forevery 1 MWe generated, dependingon the solar technology (NRC 1996,Sections 8.3.2 and 8.3.3). At aminimum, it would requireapproximately 12,740 acres toreplace the 910 MWe produced byDavis-Besse. In addition, althoughsolar technologies produce no airpollution, little or no noise, andrequire no transportable fuels,Alternatives that Meet SystemGenerating NeedsPage 7.2-17 September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportfuel storage and processing. They also create impacts to land and water resources,primarily associated with soil disturbance and runoff, in addition to air emissions whichmust be managed. However, unlike coal-fired plants, biomass and wood-waste plantshave very low levels of sulfur oxide emissions. (NRC 1996, Section 8.3.6),Que to the relatively small scale of potential projescsts----------- -ecuring------long-term fuel supplies, biomass is not considered by FENOC to be a reasonablealternative to replace Davis-Besse's base-load power generation.Municipal Solid WasteMunicipal solid waste (MSW) facilities that convert waste to energy use technologycomparable to steam-turbine technology for wood waste plants, although the capitalcosts are greater due to the need for specialized separation and handling equipment(NRC 1996, Section 8.3.7). The decision to burn MSW for energy is typically made dueto insufficient landfill space, rather than energy considerations.There are 89 operational MSW energy conversion plants in the United States(USEPA 2009a), none of which were located in Ohio as of 2007 (WTE 2007). Theseplants generate approximately 2,500 MWe, or about 0.3% of total national powergeneration (USEPA 2009a). At an average capacity of about 28 MWe, numerousMSW-fired power plants would be needed to replace the base-load capacity ofDavis-Besse.Construction impacts for a waste-to-energy plant are estimated to be similar to those fora coal-fired plant. Air emissions are potentially harmful. Increased construction costs fornew plants and economic factors (i.e., strict regulations and public opposition) may limitthe growth of MSW energy generation (NRC 1996, Section 8.3.7; USEPA 2009a).For reasons stated, MSW is not considered by FENOC to be a reasonable alternative torenewal of Davis-Besse's operating license.Other Biomass-Derived FuelsIn addition to biomass energy such as wood and municipal solid-waste fuels, there areother concepts for biomass-fired electric generators, including direct burning of energycrops, conversion to liquid biofuels, and biomass gasification. The GElS indicated thatnone of these technologies had progressed to the point of being competitive on a largescale or of being reliable enough to replace a base-load plant (NRC 1996,Section 8.3.8). After recently re-evaluating current technologies, the NRC staff believesother biomass-fired alternatives are still unable to reliably replace base-load capacity(NRC 2009b, Section 8.2.5.8). For this reason, FENOC does not consider biomass-derived fuels to be a reasonable alternative to renewal of Davis-Besse's operatinglicense.Deleted: FirstEnergy is retrofittingunits 4 and 5 of the R.E. Burger plantin Shadyside, Ohio, for biomasscapability. When completed, the unitswill be one of the largest biomassfacilities in the United States capableof producing up to 312 MWe(FirstEnergy 2009b). Nevertheless,due to the relatively small scale ofotherAlternatives that Meet SystemGenerating NeedsPage 7.2-18 September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportFuel CellsFuel cells are electrochemical devices that generate electricity without combustion andwithout water and air pollution. Fuel cells began supplying electric power for the spaceprogram in the 1960s. Today, they are being developed for more commercialapplications. The U.S. Department of Energy (USDOE) is currently partnering withseveral fuel cell manufacturers to develop more practical and affordable designs for thestationary power generation sector. If successful, fuel cell power generation shouldprove to be efficient, reliable, and virtually pollution free. At present, progress has beenslow and costs are high. The most widely marketed fuel cell is currently about $4,500per kilowatt (kW) compared to $800 to $1,500 per kW for a diesel generator and about$400 per kW or less for a natural gas turbine. By the end of this decade, the USDOEgoal is to reduce costs to as low as $400 per kW. (USDOE 2009b)However, fuel cells presently are not economically or technologically competitive withother alternatives for base-load capacity. Therefore, FENOC does not consider fuelcells to be a reasonable alternative to renewal of Davis-Besse's operating license.----------------------------------------------------Deleted: Combination of Alternatives¶Individual evaluation of renewableand advanced energy resourcesshows that, by themselves, theseenergy resources are not consideredby FENOC to be reasonablealternatives to renewal ofDavis-Besse's operating license.When considered in variouscombinations with generationequivalent to that of Davis-Besse,these same renewable and advancedenergy resources still fail to bereasonable alternatives to renewal ofDavis-Besse's operating license.¶For example, consider a mix of 25percent of renewable and advancedenergy resources, such as wind,hydroelectric, geothermal, solar, andbiomass, with 75 percent natural gasgeneration to replace the baseload908 MWe of the Davis-Besse plant.This mix of energy resources wouldresult in an increased uncertainty inenergy output due to the fluctuation ofwind and solar resources. Theenvironmental impacts associatedwith the large amount of land requiredfor siting the various resources wouldlikely exceed those associated withcontinued operation of Davis-Besse.And, the air quality impacts ofoperation of the natural gas plantgreatly exceed those associated withcontinued operation of Davis-Besse.Therefore, FENOC believes thatvarious combinations of renewableand advanced energy resources withgeneration equivalent to that ofDavis-Besse are not reasonablealternatives to renewal ofDavis-Besse's operating license.¶Alternatives that Meet SystemGenerating NeedsPage 7.2-19 September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 7.2-1 Coal-Fired Alternative Emission Control CharacteristicsCharacteristic BasisNet capacity = 910 MW Equivalent to Davis-Besse.Capacity factor = 80% From FENOC 2007, Table 7.2-2Firing mode: subcritical, tangential, dry-bottom Widely demonstrated, reliable, economical;pulverized coal tangential firing minimizes NOx emissions(FENOC 2007, Table 7.2-2)Fuel type = bituminous coal Type used in FirstEnergy Ohio River plants(FENOC 2007, Table 7.2-2)Fuel heating value = 12,285 Btu/Ib FirstEnergy Bruce Mansfield Plant average(FENOC 2007, Table 7.2-2)Heat rate = 9,800 Btu/kWh at full load FirstEnergy experience (FENOC 2007, Table 7.2-2)Fuel sulfur content = 3.52 wt% ; 2.86 lb/MMBtu FirstEnergy Bruce Mansfield Plant average(FENOC 2007, Table 7.2-2)Fuel ash content = 11.88 wt% FirstEnergy Bruce Mansfield Plant average(FENOC 2007, Table 7.2-2)Uncontrolled SOx emissions = 130 lb/ton coal USEPA estimate calculated as 38 x wt% sulfur incoal (FENOC 2007, Table 7.2-2)Uncontrolled NOx emissions = 10 lb/ton coal USEPA estimate (FENOC 2007, Table 7.2-2)Uncontrolled CO emission = 0.5 lb/ton coal USEPA estimate (FENOC 2007, Table 7.2-2)Uncontrolled PM emission = 120 lb/ton coal USEPA estimate calculated as 10 x wt% ash in coal(FENOC 2007, Table 7.2-2)Uncontrolled PM1o emission = 27 lb/ton coal USEPA estimate calculated as 2.3 x wt% of ash incoal (FENOC 2007, Table 7.2-2)C02 emissions = 6,000 lb/ton Approximate average for bituminous coalcombustion (FENOC 2007, Table 7.2-2)SOx control = wet limestone flue gas Best available technology for minimizing SOxdesulphurization (95% removal) emissions (FENOC 2007, Table 7.2-2)NOX control = low NOX burners, overfire air, Best available technology for minimizing NOxselective catalytic reduction (95% reduction) emissions (FENOC 2007, Table 7.2-2)Particulate control = fabric filters Best available technology for minimizing particulate(99.9% removal) emissions (FENOC 2007, Table 7.2-2)Btu = British thermal unit MW = megawattCO z carbon monoxide NOx = nitrogen oxidesCO, z carbon dioxide PM = particulate matterft cubic feet PMIo = PM with diameter less than 10 micronskWh kilowatt-hour SOx = sulfur oxideslb = pound USEPA = U.S. Environmental Protection AgencyMMBtu million Btu wt% = percent by weightAlternatives that Meet SystemGenerating NeedsPage 7.2-20September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 7.2-2: Gas-Fired Alternative Emission Control CharacteristicsCharacteristic BasisNet capacity = 910 MW Equivalent to Davis-Besse.Capacity factor = 80% From FENOC 2007, Table 7.2-1Fuel type = natural gas AssumedHeat rate = 6,500 Btu/kWh FENOC Estimate (FENOC 2007, Table 7.2-1)Fuel heating value = 1,025 Btu/ft3 From FENOC 2007, Table 7.2-1Fuel sulfur content = 0.2 grains/100 scf From FENOC 2007, Table 7.2-1(0.00068 wt%)SO2 emissions = 0.00064 lb/MMBtu USEPA estimate for natural gas-fired turbines(0.94 x wt% sulfur in fuel) (FENOC 2007, Table 7.2-1)NOx emissions (assuming dry low-NOx USEPA estimate for best available NOx combustioncombustors) = 0.099 lb/MMBtu control (FENOC 2007, Table 7.2-1)NOx post-combustion control: selective USEPA estimate for best available NOx post-catalytic reduction (90% reduction) combustion control (FENOC 2007, Table 7.2-1)CO emissions (assuming dry low-NOx USEPA estimate (FENOC 2007, Table 7.2-1)combustors) = 0.015 lb/MMBtuPM emissions (all PMjo) = 0.0019 lb/MMBtu USEPA estimate (FENOC 2007, Table 7.2-1)C02 emissions = 110 lb/MMBtu USEPA estimate (FENOC 2007, Table 7.2-1)Btu = British thermal unit MW = megawattCO = carbon monoxide NOx = nitrogen oxidesCO, = carbon dioxide PM = particulate matterft = cubic feet PMIo = PM with diameter less than 10 micronskWh = kilowatt-hour scf = standard cubic feetlb = pound SOx = sulfur oxidesMMBtu = million Btu USEPA = U.S. Environmental Protection Agencywt% = percent by weightAlternatives that Meet SystemGenerating NeedsPage 7.2-21September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 7.2-3: CAES Alternative Emission Control CharacteristicsCharacteristic BasisSix trains at 134 MW per trainNet capacity = 804 MW (maximum authorized under existing air permit,although only 536 MW could be online by 2017)Capacity factor = 80% Within typical range of base-load plant: results inapproximate annual output near that of Davis-Besse.Fuel type = natural gas AssumedHeat rate (HHV) = 4,395 Btu/kWh From OEPA Air Permit P01 06714: Norton CAESFuel heating value = 1,025 Btu/ft3 From FENOC 2007, Table 7.2-1Fuel sulfur content = 2 grains/100 scf From OEPA Air Permit P0106714: Norton CAES(0.0066 wt%)FASO9 emissions = 0.006 lb/MMBtu From OEPA Air Permit P0106714: Norton CAESNOx emissions (assuming water injection &,selective catalytic reduction) = 3.0 ppmvd (5 From EPA Air Permit P01 06714 Norton CAES15% oxygen and 43.08 lbs/hr(6 units at 7.18 lbs/hr each)CO emissions (assuming dry low-NOxCombustors & CO catalytic oxidation) =§ ppmvd 0) 15% oxygen and 43.68 lbs/hr From OEPA Air Permit P0106714: Norton CAES(6 units at 7.28 lbs/hr each)PM emissions (all PM10) = 0.0066 Ib/MMBtuPM eissons(al PMo) =0.066 b/M~tu From OEPA Air Permit P01 06714m Norton CAESand 23.34 lbs/hr (6 units at 3.89 lbs/hr each).CO emissions = 110 lb/MMBtu USEPA estimate (FENOC 2007. Table 7.2-1)VOC emissions =13.2 lbs/hr From OEPA Air Permit P0106714: Norton CAES(6 units at 2.2 lbs/hr each)Btu = British thermal unit MW = megawattCO = carbon monoxide NON = nitrogen oxidesCO = carbon dioxide OEPA = Ohio Environmental Protection AgencyCAES = compressed air energy storage PM = particulate matterft, = cubic feet PM10 = PM with diameter less than 10 micronsHHV = higher heating value ppmvd = parts per million volumetric drykWh -kilowatt-hour scf = standard cubic feetlb = pound SOx = sulfur oxideslbs/hr = pounds per hour USEPA = U.S. Environmental Protection AgencyMMBtu = million Btu wt% = percent by weightVOC = volatile organic compoundAlternatives that Meet SystemGenerating NeedsPage 7.2-22September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report7.3 ENVIRONMENTAL IMPACTS OF ALTERNATIVESEnvironmental impacts are evaluated in this section for the coal- and gas-firedgeneration alternatives determined by FENOC to be reasonable in Section 7.2.1compared to renewal of Davis-Besse's operating license.The impacts are characterized as being SMALL, MODERATE, or LARGE. Thedefinitions of these impact descriptions are the same as presented in the introduction toChapter 4, which in turn are consistent with the criteria established in 10 CFR Part 51,Appendix B to Subpart A, Table B-I, Footnote 3. FENOC believes the environmentalimpacts associated with the construction and operation of new generating capacity at agreenfield site would exceed those for the same type plants located at Davis-Besse orat another existing disturbed site, i.e., brownfield site.The new generating plants addressed in Section 7.2.1 would not be constructed only tooperate for the period of extended operation of Davis-Besse. Therefore, FENOCassumes for this analysis a typical design life of 40 years for the coal-fired plant,30 years for the combined-cycle natural gas-fired plant, and considers impactsassociated with operation for the entire design life of the units in this analysis. The lifespan of a wind turbine is 20 years (REN 2005): however, turbines can be replaced andthe tower would likely be in service for at least 40 years. The life span of a solar plant isestimated to be at least 30 years (TEP 2005).Chapter 8 presents a summary comparison of the environmental impacts of licenserenewal and the alternatives discussed in this section.7.3.1 COAL-FIRED GENERATIONThis section presents the impact evaluation for the representative coal-fired generationalternative. As discussed in Section 7.2.1.1, FENOC assumed for purposes of thisanalysis that the representative plant would be located at a greenfield or (preferably)brownfield site along commercially navigable waterway or existing rail way. Thisassumption is a result of the space limitation at the Davis-Besse site.Land UseLand area requirements for a coal-fired plant of similar capacity to Davis-Besse, forexample, would be approximately 1.7 acres per MWe (NRC 1996, Table 8.1), or1,547 acres for a 910 MWe plant. This amount of land use will include plant structuresand associated infrastructure. Additional acres would be needed offsite for transmissionlines and possibly rail lines, depending on the location of the site relative to the nearestinter-tie connection or rail spur. This acreage could amount to a considerable loss ofnatural habitat or agricultural land for the plant site alone dependent upon whether aI Environmental Impacts of AlternativesPage 7.3-1September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportgreenfield or brownfield site was used, excluding that required for mining and other fuel-cycle impacts. Some portion of the impacts could be mitigated by constructing newtransmission line in existing rights-of-way (ROW) to as great an extent as possible.Land-use changes also would occur offsite in an undetermined coal-mining area tosupply coal for the plant. For example, the GElS estimated that approximately 22 acresof land per MWe would be affected for mining the coal and disposing of the waste tosupport a coal-fired plant during its operational life (NRC 1996, Section 8.3.9).Therefore, for the 910 MWe plant used in this analysis, approximately 20,020 acres ofland would be needed. Partially offsetting this offsite land use would be the eliminationof the need for uranium mining and processing to supply fuel for Davis-Besse. TheGElS estimated that approximately one acre per MWe would be affected for mining andprocessing the uranium during the operating life of a nuclear power plant (NRC 1996,Section 8.3.12). Therefore, for Davis-Besse uranium mining and processing,approximately 910 acres of land would be required, resulting in offsite mining net landuse of 19,110 acres for the representative coal-fired generation alternative.In consideration of the above, FENOC considers that land use impacts associated witha coal-fired plant at an alternate site would depend on the location of the plant and beMODERATE to LARGE.Water Use and Quality -Surface WaterConstruction-phase impacts on water quality of greatest potential concern includeerosion and sedimentation associated with land clearing and grading operations at theplant site and waste disposal site, and suspension of bottom sediments duringconstruction of cooling water intake and discharge structures and facilities for bargedelivery of coal and limestone. However, land clearing and grading activities would besubject to stormwater protections in accordance with the NPDES program, and work inwaterways would be regulated by the USACE under the CWA Section 404 andSection 10 of the Rivers and Harbors Act. These activities would also be subject tocorresponding state and local regulatory controls, as applicable. In addition, theseadverse effects would be localized and temporary. As a result, FENOC considers thatimpacts on surface water quality associated with construction of the representative plantat an alternative site would be SMALL.FENOC expects that potential impacts on water quality and use associated withoperation of the representative plant would be similar to impacts associated withDavis-Besse operation. Cooling water and other wastewater discharges would beregulated by an NPDES permit, regardless of location. Cooling water intake,evaporative losses, and discharge flows for the representative coal-fired plant, assumedto use a closed-cycle cooling system, would be similar to or lower than those resultingfrom Davis-Besse operation (see Chapter 4). As a result, FENOC considers thatI Environmental Impacts of AlternativesPage 7.3-2September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportimpacts on surface water quality associated with operation of the representative plant atan alternative site would be SMALL.In view of the environmental review afforded under OPSB rules or a similar program,FENOC considers the impacts of surface water use and quality from construction andoperation of the representative plant at an alternative site would be SMALL.Water Use and Quality -Ground WaterImpacts will depend on whether the plant will use ground water for any purposes, aswell as the characteristics of local aquifers. Effects to ground water quality can alsodepend on waste-management and coal-storage practices, although proper disposaland material handling should reduce the likelihood of an effect, as would recycling agreater percentage of waste products. Regardless of location, FENOC believes it highlyunlikely that a coal-fired power plant at an alternate site will rely on ground water forplant cooling, and that ground water and waste-management regulations will limitimpacts to SMALL.Air QualityAir quality impacts of coal-fired generation differ considerably from those of nucleargeneration. A coal-fired plant emits sulfur oxides (SOx), nitrogen oxides (NO,),particulate matter (PM), and carbon monoxide (CO), all of which are regulatedpollutants. Additionally, there are substantial emissions of carbon dioxide (CO2), agreenhouse gas, although future developments such as carbon capture and storageand co-firing with biomass have the potential to reduce the carbon footprint of coal-firedelectricity generation (POST 2006). Coal also contains other constituents (e.g.,mercury, beryllium) that are potentially emitted as hazardous air pollutants, which arealso of concern from a human health standpoint. (NRC 1996, Section 8.3.9)As noted in Section 7.2.1.1, FENOC has assumed a plant design that includes controlsto minimize emissions of regulated air pollutants effectively. Based on emission factors,estimated efficiencies for emission controls, and assumed design parameters listed inTable 7.2-1, operation of the plant would result in the following annual air emissions forcriteria pollutants:" Sulfur dioxide = 8,267 tons" Nitrogen oxides = 5,087 tons* Carbon monoxide = 636 tons" Total filterable particulates = 153 tons" PM10 = 34.3 tons.The annual emissions of carbon dioxide, which is currently unregulated, would beapproximately 7.63 million tons. See Table 7.3-1 for details.I Environmental Impacts of AlternativesPage 7.3-3September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportFENOC expects that these emissions would result in a decrease in local air qualitycompared to operation of a nuclear plant. However, FENOC anticipates that both sulfurdioxide and nitrogen oxide emissions will be subject to cap and trade programs(FENOC 2007, Section 7.2.1.3). As a result, the plant would not be expected to add toregional sulfur dioxide emissions and may not add to regional nitrogen oxide emissions,at least during the ozone season (FENOC 2007, Section 7.3.2, Air Quality). Therepresentative plant would add to regional concentrations of other pollutants, includingthe criteria pollutants carbon monoxide and particulates; hazardous air pollutants; andcarbon dioxide, which is a greenhouse gas.Subject to regulatory controls, FENOC anticipates that the overall air quality would benoticeable, but not destabilizing. As a result, FENOC considers that the impacts to airquality from operation of the representative plant at an alternative site would beMODERATE.Ecological ResourcesOnsite and offsite land disturbances form the basis for impacts to terrestrial ecology.Constructing a coal-fired plant at an alternate site could alter onsite ecologicalresources because of the need to convert about 1,547 acres of land at the site toindustrial use for the plant, coal storage, and ash and scrubber sludge disposal (see theLand Use subsection above). Coal-mining operations will also affect terrestrial ecologyin offsite mining areas, although some of this land is likely already disturbed by miningoperations.Impacts could include wildlife habitat loss, reduced productivity, habitat fragmentation,and a local reduction in biological diversity. Impacts, however, will vary based on thedegree to which the proposed plant site is already disturbed. On a previous industrialsite, impacts to terrestrial ecology will be minor, unless substantial transmission lineROWs, a lengthy rail spur, or additional roads need to be constructed throughundisturbed or less-disturbed areas. Any onsite or offsite waste disposal by landfillingwill also affect terrestrial ecology at least through the time period when the disposalarea is reclaimed.During construction, impacts to aquatic ecology are likely. Regardless of where theplant is constructed, site disturbance will likely increase erosion and sedimentationrunoff into nearby waterways, increasing turbidity. While site procedures andmanagement practices may limit this effect, the impact will likely be noticeable. This isparticularly true when intake and outfall structures are constructed alongside or in thebody of water, as well as when any ROWs, roads, or rail lines require in-streamstructures to support stream crossings. Noise and disturbance from construction, inaddition to increased turbidity, may have a noticeable effect. Required regulatorypermits, however, will help to mitigate these impacts.I Environmental Impacts of AlternativesPage 7.3-4September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportDuring operations, the cooling water system would have a potential impact to aquaticcommunities. However, this system would be designed and operated in compliancewith the CWA, including NPDES limitations to ensure appropriate protection of aquaticcommunities from thermal discharges and cooling water intakes. The cooling waterintake and discharge flows would be comparable to or less than for Davis-Besse, theimpact from which is considered to be SMALL (see Chapter 4). Therefore, associatedimpacts at a comparable site on commercially navigable waterway would also beexpected to be SMALL.Management of runoff from coal piles will also be necessary. However, subject toregulatory oversight, as afforded under OPSB rules or a similar program, FENOCconsiders the impacts to ecological resources from construction and operation of therepresentative plant at an alternative site may be noticeable, but not destabilizing.On this basis, FENOC considers that the overall impact to ecological resources ofconstructing a coal-fired plant with a closed-cycle cooling system at an alternate sitewould be MODERATE.Human HealthCoal-fired power generation introduces worker risk from coal and limestone mining,worker and public risk from coal and lime/limestone transportation, worker and publicrisk from disposal of coal combustion wastes, and public risk from inhalation of stackemissions. For example, the GElS noted that there could be human health impacts(cancer and emphysema) from inhalation of toxins and particulates from a coal-firedplant, but the GElS does not identify the significance of these impacts (NRC 1996,Section 8.3.9). In addition, the coal-fired alternative also introduces the risk of coal pilefires and attendant inhalation risks, though these types of events are relatively rare.(NRC 2009b, Section 8.2.1, Human Health)Regulatory agencies, including the USEPA, USOSHA, and state agencies, set airemission standards requirements for workers and the public based on human healthimpacts. These agencies also impose site-specific emission limits as needed to protecthuman health.Given these extensive health-based regulatory controls, FENOC considers thatoperating the representative coal-fired plant at an alternate site would be SMALL.SocioeconomicsThe peak workforce during construction of the coal-fired plant alternative is estimated torange between 1.2 to 2.5 workers per MWe and the workforce required during operationis estimated to be 0.25 workers per MWe (NRC 1996, Section 8.3.9, Table 8.1 andI Environmental Impacts of AlternativesPage 7.3-5September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.2). For a plant with a capacity of 910 MWe, workforces of approximately 1,092to 2,275 construction workers and 228 permanent employees would be required.Potential impacts from construction of the coal-fired alternative would be highly locationdependent. As noted in the GELS, socioeconomic impacts are expected to be larger ata rural site than at an urban site, because more of the peak construction work forcewould need to move to the area to work (NRC 1996, Section 8.3.9). Not consideringimpacts of terminating Davis-Besse operations, socioeconomic impacts at a remoterural site could be LARGE, while impacts at a site in the vicinity of a more populatedmetropolitan area (e.g., Toledo) could be SMALL to MODERATE. FENOC assumedthat the OPSB or comparable review process, including application of appropriatemitigation found to be needed as a result, would ensure that these construction impactswould not be destabilizing to local communities.At most alternate sites, coal and lime would be delivered by barge, although delivery isfeasible for a location near a railway. Transportation impacts would depend upon thesite location. Socioeconomic impacts associated with rail transportation would beMODERATE to LARGE. Barge delivery of coal and lime/limestone would have SMALLsocioeconomic impacts.As noted in Section 4.17, communities in Ottawa County, particularly those within thetax jurisdiction of Carroll Township and the Carroll-Benton-Salem School District, wouldexperience losses in both employment and tax revenues due to Davis-Besse closure,assuming the plant is constructed outside the area.Based on the above, FENOC considers that the overall socioeconomic impacts ofconstruction and operation of the representative coal-fired plant at an alternate sitewould be MODERATE.Waste ManagementThe representative coal-fired plant would produce substantial solid waste, especially flyash and scrubber sludge. Based on emission factors and controls scaled from BeaverValley (FENOC 2007, Section 7.3.2 and Table 7.2-2)*, the plant annual wastegeneration amounts would be approximately 300,000 tons/year of ash and 470,100 tonsof flue gas desulphurization waste (dry basis), consisting primarily of hydrated calciumsulfate (gypsum) and excess limestone reactant. Although these wastes representpotentially usable products, FENOC assumed the total waste generated would bedisposed of at an offsite landfill. Based on a fill depth of 30 feet and scaling fromBeaver Valley (FENOC 2007, Section 7.3.2), approximately 644 acres would berequired for the landfill over an assumed plant operating life of 40 years.The scale factor for coal is the ratio of total electric capability, 910 MWe/1980 Mwe, or 0.460.I Environmental Impacts of AlternativesPage 7.3-6S.e~ptember 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportDisposal of the waste could noticeably affect land use and ground water quality. Inaddition, the December 2008 failure of the dike used to contain fly ash at the TennesseeValley Authority Kingston Fossil Plant in Roane County, Tennessee, and subsequentcleanup, highlight other waste management issues (USEPA 2009b). However,environmental impacts related to the location, design, and operational aspects of wastedisposal for the plant would be subject to regulatory review under OPSB rules or similarprograms. As a result, FENOC believes that with proper disposal siting, coupled withcurrent waste management and monitoring practices, waste disposal would notdestabilize any resources.On this basis, FENOC considers that waste management impacts from operation of therepresentative coal-fired plant at an alternate site would be MODERATE.AestheticsPotential aesthetic impacts of construction and operation of the representative coal-firedplant include visual impairment resulting from the presence of a large industrial facility,including 500-foot-high stacks, and cooling towers up to approximately 500 feet highwith associated condensate plumes. The stacks and condensate plumes from thecooling towers could be visible some distance from the plant. There would also be anaesthetic impact if construction of a new transmission line or rail spur were needed.Similarly, noise impacts associated with rail delivery of coal and lime/limestone if usedwould be most significant for residents living in the vicinity of the facility and along therail route.These impacts, however, are highly site-specific. Site locations could reduce theaesthetic impact of a coal-fired generation, for example, if siting were in an area thatwas already industrialized versus locating at largely undeveloped sites.In view of the environmental review afforded under OPSB rules or a similar program,FENOC considers that the impacts to aesthetics from construction and operation of therepresentative plant at an alternative site would depend on location and be SMALL toMODERATE.Cultural ResourcesFENOC assumed that the representative coal-fired plant, associated infrastructure (e.g.,roads, transmission corridors, rail lines, or other rights-of-way), and associated wastedisposal site would be located with consideration of cultural resources afforded underOPSB or comparable rules. FENOC further assumed that appropriate measures wouldbe taken to recover or provide other mitigation for loss of any resources discoveredduring onsite or offsite construction.I Environmental Impacts of AlternativesPage 7.3-7September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportOn this basis, FENOC considers that the potential impact on cultural resources fromconstruction and operation of the representative plant at an alternative site would beSMALL.7.3.2 GAS-FIRED GENERATIONThis section presents the impact evaluation for the representative gas-fired generationalternative. As discussed in Section 7.2.1.2, FENOC assumed for purposes of thisanalysis that the representative plant would be located at a greenfield or (preferably)brownfield site in northwestern Ohio. This assumption is a result of the space limitationat the Davis-Besse site.Land UseLand-use requirements for gas-fired plants are relatively small, at about 100 acres for a910 MWe plant (Section 7.2.1.2). An estimated 240 -270 additional acres would beneeded offsite at a greenfield location for new gas and electric transmission lines(FENOC 2007, Section 7.3.1, Land Use) and increased land-related impacts, which inturn would be location-specific.Land use in northwestern Ohio is predominantly rural agricultural cropland withscattered rural residences and woodlots. Located in a rural area, the change in landuse would be locally apparent and could include displacement of cropland, which ishighly productive for corn, wheat, and soybeans relative to other areas of the state;however, substantial buffer with respect to highly incompatible land uses (e.g.,residential use) could be provided and destabilization of overall land use would not beexpected. If the plant were located in an area designated for industrial use, associatedland-use impacts would not be significant. Agricultural practices could continue alongmost of the area occupied by offsite rights-of-way. (FENOC 2007, Section 7.3.1, LandUse)Regardless of where the natural gas-fired plant is built, additional land would berequired for natural gas wells and collection stations. Partially offsetting these offsiteland requirements would be the elimination of the need for uranium mining to supplyfuel for Davis-Besse. The GElS estimated that approximately one acre per MWe wouldbe affected for mining and processing the uranium during the operating life of a nuclearpower plant (NRC 1996, Section 8.3.12). Therefore, for Davis-Besse uranium miningand processing, approximately 910 acres of land would be required, resulting in a netgain in reclaimed land for the representative natural gas-fired generation alternative.In view of the environmental review afforded under OPSB rules or a similar program,FENOC considers that the overall impacts of land use from construction and operationof the representative plant at an alternative site would depend on plant location and beSMALL to MODERATE.I Environmental Impacts of AlternativesPage 7.3-8September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportWater Use and Quality -Surface WaterCooling water intake, evaporative losses, and discharge flows for the plant would beless than that of Davis-Besse, primarily because less power would be derived from asteam cycle (FENOC 2007, Section 7.2.2.1).During operation, cooling water and wastewater discharges would be regulated underthe federal CWA and corresponding state programs by an NPDES permit. Constructionactivities would be similarly regulated to ensure protection of water resources. Inaddition, impacts on water use and quality would be subject to scrutiny in the planningstage under OPSB or similar governing authority rules.Overall, FENOC considers that the impacts from construction and operation of therepresentative plant at an alternative site on surface water use and quality would beSMALL.Water Use and Quality -Ground WaterImpacts will depend on whether the plant will use ground water for any purposes, aswell as the characteristics of local aquifers. Regardless of location, FENOC assumesthat a gas-fired power plant at an alternate site will not rely on ground water for plantcooling, and that regulations for ground water use for potable water will limit impacts toSMALL.Air QualityNatural gas is a relatively clean-burning fuel with nitrogen oxides being the primaryfocus of combustion emission controls. As noted in the GELS, air quality impacts for allnatural gas technologies are generally less than for fossil technologies of equal capacitybecause fewer pollutants are emitted (NRC 1996, Section 8.3.10).As noted in Section 7.2.1.2, FENOC has assumed a plant design that includes controlsto minimize emissions of regulated air pollutants effectively. Based on emission factors,estimated efficiencies for emission controls, and assumed design parameters listed inTable 7.2-2, operation of the plant would result in the following annual air emissions forcriteria pollutants:* Sulfur dioxide = 13.3 tons* Nitrogen oxides = 205 tons" Carbon monoxide = 311 tons* Total filterable particulates = 39.4 tonsThe annual emissions of carbon dioxide, which is currently unregulated, would beapproximately 2.28 million tons. See Table 7.3-2 for details.I Environmental Impacts of AlternativesPage 7.3-9September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportFENOC expects that these emissions may result in a noticeable reduction in local airquality. However, FENOC anticipates that both sulfur dioxide and nitrogen oxideemissions will be subject to cap and trade programs (FENOC 2007, Section 7.2.1.3).As a result, the plant would not be expected to add to regional sulfur dioxide emissionsand may not add to regional nitrogen oxide emissions, at least during the ozone season(FENOC 2007, Section 7.3.1, Air Quality). The representative plant would add toregional concentrations of other pollutants, including the criteria pollutants carbonmonoxide and particulates; hazardous air pollutants such as mercury; and carbondioxide, which is presently unregulated.Subject to regulatory controls, FENOC anticipates that the overall air quality would benoticeable, but not destabilizing. As a result, FENOC considers that the impacts to airquality from operation of the representative plant at an alternative site would beMODERATE, but smaller than those of coal-fired generation.EcoloQical ResourcesAs noted in the Land Use subsection above, development of the representativecombined-cycle natural gas-fired plant may require approximately 100 acres for theplant site and approximately 240 -270 additional acres for offsite infrastructure.Although the GElS noted that land-dependent ecological impacts from construction fromgas-fired plants would be smaller than for other fossil fuel technologies of equal capacity(NRC 1996, Section 8.3.10), the type and quality of terrestrial habitat that would bedisplaced is location-specific.However, FENOC considers it likely that most of the area required for constructionwould consist of agricultural cropland with relatively low habitat value. Stream crossingsand wetland disturbance, if any, would be subject to provisions of a USACE permit(CWA Section 404) and relevant state and local requirements. (FENOC 2007,Section 7.3.1, Ecology)The most significant potential impacts to aquatic communities relate to operation of thecooling water system. However, the cooling system for the plant would be designedand operated in compliance with the CWA, including NPDES limitations for physical andchemical parameters of potential concern and provisions of CWA Sections 316(a) and316(b), which are respectively established to ensure appropriate protection of aquaticcommunities from thermal discharges and cooling water intakes. Also, the siting,design, and operation of the plant would be subject to the environmental protectionsunder OPSB rules.Overall, FENOC expects that development of the representative natural gas-fired plantwould likely have little noticeable impact on ecological resources of the area. As aresult, FENOC considers that the overall impacts to ecology resources fromI Environmental Impacts of AlternativesPage 7.3-10September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportconstruction and operation of the representative plant at an alternative site woulddepend on plant location and be SMALL to MODERATE.Human HealthThe GElS cites risk of accidents to workers and public health risks (e.g., cancer, oremphysema) from the inhalation of toxics and particulates associated with air emissionsas potential risks to human health associated with the gas-fired generation alternative(NRC 1996, Table 8.2). However, regulatory requirements imposed on facility design,construction, and operations under the authority of the Occupational Safety and HealthAct, Clean Air Act, and related statutes are designed to provide an appropriate level ofprotection to workers and the public. Additionally, regulatory agencies, including theUSEPA, USOSHA, and state agencies, set air emission standards requirements forworkers and the public based on human health impacts.Given the extensive health-based regulatory control, FENOC considers that operatingthe representative gas-fired plant at an alternate site, regardless of plant location, wouldbe SMALL.SocioeconomicsMajor sources of potential socioeconomic impacts from the representative gas-firedgeneration alternative include temporary increases in jobs, economic activity, anddemand for housing and public services in communities surrounding the site during theconstruction period. Countering these increases are losses in permanent jobs, taxrevenues, and economic activity attributable to gas-fired plant operation and terminationof operations of Davis-Besse.The estimated number of peak construction workers expected to build a gas-fired plantwith a capacity of 910 MWe is 1,092 -2,275 (NRC 1996, Tables 8.1). To operate theplant would require 137 workers (NRC 1996, Tables 8.2). Although northwestern Ohiois predominantly rural, most areas are within commuting distance of the metropolitanareas like Toledo and Cleveland, Ohio. Considering the proximity of these sources oflabor and services, FENOC expects that most of the construction workforce wouldcommute and relatively few would relocate into the area, and associated socioeconomicimpacts during construction would be SMALL.Communities in Ottawa County, however, particularly those within the taxing jurisdictionof Carroll Township and the Benton-Carroll-Salem School District, would experiencelosses in both employment and tax revenues due to Davis-Besse closure that couldconstitute MODERATE impact (see Section 4.17).FENOC believes that these impacts, although noticeable, would not be destabilizing.As a result, FENOC considers that the overall socioeconomic impact of constructionI Environmental Impacts of AlternativesPage 7.3-11September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportand operation of the representative gas-fired at an alternative site would beMODERATE.Waste ManagementGas-fired generation would result in minimal waste generation, producing minor (if any)impacts (NRC 1996, Section 8.3.10). As a result, FENOC considers wastemanagement impacts from the operation of the representative plant at an alternativesite would be SMALL.AestheticsPotential aesthetic impacts of construction and operation of a gas-fired plant includevisual impairment resulting from the presence of a large industrial facility, includingmultiple exhaust stacks at least 150 feet high, and mechanical-draft cooling towers withassociated condensate plumes. Considering the flat topography in northwestern Ohio,the stacks and condensate plumes would likely be visible for several miles from the site;new transmission lines constructed to connect the plant to the grid would also berelatively visible for the same reason, though would not be out of character for the ruralnorthwestern Ohio landscape. (FENOC 2007, Section 7.3.1, Aesthetics) FENOCexpects that the plant likely would be located in a rural area, and assumed thatadequate buffer and vegetation screens would be provided at the plant site as neededto moderate visual and noise impacts.In view of the environmental review afforded under OPSB rules, FENOC considers thatthe impacts to aesthetics from construction and operation of the representative plant atan alternative site would depend on location and be SMALL to MODERATE.Cultural ResourcesFENOC assumed that the representative gas-fired plant and associated gas-supplypipeline and transmission line would be located with consideration of cultural resourcesunder OPSB or comparable program rules. FENOC further assumed that appropriatemeasures would be taken to avoid, recover, or provide other mitigation for loss of anyresources discovered during onsite or offsite construction.On this basis, FENOC concludes that the potential adverse impact on cultural resourcesof the representative plant at an alternative site, regardless of location, would beSMALL.I Environmental Impacts of AlternativesPage 7.3-12September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report7.3.3 RENEWABLE ENERGYThis section presents the impact evaluation for wind power in the form of interconnectedwind farms and/or solar photovoltaic power, in combination with CAES. To be specific,FENOC evaluated for purposes of this NEPA analysis electricity generation comingfrom: wind power in the form of interconnected wind farms: or wind power in the form ofinterconnected wind farms with CAES: or solar (photovoltaic) power with CAES: or acombination of interconnected wind farms and solar power with CAES, as described inSections 7.2.1 and 7.2.1.3.Wind and solar energy are renewable energy sources that produce electricity withoutreleasing air or water pollutants: however, these advantages are offset byenvironmental impacts such as large land requirements (both wind and solar), potentialharm to birds and bats (wind), aesthetic concerns (wind and solar), noise concerns(wind): radar interference (wind), and generation of hazardous waste streams (solar).In addition, there would be environmental impacts associated with the construction andoperation of new transmission lines associated with new renewable energy sources.These impacts are not evaluated as part of this analysis because the scope of newtransmission would not be determined until the energy sources were sited.The environmental impacts related to interconnected wind farms are discussed inSection 7.3.3.1. The environmental impacts of interconnected wind farms with CAESare discussed in Section 7.3.3.2. The environmental impacts of solar PV power withCAES are discussed in Section 7.3.3.3. Finally, a summary of the combinedenvironmental impacts of wind farms, solar PV power, and CAES are provided inSection 7.3.3.4.7.3.3.1 Interconnected Wind EnergyUsing the assumptions and disclaimers in Section 7.2.1, development of a series ofwind farms would be required to provide replacement power for Davis-Besse.Transmission impacts associated with an interconnected grid that would serverenewable energy sources would have to be evaluated once the renewable energysources have been sited.Development of large-scale, land-based wind power facilities could have MODERATEto LARGE impacts on aesthetics, land use, and terrestrial ecology. The environmentalimpacts of a large-scale wind farm are described in the GElS (NRC 1996, Section8.3.1). In summary, the construction of roads and turbine tower supports would result inshort-term impacts, such as increases in noise, erosion, and sedimentation, anddecreases in air quality from fugitive dust and equipment emissions. Construction inundeveloped areas would have the potential to disturb and impact cultural resources orhabitat for sensitive species. During operation, some land near wind turbines could beI Environmental Impacts of AlternativesPage 7.3-13September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportavailable for compatible uses such as agriculture. There is some continuing noise fromwind turbine operation, light flicker caused by reflection of the sun, and aestheticimpacts, although whether a wind farm improves the landscape is in the eye of thebeholder. Wind farms generate very little waste and pose limited human health riskother than from occupational iniuries. There is a potential for bird and bat collisions withturbine blades, which is discussed in this subsection.Although most environmental impacts associated with a single wind farm are SMALL orcan be mitigated, the cumulative impacts from the many wind farms that would beneeded to support an interconnected grid system, such as impacts to sensitive habitatsand endangered species, could be LARGE, depending on the locations.The incorporation of offshore wind resources from Lake Erie could reduce the amount ofland use impacts: however, a new set of impacts related to offshore wind would becreated. Placing wind farms offshore eliminates some of the obstacles encounteredwhen siting wind farms on shore and limits conflicts with other planning interests.However, other impacts are created, including influence on birds, marine life,hydrography, and marine traffic. (IEAWIND 2002)A detailed discussion of impacts is presented below.Land UseThe land use requirement for interconnected wind farms in open and flat terrain is about50 acres per megawatt (MW) of installed capacity. Approximately 5% (2.5 acres) of thisarea is occupied by turbines, access roads, and other equipment. The remaining landarea can be used for compatible activities such as farming or ranching (AWEA 2002),except if the wind farms are located offshore. The Roscoe Wind Farm near Roscoe,Texas has the capacity of 209 MW and is spread-out across 30,000 acres (RWC 2010),or 143 acres per MW. When complete, the entire Roscoe Wind Complex project isexpect to have the capacity of 781 MW on approximately 100,000 acres (CBS 2010) or128 acres per MW.Assuming the use of interconnected wind as the only renewable source to generate theequivalent of Davis-Besse's net output of 910 MWe base-load power plus 910 MWe ofenergy storage to be used when wind power is not available, a series of wind farms with2.0-MWe turbines with an average capacity factor of 30% as specified by PJM andUSDOE (PJM 2011 and USDOE 2011) would require approximately 3030 turbines toproduce 1820 MWe. At 50 acres per MW, the land use potential would be as much as91,000 acres (142 square miles), with about 4550 acres (7.1 square miles) occupied byturbines and support facilities.Land use in Ohio, where additional wind generation would likely be developed, ispredominantly rural agricultural cropland with scattered rural residences and woodlots.I Environmental Impacts of AlternativesPage 7.3-14September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportIn such a location, the change in land use would be locally apparent and could includesome initial displacement of highly productive cropland for corn, wheat, and soybeans.However, a substantial buffer with respect to highly incompatible land uses (e.g.,residential use) could be provided, and destabilization of overall land use would not beexpected. Agricultural practices could continue along most of the area occupied byoffsite rights-of-way. (FENOC 2007, Section 7.3.1, Land Use)Offshore impacts have been extensively studied in Europe. An environmental impactreport has been Prepared by the Cape Wind Project (CWP) and a feasibility study wasconducted by the Great Lakes Wind Energy Center (GLWEC) for an offshore area inLake Erie near Cleveland, Ohio (GLWEC 2009). Based on the findings in the CWPEnvironmental Impact Report (EIR) (CWP 2007) and the study completed by GLWEC,land use impacts associated with offshore wind generation would be SMALL.Regardless of where the wind generation facilities are built, additional land would berequired for an interconnected grid system as described in Section 7.2.2.3. Partiallyoffsetting these offsite land requirements would be the elimination of the need foruranium mining to supply fuel for Davis-Besse. The GElS estimates that approximatelyone acre per MWe would be affected for mining and processing the uranium during theoperating life of a nuclear power plant (NRC 1996, Section 8.3.12). Therefore, for theuranium mining and processing associated with fuel for Davis-Besse, approximately910 acres of land would be required, resulting in a net avoidance of potentiallydisturbing 3640 (4550-910) acres of land when compared to wind generation land use.Based on these data, FENOC considers that the overall impacts of land use fromconstruction and operation of interconnected wind farms would depend on theirlocations, and be MODERATE to LARGE.Water Use and Quality -Surface WaterWind generation does not require cooling water or intake structures. Therefore, therewould be no impact on water use and the only potential impact on local water qualitywould be erosion or sedimentation issues during construction. These impacts would beminimized by using best management practices during construction activities and areconsidered SMALL.Water Use and Quality -Ground WaterA limited amount of ground water may be used during construction activities if otherpotable water supplies are limited. Minor amounts of water may be needed foroperating wind generation facilities if surface water resources were not available. Thepotential impact to ground water is SMALL.I Environmental Impacts of AlternativesPage 7.3-15September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportAir QualityThere are no air quality impacts associated with the operation of onshore or offshoreinterconnected wind farms. The construction of roads and turbine tower supports wouldresult in short-term impacts in air quality from fugitive dust and equipment emissionsand the overall impacts would be SMALL.Ecological ResourcesAs noted in the Land Use subsection above, development of onshore interconnectedwind farms would have a MODERATE to LARGE impact on land resources which couldhave a LARGE impact on the ecological resources, especially durinq construction.Migratory bird, eagle and raptor, and bat mortality are potential impacts related to windturbines. The deaths of birds and bats at wind farm sites have raised concerns by fishand wildlife agencies and conservation -groups. United States Fish and Wildlife Service(USFWS) estimates indicate that wind turbine rotors kill 33,000 birds annually (USFWS2002). Concerns of the potential impacts of wind power deployment have led theUSFWS to release draft guidance that provides agency employees, developers, federalagencies, and state organizations information for reviewing and selecting sites forinterconnected and community-scale wind energy facilities to avoid and minimizenegative impacts to fish, wildlife, plants and their habitats (USDO1 2011). Direct effectsinclude blade strikes, barotrauma, loss of habitat, and "displacement". Indirect effectsoccur later in time and include introduction of invasive vegetation that result in alterationof fire cycles: increase in predators or predation pressure: decreased survival orreproduction of the species: and decreased use of the habitat that may result fromeffects of the proiect or resulting "habitat fragmentation." (USFWS 2011)Although wind turbine/bird collision studies seem to indicate that wind generatingfacilities in some locations of the United States have a minor impact on birds comparedto other sources of collision mortality, one cannot assume that similar impacts wouldoccur among birds using wind-generating sites built in Ohio or offshore in Lake Erie.Based on a feasibility study conducted by Great Lakes Wind Energy Center (GLWEC)the avian morality rate of this proposed offshore project is expected to be minimal.(GLWEC 2009) FENOC assumed that construction best management practices andawareness of critical habitat during operations would minimize impacts to ecologicalresources. Therefore, impacts to migrating species would depend on the location of thewind farms and could be SMALL to MODERATE.Human HealthThe only major health risk for the construction and operation of a series of wind farms(onshore or offshore) would be accidents. FENOC assumed that all OccupationalI Environmental Impacts of AlternativesPage 7.3-16September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportSafety and Health Act requirements would be complied with during construction andoperation of these facilities and the impacts should be SMALL.SocioeconomicsMajor sources of potential socioeconomic impacts from interconnected wind farmsinclude temporary increases in lobs, economic activity, and demand for housing andpublic services in communities surrounding the sites during the construction period.These impacts would be spread throughout the region. Countering these increases arelosses in Permanent jobs, tax revenues, and economic activity attributable to thetermination of operations of Davis-Besse. Typically, renewable energy sources are notsubject to the tax rate of conventional energy-generating facilities, so the loss ofPermanent gobs and tax revenue could be significant to the communities nearDavis-Besse and thus have a SMALL to MODERATE impact.Communities in Ottawa County, however, particularly those within the taxing jurisdictionof Carroll Township and the Benton-Carroll-Salem School District, would experiencelosses in both employment and tax revenues due to Davis-Besse closure that couldconstitute MODERATE impacts.The number of peak construction workers expected to build the wind farms is unknownat this time: however, it is likely similar to a gas-fired plant with a capacity of 910 MWe,which is 1200 (NRC 1996, Tables 8.1). To operate and maintain the wind farms wouldreguire approximately 150 to 200 workers. FENOC expects that most of theconstruction workforce would commute and relatively few would relocate into the area,and associated socioeconomic impacts during construction would be SMALL.Waste ManagementConstruction of wind farms could result in generation of large amounts of vegetationfrom land clearing activities. If this material is managed correctly (e.g., recycled orcomposted) the impacts should be SMALL. Minor amounts of waste may be generatedduring the operations and maintenance of the wind turbines (onshore or offshore)which, if waste streams are managed correctly, the impacts would likely be SMALL.AestheticsMost wind farms are located in remote areas and may generate large aestheticconcerns, particularly if sited on highlands or in recreational areas and could have someeffect on the local aesthetic quality. The aesthetic impacts from wind farms located inflat-lvina rural areas would likely be SMALL.Offshore wind turbines would likely have a lesser aesthetic impact than onshore windturbines and be limited to those individuals who reside close to the shoreline orI Environmental Impacts of AlternativesPage 7.3-17September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportparticipate in recreational activities close to the wind facilities. There have beenconcerns related to the related to aesthetic impacts. (CA 2011) The overall aestheticimpacts from wind turbines would be SMALL to MODERATE.Cultural ResourcesDue to the large amount of land needed to construct the necessary wind farms, thepotential for impacting cultural resources could be LARGE. To minimize theseimpacts, FENOC assumed construction activities would consider cultural resourcesunder OPSB or comparable program rules. FENOC further assumed that appropriatemeasures for both onshore and offshore construction activities would be taken toavoid, recover, or provide other mitigation for loss of any resources discovered duringonsite or offsite construction.On this basis, FENOC concludes that the potential adverse impact on cultural resourcesof the wind farms, regardless of location, would be SMALL.7.3.3.2 Wind with Compressed Air Energy StorageEnvironmental impacts associated with wind farms are discussed above in Section7.3.3.1, and are not repeated here in detail. Impacts associated with the compressedair energy storage (CAES) facility are discussed below.By combining CAES with interconnected wind farms, the anticipated environmentalimpacts would be greater than the impacts from interconnected wind farms alone.Therefore, wind farms with CAES generating 1820 MW

• of power are expected tohave greater environmental impacts than Davis-Besse during the proposed 20 yearlicense extension.Land UseThe overall land use impact for wind generation in this energy alternative, as discussedin Section 7.3.3.1, is MODERATE to LARGE.Land use associated with the NES facility would be limited to the facility's 92 surfaceacres. There would be some land impacted during construction, but this site has beenpreviously disturbed so the impact should be SMALL. However, if another site is.Wind generation source is assumed to be available for 12 hours every day, and a CAES facilityassumed to be 100% efficient (i.e., 910 MWe of energy input from wind and/or solar to the CAES facilityresults in 910 MWe of generation from the CAES facility), would require that generation source to berated at 1820 MW in order to Provide 24-hours of baseload electricity when integrated with a 910 MWCAES facility (i.e., 12 hours to provide 910 MW of base-load generation onto the grid, and the same12 hours to provide 910 MW to recharge the CAES facility, so that the CAES facility could feed the gridthe remainder of the day).I Environmental Impacts of AlternativesPage 7.3-18September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportchosen for the CAES or an additional CAES facility is needed to meet base-load powerrequirements then there could be a MODERATE to LARGE land use impact.Water Use and Quality -Surface WaterCAES facilities have cooling towers associated with the use of gas turbines to produceelectricity and compressors to recharge the storage structure. These cooling towers aremuch smaller than those typically used for coal and gas generation plants. Coolingmakeup water evaporative losses, and discharge flows for the plant would beconsiderably less than that of Davis-Besse, primarily because less power would bederived from a steam cycle. (FENOC 2007, Section 7.2.2.1)During CAES operation, cooling water and wastewater discharges would be regulatedunder the federal CWA and corresponding state programs by an NPDES permit.Construction activities would be similarly regulated to ensure protection of waterresources. In addition, impacts on water use and quality would be subiect to scrutiny inthe planning stage under OPSB or similar governing authority rules.Overall, FENOC considers that the impacts from construction and operation ofinterconnected wind farms (onshore and offshore) combined with a CAES facility onsurface water use and quality would be SMALL.Water Use and Quality -Ground WaterImpacts would depend on whether the plant would use ground water for any purposes,as well as the characteristics of local aquifers. Regardless of location, FENOCassumed that the NES plant or a CAES plant at an alternate site would not rely onground water for plant cooling, and that regulations for ground water use for potablewater would limit impacts to SMALL.Air QualityCAES facilities use natural gas, which is a relatively clean-burning fuel with nitrogenoxides being the primary focus of combustion emission controls. As noted in the GELS,air quality impacts for all natural gas technologies are generally less than for fossiltechnologies of equal capacity because fewer pollutants are emitted (NRC 1996,Section 8.3.10).FirstEnergy Generation Corp. has applied for and received an Air Pollution Permit toInstall and Operate (PTIO) proposed emission units for the Norton CAES facility (FacilityID 1677105001) (see Table 7.2-3). The permit (Number P01 06714) was issued onSeptember 7, 2010 by the Ohio EPA. The permit establishes emission limitations, airemission controls, monitoring., reporting., and recordkeeping requirements. Theproposed emission units established in the PTIO are based on the original design of theI Environmental Impacts of AlternativesPage 7.3-19September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportfacility and include six combustion trains and one cooling tower. Each combustion trainincludes a 589 mmBtu/hr (134 MWe) combustion turbine and a 1 mmBtu/hr in-lineheater to remove moisture from the compressed air. (NES 2010) The combustionturbines and in-line heaters would fire only pipeline-quality natural gas. The only othersources associated with this facility are an emergency generator and a back-upfirewater pump: both of these units would be diesel-fired.The permitted annual air emission limits from this facility with six combustion trains(i.e., 804 Mwe) are as follows:* Sulfur dioxide (SO2) = 42.41 tons* Nitrogen oxides (NOO) = 93.67 tons* Carbon monoxide = 90.36 tons* PMlo = 46.65 tons" Volatile Organic Compounds (VOCs) = 26.40 tonsThe annual emissions of carbon dioxide from all sources would be approximately681,100 tons. These emissions are based on the current air permit for NES and couldchange if different equipment is used during plants operations. A list of air emissions forthe six combustion trains is presented in Table 7.3-4.FENOC anticipates that both sulfur dioxide and nitrogen oxide emissions would besubiect to cap and trade programs (FENOC 2007, Section 7.2.1.3). As a result, the plantwould not be expected to add to regional sulfur dioxide emissions and may not add toregional nitrogen oxide emissions, at least during the ozone season (FENOC 2007,Section 7.3.1. Air Quality). The plant would add to regional concentrations of otherpollutants, including the criteria pollutants carbon monoxide and particulates: hazardousair pollutants such as mercury: and carbon dioxide, which is Presently unregulated.Subiect to regulatory controls, FENOC anticipates that the impacts to air quality fromoperation of the CAES plant at an alternative site would be MODERATE.Ecological ResourcesAs noted in Section 7.3.3.1, development of the interconnected wind farms would havea MODERATE to LARGE impact on land resources which could have a LARGE impacton ecological resources, especially during construction.Since the NES has an existing underground storage space and only has 92 acres ofland use at the surface, the potential impact to ecological resources is SMALL.However, if another CAES site with compressed air storage on the land surface ischosen or needed to provide additional stored energy capacity the ecological impactscould be MODERATE to LARGE.I Environmental Impacts of Alternatives Page 7.3-20 Sentember 2011I Environmental Impacts of AlternativesPage 7.3-20September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportFor an alternative CAES site, FENOC considers it likely that most of the area requiredfor construction would consist of agricultural cropland with relatively low habitat value.Stream crossings and wetland disturbance, if any, would be subiect to provisions of aUSACE permit (CWA Section 404) and relevant state and local requirements.(FENOC 2007, Section 7.3.1. Ecology)The most siqnificant potential impacts to aquatic communities relate to operation of thecooling water system. However, the NES site (or alternative site) cooling system for theplant would be designed and operated in compliance with the CWA. includinq NPDESlimitations for physical and chemical parameters of potential concern and provisions ofCWA Sections 316(a) and 316(b), which are respectively established to ensureappropriate protection of aquatic communities from thermal discharges and coolingwater intakes. Also, the siting, design, and operation of the plant would be subject tothe environmental protections under OPSB or other state agency's rules.Overall, FENOC expects that development of the CAES plant would likely have littlenoticeable impact on ecoloqical resources of the area. As a result, FENOC considersthat the overall impacts to ecoloqy resources from construction and operation of therepresentative plant at an alternative site would depend on plant location and be SMALLto LARGE.Human HealthThe only maior health risk for the construction and operation of a series of wind farms(onshore or offshore) would be accidents. FENOC assumed that all OccupationalSafety and Health Act requirements would be complied with during construction andoperation of these facilities and the impacts should be SMALL.The NES or an alternative CAES facility would use natural gas in its power generationmode. The GElS cites risk of accidents to workers and public health risks (e.g., cancer,or emphysema) from the inhalation of toxics and particulates associated with airemissions as potential risks to human health associated with the gas-fired generationalternative (NRC 1996, Table 8.2). However, regulatory requirements imposed onfacility design, construction, and operations under the authority of the OccupationalSafety and Health Act, Clean Air Act, and related statutes are designed to provide anappropriate level of protection to workers and the public. Additionally, regulatoryagencies, includinq the USEPA, USOSHA, and state aqencies, set air emissionstandards requirements for workers and the public based on human health impacts.Given the extensive health-based regulatory control, FENOC considers that humanhealth impacts from operating a CAES plant at NES or an alternate site, regardless ofplant location, would be SMALL.I Environmental Impacts of AlternativesPage 7.3-21September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportSocioeconomicsMajor sources of potential socioeconomic impacts from interconnected wind farms withCAES would be similar to those discussed in Section 7.3.3.1. The number of peakconstruction workers expected to build the NES facility is unknown at this time:however, it is likely not to exceed the number for a gas-fired plant with a capacity of 910MWe, which is 1200 (NRC 1996, Table 8.1). FENOC expects that most of theconstruction workforce would commute and relatively few would relocate into the area,and associated socioeconomic impacts during construction would be SMALL. Tooperate and maintain the NES plant would require approximately 50 to 100 workers.FENOC believes that the construction impacts, although noticeable, would be spreadthroughout the State and should not impact any one local community over another. Thefinancial impacts from closing Davis-Besse, however, could be significant to the areassurrounding the station. The addition of an operational workforce for the CAES facilityand new tax revenue for the local community near the CAES facility would be abeneficial impact in that local community. As a result, FENOC considers that the overallsocioeconomic impact of construction and operation of the NES or an alternative CAESsite would be SMALL to MODERATE.Waste ManagementConstruction of interconnected wind farms could result in generation of large amounts ofvegetation from land clearing activities. If this material is managed correctly (e.g.recycled or composted) then the impacts should be SMALL. Like gas-fired generation,NES or an alternative CAES site would result in minimal waste generation, producingminor (if any) impacts (NRC 1996, Section 8.3.10). As a result, FENOC considerswaste management impacts from the operation of a CAES plant at an alternative sitewould be SMALL.AestheticsMost wind farms are located in remote areas and may generate large aestheticconcerns, particularly if sited on highlands or in recreational areas and could have someeffect on the aesthetic quality. In general, impact on aesthetic quality for wind farmslocated in flat-lying rural areas would be SMALLPotential aesthetic impacts of construction and operation of NES or an alternative CAESPlant may include visual impairment resulting from the presence of a large industrialfacility, including multiple exhaust stacks and mechanical-draft cooling towers withassociated condensate plumes. Considering the flat topography in northwestern Ohioand other areas where an alternative CAES may be placed, the stacks and condensateplumes would likely be visible for several miles from the site: new transmission linesconstructed to connect the plant to the grid would also be relatively visible for the sameI Environmental Impacts of AlternativesPage 7.3-22September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportreason, though would not be out of character for most rural areas including thenorthwestern Ohio landscape. (FENOC 2007, Section 7.3.1, Aesthetics)The NES site is on a brownfield area located iust south of Norton, Ohio. Theconstruction of the facility would cause a minor change in the appearance of the area,but aesthetic impacts would be SMALL. FENOC expects that an alternative CAES plantlikely would be located in a rural area, and assumed that adequate buffer andvegetation screens would be provided at the plant site as needed to moderate visualand noise impacts.In view of the environmental review afforded under OPSB rules, FENOC considersthat the impacts to aesthetics from construction and operation of interconnected windfarms and NES or an alternative CAES site would depend on location and be SMALLto MODERATE.Cultural ResourcesAs discussed in Section 7.3.3.1, FENOC concludes that the potential adverse impacton cultural resources of the interconnected wind farms, regardless of location, wouldbe SMALL.FENOC assumed that the NES facility or alternative CAES plant and associatedgas-supply pipeline and transmission lines would be located with consideration of culturalresources under OPSB or comparable program rules, and the impact would be SMALL.7.3.3.3 Photovoltaic Power Combined with CAESEnvironmental impacts of solar power systems can vary based on site-specificconditions. Land use and aesthetics are the primary environmental impacts of solarpower. Land requirements for PV facilities are large, compared to the land currentlyused by Davis-Besse. During operation, however, PV technologies produce no airpollution, little or no noise, and require no transportable fuels.Land UseAs stated in the GElS, land requirements are high: 35,000 ac (14,000 ha) li.e.,54.7 square milesi per 1,000 MWe for PV cells (NRC. 1996).An NREL study (for the western United States) has indicated the amount of landrequired depends on the available solar insolation and ranges from about3.8 to 7.6 acres per MW for photovoltaic systems with a capacity factor ranging from 20to 25%. (NREL 2002) Assuming an average capacity factor of 24% from NREL 2002,and 5 acres per MW, plus an additional 910 MWe needed for energy storage, and theestimated required land would be approximately 37,900 acres (59.2 square miles).I Environmental Impacts of AlternativesPage 7.3-23September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportUnlike wind power generation, all the land used to construct the solar generationfacilities would be Permanently disturbed and could not be used for other purposes.To reduce the amount of land use, the solar facilities could be placed in the samelocations as the wind generation facilities, or brownfield locations assuming these areflat areas with sufficient sunlight. PV arrays are placed on the rooftops of businessesand residential dwellings to generate electricity or to heat water. These units are usuallysmall and are designed to provide energy directly to the facility or residence to whichthey are attached. Only in a few cases are these PV arrays large enough to provideexcess energy to the grid.Based on these data, FENOC considers that the overall impacts of land use fromconstruction and operation of the representative solar power facilities alone wouldbe LARGE.Land use associated with the NES facility would be limited to the facilities' 92 surfaceacres. There would be some land impacted during construction but this site has beenpreviously disturbed so the impact should be SMALL. However, if another site ischosen for the CAES or an additional CAES facility is needed to meet base-loadpower requirements then the potential impacts to land resources could beMODERATE to LARGE.Water Use and Quality -Surface WaterSolar generation using PV technoloqy does not require cooling water or intakestructures. Therefore, there would be no impact on water use and the only potentialimpact on local water quality would be erosion or sedimentation issues duringconstruction. These impacts would be minimized by using best management practicesduring construction activities. Significant amounts of water could be used to keep thesolar panels clean so they remain effective in collecting the maximum amount of sunlightpossible. Since the areas where these solar facilities would be located are not in adesert or semi-arid environment, the demands on water resources should be reduced.Overall, the impacts on water use and quality should be SMALL to MODERATE.Surface water impacts associated with the CAES cooling systems are discussed indetail in Section 7.3.3.2, and are SMALL.Overall, FENOC considers that the impacts from construction and operation of solargeneration facilities and a CAES plant at alternative sites on surface water use andquality would be SMALL to MODERATE.I Environmental Impacts of Alternatives Page 7.3-24 Seotember 2011I Environmental Impacts of AlternativesPage 7.3-24September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportWater Use and Quality -Ground WaterImpacts would depend on whether the plant would use ground water for any purposes,as well as the characteristics of local aquifers. Regardless of location, FENOCassumed that the NES plant or a CAES plant at an alternate site would not rely onground water for plant cooling, and that regulations for ground water use for potablewater would limit impacts to SMALL.Air QualityThere are no air quality impacts associated with the operation of solar generationfacilities.Potential emissions from NES are discussed in Section 7.3.3.2 and Table 7.3-3.FENOC considers that the impacts to air quality from operation of a CAES facility at analternative site would be MODERATE.Ecological ResourcesAs noted in the Land Use subsection above, development of solar generation facilitieswould have a maior impact on land resources, which could have a significant impact onthe ecological resources durinq construction and operation of these facilities. As statedin the Land Use subsection, approximately 37,900 acres would be permanentlydisturbed, and with the possible loss of important habitat. Although FENOC assumedthat construction best management practices and awareness to critical habitat duringoperations would minimize effects to ecological resources, the potential for significantimpacts would be MODERATE to LARGE.As discussed in Section 7.3.3.2, since the NES is a former underqround limestone mineand only has 92 acres of land use at the surface, the potential impact to ecoloqicalresources is SMALL. However, if another CAES site with compressed air storage onthe land surface is chosen or needed to provide additional stored energy capacity, thenthe ecoloqical impacts could be MODERATE to LARGE.Human HealthThe health risks for the construction and operation of a series of solar qenerationfacilities would be accidents and potential exposure to hazardous materials. FENOCassumed that all Occupational Safety and Health Act requirements would becomplied with during construction and operation of these facilities and the impactsshould be SMALL.I Environmental Impacts of Alternatives Page 7.3-25 Seotember 2011I Environmental Impacts of AlternativesPage 7.3-25September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportAs discussed in Section 7.3.3.2, given the extensive health-based regulatory control,FENOC considers that operating the CAES plant at NES or an alternate site, regardlessof plant location, would be SMALL.SocioeconomicsMaior sources of potential socioeconomic impacts from the solar power with associatedNES or CAES facility alternative include temporary increases in iobs, economic activity,and demand for housing and public services in communities surrounding the sitesduring the construction period. These impacts would be spread throughout the stateand should not impact any one local community over another. Countering theseincreases are losses in permanent mobs, tax revenues, and economic activity attributableto operation of the alternative generation facilities and termination of operations ofDavis-Besse. Typically, renewable energy sources are not subject to the tax rate ofconventional energy generating facilities, so the loss of permanent iobs and tax revenuecould be significant to the communities near Davis-Besse and thus the impacts could beSMALL to MODERATE.Communities in Ottawa County, however, particularly those within the taxing jurisdictionof Carroll Township and the Benton-Carroll-Salem School District, would experiencelosses in both employment and tax revenues due to Davis-Besse's closure that couldconstitute MODERATE impacts.The number of peak construction workers expected to build the solar power facilities andthe NES facility is unknown at this time. However, it is likely not to exceed that of a gas-fired plant with a capacity of 910 MWe, which is 1200 (NRC 1996, Table 8.1). Tooperate and maintain the solar facilities and NES plant would require approximately 150to 200 workers. FENOC expects that most of the construction workforce would commuteand relatively few would relocate into the area, and associated socioeconomic impactsduring construction would be SMALL.In summary, FENOC considers that the overall socioeconomic impact of constructionand operation of the representative solar generation combined with CAES generationfacility would be SMALL to MODERATE.Waste ManagementPV technology creates environmental impacts related to manufacture and disposal.Chemicals used in the manufacture of PV cells include cadmium and lead. Potentialhuman health risks also arise from the manufacture and deployment of PV systemsbecause there is a risk of exposure to heavy metals such as selenium and cadmium.The cumulative and long-range impacts from transporting and disposing of hazardouswaste could be SMALL to MODERATE.I Environmental Impacts of AlternativesPage 7.3-26September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportAestheticsMost solar facilities are located in remote areas and would likely not generate largeaesthetic concerns and would likely meet minor public resistance. Overall, the impactsfrom the construction and operation of solar power facilities would be SMALL.Cultural ResourcesDue to the large land use to construct the necessary solar generation facilities and forthe CAES facility, the potential for impacting cultural resources could be LARGE. Tominimize these impacts, FENOC assumed construction activities would considercultural resources under OPSB or comparable program rules. FENOC further assumedthat appropriate measures would be taken to avoid, recover, or provide other mitigationfor loss of any resources discovered during onsite or offsite construction.On this basis, FENOC concludes that the potential adverse impact on cultural resourcesof the solar generating facilities, regardless of location, would be SMALL.FENOC assumed that the NES facility or alternative CAES plant and associatedgas-supply pipeline and transmission line would be located considering culturalresources under OPSB or comparable program rules and, therefore, any impacts wouldbe SMALL.7.3.3.4 Combinations of Wind and Solar with CAESAs discussed in Sections 7.2.1 and 7.2.1.3, FENOC evaluated a combination of windand solar generation along with CAES as an alternative to replace the rated electricaloutput of Davis-Besse.The environmental impact results for interconnected wind farms and PV solar andCAES facilities are discussed in detail in Sections 7.3.3.1 through 7.3.3.3. A summaryof these results is described below and listed in Table 8.0-1.Land UseThe amount of territory required for the construction and operation of a series of windfarms and solar PV facilities would result in LARGE land use impacts. Most of this landwould be in qreenfield or agricultural areas. Although some land used to develop windfarms could be used to generate solar power, there could be several issues includingagriculture needs, transmission capacity and sunlight duration that may limit themultiuse of this land.Land use associated with the NES facility would be limited to the facility's 92 surfaceacres. There would be some land impacted during construction, but this site has beenI Environmental Impacts of AlternativesPage 7.3-27September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportpreviously disturbed so the impact should be SMALL. However, if another site ischosen for the CAES or an additional CAES facility is needed to meet base-load powerrequirements, then the land use impact could be MODERATE to LARGE.Water Use and Quality -Surface WaterWind farms and solar generation using PV technology do not require cooling water orintake structures. Therefore, there would be no impact on water use and the onlypotential impact on local water quality would be erosion or sedimentation issues duringconstruction. These impacts would be minimized by using best management practicesduring construction activities.Significant amounts of water could be used to keep the solar panels clean so theyremain effective in collecting the maximum amount of sunlight as possible. Since theareas where these solar facilities would be located are not in a desert or semi-aridenvironment, the demands on water resources should be reduced. Overall, the impactson water use and quality should be SMALL to MODERATE.CAES have cooling towers associated with the use of gas turbines to produce electricityand compressors to recharge the storage structure. These cooling towers are muchsmaller than those typically used for coal and gas generation plants. Cooling makeupwater evaporative losses and discharge flows for the plant would be considerably lessthan that of Davis-Besse, primarily because less power would be derived from a steamcycle. (FENOC 2007, Section 7.2.2.1)During CAES operation, cooling water and wastewater discharges would be regulatedunder the federal CWA and corresponding state programs by an NPDES permit.Construction activities would be similarly regulated to ensure protection of waterresources. In addition, impacts on water use and quality would be subiect to scrutiny inthe planning stage under OPSB or similar governing authority rules.Overall, FENOC considers that the impacts from construction and operation of thiscombined energy alternative on surface water use and quality to be SMALL toMODERATE.Water Use and Quality -Ground WaterImpacts would depend on whether the combined energy alternative facilities would useground water for any purposes, as well as the characteristics of local aquifers.Regardless of location, FENOC assumed that the NES plant or a CAES plant at analternate site would not rely on ground water for plant cooling, and that regulations forground water use for potable water would limit impacts to SMALL. FENOC alsoassumed that construction of the facilities would employ best management practices tokeep the impact to groundwater quality SMALL.I Environmental Impacts of AlternativesPage 7.3-28September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportAir QualityThe construction of roads and turbine tower supports would result in short-term impactsin air quality from fugitive dust and equipment emissions. There are no air qualityimpacts associated with the operation of wind farms and solar PV facilities, therefore theoverall impacts would be SMALL.CAES facilities use natural gas, which is a relatively clean-burning fuel with nitrogenoxides being the primary focus of combustion emission controls. The NES facility hasbeen issued an air permit by the Ohio EPA, and emission details are discussed inSection 7.3.3.2 and Table 7.3-3. FENOC assumed that best management practiceswould be utilized during construction activities to minimize impacts to air quality. Inaddition, FENOC assumed that the NES or alternate CAES facility would comply with itsair permit, thus impacts to air quality should be MODERATE.Ecological ResourcesAs noted in the Land Use subsection above, development of wind farms and solar PVfacilities and CAES would have a MODERATE to LARGE impact on land resourceswhich could have a MODERATE to LARGE impact on the ecological resources duringconstruction and operation of these facilities. FENOC assumed that construction bestmanagement practices and awareness to critical habitat during operations wouldminimize impacts to ecological resources.Human HealthThe only major health risk for the construction and operation of a series of wind farmsand solar PV facilities, and a CAES plant would be accidents. There may be minorhealth impacts from reduced air quality during construction and the operation of theCAES facility and from handling potential hazardous substances or waste materials.FENOC assumed that all air permits and Occupational Health and Safety Actrequirements would be complied with during construction and operation of thesefacilities, and the impacts should be SMALL.SocioeconomicsMaior sources of potential socioeconomic impacts from wind farms and solar PVsystems with an associated NES or CAES facility include temporary increases in obs.economic activity, and demand for housing and public services in communitiessurrounding the sites during the construction period. Socioeconomic impacts are similarto those discussed in Sections 7.3.3.1 to 7.3.3.3 and would be SMALL to MODERATE.I Environmental Impacts of AlternativesPage 7.3-29September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportWaste ManagementPV technology creates environmental impacts related to manufacture and disposal.Chemicals used in the manufacture of PV cells include cadmium and lead. Potentialhuman health risks also arise from the manufacture and deployment of PV systemsbecause there is a risk of exposure to heavy metals such as selenium and cadmium.The cumulative and long range impacts from transporting and disposing of hazardouswaste could be a MODERATE to LARGE impact. Minimal waste streams should begenerated from the construction and operations of the wind power and CAES facilities.Therefore, the impacts should be SMALL.AestheticsMost wind farms are located in remote areas and may generate large aestheticconcerns, particularly if sited on highlands or in recreational areas. Solar PV generationrequires relatively flat land, which limits the view to the public. However, presence ofoverhead transmission lines may cause some moderate public resistance. To minimizethese impacts, the renewable generation facilities would likely be located in rural areasas much as possible. The proposed NES facility is located in a brownfield area andshould not change the aesthetic view of the area. Overall, the aesthetic impacts fromthese facilities should be SMALL.Cultural ResourcesDue to the large amount of land needed to construct the necessary wind farms and solarPV facilities, and for the CAES facility, the potential for impacting cultural resources couldbe LARGE. To minimize these impacts, FENOC assumed construction activities wouldconsider cultural resources under OPSB or comparable program rules. FENOC furtherassumed that appropriate measures would be taken to avoid, recover, or provide othermitigation for loss of any resources discovered during onsite or offsite construction. Onthis basis, FENOC concludes that the potential adverse impact on cultural resources ofthis combined energy alternative regardless of location would be SMALL.7.3.3.5 Conclusions of Combining New Generation Power Sources with StorageThe use of wind power in the form of interconnected wind farms and/or solarphotovoltaic power, in combination with CAES to provide power to replaceDavis-Besse's output by 2017 has been evaluated and discussed in the subsectionsabove. The environmental impacts associated with renewable sources and CAES wereevaluated in Subsections 7.3.3.1.7.3.3.2.7.3.3.3 and 7.3.3.4. The overall conclusionfrom this impact analysis is that the combination of these energy source alternatives hasSMALL to LARGE impacts. These impacts are compared in Section 8.0 to the impactsfrom renewal of the Davis-Besse license for another 20 years as well as those for thealternative coal and natural gas fired plants.I Environmental Impacts of AlternativesPage 7.3-30September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 7.3-1: Air Emissions from Coal-Fired AlternativeParameterO) Calculation ResultHeat RateTotal Gross Capability x Heat Rate x Conversion Factors x Capacity Factor tons/yearAnnual Coal Heat ValueConsumption 910 MW x 9,800 Btu lb 1,000 kW 8,760 hr tonxx -x- x 0.80 2,543,644kW x hr 12,285 Btu MW year year 2,000 lbEmissions Coal Consumption x Uncontrolled Emissionsx Conversion Factors x [100 -removal efficiency (%)](2) tons/year2,543,644 tons 130 lb ton 100-95year ton 2,000 lb 100NOx 2,543,644 tons 10lb ton 100-60year ton 2,000 lb 100CO 2,543,644 tons 0.51b ton 636year ton 2,000 lbPM 2,543,644 tons 120 lb ton 100-99.9year ton 2,000 lb 100PM1, 2,543,644 tons 27 lb ton 100- 99.9year ton 2,000 lb 1002,543,644 tons 6,000 lb tonC02 2,4,4 tor x -7,630,3year ton 2,000 lbBtu = British thermal unitsCO = carbon monoxideCO2 = carbon dioxidehr = hourkW = kilowattlb = poundMW = megawattNOx = nitrogen oxidesPM = total filterable particulate matterPM10 = PM having a diameter less than 10 micronsSOx = sulfur oxidesNotes:(1) Source: Table 7.2-1(2) There are no emission controls for CO and CO2.I Environmental Impacts of AlternativesPage 7.3-31September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 7.3-2: Air Emissions from Gas-Fired AlternativeParameterO) Calculation ResultGross Capability x Heat Rate x Conversion Factors x Capacity Factor MMBtu/yearAnnual GasHeat input 910 MW x 6,500 Btu 1,000 kW 8,760 hrHetInu 1 Wx x -x -- x 0.80 41,452,320kW-hr MW yearEmissions Annual Gas Heat Input x Uncontrolled Emissions tons/yearx Conversion Factors x [100 -removal efficiency (%)] (2)41,452,320 0.00064 lb ton 13.3year MMBtu 2,000 lbNOx 41,452,320 0.099 lb X ton 100 -90year MMBtu 2,000 lb 100CO 41,452,320 0.015 lb tonyear MMBtu 2,000 lbPM (all PM1o) 41,452,320 0.019 lb tonyear MMBtu 2,000 lb41,452,320 110 Ib tonCO2year MMBtu 2,000 lbBtu = British thermal unitsCO = carbon monoxideCO2 = carbon dioxidehr = hourkW = kilowattIb/MMBtu = pounds per million British thermal unitsMW = megawattNOx = nitrogen oxidesPM = particulate matterPM1o = PM having a diameter less than 10 micronsSOx = sulfur oxides (mainly SO2)Notes:(1) Source: Table 7.2-2(2) There are no emission controls for SO2, CO, PM, and CO2.I Environmental Impacts of AlternativesPage 7.3-32September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 7.3-3 Permifted Air Emissions from theProposed Norton Energv Storage ProjectParameter Quantity VolumeS_. 42.41 tons/year*NO, 93.67 tons/year*CO 90.36 tons/year*all PM1 46.65 tons/year*Volatile Or-ganic 26.40 tons/year*CompoundsC 681,100 tons/year*CO = carbon monoxideCOz = carbon dioxideNOx = nitrogen oxidesPM = particulate matterPM10 = PM having a diameter less than 10 micronsSO = sulfur dioxide* Based on rolling, 12-month permitsEmissions are li~tp.d hased on Permit information, and are from units PO01 -POO6.E~mbisinsae inulistdbae otrinPermi~toinfomaio andr~ iare~ trom unit P00(14 -W P006iEouipment Description: Each Combustion Train -589MMBtu/hr Dresser Rand natural gasfired combustion turbine (134 MW) operating in simple cycle mode with recuperatorcontrolled by catalytic oxidation, water injection, and selective catalytic reduction.As exolained in Serction 7 213. FirstEnermv estimates that only un to four unitsAs exnlained in Section 7 2 1 3 FirstEnerav estimates that onIv un to four units(i.e., 536 MW) could be online by 2017.Source: NES 2010I Environmental Impacts of Alternatives Page 7.3-33 September 2011I Environmental Impacts of AlternativesPage 7.3-33September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report[This page intentionally blank]I Environmental Impacts of Alternatives Page 7.3-34 Seotember 2011I Environmental Impacts of AlternativesPage 7.3-34September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report7.4 REFERENCESNote to reader: This list of references identifies web pages and associated URLs wherereference data were obtained. Some of these web pages may likely no longer beavailable or their URL addresses may have changed. FENOC has maintained hardcopies of the information and data obtained from the referenced web pages.,AEP 2011. AEP Ohio to Partner with Turning Point Solar on the Development of the ---Deleted: EERE 2008. Advantages---J and Disadvantages of Wind Energy,Turning Point Solar Generatinq Facility in MNoble County, Website: U.S. Department of Energy, Office of.httr:/lwww.prnewswire.com/. ... oartner-with-tturning-point-on-the-development-of-the- Energy Efficiency and Renewableturning-point-solar-generation-facility-in-noble-county-125021444.html, accessed .[ Energy, Website:September 6. 2011. Deleted: http:/Mvwwl .eere.energy.govtwindandhydro/wind_ad.htmlAWEA 2002. Most Frequently Asked Questions About Wind Energy, American WindEnergy Association, May 2002.AWEA 2011. Wind Energy Facts: Ohio, American Wind Energy Association, July 2011.CA 2011. Machines of the Ocean: The Aesthetics od Wind Farms, ContemporaryAesthetics. Website:http://www.contempaesthetics.org/newvolume/pages/article.php?articlelD=247,accessed September 7. 2011.CBS 2010. World's Largest Wind Farm Churns in Texas, CBS News, Website:cbsnews.com/stories/2009/10/02/tech/livinggreen/main5358287.shtm, accessedSeptember 1. 2011.CWP 2007. Cape wind Energy Proiect Final Environmental Impact report/Developmentof Regional Impact, Cape wind Project, February 2007.EERE 2009a. Ohio Wind Resource Map, U.S. Department of Energy, Energy Efficiencyand Renewable Energy, available athttp://www.windpoweringamerica.gov/astate-template.asp?stateab=oh, accessedJune 30, 2009.EERE 2009b. Pennsylvania Wind Resource Map, U.S. Department of Energy, EnergyEfficiency and Renewable Energy, available athttp://www.windpoweringamerica.gov/astate-template.asp?stateab=pa, accessedJune 30, 2009.EIA 2010. Electric Power Annual 2008, DOE/EIA-0348(2008), U.S. Department ofEnergy, Energy Information Administration, January 2010.References Page 7.4-1 September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportFENOC 2007. FirstEnergy Nuclear Operating Company, Beaver Valley Power StationUnit Nos. 1 and 2, License Renewal Application, Appendix E, Applicant's EnvironmentalReport -Operating License Renewal Stage, Facility Operating License No. DPR-66and NPF-73, Akron, OH, ADAMS Accession No. ML072470523.FirstEnergy 2008a. 2008 Annual Report, FirstEnergy Corp., Akron, Ohio, Website:http://www.firstenergycorp.com/financialreports/index.html, accessed January 12, 2010.FirstEnergy 2008b. FirstEnergy Generation System, 6/25/08, Website:http://www.firstenergycorp.com/corporate/Corporate-Profile/FirstEnergyGeneration_System.html, accessed July 13, 2009.FirstEnergy 2009a. FirstEnergy Boston Investor Meetings, June 11, 2009, Website:http://investors.firstenergycorp.com/phoenix.zhtml?c= 1 02230&p=irol-presentations,accessed June 21, 2009.FirstEnergy 2009b. FirstEnergy to Repower R.E. Burger Plant With Biomass, NewsRelease, FirstEnergy Corp., Akron, Ohio, April 1, 2009.GLWEC 2009. Final Feasibility Report, Great Lakes Wind Energy Center, April 2009.IEAWIND 2002. Summary of lEA R&D Wind -Topical Expert Meeting #40,Environmental issues of Offshore Wind Farms, September 2002.INEEL 1998. U.S. Hydropower Resource Assessment Final Report, DocumentDOE/ID-10430.2, Idaho National Engineering and Environmental Laboratory, December1998.NEI 2008. Nuclear Energy in Ohio Fact Sheet, Nuclear Energy Institute, July 2008.ISEP 2011. Iowa Stored Energy Park Proiect Terminated, Press Release,July 28. 2011.JACM2007. Supplying Baseload Power and Reducing Transmission Requirements byInterconnected Wind Farms, Journal of Applied Meteorology and Climatotology,November 2007.LEEDco 2011. About LEEDco Lake Erie Energy Development Corporation, Website.www.leedco.org/about-us/about-leedco, accessed August 10, 2011.NEI 2008. Nuclear Energy in Ohio Fact Sheet, Nuclear Energy Institute, July 2008.NERC 2009. 2009 Long Tern Reliability Assessment, North American ElectricReliability Corporation, October 2009.References Page 7.4-2 September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportNES 2010. Norton Energy Storage, LLC, Final Air Permit-To-Install and Operate, OhioEPA, September 2010.NRC 1996. Generic Environmental Impact Statement for License Renewal of NuclearPower Plants (GELS), NUREG-1437, Volumes 1 and 2, U.S. Nuclear RegulatoryCommission, Office of Nuclear Regulatory Research, May 1996.NRC 2002. Final Generic Environmental Impact Statement on Decommissioning ofNuclear Facilities, Supplement 1, Regarding the Decommissioning of Nuclear PowerReactors, NUREG-0586 Supplement 1, Volume 1, U.S. Nuclear RegulatoryCommission, Office of Nuclear Reactor Regulation, November 2002.NRC 2009a. Combined License Applications for New Reactors, Website:http://www.nrc.gov/reactors/new-reactors/col.html, accessed July 13, 2009.NRC 2009b. Generic Environmental Impact Statement for License Renewal of NuclearPower Plants (GELS), NUREG-1437, Supplement 36, U.S. Nuclear RegulatoryCommission, Office of Nuclear Regulatory Research, May 2009.NRC 2010. _Combined License Applications for New Reactors, Website:http://www.nrc.gov/reactors/new-reactors/col.html, accessed June 18, 2010.S2002. Fuel from the Sky -Solar Power's Potential for Western EnergySul. _ --S Deleted: NREL 1986. Wind EnergyResource Attas of the United States,National Renewable Energy Laboratory, July 2002. U.S. Department of Energy, DOEJCH10093-4, Pacific Northwest NationalNREL 2010. Large-Scale Offshore Wind Power in the United States, National Laboratory, October 1986, Website:http:llrredc.nrel.govtwind/pubs/atlas/aRenewable Energy Laboratory, June 2010. tlasindex.html, accessed July 13,%2009.11NREL 2010a. Assessment of Offshore Wind Energy for the United States, NationalRenewable Eneraqy Laboratory, September 2010.NREL 2011. Eastern Wind Integration and Transmission Study, National RenewableEnergy Laboratory, February 2011.NREL 2011a. Estimates of Windy Land Areas and Wind Energy Potential by State,National Renewable Energy Laboratory, Updated April 13, 2011.OHPUCO 2009. Alternative Energy Portfolio Standard, Chapter 4901: 1-40, Ohio PublicUtilities Commission, December 2009.PEI 2008. Compressed Air Energy Storage,: Theory, Resources, and Applications forWind Power Energy Systems Analysis group, Princeton Environmental institute,Princeton Universitv. Adril 2008...................... I I " -F ........PMJ 2011. State of the Market report for PJM, Monitoring Analytics, LLC, August 2011.ReferencesPage 7.4-3 September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportPOST 2006. Carbon Footprint of Electricity Generation, Parliamentary Office ofScience and Technology, October 2006, available athttp:/lwww.parliament.ukldocuments/upload/postpn268.pdf, accessed July 8, 2009.PSEG 2010. Governor Strickland Helps Dedicate Ohio's Largest Solar Farm, MediaRelease from Public Service Enterprise Group, August 19, 2010.REN 2005. Assessing the Life Cycle of Wind turbine Production, Renewable EnergyWorld, Website. www.renewableenerqvworld.com/rea/news/article/2005/04/assessinq -the-life-cycle-of-wind-turbine-production-25113, accessed Auqust 6, 2011.RES 2005. The Economic Impact of CAES on Wind in TX, OK. and NM, Ridge EnerqyStorage & Grid Services, L.P., June 2005.RWC 2010. Roscoe Wind Council, Website:http://www.roscoewind.org/roscoe wind farm/php. accessed September 11, 2011.SWAY 2010. Norway to Build the World's Largest Wind Turbine, Website.http://inhabitat.com/norway-to-build-the-worlds-largest-wind-turbine, accessedSeptember 1,2011.TBM 2011. lberdrola Sells Energy from Blue Creek Wind Farm project, Times BulletinMedia, February 9. 2011. Website:http://www.timesbulletin.com/main.asp?SectionlD=2&SubsectionlD=4&ArticlelD=164339.TEP2006. Photovoltaic Power Experience at Tucson Electric Power, Sandia NationalLaboratories and Tucson Electric Power Company, April 2006.USDOE 1999. Executive Summary, Clean Coal Technology Evaluation Guide -FinalReport, December 1999, available athttp://www.netl.doe.gov/technologies/coalpower/cctc/ccpi/bibliography/program/bibp-ev.html, accessed June 26, 2009.USDOE 2009a. Installed U.S. Wind Capacity and Wind Project Locations, Website:http://www.windpoweringamerica.gov/windinstalledcapacity.asp, accessedJuly 9, 2009.USDOE 2011. A national Offshore Wimd Strategy: Creating an Offshore Wind EnergyIndustry in the United States, U.S. Department of Energy, February 2011.USDOI 2011. News Release -Salazar Announces Additional Steps Towards SmarterDevelooment of Renewable Energy on U.S. Public Land, United States Department ofInterior, February 8, 2011.References Page 7.4-4 September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportUSDOE 2009b. Future Fuel Cells R&D, U.S. Department of Energy, Office of Scienceand Technology, Website:http://www.fossil.energy.gov/programs/powersystems/fuelcells/, accessed June 30,2009.USDOE 2010. Monthly Nuclear Generation by State and Reactor, 2008, U.S.Department of Energy, Energy Information Administration, Website:http://www.eia.doe.gov/cneaf/nuclear/page/nucgeneration/gensum.html, accessedJanuary 12, 2010.USEPA 2009a. Electricity from Municipal Solid Waste, U.S. Environmental ProtectionAgency, Website: http://www.epa.gov/cleanenergy/energy-and-you/affectlmunicipal-sw.html, accessed June 30, 2009.USEPA 2009b. EPA's Response to the TVA Kingston Fossil Fly Ash Release,U.S. Environmental Protection Agency, Region 4, May 11, 2009.USFWS 2002. Migratory Bird Mortality, United States Fish and Wildlife Service,January 2002.USFWS 2011. United States Fish and Wildlife Service -Draft Land-Based WindEnergy Guidelines, February 2011.WGA 2011. Timber Road Wind Farm in Ohio, Wind Action Group, Website.http://waqengineering.blogspot.com/2011/05/timber-road-wind-farm-in-ohio.html,accessed September 1. 2011.WTE 2007. 2007 Directory of Waste-to-Energy Plants in the United States, Waste-to-Energy Resources, Energy Recovery Council, Website: http://www.wte.org/waste-energy-resources-a2985, accessed June 30, 2009.References Page 7.4-5 September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report[This page intentionally blank]I ReferencesReferences Page 7.4-6 Seotember 2011Page 7.4-6September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report8.0 COMPARISON OF ENVIRONMENTAL IMPACT OF LICENSERENEWAL WITH THE ALTERNATIVESRegulatory Requirement: 10 CFR 51.45(b)(3)"To the extent practicable, the environmental impacts of the proposal and thealternatives should be presented in comparative form." as adopted by10 CFR 51.53(c)(2)."FENOC presents its evaluations of the environmental impacts of Davis-Besse licenserenewal in Chapter 4 and reasonable alternatives in Chapter 7. In this chapter, FENOCprovides a comparative summary of these impacts.Table 8.0-1 summarizes environmental impacts of the proposed action (licenserenewal) and the alternatives, for comparison purposes. The environmental impactscompared in Table 8.0-2 are those that are either Category 2 issues for the proposedaction or are issues that the GElS (NRC 1996) identified as major considerations in analternatives analysis. For example, although the NRC concluded that air quality impactsfrom the proposed action would be small (Category 1), the GElS identified major humanhealth concerns associated with air emissions from alternatives (Section 7.2.2).Therefore, Table 8.0-1 compares air quality impacts from the proposed action to thealternatives. Table 8.0-2 is a more detailed comparison of the alternatives.As shown in Table 8.0-1 and Table 8.0-2, environmental impacts of the proposed action(Davis-Besse license renewal) are expected to be SMALL for all impact categoriesevaluated. In contrast, FENOC expects that environmental impacts in some impactcategories would be MODERATE or MODERATE to LARGE for the no-actionalternative (NRC decision not to renew Davis-Besse operating license), considered withor without development of replacement generation facilities.As codified in the NRC regulations at 10 C.F.R. ý 51.95(c)(4). "the NRC staff.--------. --Deleted: As a result,adiudicatory officers, and Commission shall determine whether or not the adverseenvironmental impacts of license renewal are so great that preservinq the option oflicense renewal for energy planning decision makers would be unreasonable."The Commission explained this standard as follows:Given the uncertainties involved and the lack of control thatthe NRC has in the choice of energy alternatives in thefuture, the Commission believes that it is reasonable toexercise its NEPA authority to reiect license renewalapplications only when it has determined that the impacts ofComparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-1 September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Reportlicense renewal sufficiently exceed the impacts of all oralmost all of the alternatives that preservinq the option oflicense renewal for future decision makers would beunreasonable.Environmental Review for Renewal of Nuclear Power Plant Operating Licenses,61 Fed. Reg. 28,467, 28,473 (June 5. 1996).FENOC concludes that the environmental impacts of the continued operation ofDavis-Besse, providing approximately 910 MWe of base-load power generation through2037, when compared to alternatives discussed in Section 7.0 of this EnvironmentalReport, demonstrate that preservingq license renewal as an option is not unreasonable.Deleted: are superior to impactsassociated with the best case amongreasonable alternatives. Davis-Bessecontinued operation would createsignificantly less environmentalimpact than the construction andoperation of new base-loadgeneration capacity. Additionally,Davis-Besse continued operation willhave a significant positive economicimpact on the communitiessurrounding the stationComparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-2 September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.0-1: Impacts Comparison SummaryNo-Action Alternatives(1)ProposedImpact(2) Action Base With With(License (Decommissioning) With Coal-Fired With Gas-Fired Interconnected Renewable &Renewal) Generation Generation Wind CAESGenerationLand Use SMALL SMALL MODERATE to SMALL to MODERATE to LARGELARGE MODERATE LARGESMALL toWater Quality SMALL SMALL SMALL SMALL SMALL MODERtEMODERATEAir Quality SMALL SMALL MODERATE MODERATE(3" SMALL MODERATEEcological SMALL SMALL MODERATE SMALL to SMALL to LARGE MODERATE toResources MODERATE LARGEHuman Health SMALL SMALL SMALL SMALL SMALL SMALLSocioeconomics SMALL SMALL MODERATE MODERATE SMALL to SMALL toMODERATE MODERATEWasteM agee SMALL SMALL MODERATE SMALL SMALL SMALLManagementSMALL to SMALL to SMALL toAesthetics SMALL SMALL MODERATE MODERATE MODERATE SMALLCultural Resources SMALL SMALL SMALL SMALL SMALL SMALLPage 8.D~3 Seotember 2011Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.073September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportNotes:(1) Environmental impacts associated with the construction and operation of new coal-fired or gas-fired generating capacity at agreenfield site would exceed those for a coal-fired or gas-fired plant located at a brownfield, i.e., existing disturbed site.(2) From 10 CFR Part 51, Subpart A, Appendix B, Table B-1, Footnote 3:-SMALL -Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter anyimportant attribute of the resource.-MODERATE -Environmental effects are sufficient to alter noticeably, but not destabilize, any important attribute of theresource.-LARGE -Environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource.(3) Moderate, but less than with coal-fired generation.Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-4September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.0-2: Impacts Comparison DetailNo-Action Alternatives(1)' (2)Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R aeGeneration Generation Wind Generation GnatoGenerationAlternative DescriptionsDavis-Besse license Decommissioning New construction at New construction at New construction at New constructionrenewal for 20 years, following expiration of greenfield (but greenfield (but .reenfield locations, at ,reenfield (wind,followed by current Davis-Besse preferably brownfield) preferably brownfield) and solar) CAES atdecommissioning license. Adopting by site. site. brownfield site.reference, as boundingDavis-Besse Pulverized coal units, Combined-cycle units, Wind generation Assume CAES withdecommissioning, GElS 910-MW (equivalent 910-MW (equivalent units, 910-MW natural gas units atdescription (NRC 1996, to Davis-Besse); to Davis-Besse); (equivalent to electrical output ofSection 7.1). capacity factor 0.80. capacity factor 0.80. Davis-Besse); 804 MW (6 trains).capacity factor 0.80.Closed-cycle cooling Closed-cycle cooling No cooling required. Closed-cyclewith 500-foot-tall with mechanical-draft cooling withnatural-draft cooling cooling towers. mechanical-drafttowers, cooling towers forCAES.Coal and limestone Delivery of natural gas No fuel delivery Delivery of naturaldelivery via waterway via a new 10-mile- system required. gas via a newor rail. long pipeline. 10-mile-lonqpipeline for CAES.Page 8.0-5 Seotember 2011Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-5September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.0-2: Impacts Comparison Detail (continued)No-Action Alternativest1t (2)Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R aeGeneration Generation Wind Generation &eCaEoGenerationAir emission controls: Air emission controls: No air emission Air emissionParticulates: fabric Nitrogen oxides: dry controls required. controls: Nitrogenfilter (99.9% removal) low-NOx burners; oxides: dry low-Sulfur oxide: wet selective catalytic NOx bumers:limestone scrubber reduction (90% selective catalytic(95% removal) removal). Particulate reduction (90%Nitrogen oxide: matter and carbon removal).low-NOx burners, monoxide emissions Particulate matteroverfire air, selective limited through proper and carboncatalytic reduction combustion controls. monoxide(95% removal), emissions limitedthrough propercombustioncontrols for CAES.Emissions dispersed Exhaust dispersed via No emissions or Exhaust dispersedvia 500-foot-tall 150-foot-tall stacks. heat plume exhaust, via 150-foot-tall (orstacks. less) stacks.825 permanent and Estimated workforce: Estimated workforce: Estimated Estimated60 contract workers Construction: 1,092 -Construction: 1,092 -workforce: workforce:(Section 3.4) 2,275; Operation: 228 2,275; Operation: 137 Construction: 1,200 Construction: 1,200-1,500a Operation: -1,500: Operation:150. 150.Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-6September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.0-2: Impacts Comparison Detail (continued)No-Action Alternatives(1)' (2)Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R aeGeneration Generation Wind Generation &eCaESGenerationLand Use ImpactsSMALL -Adopting by SMALL -Adopting by MODERATE to SMALL to MODERATE to LARGE -up toreference Category 1 reference applicable LARGE -1,547 acres MODERATE -100 LARGE -Would be 91,000 acresissue findings NRC impact conclusions required for the acres for facility and dependent on how required for wind(Table A-i, Issues 52, in the GElS Section 8.4 powerblock and 240 to 270 additional many wind farms and 37,900 acres53). and Supplement 1 to associated facilities; acres for gas pipeline onshore verses for solar generationNUREG-0586. assumed 10 miles of and electric offshore and associated345-kV transmission transmission lines (Section 7.3.3). facilities:line on a 150-foot (Section 7.3.2). (Section 7.3.3).right-of-way; 22acres/MW for miningand disposal(Section 7.3.1).Page 8.0-7 Seotember 2011Comparison of Environmental Impact of.License Renewal with the AlternativesPage 8.0-7September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReporTable 8.0-2: Impacts Comparison Detail (continued)No-Action Alternativest1)' (2)Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R aeGeneration Generation Wind Generation GCatoGenertionGenerationWater Quality ImpactsSMALL -Adopting by SMALL -Adopting by SMALL -SMALL -SMALL -SMALL toreference Category 1 reference Category 1 Construction impacts Construction impacts Construction MODERATE -issue findings (Table issue finding (Table A-i, minimized by minimized by impacts minimized ConstructionA-i, Issues 1-3, 6-11, Issue 89) in the GElS regulatory controls; regulatory controls; by regulatory impacts minimizedand 31). Five Chapter 7 and operation-phase cooling water and controls by reaqulatoryCategory 2 water Section 8.4, and in impacts similar to wastewater (Section 7.3.3). controls: coolinqquality issues do not Supplement 1 to those of Davis-Besse; discharges subject to water andapply: Section 4.1, NUREG-0586. cooling water and regulatory controls wastewaterIssue 13; Section 4.6, wastewater (Section 7.3.2). discharges subjectIssue 34, Section 4.5, discharges subject to to regulatoryIssue 33; Section 4.7, regulatory controls controlsIssue 35; and (Section 7.3.1). (Section7.3.3).Section 4.8 Issue 39.Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-8September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.0-2: Impacts Comparison Detail (continued)No-Action Alternatives(')' (2)Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R aeGeneration Generation Wind Generation GnatoAir Quality ImpactsSMALL -Adopting by SMALL -Adopting by MODERATE -MODERATE -SMALL -MODERATE -reference Category 1 reference Category 1 8,267 tons SOx/year 13.3 tons S02/year Construction 42.41 tonsissue finding issue findings 5,087 tons NOx/year 205 tons NOx/year impacts minimized S02/vea(Table A-1, Issue 51). (Table A-i, Issue 88) in 636 tons CO/year 311 tons CO/year by regulatory 93.67 tonsOne Category 2 issue the GElS Chapter 7 and 153 tons PM/year 39.4 tons PM/year controls NOx/veardoes not apply: Section 8.4, and in 34.3 tons PM1o/year 2.28x106 tons (Section 7.3.3). 90.36 tons CO/yearSection 4.11, Supplement 1 to 7.63x106 tons C02/year 46.65 tons PE/yearIssue 50. NUREG-0586. C02/year (Section 7.3.2). 26.40 tons(Section 7.3.1). VOQs/year681.1 x10 tons ofC0t/yea )(Section 7.3.3).Page 8.0-9 SeDtember 2011Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-9September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental RepooTable 8.0-2: Impacts Comparison Detail (continued)No-Action Alternatives1'(2)Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R aeGeneration Generation Wind Generation &CaESGeneatio I_____________ GenerationEcological Resource ImpactsSMALL- Adopting by SMALL- Adopting by MODERATE -SMALL to SMALL to MODERATE toreference Category 1 reference Category 1 Potential loss or MODERATE -MODERATE -LARGE- Potentialissue findings issue finding alteration of more Approximately 100 Habitat and loss or alteration of(Table A-i, Issues (Table A-i, Issue 90) in than 1,500 acres of acres onsite and 240 migratory impacts more than 90,00014-24, 28-30, 41-43, the GElS Chapter 7 and habitat (e.g., to 270 acres offsite of would be greater for acres of habitatand 45-48). Three Section 8.4, and in transmission, waste largely agricultural land based wind (e.g., wind andCategory 2 issues do Supplement I to disposal landfill); land would be farms then offshore solar facilities,not apply: NUREG-0586. facilities siting would converted to industrial wind farms (e.g., transmission)*Section 4.2, Issue 25; be subject to use for plant site and wind facilities, facilities sitingSection 4.3, Issue 26; regulatory controls offsite infrastructure, transmission)@ would be subiect toand Section 4.4, limiting impacts to respectively; facilities facilities siting would regulatory controlsIssue 27. ecological resources, siting would be be subject to limiting impacts toincluding wetlands subject to regulatory regulatory controls ecologicaland threatened or controls limiting limiting impacts to resources,endangered species. impacts to ecological ecological including wetlandsImpact on aquatic resources, including resources, including and threatened orhabitats and biota wetlands and wetlands and endangeredfrom dredging (e.g., threatened or threatened or speciesfor intake and endangered species. endangered species (Section 7.3.3).discharge structures Potential for impacts (Section 7.3.3).and, if applicable, to aquatic resourcesbarge terminal), from construction andcooling water operation (e.g.,withdrawal, and cooling waterdischarge would be withdrawal andComparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-10September 201-1 Davis-Lense Nulewar PAppr StationLicense Renewal ApplicationEnvironmental RepooTable 8.0-2: Impacts Comparison Detail (continued)No-Action Alternatives1)' (2)Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R aeGeneration Generation Wind Generation &eCaEoGenerationsubject to regulatory discharge) reduced bycontrols best management(Section 7.3.1). practices andregulatory controls(Section 7.3.2).Threatened or Endangered Species ImpactsSMALL -Federally SMALL -Not an impact SMALL -Federal and SMALL -Federal and SMALL -Federal SMALL -Federaland state threatened evaluated by the GEIS. state laws prohibit state laws prohibit and state laws and state lawsor endangered destroying or destroying or prohibit destroying prohibit destroyingspecies are protected adversely affecting adversely affecting or adversely or adverselythrough company and protected species and protected species and affecting protected affecting protectedplant procedures. their habitats. their habitats. species and their species and their(Section 4.10, habitats, habitats.Issue 49)Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-11September 2011 Daviq-BeRse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.0-2: Impacts Comparison Detail (continued)No-Action Alternatives(1t' (2)Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R aeGeneration Generation Wind Generation &CaESGenerationHuman Health ImpactsSMALL -Adopting by SMALL -Adopting by SMALL -Some risk of SMALL -Similar to SMALL SMALL -Similar toreference Category 1 reference Category 1 cancer and the coal-fired (Section 7.3.3). the gas-firedissues (Table A-i, issue finding (Table A-i, emphysema from air alternative alternative (CAESIssues 54-56, 58, 61, Issue 86) in the GElS emissions and risk of (Section 7.3.2). plant)62). One Category 2 Chapter 7 and accidents to workers, (Section 7.3.3).issue does not apply: Section 8.4, and in as the NRC notes inSection 4.12, Supplement 1 to the GELS.Issue 57. Risk due to NUREG-0586. Assumed thattransmission-line regulatory controlsinduced currents would reduce risks tominimal due to acceptable levelsconformance with (Section 7.3.1).consensus code(Section 4.13,Issue 59).Page 8.0-12 Seotember 2011Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-12September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental RepotTable 8.0-2: Impacts Comparison Detail (continued)No-Action Alternatives1' (21Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R aeGeneration Generation Wind Generation &CaESGeneatin j_____________ GenerationSocioeconomic ImpactsSMALL -Adopting by SMALL -Adopting by MODERATE to MODERATE -MODERATE -MODERATE -reference Category 1 reference Category 1 Reduction in Reduction in Reduction in Reduction inissue findings issue finding (Table A-i, permanent work force permanent work force permanent work permanent work(Table A-1, Issues 64, Issue 91) in the GElS and tax base at and tax base at force and tax base force and tax base67). Two Category 2 Chapter 7 and Davis-Besse would Davis-Besse would at Davis-Besse at Davis-Besseissues do not apply: Section 8.4, and in adversely affect adversely affect would adversely would adverselySection 4.16, Issue 66 Supplement 1 to surrounding surrounding affect surrounding affect surroundingand Section 4.17.1, NUREG-0586. communities. communities. communities. communities.Issue 68. Location in Construction and Impacts from Impacts from Impacts fromhigh population area operational impacts construction would be construction would construction wouldwith no growth would depend upon mitigated by siting be miti-gated by be mitigated bycontrols minimizes the site location, plant within sitinq renewable siting renewablepotential for housing Regulatory controls commuting distance facilities within facilities withinimpacts (Section 4.14, and appropriate of large metropolitan commuting distance commutingIssue 63). mitigation would areas (Section 7.3.2). of metropolitan distance ofCapacity of public ensure that impacts areas when possible metropolitan areaswater supply as well are not destabilizing (Section 7.3.3). when possibleas education and (Section 7.3.1). (Section 7.3.3).transportationinfrastructuresminimizes potentialfor related impacts(Section 4.15, Issue65; Section 4.16,Issue 66; and SectionComparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-13September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.0-2: Impacts Comparison Detail (continued)No-Action Alternatives(1}'(2)Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R aeGeneration Generation Wind Generation GnatoGenertionGeneration4.18, Issue 70).Plant tax paymentsrange from <10% tonearly 20% of localjurisdictions taxrevenues (Section4.17.2, Issue 69).Waste Management ImpactsSMALL -Adopting by SMALL -Adopting by MODERATE -Annual SMALL -Solid waste SMALL -Solid SMALL -Solidreference Category 1 reference Category 1 waste of is minimal (Section waste is minimal waste is minimalissue findings issue finding Table A-i, approximately 7.3.2). (Section 7.3.3). (Section 7.3.3).(Table A-i, Issue 87) in the GElS 300,000 tons ash andIssues 77-85). Chapter 7 and 470,000 tons flue gasSection 8.4, and in desulphurizationSupplement 1 to waste, requiringNUREG-0586. disposal offsite in a644-acre landfill overan assumed 40-yearplant life(Section 7.3.1).Page 8.0-14 Seotember 2011Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-14September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportTable 8.0-2: Impacts Comparison Detail (continued)No-Action Alternativest1' (2)Proposed Action Base With Renewable(License Renewal) (Decommissioning) With Coal-Fired With Gas-Fired Interconnected W R aeGeneration Generation Wind Generation GCatoAesthetic ImpactsSMALL- Adopting by SMALL -Adopting by SMALL to SMALL to SMALL to SMALL -Aestheticreference Category 1 reference conclusions in MODERATE -Highly MODERATE -Highly MODERATE -impacts areissue findings (Table the GElS Section 8.4 dependent on dependent on Highly dependent on minimalA-1, Issues 73, 74). and Supplement 1 to location. Stacks, location. Stacks, location of wind (Section 7.3.3).NUREG-0586. cooling tower plumes cooling tower plumes farmslikely would be visible would be visible (Section 7.3.3).for several miles. offsite (Section 7.3.2).Operation of wastedisposal site wouldhave adverse impactpotential (Section7.3.1).Cultural Resource ImpactsSMALL -License SMALL -Adopting by SMALL -Siting of SMALL -Same as SMALL -Cultural SMALL -Culturalrenewal does not reference conclusions in plant and offsite the coal-fired resource impacts resource impactsrequire additional land the GElS Section 8.4 infrastructure (e.g., alternative (Section are minimal are minimaldisturbance (Section and Supplement 1 to transmission line, 7.3.2). (Section 7.3.2). (Section 7.3.2).4.19, Issue 71). NUREG-0586. natural gas pipeline)would be subject toregulatory review, andmitigation measureswould beimplemented (Section7.3.1).Comparison of Environmental Impact ofLicense Renewal with the AlternativesPage 8.0-15September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental ReportBtu = British thermal unitCO = carbon monoxideCO2 = carbon dioxideft3 = cubic footGElS = Generic Environmental Impact Statement (NRC 1996)kWh = kilowatt hourlb = poundMM = millionMW = megawattNOx = nitrogen oxidesPM = particulate matterPM10 = particulates having diameter less than 10 micronsNotes:(1) Environmental impacts associated with the construction and operation of new coal-fired or gas-fired generating capacity at agreenfield site would exceed those described in the table for a coal-fired or gas-fired plant located at a brownfield, i.e., existingdisturbed site.(2) From 10 CFR Part 51, Subpart A, Appendix B, Table B-i, Footnote 3:-SMALL -Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter anyimportant attribute of the resource.-MODERATE -Environmental effects are sufficient to alter noticeably, but not to destabilize, any important attribute of theresource.-LARGE -Environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource.Comparison of Environmental Impact of Page 8.0-16 September 2011License Renewal with the Alternatives Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report8.1 REFERENCESNES 2010. Norton Enerqy Storage, LLC, Final Air Permit-To-Install and Operate,Ohio EPA, September 2010.NRC 1996. Generic Environmental Impact Statement for License Renewal of NuclearPower Plants (GELS), NUREG-1437, Volumes 1 and 2, U.S. Nuclear RegulatoryCommission, Office of Nuclear Regulatory Research, May 1996.References Page 8.1-1 September 2011 Davis-Besse Nuclear Power StationLicense Renewal ApplicationEnvironmental Report[This page intentionally blank]I ReferencesPage 8.1-2September 2011

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