Generic Environmental 

Impact Statement for License 

Renewal of Nuclear Plants

Supplement 51

Regarding Callaway Plant, 

Unit 1 

Final Report

Office of Nuclear Reactor Regulation

NUREG-1437

Supplement 51
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Generic Environmental

Impact Statement for License 

Renewal of Nuclear Plants

Supplement 51

Regarding Callaway Plant, 

Unit 1 

Final Report

Manuscript Completed: October 2014

Date Published: October 2014

Office of Nuclear Reactor Regulation

NUREG-1437

Supplement 51

ABSTRACT

This supplemental environmental impact statement has been prepared in response to an 

application submitted by Union Electric Company, a subsidiary of Ameren Corporation and 

doing business as Ameren Missouri (Ameren) to renew the operating license for Callaway Plant, 

Unit 1 (Callaway), for an additional 20 years.

This supplemental environmental impact statement includes the analysis that evaluates the 

environmental impacts of the proposed action and alternatives to the proposed action. 

Alternatives considered include replacement power from new natural-gas-fired combined-cycle 

(NGCC) generation; new supercritical pulverized coal-fired generation; new nuclear generation; 

a combination alternative that includes NGCC generation, wind power, and energy efficiency; 

and not renewing the license (the no-action alternative).

The U.S. Nuclear Regulatory Commission’s (NRC’s) recommendation is that the adverse 

environmental impacts of license renewal for Callaway are not great enough to deny the option 

of license renewal for energy planning decisionmakers. This recommendation is based on the 

following:

(a) the analysis and findings in NUREG–1437, Volumes 1 and 2, Generic Environmental 

Impact Statement for License Renewal of Nuclear Plants; 

(b) the environmental report (ER) submitted by Ameren; 

(c) consultation with Federal, state, and local agencies; and

(d) the NRC’s environmental review and consideration of public comments received 

during the reviewing process. 

iii

TABLE OF CONTENTS

ABSTRACT.............................................................................................................................. iii

TABLE OF CONTENTS ............................................................................................................ v

FIGURES................................................................................................................................ xiii

TABLES .................................................................................................................................. xv

EXECUTIVE SUMMARY ....................................................................................................... xvii

ABBREVIATIONS AND ACRONYMS .................................................................................. xxiii

1.0 PURPOSE AND NEED FOR ACTION ........................................................................ 1-1

1.1 Proposed Federal Action.................................................................................. 1-1

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

1.3 Major Environmental Review Milestones.......................................................... 1-2

1.4 Generic Environmental Impact Statement........................................................ 1-4

1.5 Supplemental Environmental Impact Statement............................................... 1-6

1.6 Cooperating Agencies...................................................................................... 1-7

1.7 Consultations ................................................................................................... 1-8

1.8 Correspondence .............................................................................................. 1-9

1.9 Status of Compliance....................................................................................... 1-9

1.10 References .................................................................................................... 1-11

2.0 AFFECTED ENVIRONMENT ...................................................................................... 2-1

2.1 Facility Description........................................................................................... 2-1

2.1.1 Reactor and Containment Systems ................................................ 2-7

2.1.2 Radioactive Waste Management .................................................... 2-7

2.1.2.1 Radioactive Liquid Waste System ................................. 2-8

2.1.2.2 Radioactive Gaseous Waste System............................. 2-8

2.1.2.3 Radioactive Solid Waste Processing Systems............... 2-9

2.1.3 Nonradiological Waste Management ............................................ 2-10

2.1.3.1 Nonradioactive Waste Streams ................................... 2-10

2.1.3.2 Pollution Prevention and Waste Minimization .............. 2-12

2.1.4 Plant Operation and Maintenance................................................. 2-12

2.1.5 Power Transmission System ........................................................ 2-12

2.1.5.1 Description of the Lines............................................... 2-15

2.1.5.2 Transmission Line Corridor Vegetation 

Maintenance................................................................ 2-15

2.1.6 Cooling and Auxiliary Water Systems ........................................... 2-17

2.1.6.1 Circulating Water System............................................ 2-17

2.1.6.2 Sanitary Wastewater System ...................................... 2-19

2.1.6.3 Potable Water System................................................. 2-19

v 
Table of Contents

2.1.7 Facility Water Use and Quality...................................................... 2-19

2.1.7.1 Surface Water ............................................................. 2-19

2.1.7.2 Groundwater ............................................................... 2-19

2.2 Surrounding Environment .............................................................................. 2-21

2.2.1 Land Use...................................................................................... 2-21

2.2.2 Air Quality and Meteorology.......................................................... 2-22

2.2.2.1 Air Quality ................................................................... 2-23

2.2.3 Geologic Environment .................................................................. 2-24

2.2.3.1 Physiography and Geology ......................................... 2-25

2.2.3.2 Soils ............................................................................ 2-27

2.2.3.3 Seismic Setting ........................................................... 2-27

2.2.4 Surface Water Resources............................................................. 2-28

2.2.4.1 Stormwater Retention Ponds....................................... 2-33

2.2.5 Groundwater Resources............................................................... 2-34

2.2.6 Aquatic Resources ....................................................................... 2-37

2.2.6.1 Description of Aquatic Habitats in the 

Missouri River System................................................. 2-38

2.2.6.2 Description of Aquatic Biota of the Missouri River 

System........................................................................ 2-40

2.2.7 Terrestrial Resources ................................................................... 2-42

2.2.7.1 Vegetation Communities and Resource 

Management ............................................................... 2-42

2.2.7.2 Wildlife ........................................................................ 2-45

2.2.7.3 Transmission Line ROWs............................................ 2-45

2.2.8 Protected Species and Habitats.................................................... 2-46

2.2.8.1 Action Area.................................................................. 2-46

2.2.8.2 Aquatic Species and Habitats...................................... 2-47

2.2.8.3 Terrestrial Species and Habitats.................................. 2-51

2.2.9 Socioeconomics ........................................................................... 2-56

2.2.9.1 Housing....................................................................... 2-57

2.2.9.2 Public Services............................................................ 2-57

2.2.9.3 Offsite Land Use ......................................................... 2-61

2.2.9.4 Visual Aesthetics and Noise ........................................ 2-63

2.2.9.5 Demography................................................................ 2-63

2.2.9.6 Economy ..................................................................... 2-67

2.2.10 Historic and Archaeological Resources ........................................ 2-71

2.2.10.1 Cultural Background.................................................... 2-71

2.2.10.2 Historic and Archaeological Resources ....................... 2-74

2.3 Related Federal and State Activities .............................................................. 2-78

2.4 References .................................................................................................... 2-78

vi
Table of Contents

3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT............................................... 3-1

3.1 References ...................................................................................................... 3-1

4.0 ENVIRONMENTAL IMPACTS OF OPERATION ........................................................ 4-1

4.1 Land Use ......................................................................................................... 4-1

4.2 Air Quality ........................................................................................................ 4-2

4.3 Geologic Environment...................................................................................... 4-3

4.3.1 Geology and Soils .......................................................................... 4-3

4.4 Surface Water Resources ................................................................................ 4-3

4.4.1 Generic Surface Water Issues ........................................................ 4-4

4.4.2 Surface Water Use Conflicts........................................................... 4-4

4.5 Groundwater Resources .................................................................................. 4-5

4.5.1 Generic Groundwater Issues .......................................................... 4-5

4.5.2 Groundwater Use and Quality Conflicts .......................................... 4-5

4.5.2.1 Potable Water, Service Water, and Dewatering; 

Plants That Use More Than 100 Gallons Per 

Minute ........................................................................... 4-5

4.5.2.2 Plants Using Cooling Towers Withdrawing 

Makeup Water From a Small River................................ 4-6

4.5.2.3 Radionuclides Released to Groundwater ...................... 4-6

4.6 Aquatic Resources........................................................................................... 4-7

4.6.1 Exposure of Aquatic Organisms to Radionuclides .......................... 4-8

4.7 Terrestrial Resources....................................................................................... 4-9

4.7.1 Generic Terrestrial Resource Issues............................................... 4-9

4.7.1.1 Exposure of Terrestrial Organisms to 

Radionuclides................................................................ 4-9

4.7.2 Effects on Terrestrial Resources (Non-cooling System 

Impacts)........................................................................................ 4-10

4.8 Protected Species and Habitats..................................................................... 4-11

4.8.1 Correspondence with Federal and State Agencies ....................... 4-11

4.8.2 Aquatic Species and Habitats ....................................................... 4-11

4.8.3 Terrestrial Species and Habitats................................................... 4-15

4.9 Human Health................................................................................................ 4-19

4.9.1 Generic Human Health Issues ...................................................... 4-19

4.9.1.1 New Category 1 Human Health Issues........................ 4-20

4.9.2 Radiological Impacts of Normal Operations .................................. 4-20

4.9.2.1 Radiological Impacts of Normal Operations................. 4-20

4.9.2.2 Callaway Radiological Environmental Monitoring 

Program ...................................................................... 4-21

4.9.2.3 Callaway Radioactive Effluent Release Program......... 4-22

4.9.3 Microbiological Organisms—Human Health.................................. 4-23

4.9.4 Electromagnetic Fields—Acute Effects (Electric Shock) ............... 4-24

4.9.5 Electromagnetic Fields—Chronic Effects...................................... 4-25

vii
Table of Contents

4.10 Socioeconomics............................................................................................. 4-25

4.10.1 Generic Socioeconomic Issues..................................................... 4-26

4.10.2 Housing Impacts........................................................................... 4-26

4.10.3 Public Services: Public Utilities .................................................... 4-27

4.10.4 Public Services: Transportation Impacts...................................... 4-27

4.10.5 Offsite Land Use—License Renewal Term ................................... 4-28

4.10.5.1 Population-Related Impacts ........................................ 4-28

4.10.5.2 Tax Revenue-Related Impacts .................................... 4-28

4.10.6 Historic and Archaeological Resources ........................................ 4-28

4.10.7 Environmental Justice................................................................... 4-30

4.10.7.1 Minority Population Within 50 Miles of Callaway.......... 4-31

4.10.7.2 Low-Income Population Within 50 Miles of 

Callaway ..................................................................... 4-33

4.10.7.3 Analysis of Impacts ..................................................... 4-35

4.10.7.4 Subsistence Consumption of Fish and Wildlife............ 4-35

4.11 Evaluation of New and Potentially Significant Information.............................. 4-36

4.12 Cumulative Impacts ....................................................................................... 4-37

4.12.1 Air Quality..................................................................................... 4-40

4.12.2 Water Resources.......................................................................... 4-42

4.12.2.1 Surface Water Resources ........................................... 4-42

4.12.2.2 Groundwater Resources.............................................. 4-43

4.12.3 Aquatic Resources ....................................................................... 4-44

4.12.3.1 Missouri River Mitigation Project ................................. 4-44

4.12.3.2 Actions Planned at Big Muddy National Wildlife 

Refuge and MDC Natural/Conservation Areas ............ 4-45

4.12.3.3 Climate Change .......................................................... 4-45

4.12.3.4 Final Assessment of Cumulative Impacts on 

Aquatic Resources ...................................................... 4-45

4.12.4 Terrestrial Resources ................................................................... 4-46

4.12.5 Human Health............................................................................... 4-47

4.12.6 Socioeconomics ........................................................................... 4-48

4.12.6.1 Socioeconomic Factors ............................................... 4-48

4.12.6.2 Environmental Justice ................................................. 4-49

4.12.7 Historic and Archaeological Resources ........................................ 4-50

4.12.8 Summary of Cumulative Impacts .................................................. 4-51

4.13 References .................................................................................................... 4-53

viii
Table of Contents

5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS................................ 5-1

5.1 Design-Basis Accidents ................................................................................... 5-1

5.2 Severe Accidents............................................................................................. 5-2

5.3 Severe Accident Mitigation Alternatives ........................................................... 5-3

5.3.1 Overview of SAMA Process............................................................ 5-3

5.3.2 Estimate of Risk.............................................................................. 5-4

5.3.3 Potential Plant Improvements......................................................... 5-6

5.3.4 Evaluation of Risk Reduction and Costs of Improvements.............. 5-7

5.3.5 Cost-Benefit Comparison................................................................ 5-8

5.3.6 Conclusions.................................................................................... 5-9

5.4 References .................................................................................................... 5-10

6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE, SOLID

WASTE MANAGEMENT, AND GREENHOUSE GAS EMISSIONS............................ 6-1

6.1 The Uranium Fuel Cycle .................................................................................. 6-1

6.2 Greenhouse Gas Emissions ............................................................................ 6-3

6.2.1 Existing Studies.............................................................................. 6-3

6.2.1.1 Qualitative Studies ........................................................ 6-4

6.2.1.2 Quantitative Studies ...................................................... 6-4

6.2.1.3 Summary of Nuclear Greenhouse Gas Emissions 

Compared to Coal ......................................................... 6-6

6.2.1.4 Summary of Nuclear Greenhouse Gas Emissions 

Compared to Natural Gas.............................................. 6-7

6.2.1.5 Summary of Nuclear Greenhouse Gas Emissions 

Compared to Renewable Energy Sources..................... 6-7

6.2.2 Conclusions: Relative Greenhouse Gas Emissions ....................... 6-8

6.3 References .................................................................................................... 6-10

7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING ........................................... 7-1

7.1 Decommissioning............................................................................................. 7-1

7.2 References ...................................................................................................... 7-3

8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES .................................................. 8-1

8.1 Gas-Fired Generation ...................................................................................... 8-4

8.1.1 Air Quality....................................................................................... 8-6

8.1.1.1 Sulfur and Nitrogen Oxides and Carbon Dioxide ........... 8-7

8.1.1.2 Particulates ................................................................... 8-7

8.1.1.3 Carbon Monoxide.......................................................... 8-7

8.1.1.4 Hazardous Air Pollutants............................................... 8-8

8.1.1.5 Construction Impacts..................................................... 8-8

8.1.1.6 Additional Operating Impacts ........................................ 8-8

8.1.2 Surface Water Resources............................................................... 8-9

8.1.3 Groundwater Resources............................................................... 8-10

8.1.4 Aquatic Ecology............................................................................ 8-10

ix
Table of Contents

8.1.5 Terrestrial Ecology........................................................................ 8-10

8.1.6 Human Health............................................................................... 8-11

8.1.7 Land Use...................................................................................... 8-12

8.1.8 Socioeconomics ........................................................................... 8-12

8.1.9 Transportation .............................................................................. 8-13

8.1.10 Aesthetics and Noise.................................................................... 8-14

8.1.11 Historic and Archeological Resources .......................................... 8-14

8.1.12 Environmental Justice................................................................... 8-14

8.1.13 Waste Management...................................................................... 8-15

8.2 Coal-Fired Generation ................................................................................... 8-15

8.2.1 Air Quality..................................................................................... 8-17

8.2.1.1 Sulfur and Nitrogen Oxides and Carbon Dioxide ......... 8-19

8.2.1.2 Particulates ................................................................. 8-19

8.2.1.3 Carbon Monoxide........................................................ 8-20

8.2.1.4 Hazardous Air Pollutants............................................. 8-20

8.2.1.5 Construction Impacts................................................... 8-20

8.2.1.6 Additional Operating Impacts ...................................... 8-20

8.2.2 Surface Water Resources............................................................. 8-21

8.2.3 Groundwater Resources............................................................... 8-22

8.2.4 Aquatic Ecology............................................................................ 8-22

8.2.5 Terrestrial Ecology........................................................................ 8-23

8.2.6 Human Health............................................................................... 8-24

8.2.7 Land Use...................................................................................... 8-25

8.2.8 Socioeconomics ........................................................................... 8-25

8.2.9 Transportation .............................................................................. 8-26

8.2.10 Aesthetics and Noise.................................................................... 8-27

8.2.11 Historic and Archeological Resources .......................................... 8-27

8.2.12 Environmental Justice................................................................... 8-28

8.2.13 Waste Management...................................................................... 8-28

8.3 New Nuclear Reactor..................................................................................... 8-29

8.3.1 Air Quality..................................................................................... 8-30

8.3.1.1 Construction Impacts................................................... 8-31

8.3.1.2 Additional Operating Impacts ...................................... 8-31

8.3.2 Surface Water Resources............................................................. 8-31

8.3.3 Groundwater Resources............................................................... 8-32

8.3.4 Aquatic Ecology............................................................................ 8-33

8.3.5 Terrestrial Ecology........................................................................ 8-33

8.3.6 Human Health............................................................................... 8-34

8.3.7 Land Use...................................................................................... 8-34

8.3.8 Socioeconomics ........................................................................... 8-35

8.3.9 Transportation .............................................................................. 8-36

x 
Table of Contents

8.3.10 Aesthetics and Noise.................................................................... 8-36

8.3.11 Historic and Archeological Resources .......................................... 8-37

8.3.12 Environmental Justice................................................................... 8-37

8.3.13 Waste Management...................................................................... 8-38

8.4 Combination Generation ................................................................................ 8-38

8.4.1 Air Quality..................................................................................... 8-39

8.4.1.1 Construction Impacts................................................... 8-39

8.4.1.2 Additional Operating Impacts ...................................... 8-40

8.4.2 Surface Water Resources............................................................. 8-41

8.4.3 Groundwater Resources............................................................... 8-42

8.4.4 Aquatic Ecology............................................................................ 8-42

8.4.5 Terrestrial Ecology........................................................................ 8-42

8.4.6 Human Health............................................................................... 8-43

8.4.7 Land Use...................................................................................... 8-43

8.4.8 Socioeconomics ........................................................................... 8-44

8.4.9 Transportation .............................................................................. 8-46

8.4.10 Aesthetics and Noise.................................................................... 8-46

8.4.11 Historic and Archeological Resources .......................................... 8-47

8.4.12 Environmental Justice................................................................... 8-47

8.4.13 Waste Management...................................................................... 8-48

8.5 Alternatives Considered But Dismissed ......................................................... 8-48

8.5.1 Oil-Fired Generation ..................................................................... 8-48

8.5.2 Wind............................................................................................. 8-49

8.5.3 Solar............................................................................................. 8-50

8.5.4 Hydropower.................................................................................. 8-51

8.5.5 Small Modular Reactor ................................................................. 8-51

8.5.6 Biomass Energy ........................................................................... 8-52

8.5.7 Fuel Cells ..................................................................................... 8-52

8.5.8 Delayed Retirement...................................................................... 8-53

8.5.9 Demand-Side Management.......................................................... 8-53

8.5.10 Purchased Power ......................................................................... 8-53

8.5.11 Non-Powered Dams ..................................................................... 8-54

8.6 No-Action Alternative ..................................................................................... 8-54

8.6.1 Air Quality..................................................................................... 8-54

8.6.2 Surface Water Resources............................................................. 8-55

8.6.3 Groundwater Resources............................................................... 8-55

8.6.4 Aquatic Ecology............................................................................ 8-55

8.6.5 Terrestrial Ecology........................................................................ 8-55

8.6.6 Human Health............................................................................... 8-55

8.6.7 Land Use...................................................................................... 8-56

8.6.8 Socioeconomics ........................................................................... 8-56

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Table of Contents

8.6.9 Transportation .............................................................................. 8-56

8.6.10 Aesthetics and Noise.................................................................... 8-56

8.6.11 Historic and Archaeological Resources ........................................ 8-56

8.6.12 Environmental Justice................................................................... 8-56

8.6.13 Waste Management...................................................................... 8-57

8.7 Alternatives Summary.................................................................................... 8-57

8.8 References .................................................................................................... 8-58

9.0 CONCLUSION ............................................................................................................ 9-1

9.1 Environmental Impacts of License Renewal..................................................... 9-1

9.2 Comparison of Environmental Impacts of License Renewal and 

Alternatives...................................................................................................... 9-1

9.3 Resource Commitments................................................................................... 9-2

9.3.1 Unavoidable Adverse Environmental Impacts................................. 9-2

9.3.2 Short-Term Versus Long-Term Productivity.................................... 9-3

9.3.3 Irreversible and Irretrievable Commitments of Resources............... 9-3

9.4 Recommendations........................................................................................... 9-4

10.0 LIST OF PREPARERS ............................................................................................. 10-1

11.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM

COPIES OF THIS SEIS ARE SENT.......................................................................... 11-1

12.0 INDEX ....................................................................................................................... 12-1

APPENDIX A COMMENTS RECEIVED ON THE CALLAWAY 

ENVIRONMENTAL REVIEW..................................................................... A-1

APPENDIX B NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR 

LICENSE RENEWAL OF NUCLEAR POWER PLANTS.......................... B-1

APPENDIX C APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS..................C-1

APPENDIX D CONSULTATION CORRESPONDENCE...................................................D-1

APPENDIX E CHRONOLOGY OF ENVIRONMENTAL REVIEW 

CORRESPONDENCE................................................................................E-1

APPENDIX F U.S. NUCLEAR REGULATORY COMMISSION STAFF 

EVALUATION OF SEVERE ACCIDENT MITIGATION 

ALTERNATIVES FOR CALLAWAY PLANT, UNIT 1, IN SUPPORT 

OF LICENSE RENEWAL APPLICATION REVIEW................................. . F-1

APPENDIX G DESCRIPTION OF PROJECTS CONSIDERED IN THE 

CUMULATIVE IMPACT ANALYSIS .......................................................... G-1

APPENDIX H BIOLOGICAL ASSESSMENT OF THE POTENTIAL EFFECTS ON 

FEDERALLY LISTED PALLID STURGEON FROM THE 

PROPOSED LICENSE RENEWAL FOR THE CALLAWAY PLANT, 

UNIT 1 ...................................................................................................... H-1

xii
FIGURES

Figure 1–1. Environmental Review Process ........................................................................ 1-3

Figure 1–2. Environmental Issues Evaluated During License Renewal ............................... 1-6

Figure 2–1. Callaway Plant, 6-Mi Radius Map ..................................................................... 2-2

Figure 2–2. Callaway Plant, 50-Mi (80-Km) Radius Map ..................................................... 2-3

Figure 2–3. Callaway Plant, Site Layout, and Property Boundary........................................ 2-4

Figure 2–4. Callaway Plant Layout ...................................................................................... 2-5

Figure 2–5. Reform Conservation Area ............................................................................... 2-6

Figure 2–6. Callaway Plant Transmission Corridors .......................................................... 2-14

Figure 2–7. Callaway Plant and Locations of Pipeline and Surface Water Intake and 

Discharge Structures ...................................................................................... 2-20

Figure 2–8. Callaway Site Topography.............................................................................. 2-26

Figure 2-9. Regional Surface Water Basins ...................................................................... 2-29

Figure 2–10. Surface Water Bodies in the Vicinity of the Callaway Plant............................. 2-30

Figure 2–11. Hydrogeologic Units Underlying the Callaway Plant........................................ 2-36

Figure 2–12. Schematic of the Aquatic Food Web in the Lower Missouri River ................... 2-40

Figure 4–1. 2010 Census Minority Block Groups Within a 50-Mile Radius of the 

Callaway Plant................................................................................................ 4-32

Figure 4–2. 2010 Census Low-Income Block Groups Within a 50-Mile Radius of the 

Callaway Plant................................................................................................ 4-34

Figure 4–3. Projects and Actions With Potential for Cumulative Impacts ........................... 4-39

Figure H–1. Location of the Callaway Plant, Showing a 50-Mile Radius.............................. H-2 

Figure H–2. Callaway Plant Site Layout and Property Boundary......................................... H-4 

Figure H–3. Cross-Section of the Callaway Plant Intake Structure Showing Trash 

Racks, Traveling Screens, and Fish Escape Gates ......................................... H-5 

xiii

TABLES

Table ES–1. Summary of NRC Conclusions Relating to Site-Specific Impacts of 

License Renewal ................................................................................................ xx

Table 1–1. Licenses and Permits ..................................................................................... 1-10

Table 2–1. Annual Fuel Use and Calculated Air Emission Estimates for Significant 

Sources at Callaway....................................................................................... 2-24

Table 2–2. 2008 Water Quality Data From the Boonville, Missouri, USGS 

Monitoring Station........................................................................................... 2-31

Table 2–3. 2008 Water Quality Data From the Hermann, Missouri, USGS 

Monitoring Station........................................................................................... 2-32

Table 2–4. Permitted Outfalls ........................................................................................... 2-34

Table 2–5. Vegetation Communities Crossed by the Transmission Line Corridors........... 2-46

Table 2–6. Federally and Missouri-Listed Aquatic Species............................................... 2-47

Table 2–7. Federally and Missouri-Listed Terrestrial Species........................................... 2-52

Table 2–8. Callaway Employee Residence, by County..................................................... 2-57

Table 2–9. Housing in Boone, Callaway, and Cole Counties in 2010 ............................... 2-57

Table 2–10. Select Public Water Supply Systems in Boone, Callaway, and 

Cole Counties................................................................................................. 2-59

Table 2–11. Major Commuting Routes in the Vicinity of Callaway and 2010 AADT 

Counts............................................................................................................ 2-61

Table 2–12. Population and Percent Growth in Boone, Callaway, and Cole Counties 

From 1980 to 2010 and Projected for 2020 to 2050........................................ 2-64

Table 2–13. Demographic Profile of the Population in the Callaway Three-County 

Socioeconomic ROI in 2010 ........................................................................... 2-65

Table 2–14. Migrant Farm Workers and Temporary Farm Workers in Counties 

Located Within 50 Mi of Callaway................................................................... 2-66

Table 2–15. Seasonal Housing in Counties Located Within 50 Mi of Callaway................... 2-67

Table 2–16. Major Employers in Callaway County ............................................................. 2-68

Table 2–17. Employment by Industry in ROI ...................................................................... 2-68

Table 2–18. Estimated Income Information for the Callaway ROI....................................... 2-69

Table 2–19. Comparison of Ameren Missouri Property Tax Payments for Callaway as 

a Percentage of Callaway County Property Tax Revenues (2004–2011)........ 2-70

Table 2–20. South Callaway County R-II School District Tax Information (2004–2010)...... 2-70

Table 2–21. NRHP-Eligible or Potentially Eligible Historic or Archaeological 

Resources on the Ameren Property................................................................ 2-76

Table 4–1. Land Use Issues............................................................................................... 4-1

Table 4–2. Air Quality Issues.............................................................................................. 4-2

Table 4–3. Surface Water Use and Quality Issues ............................................................. 4-4

Table 4–4. Groundwater Use and Quality Issues ............................................................... 4-5

Table 4–5. Aquatic Resource Issues .................................................................................. 4-8

Table 4–6. Terrestrial Resource Issues.............................................................................. 4-9

Table 4–7. Protected Species and Habitat Issues ............................................................ 4-11

xv 
Tables

Table 4–8. Human Health Issues ..................................................................................... 4-19

Table 4–9. Socioeconomic Issues.................................................................................... 4-26

Table 4–10. Summary of Cumulative Impacts on Resource Areas..................................... 4-52

Table 5–1. Issues Related to Postulated Accidents............................................................ 5-1

Table 5–2. Callaway Core Damage Frequency for Internal Events..................................... 5-5

Table 5–3. Breakdown of Population Dose by Containment Release Mode ....................... 5-6

Table 6–1. Issues Related to the Uranium Fuel Cycle and Solid Waste 

Management. ................................................................................................... 6-1

Table 6–2. Nuclear Greenhouse Gas Emissions Compared to Coal .................................. 6-6

Table 6–3. Nuclear Greenhouse Gas Emissions Compared to Natural Gas....................... 6-7

Table 6–4. Nuclear Greenhouse Gas Emissions Compared to Renewable Energy 

Sources ............................................................................................................ 6-8

Table 7–1. Issues Related to Decommissioning ................................................................. 7-2

Table 8–1. Characteristics of Electrical Generating Technologies ...................................... 8-4

Table 8–2. Characteristics of 1,186-MW NGCC ................................................................. 8-5

Table 8–3. Characteristics of 1,186-MW SCPC................................................................ 8-17

Table 8–4. Characteristics of 1,200-MW Nuclear Alternative............................................ 8-30

Table 8–5. Characteristics of 1,186-MW Combination Alternative .................................... 8-39

Table 8–6. Summary of Environmental Impacts of Proposed Action and Alternatives ...... 8-58

Table 10–1. List of Preparers ............................................................................................. 10-2

Table A–1. Individuals Providing Comments During the Scoping Comment Period ........... A-2 

Table A–2. Technical Issue Categories.............................................................................. A-3 

Table A–3. Individuals Providing Comments During the Scoping Comment Period ......... A-30 

Table A–4. Comment Categories..................................................................................... A-31 

Table B–1. Generic Summary of Findings on NEPA Issues for License Renewal of 

Power Plants ................................................................................................... B-2 

Table C–1. Federal (and Associated State) Environmental Requirements ......................... C-2 

Table D–1. Consultation Correspondence ......................................................................... D-2 

Table E–1. Environmental Review Correspondence.......................................................... E-2 

Table F–1. Callaway Core Damage Frequency for Internal Events.................................... F-3 

Table F–2. Breakdown of Population Dose by Containment Release Mode ...................... F-4 

Table F–3. Callaway PRA Historical Summary.................................................................. F-5 

Table F–4. Important Fire Areas and Their Contribution to Fire CDF................................. F-9 

Table F–5. SAMA Cost/Benefit Screening Analysis for Callaway Plant............................ F-23 

Table G–1. Projects and Actions Considered in the Cumulative Impacts Analysis ............. G-2

xvi
EXECUTIVE SUMMARY

BACKGROUND

By letter dated December 15, 2011, Union Electric Company, a subsidiary of Ameren 

Corporation and doing business as Ameren Missouri (Ameren or the applicant), submitted an 

application to the U.S. Nuclear Regulatory Commission (NRC) to issue a renewed operating 

license for Callaway Plant, Unit 1 (Callaway) for an additional 20-year period.

In accordance with Title 10, Part 51.20(b)(2), of the Code of Federal Regulations

(10 CFR 51.20(b)(2)), the renewal of a power reactor operating license requires preparation of 

an environmental impact statement (EIS) or a supplement to an existing EIS. In addition, 

10 CFR 51.95(c) states in part that “the Commission shall prepare an EIS, which is a 

supplement to NUREG–1437, Generic Environmental Impact Statement (GEIS) for License 

Renewal of Nuclear Plants (June 2013).” 

The GEIS was originally published in 1996, and amended in 1999. Subsequently, in 2013, the 

NRC published a final rule (78 FR 37282 and 78 FR 46255) revising 10 CFR Part 51, 

“Environmental protection regulations for domestic licensing and related regulatory functions.” 

The final rule updates the potential environmental impacts associated with the renewal of an 

operating license for a nuclear power reactor for an additional 20 years. A revised GEIS, which 

updates the 1996 GEIS, provides the technical basis for the final rule. The revised GEIS 

specifically supports the revised list of National Environmental Policy Act (NEPA) issues and 

associated environmental impact findings for license renewal contained in Table B–1 in 

Appendix B to Subpart A of the revised 10 CFR Part 51. In Table B-1, the NRC uses the term 

“Category 1” to classify issues that have generic findings for license renewal, and “Category 2” 

to classify issues that do not have generic findings and require a plant-specific determination. 

The 2013 GEIS and rule revised the previous rule to consolidate similar Category 1 and 2 

issues; change some Category 2 issues into Category 1 issues; consolidate some of those 

issues with existing Category 1 issues; and add new Category 1 and 2 issues.

The final rule became effective July 22, 2013, after publication in the Federal Register. 

Compliance by license renewal applicants is not required until June 20, 2014, (i.e., license 

renewal applications submitted later than 1 year after publication must be compliant with the 

new rule). Nevertheless, under NEPA, the NRC must now consider and analyze, in its license 

renewal Supplemental Environmental Impact Statement (SEIS), the potential significant impacts 

described by the revised rule’s new Category 2 issues, and to the extent there is any new and 

significant information, the potential significant impacts described by the revised rule’s new 

Category 1 issues.

In addition, on September 19, 2014, the NRC published a revised rule at 10 CFR 51.23 

(Continued Storage Rule) and associated Generic Environmental Impact Statement for 

Continued Storage of Spent Nuclear Fuel. The NRC staff intents to address any impacts from 

the Continued Storage Rule subsequently in a Record of Decision or as supplement to this 

SEIS, as appropriate. 

Upon acceptance of Ameren’s application, the NRC staff began the environmental review 

process described in 10 CFR Part 51, “Environmental protection regulations for domestic 

licensing and related regulatory functions,” by publishing a notice of intent to prepare a 

xvii
Executive Summary

supplemental EIS (SEIS) and conduct scoping. In preparation of this SEIS for Callaway, the 

NRC staff performed the following:

 conducted public scoping and draft SEIS meetings in Fulton, Missouri; 

 conducted a site audit at Callaway in May 2012; 

 reviewed Ameren’s ER for Callaway and compared it to the GEIS; 

 consulted with other agencies; 

 conducted a review of the issues following the guidance set forth in 

NUREG–1555, Standard Review Plans for Environmental Reviews for 

Nuclear Power Plants, Supplement 1: “Operating License Renewal”; and

 considered public comments received during the reviewing process. 

PROPOSED ACTION

Ameren initiated the proposed Federal action (i.e., issuing a renewed power reactor operating 

license) by submitting an application for license renewal of Callaway, for which the existing 

license (NPF-30) will continue in effect until October 18, 2024. The NRC’s Federal action is the 

decision of whether or not to renew the license for an additional 20 years.

PURPOSE AND NEED FOR ACTION

The purpose and need for the proposed action (i.e., issuance of a renewed license) is to provide 

an option that allows for power generation capability beyond the term of the current nuclear 

power plant operating license to meet future system generating needs. Such needs may be 

determined by other energy-planning decisionmakers, including State agencies, utilities, and, 

where authorized, Federal agencies (other than the NRC). This definition of purpose and need 

reflects the NRC’s recognition that, unless there are findings in the safety review required by the 

Atomic Energy Act or findings in the NEPA environmental analysis that would lead the NRC to 

deny a license renewal application, the NRC does not have a role in the energy-planning 

decisions of whether a particular nuclear power plant should continue to operate.

If the renewed license is issued, the appropriate energy-planning decisionmakers, along with 

Ameren, will ultimately decide if the plant will continue to operate based on factors such as the 

need for power. If the renewed license is denied, then the facility must be shut down on or 

before the expiration date of the current operating license, which is October 18, 2024.

xviii
Executive Summary

ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL

The SEIS evaluates the potential environmental impacts of the 

proposed action. The environmental impacts from the proposed 

action are designated as SMALL, MODERATE, or LARGE. As 

set forth in the GEIS, Category 1 issues are those that meet all of 

the following criteria:

(a) The environmental impacts associated with the issue 

are determined to apply either to all plants or, for some 

issues, to plants having a specific type of cooling 

system or other specified plant or site characteristics.

(b) A single significance level (i.e., SMALL, MODERATE, 

or LARGE) has been assigned to the impacts, except 

for collective offsite radiological impacts from the fuel 

cycle and from high-level waste and spent fuel

disposal.

(c) Mitigation of adverse impacts associated with the issue is considered in the analysis, 

and it has been determined that additional plant-specific mitigation measures are not 

likely to be sufficiently beneficial to warrant implementation.

For Category 1 issues, no additional site-specific analysis is required in this SEIS unless new 

and significant information is identified. Chapter 4 of this SEIS presents the process for 

identifying new and significant information. Site-specific issues (Category 2) are those that do 

not meet one or more of the criteria for Category 1 issues; therefore, an additional site-specific 

review for these nongeneric issues is required, and the results are documented in the SEIS.

The environmental review for Callaway was performed using the criteria from the 1996 and 

2013 GEIS. Neither Ameren nor NRC identified information that is both new and significant 

related to Category 1 issues that would call into question the conclusions in the GEIS. This 

conclusion is supported by NRC’s review of the applicant’s ER, other documentation relevant to 

the applicant’s activities, the public scoping process and substantive comments raised, and the 

findings from the environmental site audit conducted by NRC staff. 

The NRC staff reviewed information relating to the new issues identified in the 2013 GEIS, 

specifically, geology and soils; radionuclides released to the groundwater; effects on terrestrial 

resources (non-cooling system intake); exposure of terrestrial organisms to radionuclides; 

exposure of aquatic organisms to radionuclides; human health impacts from chemicals; physical 

occupational hazards; environmental justice; and cumulative impacts. These issues are 

documented in Chapter 4 of this SEIS.

The NRC staff did not identify any new issues applicable to Callaway that have a significant 

environmental impact. The NRC staff, therefore, relies upon the conclusions of the 1996 and 

2013 GEIS for all Category 1 issues applicable to Callaway.

Table ES–1 summarizes the Category 2 issues applicable to Callaway, if any, as well as the 

NRC staff’s findings related to those issues. If the NRC staff determined that there were no 

Category 2 issues applicable for a particular resource area, the findings of the GEIS, as 

documented in Appendix B to Subpart A of 10 CFR Part 51, stand. Hereafter in this SEIS, 

general references to the GEIS, without stipulation, are inclusive of the 1996 and 1999 GEISs. 

Information and findings specific to the June 2013 final rule and GEIS, are clearly identified.

SMALL: Environmental 

effects are not detectable or 

are so minor that they will 

neither destabilize nor 

noticeably alter any 

important attribute of the 

resource.

MODERATE: 

Environmental effects are 

sufficient to alter noticeably, 

but not to destabilize, 

important attributes of the 

resource.

LARGE: Environmental 

effects are clearly noticeable 

and are sufficient to 

destabilize important 

attributes of the resource.

xix
Executive Summary

With respect to environmental justice, the NRC staff has determined that there will be no 

disproportionately high and adverse impacts to these populations from the continued operation 

of Callaway during the license renewal period. Additionally, the NRC staff has determined that 

no disproportionately high and adverse human health impacts are expected in special pathway 

receptor populations in the region as a result of subsistence consumption of water, local food, 

fish, and wildlife.

Table ES–1. Summary of NRC Conclusions Relating to Site-Specific Impacts 

of License Renewal

Resource Area Relevant Category 2 Issues Impacts

Land Use None SMALL

Air Quality None SMALL

Geology and Soils None SMALL

Surface Water Resources Water use conflicts SMALL

Groundwater Resources Groundwater use conflicts SMALL

Radionuclides released to groundwater(a) SMALL

Aquatic Resources None SMALL

Terrestrial Resources Effects on terrestrial resources (non-cooling 

system impacts)

(a) SMALL

Protected Species Threatened or endangered species No effect to may 

affect but is not likely 

to adversely affect(b)

Human Health Microbiological organisms

Electromagnetic fields: acute effects 

(electric shock)

SMALL

Socioeconomics Housing Impacts

Public services (public utilities)

Offsite land use

Public services (public transportation)

Historic and archaeological resources

SMALL

Cumulative Impacts (a)

Aquatic resources LARGE

Terrestrial resources SMALL to 

MODERATE

All other resource areas SMALL

(a) These issues are new Category 2 issues identified in the 2013 GEIS and Rule (78 FR 37282). U.S. Nuclear 

Regulatory Commission. “Revisions to Environmental Review for Renewal of Nuclear Power Plant Operating 

Licenses.” June 2013. (b)

For Federally protected species, the 2013 GEIS and rule state that, in complying with the Endangered Species 

Act (ESA), the NRC will report the effects of continued operations and refurbishment in terms of its ESA 

findings, which varies by species for Callaway. 

SEVERE ACCIDENT MITIGATION ALTERNATIVES

Ameren had not previously considered alternatives to reduce the likelihood or potential 

consequences of a variety of highly uncommon, but potentially serious, accidents at Callaway. 

In accordance with 10 CFR 51.53(c)(3)(ii)(L), therefore, Ameren must evaluate severe accident

mitigation alternatives (SAMA) in the course of the license renewal review. SAMA are potential 

xx 
Executive Summary

ways to reduce the risk or potential impacts of uncommon, but potentially severe, accidents, and 

may include changes to plant components, systems, procedures, and training.

The NRC staff reviewed the evaluation in the applicant’s ER of potential SAMA and participated 

in a SAMA site audit. Based on its review, the NRC staff concluded that none of the potentially 

cost-beneficial SAMA relate to adequately managing the effects of aging during the period of 

extended operation. Therefore, they need not be implemented as part of the license renewal, in 

accordance with 10 CFR Part 54, “Requirements for renewal of operating licenses for nuclear 

power plants.” 

ALTERNATIVES

The NRC staff considered the environmental impacts associated with alternatives to license 

renewal. These alternatives include other methods of power generation, as well as not 

renewing the Callaway operating license (the no-action alternative). Replacement power 

options considered were as follows:

 natural gas-fired combined-cycle (NGCC), 

 supercritical pulverized coal-fired (SCPC), 

 new nuclear reactor, and

 combination generation (NGCC, wind power, and energy efficiency). 

The NRC staff initially considered a number of additional alternatives for analysis as alternatives 

to license renewal of Callaway; these were later dismissed because of technical, resource 

availability, or commercial limitations that currently exist and that the NRC staff believes are 

likely to continue to exist when the current Callaway license expires. The no-action alternative

by the NRC staff, and the effects it would have, also were considered.

Where possible, the NRC staff evaluated potential environmental impacts for these alternatives

located both at the Callaway site and at some other unspecified alternate location. Alternatives 

considered, but dismissed, were as follows:

 oil-fired power generation, 

 wind power, 

 solar power, 

 hydropower, 

 small modular reactor, 

 biomass energy, 

 fuel cells, 

 delayed retirement of existing non-nuclear power plants, 

 demand-side management, and

 purchased power. 

The NRC staff evaluated each alternative using the same impact areas that were used in 

evaluating impacts from license renewal.

xxi
Executive Summary

RECOMMENDATION

The NRC’s recommendation is that the adverse environmental impacts of license renewal for 

Callaway are not great enough to deny the option of license renewal for energy-planning 

decisionmakers. This recommendation is based on the following:

 analysis and findings in the GEIS; 

 the ER submitted by Ameren; 

 consultation with Federal, state, and local agencies; 

 the NRC staff’s own independent review; and

 consideration of public comments received during the reviewing process. 

xxii
ABBREVIATIONS AND ACRONYMS

°C degree(s) Celsius

°F degree(s) Fahrenheit

μg microgram(s) 

μm micrometer(s)

μS/cm-1 microsiemen(s) per centimeter-1

AADT average annual daily traffic 

ac acre(s)

ac alternating current

ACC averted cleanup and decontamination costs

ACHP Advisory Council on Historic Preservation

ADAMS Agencywide Documents Access and Management System

AEA Atomic Energy Act of 1954

AEA Atomic Energy Authority

AEPS alternate emergency power system

AFW auxiliary feedwater

ALARA as low as is reasonably achievable

Ameren Ameren Missouri

AOC averted offsite property damage costs

AOE averted occupational exposure

AOSC averted onsite costs

APE area of potential effect

APE averted public exposure

AQCR Air Quality Control Region

ATWS anticipated transient(s) without scram

AWG American wire gauge

BGS below ground surface

BMP best management practice

BO biological opinion

BP before present

BTU British thermal unit(s)

BTU/ft3 British thermal unit(s) per cubic foot 

BTU/kWh British thermal unit(s) per kilowatt-hour

xxiii
Abbreviations and Acronyms

CAA Clean Air Act, as amended through 1990

CAIR Clean Air Interstate Rule

Callaway Callaway Plant, Unit 1

CCS carbon capture and storage

CCSM Conservation Commission of the State of Missouri

CCW component cooling water

CDF core damage frequency

CDM Camp Dresser & McKee

CDM Clean Development Mechanism

CENRAP Central Regional Air Planning Association

CEQ Council on Environmental Quality

CET containment event tree

CFR Code of Federal Regulations

cfs cubic foot (feet) per second

cm centimeter(s)

cm/s centimeter(s) per second

CO carbon monoxide 

CO2 carbon dioxide

CO2e carbon dioxide equivalent(s)

COE cost(s) of enhancement

COLA combined license application

CRMP Cultural Resources Management Plan

CSAPR Cross-State Air Pollution Rule

CSP concentrating solar power

CSR Code of State Regulations

CST condensate storage tank

CWA Clean Water Act of 1972

dBA decibel(s) (adjusted) 

DBA design-basis accident

dc direct current

DOE U.S. Department of Energy

DOLIR Department of Labor and Industrial Relations

DSEIS draft Supplemental Environmental Impact Statement

DSM demand-side management 

xxiv
Abbreviations and Acronyms

E & E Ecology and Environment

E.O. Executive Order

EDG emergency diesel generator

EF Enhanced Fujita (scale)

EIA Energy Information Administration (of DOE) 

EIS environmental impact statement

ELF-EMF extremely low frequency electromagnetic field

ELT ecological landtype

EMS environmental management system

EPA U.S. Environmental Protection Agency

EPCRA Emergency Planning and Community Right-to-Know Act of 1986

EPR Evolutionary Power Reactor

EPRI Electric Power Research Institute

EPT Ephemeroptera-Plecoptera-Trichoptera

EPZ emergency planning zone

ER Environmental Report 

ESA Endangered Species Act of 1973, as amended

ESP early site permit

ESW emergency service water

F&O Fact and Observation

FDA Food and Drug Administration

FES final environmental statement

FIVE fire-induced vulnerability evaluation

FL fork length

fps foot (feet) per second

FR Federal Register

FRS floor response spectra

FSAR final safety analysis report

ft foot (feet)

ft3 cubic foot (feet)

FWS U.S. Fish and Wildlife Service

g force of acceleration relative to that of Earth’s gravity

g Ceq/kWh gram(s) of carbon-equivalent per kilowatt-hour 

gal gallon(s)

xxv 
Abbreviations and Acronyms

GEIS Generic Environmental Impact Statement for License Renewal of 

Nuclear Plants, NUREG–1437

GHG greenhouse gas 

GL generic letter

gpd gallon(s) per day 

gpm gallon(s) per minute 

GW groundwater

ha hectare(s)

HAP hazardous air pollutant

HEP human error probability

HFO high winds, floods, and other

HLDSA high-level drum storage area

hr hour(s)

HRA human reliability analysis

HVAC heating, ventilation, and air conditioning

HWSB hazardous waste storage building

Hz hertz

IAEA International Atomic Energy Agency

IEEE Institute of Electrical and Electronics Engineers

IGCC integrated gasification combined-cycle 

in. inch(es)

in/s inch(es) per second

INEEL Idaho National Engineering and Environmental Laboratory

INL Idaho National Laboratory

IPCC Intergovernmental Panel on Climate Change

IPE individual plant examination

IPEEE individual plant examination of external events

ISFSI independent spent fuel storage installation

ISLOCA interfacing-systems loss-of-coolant accident

kg kilogram(s)

km kilometer(s)

km2 square kilometer(s)

kph kilometer(s) per hour

kV kilovolt(s)

kWh kilowatt hour(s)

xxvi 
Abbreviations and Acronyms

kWh/m2

/day kilowatt hour(s) per square meter per day

kWh/m2

/year kilowatt hour(s) per square meter per year

L litre(s)

L/day litre(s) per day

L/min litre(s) per minute

L/s litre(s) per second

LAR license amendment request

LATE-COP containment overpressure (late)

lb pound(s)

LCTHF Lewis and Clark Trail Heritage Foundation

LERF large early release frequency

LLMW low-level mixed waste

LOCA loss-of-coolant accident

LOSP loss of offsite power

LRA license renewal application

m meter(s)

m/s meter(s) per second

m2

 square meter(s)

m3 cubic meter(s)

m3

/day cubic meter(s) per day

m3

/s cubic meter(s) per second 

MAAP Modular Accident Analysis Program

MACCS2 MELCOR Accident Consequence Code System 2

MACR maximum averted cost risk

MACTEC MACTEC Engineering and Consulting, Inc.

MAS Missouri Archaeological Society

MATS Mercury and Air Toxics Standards

MBTA Migratory Bird Treaty Act

MCDC Missouri Census Data Center

MCR main control room

MDAFW motor-driven auxiliary feedwater pump

MDC Missouri Department of Conservation

MDESE Missouri Department of Elementary and Secondary Education

MDNR Missouri Department of Natural Resources

mg/L milligram(s) per liter

xxvii 
Abbreviations and Acronyms

mgd million gallons per day 

mGy milligray

mi mile(s)

mi2 square mile(s)

min minute(s)

MISO Midwest Independent System Operator

MIT Massachusetts Institute of Technology

mm millimeter(s)

MMBTU million British thermal units

MMI modified Mercalli intensity

MMPA Marine Mammal Protection Act of 1972

MMT million metric ton(s)

MOA Missouri Office of Administration

MoDOT Missouri Department of Transportation

mph mile(s) per hour

mrad milliradiation absorbed dose

MRCC Midwestern Regional Climate Center

mrem millirem (unit of dose equivalent in tissue)

MRRP Missouri River Recovery Program

MSA Magnuson–Stevens Fishery Conservation and Management Act, 

as amended through 2006

MSL mean sea level

mSv millisievert(s) 

MT metric ton(s)

MW megawatt(s)

MWd/MTU megawatt-days per metric ton of uranium 

MWe megawatt(s) electric

MWt megawatt(s) thermal

NAAQS National Ambient Air Quality Standards

NAS National Academy of Sciences

NASS National Agricultural Statistics Service

NCDC National Climatic Data Center

NCES National Center for Education Statistics

NCP normal charging pump

NEA Nuclear Energy Agency

xxviii 
Abbreviations and Acronyms

NEI Nuclear Energy Institute

NEPA National Environmental Policy Act of 1969

NERC North American Electric Reliability Corporation

NESC® National Electrical Safety Code® 

NETL National Energy Technology Laboratory

NFPA National Fire Protection Association

NGCC natural-gas-fired combined-cycle 

NGDC National Geophysical Data Center

NHL National Historic Landmark

NHP Natural Heritage Program

NHPA National Historic Preservation Act of 1966, as amended

NIEHS National Institute of Environmental Health Sciences

NMFS National Marine Fisheries Service (of NOAA)

NOAA National Oceanic and Atmospheric Administration 

NOx nitrogen oxide(s)

NPD non-powered dam

NPDES National Pollutant Discharge Elimination System 

NPF nuclear power facility

NPS National Park Service

NRC U.S. Nuclear Regulatory Commission 

NRCS National Resources Conservation Service

NREL National Renewable Energy Laboratory

NRHP National Register of Historic Places

NRR Nuclear Reactor Regulation, Office of

NSPS New Source Performance Standard

NSR New Source Review

NTTF Near-Term Task Force

NTU Nephelometric Turbidity Unit(s)

NUREG NRC technical report designation (Nuclear Regulatory 

Commission)

NWS National Weather Service

ODCM offsite dose calculation manual

OECD/IEA Organisation for Economic Co-operation and 

Development/International Energy Agency

OSEDA Office of Social and Economic Data Analysis

xxix
Abbreviations and Acronyms

Pb lead

PDS plant damage state

person-rem person–roentgen(s) equivalent man

person-Sv person-sievert(s)

PGA peak ground acceleration

PL Public Law

PM particulate matter

PM10 particulate matter, ≤10 micrometers

PM2.5 particulate matter, ≤2.5 micrometers

PNNL Pacific Northwest National Laboratory

PORV pilot-operated relief valve

POST Parliamentary Office of Science and Technology

PPIC Pollution Prevention Information Clearinghouse

PRA probabilistic risk assessment

PSD Prevention of Significant Deterioration

PSRST primary spent resin storage tank

PV photovoltaic

PWR pressurized-water reactor

RAI request(s) for additional information

RCP reactor coolant pump

RCRA Resource Conservation and Recovery Act of 1976, as amended

RCS reactor coolant system

rem unit of dose equivalent in tissue

REMP Radiological Environmental Monitoring Program

RES Office of Nuclear Regulatory Research

RFF Resources for the Future

RHR residual heat removal

RKm River Kilometer (along the Missouri)

RLE review-level earthquake

RM River Mile (along the Missouri)

ROI region of influence

ROW right-of-way

RPC replacement power cost

RPMA recovery priority management area

RPV reactor pressure vessel

xxx 
Abbreviations and Acronyms

RRW risk reduction worth

RTC Rails-to-Trails Conservancy

RWST refueling water storage tank

SAMA severe accident mitigation alternative(s) 

SAR safety analysis report

SBO station blackout

SC&A SC&A, Inc.

SCPC supercritical pulverized coal-fired

SCR selective catalytic reduction 

SEIS supplemental environmental impact statement 

SER safety evaluation report

SG steam generator

SGTR steam generator tube rupture

SHPO State Historic Preservation Office

SMA Seismic Margin Assessment

SMR small modular reactor

SNF spent nuclear fuel

SO2 sulfur dioxide

SQG small quantity generator

SSC structure, system, and component

SSE safe shutdown earthquake

SSEL safe shutdown equipment list

Sv sievert(s)

SW service water ( or surface water) 

TDAFP turbine-driven auxiliary feedwater pump

TSS total suspended solids

U uranium

U.S. United States

U.S.C. United States Code

UEC Union Electric Company

UHS ultimate heat sink

USACE U.S. Army Corps of Engineers

USBR Bureau of Reclamation

USCB U.S. Census Bureau

USDA U.S. Department of Agriculture

xxxi 
Abbreviations and Acronyms

USGCRP U.S. Global Change Research Program

USGS U.S. Geological Survey

VCSNS Virgil C. Summer Nuclear Station

VOC volatile organic compound

WET Whole Effluent Toxicity

WQC water quality certification

WTE waste-to-energy

xxxii 
1.0 PURPOSE AND NEED FOR ACTION

Under the U.S. Nuclear Regulatory Commission’s (NRC’s) environmental protection regulations 

in Title 10, of the Code of Federal Regulations (10 CFR) Part 51, “Environmental protection 

regulations for domestic licensing and related regulatory functions,” which implement the 

National Environmental Policy Act (NEPA) (42 U.S.C. 4321 et seq.), renewal of a nuclear power 

plant operating license requires the preparation of an environmental impact statement.

The Atomic Energy Act of 1954 (AEA) (42 U.S.C. 2011 et seq.) originally specified that licenses 

for commercial power reactors be granted for up to 40 years, with an option to renew for another 

20 years. The 40-year licensing period was based on economic and antitrust considerations 

rather than on technical limitations of the nuclear facility.

The decision to seek a license renewal rests entirely with nuclear power facility owners and, 

typically, is based on the facility’s economic viability and the investment necessary to continue 

to meet NRC safety and environmental requirements. The NRC makes the decision to grant or 

deny license renewal based on whether the applicant has demonstrated that the environmental 

and safety requirements in the agency’s regulations can be met during the period of extended 

operation.

1.1 Proposed Federal Action

Union Electric Company, a subsidiary of Ameren Corporation and doing business as Ameren 

Missouri (Ameren or the applicant), initiated the proposed Federal action by submitting an 

application for license renewal of Callaway Plant, Unit 1 (Callaway), for which the existing 

license (NPF-30) will remain in effect until October 18, 2024. The NRC’s Federal action is the 

decision whether to renew the license for an additional 20 years.

1.2 Purpose and Need for the Proposed Federal Action

The purpose and need for the proposed action (i.e., issuance of a renewed license) is to provide 

an option that allows for power generation capability beyond the term of the current nuclear 

power plant operating license to meet future system generating needs. Such needs may be 

determined by other energy-planning decisionmakers, such as State agencies, utilities, and, 

where authorized, Federal agencies (other than the NRC). This definition of purpose and need 

reflects the NRC’s recognition that, unless there are findings in the safety review required by the 

AEA or findings in the NEPA environmental analysis that would lead the NRC to reject a license 

renewal application, the NRC does not have a role in the energy-planning decisions of State

regulators and utility officials as to whether a particular nuclear power plant should continue to 

operate.

If the renewed license is issued, State regulatory agencies and Ameren ultimately will decide if 

the plant will continue to operate based on such factors as the need for power or other matters 

within the State’s jurisdiction or the purview of the owners. If the renewed license is denied, 

then the facility must be shut down on or before the expiration date of the current operating 

license, which is October 18, 2024.

1-1 
Purpose and Need for Action

1.3 Major Environmental Review Milestones

Ameren submitted an environmental report (ER) (Ameren 2011a) as part of its license renewal 

application (Ameren 2011b) in December 2011. After reviewing the application and the ER for 

sufficiency, the NRC published a Notice of Acceptability and Opportunity for Hearing in the 

Federal Register on February 24, 2012 (77 FR 11173). The NRC published another notice in 

the Federal Register, also on February 24, 2012, on its intent to conduct scoping, thereby 

beginning the 60-day scoping period (77 FR 11171).

The agency held two public scoping meetings on March 14, 2012, in Fulton, Missouri. The NRC 

report entitled Environmental Impact Statement Scoping Process, Summary Report, Callaway 

Plant, Unit 1, Callaway County, MO, dated September 9, 2013, presents the comments received 

during the scoping process (NRC 2013a). Appendix A to this Supplemental Environmental 

Impact Statement (SEIS) presents the comments considered to be within the scope of the 

environmental license renewal review and the NRC responses.

To independently verify information provided in the ER, the NRC staff conducted a site audit at 

Callaway in May 2012. During the site audit, the NRC staff met with plant personnel, reviewed 

specific documentation, toured the facility, and met with interested Federal, State, and local 

agencies. The NRC report entitled, Summary of Site Audit Related to the Review of the License 

Renewal Application for Callaway Plant, Unit 1, dated June 22, 2012, summarizes the site audit 

and the attendees (NRC 2012).

Figure 1–1 shows the major milestones in the review of the SEIS. Upon completion of the 

scoping period and site audit, the NRC staff prepared and issued this SEIS. This document was

made available for public comment for 45 days. During this time, the NRC hosted public 

meetings and collected public comments. Based on the information gathered, the NRC 

amended the findings of this SEIS, as necessary, and then publish the final SEIS. The NRC 

has established a license renewal process that can be completed in a reasonable period of time 

with clear requirements to ensure safe plant operation for up to an additional 20 years of plant 

life. The safety review is conducted simultaneously with the environmental review. The NRC 

documents the findings of the safety review in a safety evaluation report (SER). The NRC 

considers the findings in both the SEIS and the SER in its decision to either grant or deny the 

issuance of a renewed license.

1-2 
Purpose and Need for Action

NRC staff reviews 

application

Staff conducts

environmental site audit

The NRC issues draft 

SEIS

Company submits

an application

to the NRC

*Scoping 

process

*Draft SEIS 

process

The NRC issues final 

SEIS

NRC decision on 

whether to renew 

license

* Opportunity

for public

involvement

Figure 1–1. Environmental Review Process

1-3 
Purpose and Need for Action

1.4 Generic Environmental Impact Statement

The NRC performed a generic assessment of the environmental impacts associated with 

license renewal to improve the efficiency of the license renewal process. NUREG–1437, 

Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), 

documented the results of the NRC staff’s systematic approach to evaluate the environmental 

consequences of renewing the licenses of individual nuclear power plants and operating them 

for an additional 20 years (NRC 1996, 1999). The NRC staff analyzed in detail and resolved 

those environmental issues that could be resolved generically in the GEIS. The GEIS was 

originally issued in 1996, and Addendum 1 to the GEIS was issued in 1999. 

The GEIS established 92 separate issues for the NRC staff to independently verify. Of these 

issues, the NRC staff determined that 69 are generic to all plants with generic conclusions 

(Category 1), while 23 issues do not lend themselves to generic consideration and require 

plant-specific assessment (Category 2). 

Two other issues—environmental justice and chronic effects of electromagnetic fields—

remained uncategorized and must be evaluated on a site-specific basis. Appendix B of this 

SEIS lists the 92 issues.

On June 20, 2013, the NRC published a final rule (78 FR 37282) revising its environmental 

protection regulation, Title 10 of the Code of Federal Regulations (10 CFR) Part 51, 

“Environmental protection regulations for domestic licensing and related regulatory functions.” 

Specifically, the final rule updates the potential environmental impacts associated with the 

renewal of an operating license for a nuclear power reactor for an additional 20 years. A 

revised GEIS (NRC 2013b), which updates the 1996 GEIS, provides the technical basis for the 

final rule. The revised GEIS specifically supports the revised list of NEPA issues and 

associated environmental impact findings for license renewal contained in Table B–1 in 

Appendix B to Subpart A of the revised 10 CFR Part 51. The revised GEIS and final rule reflect 

lessons learned and knowledge gained during previous license renewal environmental reviews. 

In addition, public comments received on the draft revised GEIS and rule and during previous 

license renewal environmental reviews were re-examined to validate existing environmental 

issues and identify new ones.

The final rule identifies 78 environmental impact issues, of which 17 will require plant specific 

analysis. The final rule consolidates similar Category 1 and 2 issues, changes some Category 2 

issues into Category 1 issues, and consolidates some of those issues with existing Category 1 

issues. The revised rule also adds new Category 1 and 2 issues. The new Category 1 issues 

include geology and soils, exposure of terrestrial organisms to radionuclides, exposure of 

aquatic organisms to radionuclides, human health impact from chemicals, and physical 

occupational hazards. Radionuclides released to groundwater, effects on terrestrial resources 

(non-cooling system impacts), minority and low-income populations (i.e., environmental justice), 

and cumulative impacts were added as new Category 2 issues.

The final rule became effective 30 days after its publication in the Federal Register. Compliance 

by license renewal applicants is not required until 1 year from the date of publication 

(i.e., license renewal ERs submitted later than 1 year after publication must be compliant with 

the new rule). Nevertheless, under NEPA, the NRC must now consider and analyze, in its 

license renewal SEISs, the potential significant impacts described by the final rule’s new 

Category 2 issues, and to the extent there is any new and significant information, the potential 

significant impacts described by the final rule’s new Category 1 issues.

In addition, on August 26, 2014, the Commission approved a revised rule at 10 CFR 51.23 

(Continued Storage Rule) and associated Generic Environmental Impact Statement for 

1-4 
Purpose and Need for Action

Continued Storage of Spent Nuclear Fuel (NUREG-2157, ADAMS Accession 

No. ML14237A092). Subsequently, on September 19, 2014, the NRC published the revised 

rule (79 FR 56238) in the Federal Register along with NUREG-2157 (NRC 2014). The NRC 

staff intends to address any impacts from the Continued Storage Rule subsequently in a Record 

of Decision or as a Supplement to the FSEIS, as appropriate.

Section 1.5 provides an explanation of how the final rule applies to the NRC staff’s review of 

Callaway’s license renewal application.

For each potential environmental issue, the GEIS does the following:

 describes the activity that affects the environment; 

 identifies the population or resource that is affected; 

 assesses the nature and magnitude of the impact on the affected population 

or resource; 

 characterizes the significance of the effect for both beneficial and adverse 

effects; 

 determines if the results of the analysis apply to all plants; and

 considers whether additional mitigation measures would be warranted for 

impacts that would have the same significance level for all plants. 

The NRC’s standard of significance for impacts was established using the Council on 

Environmental Quality terminology for “significant.” The NRC established three levels of 

significance for potential impacts—SMALL, 

MODERATE, and LARGE—as defined below.

SMALL—Environmental effects are not detectable 

or are so minor that they will neither destabilize nor 

noticeably alter any important attribute of the 

resource.

MODERATE—Environmental effects are sufficient 

to alter noticeably, but not to destabilize, important 

attributes of the resource.

LARGE—Environmental effects are clearly 

noticeable and are sufficient to destabilize important 

attributes of the resource.

The GEIS includes a determination of whether the analysis of the environmental issue could be 

applied to all plants and whether additional mitigation measures would be warranted 

(Figure 1–2). The NRC assigns issues a Category 1 or a Category 2 designation. As set forth 

in the GEIS, Category 1 issues are those that meet the following criteria:

 The environmental impacts associated with the issue have been determined 

to apply either to all plants or, for some issues, to plants having a specific 

type of cooling system or other specified plant or site characteristics.

 A single significance level (i.e., SMALL, MODERATE, or LARGE) has been 

assigned to the impacts (except for collective offsite radiological impacts from 

the fuel cycle and from high-level waste and spent fuel disposal).

 Mitigation of adverse impacts associated with the issue has been considered 

in the analysis, and it has been determined that additional plant-specific 

Significance indicates the importance 

of likely environmental impacts and is 

determined by considering two variables: 

context and intensity. 

Context is the geographic, biophysical, 

and social context in which the effects will 

occur. 

Intensity refers to the severity of the 

impact, in whatever context it occurs. 

1-5 
Purpose and Need for Action

mitigation measures are likely not to be sufficiently beneficial to warrant 

implementation.

For generic issues (Category 1), no additional site-specific analysis is required in the SEIS 

unless new and significant information is identified. Chapter 4 of this report presents the 

process for identifying new and significant information. Site-specific issues (Category 2) are 

those that do not meet one or more of the criteria of Category 1 issues and, therefore, additional 

site-specific review for these issues is required. The SEIS presents the results of the 

site-specific review.

Figure 1–2. Environmental Issues Evaluated During License Renewal

The NRC staff initially evaluated 92 issues in the GEIS. Based on the findings of the GEIS, a 

site-specific analysis is required for 23 of those 92 issues. 

1.5 Supplemental Environmental Impact Statement

This SEIS presents an analysis that considers the environmental effects of the continued 

operation of Callaway, alternatives to license renewal, and mitigation measures for minimizing 

adverse environmental impacts. Chapter 8 contains analysis and comparison of the potential 

environmental impacts from alternatives, and Chapter 9 presents the recommendation to the 

Commission on whether or not the environmental impacts of license renewal are so great as to 

deny the option of license renewal for energy-planning decisionmakers. The recommendation 

includes consideration of comments received during the public scoping period and comments 

received during the SEIS public comment period. 

1-6 
Purpose and Need for Action

New and significant information either:

(1) identifies a significant environmental 

issue not covered in the GEIS, or

(2) was not considered in the analysis in 

the GEIS and leads to an impact 

finding that is different from the 

finding presented in the GEIS.

In the preparation of this SEIS for Callaway, the NRC staff conducted the following activities:

 reviewed the information provided in Ameren’s ER; 

 consulted with other Federal, state, and local agencies; 

 conducted an independent review of the issues during the site audit; and

 considered the public comments received during the reviewing process.

New information can be identified from a 

number of sources, including the applicant, the 

NRC, other agencies, or public comments. If a 

new issue is revealed, it is first analyzed to 

determine if it is within the scope of the license 

renewal evaluation. If it is within the scope of 

license renewal and if it is not addressed in the 

GEIS, then the NRC determines its significance 

and documents its analysis in the SEIS.

Ameren submitted its ER under NRC’s 1996 rule governing license renewal environmental 

reviews (61 FR 28467, June 5, 1996, as amended), as codified in NRC’s environmental 

protection regulation, 10 CFR 51. The 1996 GEIS (NRC 1996) and Addendum 1 to the GEIS 

(NRC 1999) provided the technical basis for the list of NEPA issues and associated 

environmental impact findings for license renewal contained in Table B–1 in Appendix B to 

Subpart A of 10 CFR Part 51. For Callaway, the NRC staff initiated its environmental review in 

accordance with the 1996 rule and GEIS (NRC 1996, 1999) and documented its findings in 

Chapter 4 of this SEIS.

As described in Section 1.4, the NRC published a final rule (78 FR 37282, June 20, 2013) 

revising 10 CFR 51 including the list of NEPA issues and findings in Table B–1 of 10 CFR 51. 

Under NEPA, the NRC must now consider and analyze in this SEIS the potential significant 

impacts described by the final rule’s new Category 2 issues, and to the extent there is any new 

and significant information, the potential significant impacts described by the final rule’s new 

Category 1 issues. The new Category 1 issues include geology and soils, exposure of 

terrestrial organisms to radionuclides, exposure of aquatic organisms to radionuclides, human 

health impact from chemicals, and physical occupational hazards. Radionuclides released to 

groundwater, effects on terrestrial resources (non-cooling system impacts), minority and 

low-income populations (i.e., environmental justice), and cumulative impacts were added as 

new Category 2 issues. The staff evaluates these new issues in Sections 4.3.1, 4.5.2.3, 4.6.1, 

4.7.1.1, 4.7.2, 4.9.1.1, and 4.10.7 of this SEIS. As also described in Section 1.4, the NRC also 

published a revised rule at 10 CFR 51.23 rule that generically determined the impacts 

associated with the continued storage of spent nuclear fuel beyond the licensed life for reactor

operations. Hereafter in this SEIS, general references to the “GEIS” without stipulation are 

inclusive of the 1996 and 1999 GEIS (NRC 1996, 1999). Information and findings specific to the 

June 2013 final rule (78 FR 37282) and/or the June 2013 GEIS (NRC 2013) are appropriately 

referenced as such in Sections 4.3.1, 4.5.2.3, 4.6.1, 4.7.1.1, 4.7.2, 4.9.1.1, and 4.10.7 of this 

SEIS.

1.6 Cooperating Agencies

During the scoping process, no Federal, state, or local agencies were identified as cooperating 

agencies in the preparation of this SEIS. 

1-7 
Purpose and Need for Action

1.7 Consultations

The Endangered Species Act of 1973, as amended; the National Historic Preservation Act of 

1966; and other such acts require that Federal agencies consult with applicable state and 

Federal agencies and groups before taking action that may affect resources, such as 

endangered species, historic and archaeological resources, and others. Below are the 

agencies and groups with whom the NRC consulted. Appendix D to this report includes a list of 

consultation documents.

 Absentee Shawnee Tribe of Indians of Oklahoma; 

 Advisory Council on Historic Preservation; 

 Caddo Nation; 

 Cherokee Nation; 

 Cheyenne and Arapaho Tribes of Oklahoma; 

 Chickasaw Nation of Oklahoma; 

 Choctaw Nation of Oklahoma; 

 Citizen Potawatomi Nation; 

 Delaware Nation; 

 Eastern Shawnee Tribe of Oklahoma; 

 Iowa Tribe of Kansas and Nebraska; 

 Iowa Tribe of Oklahoma; 

 Miami Tribe of Oklahoma; 

 Missouri Department of Conservation; 

 Missouri Department of Natural Resources (MDNR); 

 Missouri State Historic Preservation Officer; 

 Muscogee (Creek) Nation of Oklahoma; 

 Omaha Tribe of Nebraska and Iowa; 

 Osage Nation; 

 Otoe-Missouria Tribe of Oklahoma; 

 Pawnee Nation of Oklahoma; 

 Peoria Tribe of Oklahoma; 

 Ponca Tribe of Indians of Oklahoma; 

 Ponca Tribe of Nebraska; 

 Prairie Band of Potawatomi Indians; 

 Quapaw Tribe of Oklahoma; 

 Sac and Fox Nation of Oklahoma; 

 Sac and Fox Nation of Missouri in Kansas and Nebraska; 

 Sac and Fox Tribe of Mississippi in Iowa; 

1-8 
Purpose and Need for Action

 Shawnee Tribe; 

 United Keetoowah Band of Cherokee Indians of Oklahoma; 

 U.S. Environmental Protection Agency (EPA), Region 7; 

 U.S. Fish and Wildlife Service, Midwest, Region 3, Columbia, Missouri and 

Fort Snelling, Minnesota; 

 Winnebago Tribe of Nebraska; and

 Wyandotte Nation. 

1.8 Correspondence

During the environmental review, the NRC staff contacted the Federal, state, regional, local, and 

tribal agencies listed in Section 1.7, as well as the U.S. Department of the Interior, Bureau of 

Land Management. 

Appendix E to this SEIS contains a chronological list of all the documents sent and received 

during the environmental review.

Chapter 11 provides a list of persons who received a copy of this SEIS. 

1.9 Status of Compliance

Ameren is responsible for complying with all NRC regulations and other applicable Federal, 

state, and local requirements. Appendix C of the SEIS describes some of the major Federal 

statutes. Table 1–1 lists the permits and licenses issued by Federal, state, and local authorities 

for activities at Callaway.

1-9 
Purpose and Need for Action

Table 1–1. Licenses and Permits

Permit Number Dates Responsible 

Agency

Operating license NPF-30 Issued: 10/18/1984

Expires: 10/18/2024 NRC

National pollutant

discharge elimination

system (NPDES) permit

MO-0098001

Permit Renewal Application

was submitted to MDNR on

08/01/2013. Awaiting 

Permit issuance.

Issued: 4/14/2010

Expired: 2/12/2014

MDNR

Part 70 air permit (Title V; for 

auxiliary boiler, emergency 

electrical generators, and 

storage tanks)

OP2008-045

Application for renewal was 

submitted to MDNR on 

02/19/2013. Awaiting permit 

issuance.

Issued: 9/18/2008

Expired: 9/17/2013

MDNR

Air permit to construct 

permanent backup generators 102010-005

Issued: 10/8/2010

Expired: Construction of the 

backup generators is 

complete and the permit is, 

therefore, expired

MDNR

Section 404 permit for 

discharge and fill in a wetland 

or water of the United States 

for maintenance and 

expansion of Callaway 

wastewater treatment ponds

Not Applicable 

(N/A) N/A

U.S. Army Corps 

of Engineers, 

Kansas City 

District

Section 401 water quality 

certification (integrated with 

NPDES permit issuance)

MO-0098001

Issued: 4/14/2010

Expired: 2/12/2014

(integrated with NPDES and 

the permit is under review)

MDNR

License to ship radioactive 

material

061912 550

089UW

Issued: 6/19/2012

Expires: 6/30/2015

U.S. Department 

of Transportation

Registration of industrial 

hazardous waste 

Solid waste 

registration 

No.: 003518

EPA ID: 

MOD000687392

Issued: 6/17/2010

Expires: N/A MDNR and EPA

Permit for maintenance 

dredging (Section 10 of the 

River and Harbors Act of 

1899)

No Current 

Permits

Issued: N/A

Expires: N/A

U.S. Army Corps 

of Engineers

Potable water system permit Permit 

No. MO3182219

Issued: 1/19/2014

Expires: N/A MDNR

Sources: Ameren 2011a, 2014; MDNR 2008, 2010a, 2010b

1-10
Purpose and Need for Action

1.10 References

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

protection regulations for domestic licensing and related regulatory functions.”

77 FR 11171. U.S. Nuclear Regulatory Commission. “License renewal application for Callaway 

Plant, Unit 1, Union Electric Company.” Action: Intent to prepare environmental impact 

statement and conduct scoping process. Federal Register 77 (37):11171–11173.

February 24, 2012.

77 FR 11173. U.S. Nuclear Regulatory Commission. “Renewal of facility operating license 

No. NPF-30, Union Electric Company, Callaway Plant, Unit 1.” Action: License renewal 

application; docketing and opportunity for hearing and petition for leave to intervene.

Federal Register 77 (37):11173–11175. February 24, 2012.

78 FR 37282. U.S. Nuclear Regulatory Commission. “Revisions to Environmental Review for 

Renewal of Nuclear Power Plant Operating Licenses.” Federal Register 78(119):37282–37324. 

June 20, 2013.

79 FR 56238. U.S. Nuclear Regulatory Commission. “Continued Storage of Spent 

Nuclear Fuel.” Federal Register 79(182):56238–56263. September 19, 2014.

[Ameren] Ameren Missouri. 2011a. “License Renewal Application, Callaway Plant Unit 1, 

Appendix E, Applicant’s Environmental Report, Operating License Renewal Stage.” Fulton, MO: 

Ameren. December 15, 2011. Agencywide Documents Access and Management System 

(ADAMS) Nos. ML113540349, ML113540352, and ML113540354.

[Ameren] Ameren Missouri. 2011b. “License Renewal Application, Callaway Plant Unit 1, 

Facility Operating License No. NPF-30.” Fulton, MO: Ameren. December 15, 2011. ADAMS 

No. ML1135303720.

[Ameren] Ameren Missouri. 2013. “Follow-up to E-RAI Set #2 Responses to the Callaway LRA.” 

Fulton, MO: Ameren. October 9, 2013. ADAMS No. ML13283A182.

[Ameren] Ameren Missouri. 2014. “License Renewal Application, Callaway Plant Unit 1, 

Appendix E, Applicant’s Environmental Report, Operating License Renewal Stage,” 2014 

update. Fulton, MO: Ameren. May 19, 2014. Agencywide Documents Access and Management 

System (ADAMS) Nos. ML14139A497. 

Atomic Energy Act of 1954, as amended. 42 U.S.C. 2011 et seq.

[MDNR] Missouri Department of Natural Resources. 2008. Part 70 Permit to Operate. Air 

Operating Permit No. OP2008-045. September 18, 2008. Available at

<http://www.dnr.mo.gov/env/apcp/air_permits.htm> (accessed 28 June 2012).

[MDNR] Missouri Department of Natural Resources. 2010a. Missouri State Operating Permit 

No. MO-0098001 for Ameren UE, Callaway Power Plant (also known as the plant’s NPDES

permit). St. Louis, MO: Missouri DNR. Effective date: February 13, 2009. Revised date: 

April 14, 2010. ADAMS No. ML12271A484.

[MDNR] Missouri Department of Natural Resources. 2010b. Permit to Construct. Permit 

No. 102010-005). Available at <http://www.dnr.mo.gov/env/apcp/air_permits.htm> (accessed 

28 June 2012).

National Environmental Policy Act of 1969, as amended. 42 U.S.C. 4321 et seq.

1-11
Purpose and Need for Action

[NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG–1437, Volumes 1 

and 2. May 1996. ADAMS Nos. ML040690705 and ML040690738.

[NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3 –Transportation, Table 9.1, 

Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic 

Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: 

NRC. NUREG–1437, Volume 1, Addendum 1. August 1999. ADAMS No. ML040690720.

[NRC] U.S. Nuclear Regulatory Commission. 2012. “Summary of Site Audit Related to the 

Review of the License Renewal Application for Callaway Plant, Unit 1 (TAC Nos. ME7715 

and ME7716).” Washington, DC: NRC. June 22, 2012. ADAMS No. ML12159A154.

[NRC] U.S. Nuclear Regulatory Commission. 2013a. “Environmental Impact Statement Scoping 

Process, Summary Report, Callaway Plant, Unit 1, Callaway County, MO.” Rockville, MD: NRC. 

September 9, 2013. ADAMS No. ML13182A614. 

[NRC] U.S. Nuclear Regulatory Commission. 2013b. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. Washington, DC: Office of Nuclear Reactor 

Regulation. NUREG-1437, Revision 1, Volumes 1, 2, and 3. June 2013. ADAMS Accession 

Nos. ML13106A241, ML13106A242, and ML13106A244.

[NRC] U.S. Nuclear Regulatory Commission. 2014. Generic Environmental Impact Statement

for Continued Storage of Spent Nuclear Fuel. Washington, DC: NRC, Office of Nuclear Material 

Safety and Safeguards. NUREG–2157, Volumes 1 and 2. September 2014. ADAMS 

Accession Nos. ML14196A105 and ML14196A107. 

1-12
2.0 AFFECTED ENVIRONMENT

Callaway Plant, Unit 1 (Callaway) is located in Callaway County, Missouri, approximately 10 mi 

(16 km) southeast of Fulton and 80 mi (129 km) west of St. Louis. The State capital, 

Jefferson City, is approximately 25 mi (40 km) southwest of the site, and the Missouri River 

flows 5 mi (8 km) south of the site. Figures 2–1 and 2–2 are a 6-mi (10-km) radius map and a 

50-mi (81-km) radius map, respectively.

Because the existing conditions are partially the result of past construction and operations at the 

plant, this chapter presents the impacts of these past and ongoing actions and how they have 

shaped the environment. Section 2.1 describes the facility and its operation; Section 2.2 

describes the affected environment; and Section 2.3 describes related Federal and State 

activities near the site.

2.1 Facility Description

Callaway is a single-unit nuclear power plant that began commercial operation on 

December 19, 1984. The Callaway site covers 7,354 acres (ac) (2,976 hectares (ha)). 

Figure 2–3 shows the Callaway site layout and property boundary. The property is composed of 

three main areas. The first area is the 2,765-ac (1,119-ha) power plant site area containing the 

major power generation facilities (Figure 2–4), which include the following:

 the containment building and related structures,

 a natural-draft cooling tower,

 a switchyard,

 the ultimate heat sink retention pond and cooling tower,

 a water treatment plant, and

 administration buildings, warehouses, and other features (Ameren 2011d).

The majority of these facilities are located on 512 ac (207 ha) of the 2,765-ac (1,119-ha) plant 

site area.

Union Electric Company (UEC), a subsidiary of Ameren Corporation and doing business as 

Ameren Missouri (Ameren or the applicant), planned to build a Callaway, Unit 2, near the Unit 1 

reactor, and it submitted a combined license application (COLA) to the U.S. Nuclear Regulatory 

Commission (NRC) in 2008. In 2009, Ameren suspended its efforts to build the new unit, 

because of financial and legislative complications. 

The second area is a 2,135-ac (864-ha) corridor area containing the intake and blowdown 

pipelines between the plant and the river intake structure. The third area comprises 2,454 ac 

(993 ha) that are not used for power generation (Ameren 2011d).

The Callaway property encompasses the 6,759-ac (2,735-ha) Reform Conservation Area, which 

is managed by the Missouri Department of Conservation (MDC) (MDC 2012a). Except for the 

plant site area, Ameren has made the remaining approximately 6,300 ac (2,550 ha) of the 

conservation area available for public access (Figure 2–5) (Ameren 2011d).

2-1 
Affected Environment

Figure 2–1. Callaway Plant, 6-Mi Radius Map

Source: Modified from Ameren 2011d

2-2 
Affected Environment

Figure 2–2. Callaway Plant, 50-Mi (80-Km) Radius Map

Source: Modified from Ameren 2011d

2-3 
Affected Environment

Figure 2–3. Callaway Plant, Site Layout, and Property Boundary

Source: Modified from Ameren 2011d

2-4 
Affected Environment

Figure 2–4. Callaway Plant Layout

Source: Modified from Ameren 2011d

2-5 
Affected Environment

Figure 2–5. Reform Conservation Area

Source: Conservation Commission of the State of Missouri © 2011. Reprinted by permission.

2-6 
Affected Environment

2.1.1 Reactor and Containment Systems

The Callaway nuclear facility follows the Standardized Nuclear Unit Power Plant System design. 

The nuclear steam supply system is a four-loop Westinghouse pressurized-water reactor. The 

electrical capacity is 1,236 megawatts-electric. The reactor core heats water to approximately 

590 °F (310 °C). Boiling does not occur because the pressure exceeds 2,200 pounds per 

square inch (15.2 megapascals). The heated water is pumped to four U-tube heat exchangers 

known as steam generators (SGs), where the heat boils the water on the shell side of the SG 

into steam. After the steam is dried in the SG, it is routed to the turbines. The dry steam turns 

the turbines, which are connected to the electrical generator where the electricity is produced 

(Ameren 2011d).

The nuclear fuel is low-enriched uranium dioxide with enrichments less than 5 percent by weight 

uranium-235. The maximum fuel assembly burnup is less than 60,000 megawatt-days per 

metric ton of uranium. Callaway operates on an 18-month refueling cycle (Ameren 2011d).

The reactor, SGs, and related systems are inside a containment structure that is designed to 

withstand the pressure and prevent radioactive leakage to the environment. The containment 

structure is a post-tensioned, pre-stressed, reinforced concrete cylinder with a slab base and a 

hemispherical dome that gives the structure its pressure-resistance capability. A welded steel 

liner is attached to the inside face of the concrete shell to supply a high degree of leak tightness. 

Also, the 4-ft-thick (1.2-m-thick) concrete walls serve as a radiation shield for both normal and 

postulated accident conditions (Ameren 2011d).

The containment structure has a ventilation system, which is used to maintain pressure and 

temperatures within acceptable limits. The ventilation system exhaust is monitored for 

radioactivity before its discharge to the environment through the plant vent. High-efficiency 

particulate air filters are used to filter the vented air before its release. The containment 

structure has the capability to be isolated from the environment (Ameren 2011d).

2.1.2 Radioactive Waste Management

The radioactive waste systems collect, treat, and dispose of radioactive and potentially 

radioactive wastes that are byproducts of Callaway operations. The byproducts are activation 

products resulting from the irradiation of reactor water and impurities within the reactor water 

(principally metallic corrosion products) and fission products, resulting from defective fuel 

cladding or uranium contamination within the reactor coolant system. Operating procedures for 

the radioactive waste system ensure that radioactive wastes are safely processed and 

discharged from Callaway. The systems are designed and operated to ensure that the 

quantities of radioactive materials released from Callaway are as low as is reasonably 

achievable (ALARA) and within the dose standards 

stated in Part 20 of Title 10 of the Code of Federal 

Regulations (10 CFR Part 20), “Standards for protection 

against radiation,” and 10 CFR Part 50, “Domestic 

licensing of production and utilization facilities.” The 

Callaway Offsite Dose Calculation Manual (ODCM) 

contains the methods and parameters used to calculate 

offsite doses resulting from radioactive effluents. These 

methods are used to ensure that radioactive material 

discharged from Callaway meets regulatory dose standards.

Radioactive wastes resulting from Callaway operations are classified as liquid, gaseous, and 

solid. Radioactive wastes generated by Callaway operations are collected and processed to 

By design, the operation of nuclear 

power plants is expected to result in 

small releases of radiological effluents 

(gaseous, liquid, and solid) through 

controlled processes. However, 

releases must meet stringent NRC 

and EPA regulatory limits.

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Affected Environment

meet applicable requirements. The design and operational objectives of the radioactive waste 

management systems are to limit the release of radioactive effluents from Callaway during 

normal operation and anticipated operational occurrences (Ameren 2010c).

Reactor fuel that has exhausted a certain percentage of its fissile uranium content is referred to 

as spent fuel. Spent fuel assemblies are removed from the reactor core and replaced with fresh 

fuel assemblies during routine refueling outages, typically every 18 months. Callaway currently 

has a spent fuel pool for storage of spent nuclear fuel at the plant. As discussed in Section 2.15 

of Ameren’s Environmental Report (ER), an independent spent fuel storage installation (ISFSI) 

is proposed for the plant because the pool does not have adequate storage capacity to take the 

plant to the end of its current operating license. By approximately 2020, the spent fuel pool will 

not have enough capacity to offload an entire core. Ameren intends to construct an ISFSI, but 

this project is sufficiently far enough in the future that no specific plans have been prepared at 

this time (Ameren 2011d).

The NRC regulates the management of radioactive materials and wastes under the Atomic 

Energy Act of 1954 (AEA), as amended (42 United States Code (U.S.C.) 2011 et seq.). 

Systems used at Callaway to process liquid, gaseous, and solid radioactive wastes are 

described in the following sections.

2.1.2.1 Radioactive Liquid Waste System

The Callaway liquid waste system collects, holds, treats, processes, and monitors all liquid 

radioactive wastes for reuse or disposal. The system is divided into several subsystems so that 

liquid wastes from various sources can be segregated and processed separately. 

Cross-connections between the subsystems offer additional flexibility for processing the wastes 

by alternate methods. The wastes are collected, treated, and disposed of according to their 

conductivity or radioactivity (Ameren 2010c).

Liquid waste is collected in sumps and drain tanks and transferred to the appropriate subsystem 

collection tanks for subsequent treatment, disposal, or recycling. Liquid waste is processed or 

treated by a variety of methods specifically designed to offer maximum decontamination factors. 

The treatment methods include filtration and demineralization. The liquid waste is typically 

processed by passing it through equipment components mounted on a skid. Following 

treatment, the processed wastes in the waste evaporator condensate tank, waste monitor tanks, 

or secondary liquid waste monitor tanks are analyzed for chemical and radioactive content 

before being discharged. Ameren discharges liquid waste from Callaway in accordance with the 

procedures and methods described in the ODCM so that exposures to members of the public do 

not exceed the dose limits specified in 10 CFR Part 20 and in 10 CFR Part 50, Appendix I, 

“Numerical guides for design objectives and limiting conditions for operation to meet the 

criterion ‘as low as is reasonably achievable’ for radioactive material in light-water-cooled 

nuclear power reactor effluents.” The liquid effluent discharges from the plant into the Missouri 

River via a pipeline. Liquid radioactive effluent releases are continuously monitored and can be 

automatically stopped in the event of a high-radiation alarm or power failure (Ameren 2010c).

2.1.2.2 Radioactive Gaseous Waste System

Gaseous waste management systems collect and process radioactive and potentially 

radioactive waste gas and control the release of gaseous radioactive effluents to the 

atmosphere. This system also limits the release of gaseous radioactivity so that personnel 

exposure and radioactive releases in restricted and unrestricted areas are ALARA. The 

radioactive gaseous waste system is used to reduce radioactive materials in gaseous effluents 

before discharge to meet the dose limits in 10 CFR Part 20 and the dose design objectives in 

Appendix I to 10 CFR Part 50. The major source of gaseous radioactive waste is purging of the 

2-8 
Affected Environment

volume control tank and discharge tank vents, and other equipment in the containment, 

radioactive waste, and auxiliary buildings.

Before being released into the environment through the radioactive waste building or auxiliary 

building ventilation systems, the gas is passed through charcoal and particulate filtration media. 

Ameren monitors radioactive discharges in accordance with the procedures and methods 

described in the ODCM so that exposures to members of the public do not exceed the dose

limits specified in 10 CFR Part 20 and Appendix I to 10 CFR Part 50 (Ameren 2010c).

2.1.2.3 Radioactive Solid Waste Processing Systems

The Callaway solid waste management system is designed to safely collect, process, package, 

store, and prepare radioactive wet and dry solid waste materials generated by plant operations 

for shipment to an offsite waste processor for disposal at a licensed burial facility. The system 

is designed to process waste while maintaining occupational exposures ALARA. To ensure 

compliance with applicable regulations in 10 CFR Parts 20, 61, and 71, the characterization, 

classification, processing, waste storage, handling, and transportation of solid wastes are 

controlled by the process control program.

The solid radioactive waste system is designed to collect, process, and package low-level 

radioactive wastes generated as a result of normal plant operation. It also is capable of storing 

the packaged waste until it is shipped off site to a waste processor for treatment and disposal, 

or to a licensed burial site. The solid radioactive waste equipment is located in the radioactive 

waste building. The system consists of a dry waste system, resin handling system, filter 

handling system, and waste disposal system. Both wet and dry radioactive solid wastes are 

processed. Wet solid wastes include spent resins, filter cartridges, filter sludges, evaporator 

bottoms, waste from floor drain filters, and fuel pool filters. Dry solid wastes include 

contaminated rags, clothing, paper, small equipment parts, and solid laboratory waste. Large or 

highly radioactive components and equipment are packaged in special shipping containers for 

transportation to an offsite vendor for processing and disposal. Solid radioactive wastes that 

are packaged and shipped from Callaway are shipped in containers that meet the requirements 

established by the U.S. Department of Transportation and the NRC (Ameren 2010c).

Class A waste is collected sorted, packaged, and shipped off site to approved vendors for 

further processing and disposal (Ameren 2012b).

Currently, charcoal filters and some resin that are considered Class B and C wastes are 

drummed and stored in the radioactive waste high-level drum storage area (HLDSA). Since 

Callaway does not have access to a licensed low-level radioactive waste disposal facility for its 

Class B and C wastes, the HLDSA is being used for storage of this waste. As stated in the 

Callaway Energy Center Radioactive Waste Management Plan, the HLDSA can hold a 

maximum of 395 drums. As of May 29, 2012, the HLDSA had an inventory of 138 drums. At a 

normal fill rate of 5 drums per year, the HLDSA would take more than 50 years to reach 

capacity if no Class B and C wastes were shipped off site (Ameren 2012b).

Additional spent resin is stored in the radioactive waste primary spent resin storage tank 

(PSRST). Used resin is transferred from the PSRST to container liners stored in shielded vaults 

that are located in an area called the low-level drum storage area. Ameren intends to obtain 

additional liners and shielded vaults to store the spent resins, as necessary (Ameren 2012b).

With the above steps in place, Ameren has determined that it has adequate facilities for the safe 

handling and storage of low-level radioactive waste during the term of license renewal. In 

addition, Ameren is currently in discussion with vendors that process and dispose of Class B 

and C wastes (Ameren 2012b).

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Affected Environment

Therefore, based on its review, the NRC staff concludes that Ameren has appropriate programs 

and facilities in place for the processing and disposal of its Class A wastes and has a sufficient 

amount of storage on site to safely handle and store its Class B and C wastes during the license 

renewal term.

2.1.3 Nonradiological Waste Management

Ameren generates nonradioactive wastes at Callaway as part of routine plant maintenance, 

cleaning activities, and plant operations. The generation, handling, and storage of hazardous 

wastes is regulated by the U.S. Environmental Protection Agency (EPA) under the Resource 

Conservation and Recovery Act of 1976, as amended (RCRA) (42 U.S.C. 6901 et seq.). The 

RCRA waste regulations governing the disposal of solid and hazardous waste are contained in 

40 CFR—Protection of the Environment. Regulations in 40 CFR Parts 239–259 apply to solid 

(nonhazardous) waste, 40 CFR Parts 260–279 contain regulations for hazardous waste, and 

40 CFR Parts 280–282 contain the requirements for underground storage tanks. Subtitle C of 

the RCRA regulations establishes a system for controlling hazardous waste from “cradle to 

grave,” and RCRA Subtitle D encourages states to develop comprehensive plans to manage 

nonhazardous solid waste and mandates minimum technological standards for municipal solid 

waste landfills. Missouri State RCRA regulations are administered by the Missouri Department 

of Natural Resources (MDNR) and address the identification, generation, minimization, 

transportation, final treatment, storage, and disposal of hazardous and nonhazardous wastes.

2.1.3.1 Nonradioactive Waste Streams

Hazardous Waste

Ameren generates solid waste, as defined by RCRA, as part of routine plant maintenance, 

cleaning activities, and plant operations. Missouri is within EPA Region 7, and hazardous, 

nonradioactive wastes in the state are regulated by Region 7’s Solid Waste Program. In 1977, 

EPA authorized MDNR to administer portions of the RCRA program in the State of Missouri, 

which are incorporated into Title 10, Divisions 25, 26, and 80, of the Missouri Code of State 

Regulations (10 CSR Parts 25, 26, and 80).

EPA classifies certain nonradioactive wastes as hazardous based on characteristics such as 

ignitability, corrosivity, reactivity, and toxicity (hazardous wastes are listed in 40 CFR Part 261, 

“Identification and listing of hazardous waste”). State-level regulators may add wastes to EPA’s 

list of hazardous wastes. The RCRA supplies standards for the treatment, storage, and 

disposal of hazardous waste for hazardous waste generators (regulations are available in 

40 CFR Part 262, “Standards applicable to generators of hazardous waste”).

EPA recognizes the following main types of hazardous waste generators (40 CFR 260.10, 

“Purpose, scope, and applicability”), based on the quantity of the hazardous waste produced:

 large quantity generators that generate 2,200 lb (1,000 kg) per month or more 

of hazardous waste, more than 2.2 lb (1 kg) per month of acutely hazardous 

waste, or more than 220 lb (100 kg) per month of acute spill residue or soil;

 small quantity generators (SQGs) that generate more than 220 lb (100 kg) 

but less than 2,200 lb (1,000 kg) of hazardous waste per month; and

 conditionally exempt SQGs that generate 220 lb (100 kg) or less per month of 

hazardous waste, 2.2 lb (1 kg) or less per month of acutely hazardous waste, 

or less than 220 lb (100 kg) per month of acute spill residue or soil.

The State of Missouri has incorporated EPA’s regulations on hazardous wastes by reference 

and recognizes Callaway as an SQG of hazardous wastes under 10 CSR 25, “Hazardous 

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Affected Environment

Waste Management Commission.” Callaway hazardous wastes include waste paint, waste 

solvents, laboratory chemicals, and microfilm processing waste. Typical hazardous constituents 

consist of chromium, lead, mercury, silver, and solvents (Ameren 2012e). Ameren periodically 

also generates other special wastes, such as refrigerants, antifreeze, lead, and asbestos. 

Hazardous wastes are stored on site in the prefabricated hazardous waste storage building 

(HWSB), which has specialized containment sumps. Waste is stored in the HWSB for up to 

180 days before disposal via an offsite vendor, which is done in accordance with Missouri State 

requirements (Ameren 2012e, undated a).

Conditions and limitations for wastewater discharge by Callaway are specified in Missouri State 

Operating Permit No. MO–0098001 (MDNR 2010a) issued under the National Pollutant 

Discharge Elimination System (NPDES) program. Radioactive liquid waste is addressed in 

Section 2.1.2 of this supplemental environmental impact statement (SEIS). Section 2.2.4 gives 

more information about Callaway’s NPDES permit and permitted discharges.

The Emergency Planning and Community Right-To-Know Act (EPCRA) (42 U.S.C. 116 et seq.) 

requires applicable facilities to supply information about hazardous and toxic chemicals to local 

emergency planning authorities and EPA. On October 17, 2008, EPA completed several 

changes to the Emergency Planning (Section 302), Emergency Release Notification 

(Section 304), and Hazardous Chemical Reporting (Sections 311 and 312) regulations that were 

proposed on June 8, 1998 (63 FR 31268). Callaway is subject to Federal EPCRA reporting 

requirements; thus, Ameren submits an annual Section 312 (Tier II) report on hazardous 

substances to local emergency response agencies (Ameren 2011e, 2012g). Ameren also 

submits Toxic Release Inventory Reports for hazardous air pollutants (HAPs) in accordance 

with EPCRA. On the annual emission inventory questionnaires submitted to MDNR for the 

5-year period from 2007 through 2011, Ameren reported zero tons of HAPs for Callaway 

(Ameren 2008b, 2009c, 2010b, 2011b, 2012c).

Universal Waste

EPA classifies several hazardous wastes as universal wastes, including batteries, pesticides, 

mercury-containing items, and fluorescent lamps. MDNR has incorporated EPA’s regulations 

(40 CFR Part 273, “Standards for universal waste management”) regarding universal wastes by 

reference in 10 CSR 25–16. Universal wastes produced at Callaway are recycled or disposed 

of in accordance with MDNR regulations (Ameren undated a, undated b).

Mixed Waste

Low-level mixed wastes (LLMWs) are wastes that contain low-level radioactive waste and 

RCRA hazardous waste (40 CFR 266.210). The State of Missouri regulates the hazardous 

component of the mixed waste through RCRA, and the NRC regulates radioactive waste subject 

to the AEA. Ameren periodically produces small amounts of LLMW (less than approximately 

5 gallons (gal) per year in 2010 and 2011) (Ameren 2011c, 2012d), mainly from maintenance 

activities that use hexane. Such mixed wastes are placed into storage pending testing and 

evaluation for the radioactive and hazardous content. Ameren sends mixed waste off site for 

treatment or disposal at approved facilities (Ameren undated a).

Ameren generates radioactively contaminated used oil from routine activities and reactor

coolant pump oil from refueling outages. This used oil is stored with other radioactive wastes. 

Ameren tests the used oil to determine if the hazardous constituents meet the definition of a 

hazardous waste. If not, which is usually the case, Ameren sends the oil off site for disposal as 

a radioactive waste. Approximately 100 gal per year of such radioactive used oil are generated 

at Callaway (Ameren 2012e). If the hazardous constituents in the oil meet the definition of a 

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Affected Environment

hazardous waste, Ameren manages the used oil as a mixed waste and sends it off site for 

treatment or disposal (Ameren undated a).

2.1.3.2 Pollution Prevention and Waste Minimization

Ameren has a Waste Minimization/Pollution Prevention Program to minimize Callaway’s 

environmental impact and conserve natural resources. The facility prevents environmental 

pollution by eliminating or reducing the following whenever possible:

 use of toxic substances, 

 release of toxic pollutants, and

 generation of hazardous and other wastes.

Ameren accomplishes waste minimization by selecting currently available methods of treatment, 

storage, and disposal that minimize the present and future threat to human health and the 

environment (Ameren undated c).

2.1.4 Plant Operation and Maintenance

Maintenance activities carried out at Callaway include inspection, testing, and surveillance to 

maintain the current licensing basis of the facility and ensure compliance with environmental 

and safety requirements. Various programs and activities currently exist at Callaway to 

maintain, inspect, test, and monitor the performance of facility equipment. These maintenance 

activities include inspection requirements for reactor vessel materials, boiler and pressure 

vessel inservice inspection and testing, a maintenance structures monitoring program, and 

maintenance of water chemistry.

Additional programs include those carried out to meet technical specification surveillance 

requirements, those carried out in response to generic communications from the NRC, and 

various periodic maintenance, testing, and inspection procedures (Ameren 2010c). Certain 

program activities are carried out during the operation of Callaway, while others are carried out 

during scheduled refueling outages. Nuclear power plants must periodically discontinue the 

production of electricity for refueling, periodic inservice inspection, and scheduled maintenance. 

Callaway refuels on an 18-month interval (Ameren 2011d).

2.1.5 Power Transmission System

Four Ameren-owned transmission lines connect Callaway to the transmission system: the 

Montgomery #1 and #2 Lines, the Bland Line, and the Loose Creek Line (Figure 2–6). Although 

these lines were constructed 

specifically for Callaway, Ameren 

intends to maintain these transmission 

lines indefinitely as an integral part of 

the larger transmission distribution 

system after Callaway is 

decommissioned. The transmission 

line description below discusses the 

entire length of the transmission lines. 

Transmission line corridors (or right-of-ways) are strips 

of land used to construct, operate, maintain, and repair 

transmission line facilities. The transmission line is 

usually centered in the corridor. The width of a 

corridor depends on the voltage of the line and the 

height of the structures. Transmission line corridors 

typically must be clear of tall-growing trees and 

structures that could interfere with a power line.

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Affected Environment

However, in its analysis, the NRC staff only considers the portion of the transmission lines 

extending from Callaway to the first substation.1

 At Callaway, an onsite switchyard lies 

southwest of the Unit 1 reactor building and connects lines from the plant into the regional 

power distribution system. Lines beyond this switchyard have been integrated into the regional 

electric grid and would stay in service regardless of Callaway license renewal, and, thus, would 

not be affected by the proposed action. Thus, the inscope transmission lines are contained 

within the footprint of the Callaway site. Unless otherwise noted, the discussion of the power 

transmission system is adapted from Ameren’s ER (Ameren 2011d).

1 On June 20, 2013, the NRC published a final rule (78 FR 37282) revising its environmental protection regulation, Title 10 

of the Code of Federal Regulations (10 CFR) Part 51, “Environmental protection regulations for domestic licensing and 

related regulatory functions.” A revised generic environmental impact statement (GEIS) (NRC 2013), which updates the 

1996 GEIS, provides the technical basis for the final rule. The final rule redefines the number and scope of the 

environmental impact issues that must be addressed by the NRC and applicants during license renewal environmental 

reviews. The rule incorporates lessons learned and knowledge gained from license renewal environmental reviews 

conducted by the NRC since 1996. Among other changes, the final rule revises the definition of in -scope of transmission 

lines to be those “transmission lines that connect the nuclear power plant to the substation where electricity is fed into the 

regional power distribution system and transmission lines that supply power to the nuclear plant from the grid.”

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Affected Environment

Figure 2–6. Callaway Plant Transmission Corridors

Source: Modified from Ameren 2011d

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Affected Environment

2.1.5.1 Description of the Lines

The Montgomery #1 and #2 Lines consist of two 345-kV lines installed on double-circuit, steel 

lattice towers. The lines originate at the Callaway Substation and terminate at the Montgomery 

Substation, near Florence, Missouri. The overall length of the route from Callaway to 

Montgomery is 23.2 mi (37.3 km). The lines run approximately northeast for about 11.9 mi 

(19.1 km) within a 200-ft wide (61.0-m wide) corridor and then turn more easterly for the last 

11.3 mi (18.2 km), joining a corridor containing a 161 kV line. The Montgomery Lines occupy 

150 ft (45.7 m) of the width of the joint corridor.

The Bland Line is a 345-kV line installed on double-circuit, steel lattice towers. The line 

originates at the Callaway Substation and terminates at the Bland Substation, north of 

Owensville, Missouri. The overall length of the route from Callaway to Bland is 31.5 mi 

(50.7 km). The line runs approximately southeast for about 6.7 mi (10.8 km) within a 200-ft wide 

(61.0-m wide) corridor shared with the Loose Creek Line (the lines also share the same towers). 

The Bland Line then continues southeast for the rest of its route. In this portion of the route, it 

runs for 2.5 mi (4.0 km) within an unshared 200-ft wide (61.0-m wide) corridor and then joins a 

corridor shared with a 161-kV line for 17.4 mi (28.0 km). The Bland Line occupies 150 ft 

(45.7 m) of the width of the joint corridor. For the last 4.9 mi (7.9 km), the line runs within a 

200-ft wide (61.0-m wide) corridor not shared with any other line.

The Loose Creek Line is a 345-kV line installed on double-circuit, steel lattice towers in the 

corridor shared with the Bland Line and on wooden H-frame towers after leaving the Bland Line. 

The line originates at the Callaway Substation and terminates at the Loose Creek Substation, 

near Loose Creek, Missouri. The overall length of the route from Callaway to Loose Creek is 

23.3 mi (37.5 km). The line runs approximately southeast for about 6.7 mi (10.8 km) within a 

200-ft wide (61.0-m wide) corridor shared with the Bland Line (the lines also share the same 

towers). The Loose Creek Line then turns approximately southwest for the rest of its route, 

which runs for 16.6 mi (26.7 km) within a separate 200-ft wide (61.0-m wide) corridor.

In total, the transmission lines are contained within 71.3 mi (114.7 km) of corridor comprising 

about 1,555 ac (629 ha). The lines pass through land that is primarily deciduous forest, 

grassland, and farmland. The areas are mostly remote and have low population densities. The 

lines cross several county, state, and U.S. highways (and in the case of the Montgomery Lines, 

Interstate 70). In addition, the Bland and Loose Creek lines pass over the Missouri River, and 

the Bland Line also passes over the Gasconade River. The lines also cross smaller creeks and 

drainages. 

Other than the Reform Conservation Area lands within the Callaway site boundary, these lines 

do not cross any critical habitats, state or Federal wildlife preserves, refuges, or parks.

2.1.5.2 Transmission Line Corridor Vegetation Maintenance

The Missouri Code of State Regulations, Title 4, Division 240, Chapter 23, Subchapter 20 

(4 CSR 240–23.020), establishes state requirements for patrols and inspections of electrical 

infrastructure. Ameren’s Transmission Vegetation Management Program describes Ameren’s 

surveillance and maintenance procedures, which ensure that design ground clearances are 

maintained (Ameren 2007a). Ameren carries out aerial or ground inspections of the lines and 

corridors twice annually. Aerial inspections in general check for the following, which would be 

evidence of clearance problems (Ameren 2011d):

 encroachments,

 broken conductors,

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Affected Environment

 broken or leaning structures, and

 signs of trees burning.

Ground inspections include the following:

 examination for clearance at questionable locations,

 assessment of the integrity of structures, and

 surveillance for dead or diseased trees that might fall on the transmission 

lines. 

As specified in its Transmission Vegetation Management Program (Ameren 2007a), Ameren 

requires that minimum clearances be maintained at all times in accordance with the Institute of 

Electrical and Electronics Engineers (IEEE) Standard 516–2003, “IEEE Guide for Maintenance 

Methods on Energized Power Lines.” In the wire zone (the area encompassing the conductors 

and structures and extending out 20 ft (6.1 m) beyond the outside conductor), vegetation is 

maintained at a minimum clearance distance of 20 ft (6.1 m) from the conductor and a minimum 

side clearance of 20 ft (6.1 m). If a line normally operates with less than 30 ft (9.1 m) of ground 

clearance, then vegetation is maintained at a height of less than 10 ft (3.0 m) within the wire 

zone and the border zone (the border zone is the area from the outside edge of the wire zone to 

the mature tree line, the outside edge of the right-of-way (ROW), or both). Ameren does not 

allow tree growth to overhang any conductor, structure, or guy line associated with transmission 

circuits or structures. 

When Ameren actively carries out vegetative maintenance, it applies additional requirements 

designed to ensure that the minimum clearance distances are maintained year-round. For 

example, in the wire zone, vegetation is managed to promote the growth of native plant species 

with a mature height of less than 10 ft (3.0 m). In the border zone, vegetation is managed to 

promote the growth of plant species with a mature height of less than 20 ft (6.1 m), and 

vegetation is maintained with a side clearance of 40 ft (12.2 m) from the conductor or to the 

existing maintained ROW. Plant species that normally reach a mature height greater than what 

is allowed for their zone are removed by mechanical methods or controlled by applications of 

EPA-approved herbicides. If operating conditions cause conductors to sag, then vegetation is 

managed in those areas to ensure clearance between the vegetation and the conductor.

Ameren reviews and approves each plan for herbicide use before herbicides may be used. 

Herbicides are applied using a variety of methods, including aerial foliar (helicopter), low-volume 

foliar, high-volume foliar, dormant stem (basal), cut stubble, and cut stump. Contractors that 

apply the herbicides must maintain application records in accordance with Missouri pesticide 

use regulations. During ground applications, Ameren applies pesticides only to woody plants, 

vines, and noxious vegetation. They do not treat forbs, legumes, grasses, wildflowers, 

cultivated plants, fruit trees, yard trees, or brush along public areas. Only herbicides approved 

for wetlands use are used in wetland areas. Ameren notifies property owners in advance of the 

intent to apply herbicides (Ameren 2007a).

Ameren does not routinely carry out specific studies of threatened and endangered species in 

transmission line corridors; however, it corresponds with the U.S. Fish and Wildlife Service

(FWS) and MDC to obtain records of species found along transmission line corridors 

(Ameren 2012f; FWS 2010; MDC 2010b). As a result of that and other processes, several 

Federally or Missouri-listed threatened or endangered species have been identified with the 

potential to occur in areas crossed by the transmission lines; these species are described in 

Section 2.2.8. In its response to requests for additional information (RAI) concerning 

transmission line maintenance, Ameren indicated that it takes threatened and endangered 

2-16
Affected Environment

species into account as part of vegetation maintenance and “special precaution is taken to avoid 

areas where threatened and endangered species are present” (Ameren 2012e).

2.1.6 Cooling and Auxiliary Water Systems

The cooling and auxiliary water system can be characterized as comprising four interconnected 

systems: circulating water system, demineralized water makeup system, sanitary wastewater

system, and potable water system. Each of these systems is described in the following 

sections.

2.1.6.1 Circulating Water System

To cool the reactor, Callaway uses a closed-cycle circulating water system consisting of a 

cooling water intake structure, circulating water pumps, a main condenser, a cooling tower, 

makeup and blowdown systems, and a discharge structure. This system circulates 

530,000 gallons per minute (gpm) (33,438 litres per second (L/s)) to remove the waste heat 

from normal operations using a 555-ft high (169-m high) hyperbolic, natural-draft cooling tower 

(Ameren 2011d).

The average daily volume of water discharged to the Missouri River is 7.5 cubic feet per second 

(cfs) (0.2 cubic meter per second (m3

/s)), while the maximum daily discharge is 25 cfs 

(0.71 m3

/s) (MDNR 2010a).

Water for the circulating water system is supplied by the river water intake structure, which is 

located on the northern shore of the Missouri River. The intake structure is constructed of 

reinforced concreted and is located within an opening of a Corps of Engineers’ rock revetment. 

The upstream riverbank is set back slightly from the riverside face of the intake structure and 

the rock revetment. The downstream riverbank is set back from the rock revetments. The 

structure is 31 ft (9.5 m) high and is 41 ft (12.5 m) wide, parallel to the river. To protect the 

intake structure from barges, pilings are installed on the upstream side. The main channel of 

the river flows directly in front of the intake structure as the channel follows the north shore of 

the river at this point.

River water entering the intake structure travels through vertical through one of three bays that 

are oriented perpendicular to the river (UEC 1986). The openings for two of the pump bays are 

7 ft (2 m) wide and the third bay is 8.5 ft (2.6 m) wide. Low-velocity fish escape openings are 

set in the side of each bay. River water that enters the intake structure flows through vertical 

trash racks designed to stop large objects and debris from entering the structure. The vertical 

trash racks are composed of 0.5-in. (1.3-cm) bars and only allow objects smaller than 0.5 in2 to 

pass through into the intake structure (Ameren 2012a). The river water then flows into one of 

the three bays, each of which is equipped with a vertical traveling screen that removes the 

material that was small enough to have passed through the trash racks. Each vertical traveling 

screen has a 1/2-in. (1.3-cm) mesh and an automatic spray wash. In the winter, the spray wash 

water is warmed by electric heaters to prevent freezing. The intake velocity at the traveling 

screen is 0.307 foot per second (fps) (.09 m/s); this is based on a normal flow of 9,000 gpm 

(34,065 litres per minute (L/min)) and a normal water level of 16 ft (4.9 m) of water in the pump 

bay (UEC 1986). The highest theoretical velocity is 0.595 fps (0.18 mps) and is based on 

maximum pump flow and low river water levels (Ameren 2012a). The bays also contain fish 

escape openings in their side walls (Ameren 2011d).

One to two times a year the intake water is supplemented with a molluscicide (8 gal (30 litres 

(L)) per treatment) (UEC 1986), as specified under the Missouri State Operating Permit, which 

also serves as its Federal National Pollution Discharge Elimination System permit, Whole 

Effluent Toxicity (WET) testing is required as part of monitoring conditions. This WET testing 

2-17
Affected Environment

monitors for discharges of toxic substances to ensure that they are in compliance with the 

permit limits (MDNR 2010a).

Each bay is equipped with a large vertical three-stage centrifugal pump with enclosed impellers. 

The centrifugal pump bearings are lubricated with water from wells located adjacent to the 

intake structure. These wells extract groundwater from a deep underlying aquifer. Two 

centrifugal pumps will satisfy the needs of the plant during normal plant operational 

requirements. However, during periods of plant power outages, less cooling water is needed 

and during those times only one centrifugal pump will be operated.

Once inside the bay, river water is mixed with the relatively small amounts of well water that was 

used to lubricate the pump bearings. The water in the bay is then pumped into a 5.5-mi long 

(3.1-km long) intake pipeline to the water treatment plant located on the southeast side of the 

plant. Any excess water in a bay or not needed to maintain system pressure in the pipeline is 

returned to the Missouri River.

The water treatment plant removes suspended solids from the river water. Suspended solids 

are removed in three clarifiers using flocculants, and when necessary, sodium hypochlorite and 

a molluscicide are also added. During the winter, when the temperature is less than 40 °F 

(4 °C) a coagulant aid may also be added to the river water (Ameren 2012e). During the 

summer when temperatures exceed 60 °F (16 °C), the water treatment plant also adds bleach 

to the river water. Bleach is added at a ratio of 200 gal (757 L) per clarifier per week. In 

addition in the spring and the fall a molluscicide is also added to the water. Water that has been 

processed by the water treatment plant is pumped to the cooling tower (Ameren 2011d).

Sludge removed from river water by the water treatment plant clarifiers is pumped to 

sedimentation (settling) ponds. There are currently a total of four existing sedimentation ponds, 

but only two are in use as the other two are filled and have no additional capacity to receive 

sludge. After the solids in the sludge have settled to the bottom of the ponds the now clarified 

water is recycled back to the water treatment plant. The four existing ponds, inclusive of those 

that are at capacity, total approximately 30 ac (12 ha) and support aquatic and terrestrial 

wildlife. 

From 2014 until the end of the license renewal period, Ameren expects it will construct 4 to 

5 additional sedimentation ponds to support continued operation of Callaway during this time. 

Exelon plans to complete construction of two of these ponds in 2015. All new ponds will be built 

on land that was previously disturbed by construction activities and has been evaluated for 

cultural resources. Each new sedimentation pond will cover a surface area of approximately 

4.4 ac (1.8 ha) and will take about 6 months to construct. During construction Ameren will 

follow best management practices (PMPs) to suppress dust and minimize soil erosion. 

Appropriate permits and plan approvals from the State of Missouri will also be obtained. 

Excavated soil will be placed along the berms of the existing lagoons and may later be used for 

reclamation activities. In consultation with the Missouri Department of Natural Resources, the 

long term reclamation plan for each sedimentation pond is to cap the pond and return it to a 

natural state (Ameren 2014b, 2014c).

Most of the water in the circulating water system is lost to the atmosphere. The Missouri River 

is the source of makeup water to replace water lost in the cooling tower to evaporation, drift, and 

blowdown. With time, water lost to the atmosphere causes the concentration of salts in the 

condenser cooling water to increase. If the concentration of salts gets too high, they can lead to 

corrosion and impairment of the plant itself. Therefore, to maintain the salt concentrations of the 

circulating water system at no more than four times that of the makeup water, some of the 

circulating water is discharged via the blowdown pipeline to the Missouri River (Ameren 2011d). 

To prevent fouling by corrosion and biological organisms, antiscalants and dispersants, 

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Affected Environment

biocides, and corrosion inhibitors are added to the water in the circulating water system. Along 

with the excess salts in the cooling water system, some of these additives are also discharged 

to the Missouri River.

The temperature of permitted water discharges is routinely monitored as required by the 

NPDES Permit for Callaway. NPDES permit discharge data indicate the temperature of water 

flowing into the blowdown pipeline and then into the Missouri River, rarely exceeds 90 °F (32 °C) 

(Ameren 2011d, 2013c). In winter, the temperature of water flowing into the blowdown pipeline 

averages 71 °F (22 °C) and in summer, averages 84 °F (29 °C). For summer, the maximum 30 

day value for water discharged to the pipeline is reported as 91.4 °F (33 °C) (Ameren 2013c).

Demineralized Water Makeup System. Demineralized water is needed for various plant 

systems. The demineralized water makeup system has a capacity of approximately 

300,000 gallons per day (gpd) (1,135,624 litres per day (L/day)) and draws water from a deep 

onsite well. The water obtained from the well is treated and stored in a tank until it is needed. 

Treatment consists of filtration and ion exchange, which employs resins that are regenerated 

using acids and caustics. The acids and caustics used to regenerate the resins are neutralized 

after use in a neutralization tank. After neutralization is complete, the water in the neutralization 

tank is recycled to the water treatment plant (Ameren 2011d).

2.1.6.2 Sanitary Wastewater System

The sanitary wastewater system collects, treats, and discharges up to 40,000 gal (151,416 L) of 

sanitary wastewater per day. The system is composed of three unaerated sewage treatment 

lagoons located adjacent to the water treatment plant settling ponds. In the first treatment 

lagoon, the sewage is processed by bacteria under natural conditions. Effluent from the lagoon 

then flows by gravity to the second lagoon, where aerobic bacteria digestion continues. Effluent 

from the second lagoon flows by gravity to the third lagoon, where any remaining solids settle 

out. The resulting clear water is then pumped to one of the two settling ponds that are no longer 

used to settle out water treatment plant sludge (Ameren 2011d).

2.1.6.3 Potable Water System

The potable water system supplies chlorinated water for the domestic water needs of Callaway. 

Water for this system is drawn from the same deep onsite well (Section 2.1.7.2) that supplies 

water to the demineralized water system.

2.1.7 Facility Water Use and Quality

Surface and groundwater sources are used in Callaway operations; the largest source is the 

Missouri River and the second is the onsite groundwater wells.

2.1.7.1 Surface Water

As discussed above in Section 2.1.6, the Missouri River supplies intake water to the water 

treatment plant. To cool the reactor, the plant typically removes between 14,000 gpm 

(52,996 L/min) to 17,000 gpm (64,352 L/min) of water from the Missouri River. Of this amount 

approximately 13 percent (1,820 to 2,200 gpm (6,889 to 8,327 L/min)) is returned to the river 

and between 12,200 gpm and 15,000 gpm (46,177 L/min to 56,775 L/min) is lost (consumed) to 

evaporation in the cooling tower. The closed-cycle circulating water system pumps 

530,000 gpm (33,438 L/s) to remove the waste heat from normal operations (Ameren 2011d).

2.1.7.2 Groundwater

Callaway does not use water from any municipal water supplier (Ameren 2011d). Three onsite 

wells are available to supply water for process water makeup, potable water, fire protection, and 

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Affected Environment

other uses (Figure 2–7). The depth of the three wells (Wells 1, 2, and 3) range from 1,100 ft 

(335 m) to 1,510 ft (460 m) below ground surface. Of the three onsite wells, only Well 3 is 

currently in use. Well 3 pumps groundwater at 400 gpm (1,520 L/min) for 2 hours per day 

(Ameren 2011d). This is equivalent to 33 gpm (124 L/min) over 24 hours.

Figure 2–7. Callaway Plant and Locations of Pipeline and Surface Water Intake and 

Discharge Structures

Source: Modified from Ameren 2011d

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Affected Environment

Two additional wells (intake Wells 1 and 2) are located near the Missouri River, approximately 

100 ft (31 m) upstream of the intake structure. The groundwater from these wells is used to 

lubricate the bearings of the pumps in the bays of the intake structure. Intake Well 1 has a 

depth of 854 ft (260 m) and intake Well 2 is has a depth of 110 ft (33.5 m) (Ameren 2008c). 

Only intake Well 1 is continuously pumped. Intake Well 2 is rarely used and remains on 

stand-by status. It is used if repairs need to be made to intake Well 1 or if intake Well 1 should 

ever fail. Intake Well 2 is designed to produce 300 gpm (1,135 L/min) and intake Well 1 is 

designed to produce 665 gpm (2,527 L/min). However, Callaway currently uses only 120 gpm 

(456 L/min), all of which is supplied by intake Well 1 (Ameren 2011d).

The remaining source of groundwater withdrawal at Callaway is a groundwater pump that was 

installed in a sump during the mid-1990s to help in the remediation of a fuel oil leak. This sump 

is located near the reactor building and the corner of the fuel building and is normally pumped 

continuously at a rate of approximately 65 gpm (246 L/min) to a waste oil separator (Ameren 

2008d). Groundwater flowing into this sump is from fill material and from the large water-filled 

pit that was excavated for a second reactor that was never built. Water pumped from the sump 

goes to the radwater circuit and is eventually discharged to the Missouri River. The water filled 

pit is being filled in with earthen fill and should be completely full sometime in 2015 (Ameren 

2014a).

Water use rights or permits are not required in Missouri (MDNR 2000, 2003). However, any 

water withdrawal exceeding 70 gpm (266 L/min) from either groundwater or surface water must 

be reported to MDNR. The facility is classified as a Major Water User (MDNR 2003).

2.2 Surrounding Environment

This section describes the affected environment at and near the Callaway site. These data and 

information form the basis for assessing the potential effects of license renewal and other 

alternatives, including the no-action alternative, evaluated in Chapter 8.

2.2.1 Land Use

The Callaway site is located on 7,354 ac (2,976 ha) in Callaway County, Missouri, 

approximately 10 mi (16 km) from Fulton, Missouri (Figure 2–2). The site is composed of three 

main areas: the power plant site area, the corridor area, and a peripheral area. The 2,765-ac 

(1,119-ha) plant site area contains the major power generation facilities, as described in 

Section 2.1 and shown on Figure 2–4. Ameren uses 512 ac (207 ha) of the plant site area for 

power production. The 2,135-ac (864-ha) corridor area includes the intake and blowdown 

pipelines, which extend south from the developed portion of the site to the Missouri River. The 

2,454-ac (993-ha) undeveloped peripheral area is not used for power generation.

Ameren has made approximately 6,300 ac (2,550 ha) of its 7,354-ac (2,976-ha) property 

available for public use. The MDC manages this property, which is known as the Reform 

Conservation Area. Public use activities within the Reform Conservation Area include hiking, 

bird watching, fishing, picnicking, and hunting (Ameren 2011d). Fishing is allowed in four of the 

site ponds, and hunting is generally permitted, with the exception of certain exclusion areas. 

The MDNR’s Katy Trail, a rails-to-trails project, traverses the southern tip of the Callaway 

property.

Approximately 1,000 ac (405 ha) of the site are leased for row crops, primarily corn and wheat 

(MDC 2008). Approximately 100 manmade ponds were constructed on the site for cropland 

irrigation, watering livestock, and erosion control.

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Affected Environment

Approximately 71 mi (114 km) of transmission lines are associated with Callaway. These 

comprise two 345-kV lines that run to the northeast and two 345-kV lines that run to the south. 

The two northern lines share a 150 to 200-ft (46 to 61-m) wide corridor for 23.2 mi (37.3 km) 

from Callaway to the Montgomery Substation in Montgomery County, Missouri. The two 

southern lines share a 200-ft (61-m) wide corridor for approximately 6.7 mi (10.8 km) from 

Callaway (Figure 2–6). One of the southern lines continues approximately 25 mi (40 km) to the 

southeast to the Bland Substation in Gasconade County, Missouri. The other southern line 

continues approximately 16.6 mi (26.7 km) to the southwest to the Loose Creek Substation in 

Osage County, Missouri. The transmission lines, owned and maintained by Ameren, traverse 

deciduous forest, grassland, and cropland.

2.2.2 Air Quality and Meteorology

The Callaway site is located in Callaway County, Missouri, approximately 10 mi (16.1 km) 

southeast of Fulton, Missouri, and 80 mi (128.75 km) west of the St. Louis metropolitan area. 

The climate type of this region is continental and marked by strong seasonality, which is 

characteristic of an inland location. Climate characteristics vary across the State along a 

diagonal line trending northwest to southeast. Both mean annual temperature and precipitation 

exhibit gradients along this line (Ameren 2011d).

The region’s temperature and precipitation are greatly influenced by the lack of topographic 

barriers. Frequent changes in temperature result from its inland location. In the winter, dry, 

cold air masses periodically move south from the northern plains and Canada. In summer, 

moist, warm air masses from the Gulf of Mexico produce large amounts of rain from frontal or 

convective activity. However, in summer, high-pressure systems can stall over Missouri, 

creating extended drought periods (Ameren 2011d).

Ameren maintains a 197-ft (60-m) high meteorological tower. The tower base is approximately 

824 ft (251 m) above sea level and is located 1.4 mi (2.26 km) east-northeast of the Callaway 

site (Ameren 2009a). The elevation difference between the meteorological tower site and the 

Callaway site is 16 ft (5 m). The tower is instrumented at two levels—33 ft (10 m) and 197 ft 

(60 m)—to measure wind, relative humidity, and temperature (Ameren 2009a). Redundant 

measurements of wind and temperature are made at both levels by backup instrumentation 

(Ameren 2009a); there is no redundant instrumentation for relative humidity. Precipitation is 

measured at a height of 3.2 ft (1 m) near the tower. Observations are taken every minute 

(except for precipitation) and averaged to hourly values, which are made available to the 

Callaway computer. Temperature data from the two measurement levels are also used to 

calculate the temperature difference (ΔT) between the two measurement levels. Precipitation 

occurring during an hour is determined by subtracting the reading at the end of the hour from 

the reading at the start of the hour (Ameren 2009a). The Columbia Regional Airport National 

Weather Service (NWS) office in Columbia, Missouri, offers atmospheric pressure data and 

backup meteorological support for the Callaway site.

The Callaway, Unit 2 COLA, served as a reference for meteorological data. In the COLA, 

Ameren presented site meteorological data for a 3-year period (2004 to 2006), as well as older 

historical data. The 2004 to 2006 site data were collected at the primary meteorological tower 

at Callaway; older historical data were collected at nearby NWS observation stations. Wind 

observations for the 2004 to 2006 period show that the prevailing wind direction is from the 

south-southeast (approximately 12 percent of the time); winds from the 

southwest-south-southeast sector occur approximately 45 percent of the time during the year. 

Seasonally, winds are from the south-southeast during spring, summer, and fall; during winter 

the predominant wind direction is from the northwest.

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Affected Environment

The annual average wind speed is within the 6.9 to 11-miles per hour (mph) (11.1 to 

17.7-kilometers per hour (kph)) category. The highest peak wind gust during the period 1950 to 

2006 was 81 mph (130.3 kph) and occurred in August 2003. Monthly mean temperatures at 

Callaway range from 33.1 °F (0.6 °C) in January to 76.5 °F (24.7 °C) in July (Ameren 2009a). 

Extreme temperatures range from a low of minus 26 °F (minus 32 °C) on February 13, 1905, to 

a high of 116.0 °F (46.7 °C) on July 15, 1954 (MRCC 2012).

Approximately 41 in. (104 cm) of liquid precipitation falls throughout the year (annual average), 

based on a 30-year record, with May being the wettest month on average (4.87 in. (12.4 cm)) 

and January being the driest month on average (1.73 in. (4.39 cm)) (Ameren 2011d). The driest 

and wettest years on record are, respectively, 1901 (21.35 in. (54.23 cm)) and 1993 (62.49 in. 

(158.7 cm)) (MRCC 2012). Annual snowfall for the area is normally 23.3 in. (59.2 cm). Dense 

fog, with visibility less than or equal to 0.25 mi (0.40 km), normally occurs 23 days per year, with 

the majority of these days occurring during the months of December through February. Severe 

weather is common to the area; thunderstorms are normally observed 49 days per year 

(NOAA 2011). Severe weather events spawned from thunderstorms and other weather 

systems include hail, strong winds, tornadoes, and flash floods. In the past 5 years, there have 

been 42 large-hail (more than 0.75 in. (1.9 cm) in diameter) events reported in Callaway County, 

but many of the hail reports are associated with the same storm. Similarly, during the same 

period, thunderstorms producing winds in excess of 76 mph (40 m/s) were reported on 

23 occasions. Tornadoes are also a hazard in the region. In the past 5 years, four tornadoes 

were reported in Callaway County, but all were classified on the Enhanced Fujita (EF) scale as 

an EF0 (i.e., winds of 65 to 85 mph (29 to 38 m/s), 3-second wind gust). There were also 

12 flash flooding events over the period (NCDC 2012). In addition, remnants of tropical systems 

making landfall on the U.S. Gulf Coast can occasionally bring heavy rains to the area.

The National Oceanic and Atmospheric Administration (NOAA) maintains a database of tropical 

cyclone tracks and intensities that covers the period from 1842 through 2010. During this 

period, five tropical systems passed within 50 mi (80 km) of the Callaway site. With the 

exception of an unnamed tropical storm that passed through the region in 1923, the other four 

systems were or had diminished to tropical or subtropical depressions (i.e., with sustained winds 

of less than 52 mph (23 m/s)) by the time they had reached the Callaway region. These include 

hurricanes Gilbert (1988), Elena (1985), and Claudette (1979), and tropical storm Candy (1968) 

(NOAA 2012).

2.2.2.1 Air Quality

The Callaway site is located in Callaway County, Missouri, which is in the Northern Missouri 

Intrastate Air Quality Control Region (AQCR) (40 CFR 81.116). There are 44 counties in the 

Northern Missouri Intrastate AQCR. EPA regulates six criteria pollutants under the National 

Ambient Air Quality Standards (NAAQS): carbon monoxide, lead, nitrogen oxides, ozone, sulfur 

dioxide, and particulate matter (PM). Callaway County (and the rest of the Northern Missouri 

Intrastate AQCR) is designated as unclassified or in attainment for all NAAQS criteria pollutants 

(40 CFR 81.326).

Regulated air pollutants—including sulfur dioxide, carbon monoxide, nitrogen oxide, lead and 

particulates—are emitted from five existing standby diesel-powered generators, two emergency 

diesel-powered fire protection fire-water pumps, the cooling tower (particulates only), and one 

auxiliary boiler at the Callaway site (Ameren 2011a; MDNR 2008). On June 4, 2010, MDNR 

issued a construction permit to Ameren (Permit No. 062010–003) to install five additional 

diesel-powered standby generators at Callaway (MDNR 2010b). On October 8, 2010, MDNR 

issued a construction permit to Ameren (Permit No. 102010–005) to install four permanent 

2-23
Affected Environment

diesel-powered standby generators to replace the five generators installed under Permit 

No. 06210 003 (MDNR 2010c). 

Existing emission sources at Callaway are regulated under Operating Permit No. OP2008–045 

(MDNR 2008). This operating permit expired on September 17, 2013. Ameren submitted a 

renewal application to the MDNR on January 19, 2013, and the application is under review. The 

facility will operate under the previous permit until the department issues a new operating 

permit. It is expected that MDNR will issue a renewed operating permit for an additional 

5 years, incorporating any changes to emission sources at Callaway during the 5-year period of 

the existing permit. Table 2–1 lists the diesel fuel usage for the auxiliary boiler (the largest use 

of diesel) and associated air emissions from the existing regulated sources. There are no plans 

for refurbishment of structures or components at the Callaway site for license renewal. 

Therefore, there are no changes to expected air emissions associated with license renewal 

(Ameren 2011d).

Mandatory Class I Federal Areas, where visibility is an important value, are listed in 

40 CFR Part 81, Subpart D. There are no mandatory Class I Federal areas within 50 mi 

(80 km) of the Callaway site. The closest mandatory Class I Federal area is the Mingo National 

Wildlife Refuge, which is located approximately 150 mi (241 km) southeast of the Callaway site 

(40 CFR 81.416). Because of the significant distance from the site and prevailing wind 

direction, no adverse effects on Class I areas are anticipated from Callaway operation. 

Table 2–1. Annual Fuel Use and Calculated Air Emission Estimates for 

Significant Sources at Callaway

Year Fuel Usage 

(gal)(a)

NOX

(tons)(b)

CO

(tons)(b)

SO2 

(tons)(b)

PM 

(tons)(b)

PM10 

(tons)(b)

VOCs 

(tons)

(b)

HAPs 

and Pb

(tons)(b)

CO2 

(tons)

(b), (c)

2007 132,003 18.5 4.25 6.47 0.59 0.59 0.55 0.00 2,292

2008 131,984 19.0 4.34 5.51 0.71 0.71 0.69 0.00 2,195

2009 43,963 7.94 1.82 2.53 0.26 0.26 0.25 0.00 845

2010 364,810 22.0 4.92 6.72 0.70 0.70 0.62 0.00 5,042

2011 312,020 20.6 4.11 5.0 0.59 0.59 0.66 0.00 4,611

(a) To convert gallons to litres, multiply by 3.8. Fuel use for the auxiliary boiler only.

(b) To convert tons to metric tonnes, multiply by 0.91.

(c) Estimated by staff using Ameren annual emission reports (fuel use for the auxiliary boiler and horsepower-hours for 

emergency/standby diesel engines) and EPA default CO2 emission factors for liquid fuels, commercial/industrial 

engines, and large stationary engines (EPA 1995, 2010).

Key:

HAPs = Hazardous air pollutants; NOx = nitrogen oxides; CO = carbon monoxide; SO2 = sulfur dioxide; 

PM = particulate matter; PM10 = particulate matter with an aerodynamic diameter of 10 microns or less; 

VOCs = volatile organic compounds; Pb = lead; CO2 = carbon dioxide. 

Sources: Ameren 2008b, 2009c, 2010b, 2011b, 2012c

2.2.3 Geologic Environment

This section describes the current geologic environment of the Callaway site and vicinity, 

including landforms, geology, soils, and seismic conditions.

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Affected Environment

2.2.3.1 Physiography and Geology

The Callaway site straddles the boundary between the Dissected Till Plains physiographic 

section to the north and the Ozark Plateau physiographic province to the south. The site is 

located on a gently rolling plateau that was formed through erosion by the Missouri River and its 

tributary streams. This plateau covers an area between 6 and 8 mi (9.5 and 13 km) square. 

Elevations on the plateau range from 800 to 858 ft (244 to 262 m) above mean sea level (MSL). 

The elevation of the plant site is approximately 845 ft (258 m) above MSL. The streams that 

drain the plateau and the plant site have steep gradients and drain south towards the Missouri 

River. At the closest approach, the Missouri River and its floodplain lie about 5 mi (8 km) south 

of the plant site and, at an average elevation of 509 ft (155 m) MSL, are about 300 ft (91 m) 

lower in elevation (Figure 2–8) than the site (Ameren 2010c).

The composition of the subsurface beneath the site area can be described as unconsolidated 

materials overlying bedrock. These unconsolidated materials consist of glacial and post-glacial 

deposits of Quaternary age (recent to about 700,000 years old) and a much older unit called the 

Graydon Chert Conglomerate, which does have some lithified (hardened) layers. The glacial 

and post-glacial sediments consist of three major layers: loess (windblown silt), a lacustrine 

clay (lakebed deposits), and a generally reddish-brown silty/sandy/gravelly clay glacial till. 

These materials can extend 30 to 40 ft (9 to 12 m) beneath the subsurface in the vicinity of the 

site. The Graydon Chert Conglomerate is primarily a hard, gravelly clay with white, gray, and

reddish-brown chert fragments throughout. This conglomerate averages 25 ft (8 m) in thickness 

and, in places, contains sandstone. Beneath these surficial materials lies a series of 

sedimentary rock layers that are approximately 2,000 ft (610 m) thick. These sedimentary units 

primarily consist of limestone, dolomite, and sandstones with intermixed siltstones and shales. 

The basement rock beneath these sedimentary layers is primarily composed of ancient volcanic 

rocks of granitic composition and metamorphic rocks (Ameren 2010c).

Site preparation and earthwork for Callaway included stripping, excavating, dewatering, and 

backfilling. All glacial and post-glacial sediments and soils were overexcavated beneath the 

major plant structures. These materials were replaced with compacted backfill and crushed 

rock structural fill to attain the site and foundation grades, and the backfill materials were tested 

to ensure adequate support for finished plant structures (Ameren 2010c).

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Affected Environment

Figure 2–8. Callaway Site Topography

Source: Modified from Ameren 2011d

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Affected Environment

2.2.3.2 Soils

In general, soil unit mapping by the Natural Resources Conservation Service (NRCS) identifies 

the majority of the site (the Callaway facility, wooded areas, and vacant land areas) as silt loam 

and loam. The silt loam is poorly drained soil, and the loam is classified as well-drained soil. 

These surface soils are modified post-glacial loess materials (NRCS 2012). These silt loam and 

loam surface soils are described in more detail below.

The NRCS identifies the majority of the Callaway site where facilities are located as containing 

Mexico silt loam, 1 to 4 percent slopes, eroded; Mexico silt loam, 0 to 2 percent slopes; and 

Putnam silt loam, 0 to 1 percent slopes. In general, these soils are poorly drained with a high 

available water capacity, no frequency of flooding or ponding, and are found on hillslopes or 

divides. The Mexico series formed from loess (wind-blown silt) and pedisediments, and the 

Putnam series formed from loess.

The area north of the developed main plant complex generally consists of vacant land (soil or 

grass) and undisturbed wooded areas and includes soils mapped as Mexico silt loam, 1 to 

4 percent slopes, eroded (described above); Mexico silt loam, 0 to 2 percent slopes (described 

above); Keswick loam, 5 to 9 percent slopes, eroded; and Moniteau silt loam, 0 to 2 percent 

slopes, occasionally flooded. The Keswick loam consists of moderately well drained, slowly 

permeable soils on uplands. It has moderate available water capacity, no frequency of flooding 

or ponding, and formed in a thin layer of pedisediments and in the underlying weathered glacial 

till. The Moniteau silt loam is poorly drained, has high available water capacity, has no ponding 

but occasional flooding is possible, and is found on floodplain steps. It formed from silty 

alluvium.

The area south of the plant area generally consists of vacant land (soil or grass) and 

undisturbed wooded areas, and include soils mapped as Mexico silt loam, 1 to 4 percent slopes, 

eroded (described above); and Mexico silt loam, 0 to 2 percent slopes (described above); 

Goss-Gasconade-Rock outcrop complex, 5 to 35 percent slopes; Gorin silt loam, 3 to 9 percent 

slopes, eroded; Winfield silt loam, 14 to 20 percent slopes, eroded; and Blencoe silty clay loam, 

0 to 2 percent slopes, occasionally flooded. The Goss-Gasconade-Rock outcrop complex is 

well drained, has low available water capacity, no ponding or flooding, and is found on 

hillslopes. It formed from cherty limestone residuum. The Gorin silt loam is somewhat poorly 

drained, has very low available water capacity, no ponding or flooding, and is found on ridges. 

It formed in loess and pedisediments. The Winfield silt loam includes moderately well drained, 

moderately permeable soils on uplands, and has high available water capacity with no ponding 

or flooding. This soil unit is found on hillslopes and formed from loess. The Blencoe silty clay 

loam is somewhat poorly drained, has low available water capacity, has no ponding but 

occasional flooding, and is found on floodplain steps (CSS 1992; NRCS 2012).

2.2.3.3 Seismic Setting

The site is located within the vast Central Stable Region of North America, which is 

characterized by a relatively gentle tectonic history. Recent earthquake activity in the site 

region has been minor. According to the U.S. Geological Survey (USGS), a total of nine small 

earthquakes, ranging in magnitude from 2.3 to 4.2, have been recorded since 1973 within a 

62 mi (100 km) radius of Callaway. Of these, the earthquake closest to the site was located 

45 mi (72 km) to the southeast. No significant earthquake has been recorded within a 62 mi 

(100 km) radius of the site (USGS 2012a). A significant earthquake is defined by the National 

Geophysical Data Center (NGDC) as one that caused moderate damage and loss of life, was 

magnitude 7.5 or higher, resulted in modified Mercalli intensity (MMI) shaking greater than X 

(some well-built wooden structures destroyed; most masonry and frame structures destroyed 

with foundations; rails bent), or a combination of these situations (NGDC 2012).

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Affected Environment

However, larger earthquakes have occurred within the region in the Mississippi Valley fault 

zone, which contains the New Madrid seismotectonic region. This region, which is more than 

175 mi (282 km) southeast of the site, was the center of the largest earthquakes ever recorded 

in the central and eastern United States. These quakes occurred around New Madrid, Missouri, 

in 1811–1812 and ranged in magnitude from about 7.0 to 7.7 (USGS 2012a). On the MMI scale 

(USGS 2012d), the intensity of these earthquakes ranged from MMI XI to XII at the epicenter 

and are estimated to have been VI to VII at the Callaway site (Ameren 2010c; USGS 2012c). 

Based on the New Madrid event, the safe-shutdown earthquake (SSE) is defined as a horizontal 

peak ground acceleration (PGA) at foundation level of 0.20 g (i.e., force of acceleration relative 

to that of Earth’s gravity, “g”), which is equivalent to an intensity approaching MMI VIII. The 

plant “operating-basis” earthquake was established as 0.12 g (Ameren 2010c). 

For the purposes of comparing the SSE with a more contemporary measure of predicted 

earthquake ground motion, the NRC staff reviewed current PGA data from the USGS National 

Seismic Hazard Mapping Project. The PGA value cited is based on a 2 percent probability of 

exceedance in 50 years. This corresponds to an annual frequency (chance) of occurrence of 

about 1 in 2,500, or 4 x 10-4 per year. For Callaway, the calculated PGA is approximately 0.10 g 

(USGS 2012b).

Several subsurface field exploration programs were conducted to evaluate the glacial and 

post-glacial soils overlying the Graydon chert conglomerate and underlying bedrock. No 

evidence of any actual or potential surface or subsurface subsidence, uplift, or collapse resulting 

from tectonic or solution activity was observed during the field exploration (Ameren 2010c).

2.2.4 Surface Water Resources

Callaway is located within the Missouri River Basin and the Auxvasse Creek and Logan Creek 

subwatersheds, approximately 5 mi (8 km) northwest of the Missouri River (Ameren 2011d). 

The plant is situated on a plateau approximately 300 ft (91.5 m) above the floodplain of the 

Missouri River (Ameren 2009a). Two streams (Mud Creek and Logan Creek) flow through the 

southern portion of the Callaway property. Most of the surface drainage from the site flows 

toward these two streams. Mud Creek receives drainage from the south-southwest of the site, 

and Logan Creek receives drainage from the south-southeast (Figure 2-10). The remainder of 

the Callaway site drains to Auxvasse Creek, a major tributary of the Missouri River. Auxvasse 

Creek, which is located approximately 2 mi (3.3 km) west of Callaway, receives surface 

drainage from the western and northern portions of the plateau (Ameren 2009a). Eventually all 

creeks and streams that drain the Callaway site discharge to the Missouri River. The Callaway 

intake structure is located at Missouri River Mile (RM) 115.4 (River Kilometer (RKm) 184.6). 

The USGS monitors flow and water quality at stations upstream and downstream of Callaway; 

this data is used to characterize water quality in the vicinity of Callaway. The upstream 

monitoring and gauging station is located at Boonville, Missouri, at Missouri RM 196.6 

(RKm 314.6), and the downstream monitoring and gauging station is located at Hermann, 

Missouri, at Missouri RM 97.9 (RKm 156.6) (Ameren 2011d, USGS 2014a, 2014b). At the 

Hermann, Missouri gaging station, annual Missouri River discharge rates between 1958 and 

through 2013, averaged 87,922 cfs (2,490 m3/s) and ranged from a high of 187,200 cfs 

(5,301 m3/s) to a low of 40,810 cfs (1,156 m3/s). Water quality data from the Hermann and 

Booneville gauging stations from the year 2008 (USGS 2009a, 2009b) indicate that the Missouri 

is a river with moderate levels of dissolved solids and moderate-to-high levels of suspended 

solids. Dissolved oxygen levels are adequate to support a range of aquatic life, even in late 

summer when water temperatures are high (see Tables 2–2 and 2–3).

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Figure 2–9. Regional Surface Water Basins

Source: Modified from Ameren 2009b

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Figure 2–10. Surface Water Bodies in the Vicinity of the Callaway Plant

Source: Modified from Ameren 2011d

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Table 2–2. 2008 Water Quality Data From the Boonville, Missouri, 

USGS Monitoring Station

Month Temperature (°C) 

Min–Max (mean(a)) 

Dissolved Oxygen 

(mg/L)

Min–Max (mean(a)) 

Specific 

Conductance 

(μS/cm-1) 

Min–Max (mean(a))

Turbidity 

(NTUs)

Min–Max 

(mean(a))

January No data 

published

No data

published

No data 

published

No data 

published

February No data

published

No data 

published

No data

published

No data 

published

March 2.2–9.7 9.9–11.1 378–629 73–830

April 8.3–16.5 (11.5) 7.2–10.3 (9.3) 362–647 (520) 68–1030 (930)

May 14.6–22.1 (17.9) 5.8–9.1 (7.9) 470–772 (617) 56–1,240 (300)

June 21.0–25.3 (23.9) 3.5–6.1 (4.7) 347–545 (428) No data 

published

July 23.8–29.4 (26.7) 4.1–7.1 (5.7) 278–700 (505) No data 

published

August 25.1–30.5 (27.3) 4.0–9.5 (6.7) 265–688 (609) 32–570 (120)

September 19.8–23.1 (22.1) 4.7–8.6 (6.8) 243–703 (504) 28–250 (210)

(a) Mean values were not provided for months with incomplete data sets.

Key:

mg/L = milligrams per litre; μS/cm-1 = microsiemens per centimeter-1; NTUs = Nephelometric Turbidity Units

Source: USGS 2009a

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Table 2–3. 2008 Water Quality Data From the Hermann, Missouri, 

USGS Monitoring Station

Month Temperature

(°C)

Min–Max 

(mean(a))

Dissolved Oxygen 

(mg/L)

Min–Max (mean(a)) 

Specific Conductance 

(μS/cm-1) 

Min–Max (mean(a)) 

Turbidity

(NTUs)

Min–Max 

(mean(a))

January No data

published

No data

published

No data 

published

No data

published

February No data

published

No data

published

No data

published

No data

published

March 6.2–10.0 9.6–12.1 119–439 34–350

April 9.9–15.6 (12.1) 8.2–10.7 (9.5) 167–402 (293) 42–570 (190)

May 14.7–21.7 (17.3) 6.6–9.0 (8.2) 287–509 (378) 31–440 (150)

June 21.4–24.9 (23.6) 4.2–7.0 (5.2) 321–463 (380) 190–1,430 (560)

July 23.5–26.4 5.0–6.0 299–355 120–600

August 25.7–27.6 6.0–8.2 582–666 17–160

September 20.1–27.4 (22.40) 4.1–8.0 (5.7) 238–650 (426) 19–520

(a)Mean values were not provided for months with incomplete data sets.

Key:

mg/L = milligrams per litre; μS/cm-1 = microsiemens per centimeter-1; NTUs = Nephelometric Turbidity Units

Source: USGS 2009b

Callaway’s surface water discharges are permitted under a State operating permit 

(MDNR 2010a), which also serves as its Federal NPDES permit. This permit was issued on 

February 13, 2009, and expires on February 12, 2014. This permit covers a total of 11 outfalls, 

including direct discharges to the Missouri River and to other receiving streams that eventually 

flow into the Missouri River. Table 2–4 gives further details on these outfalls, including 

permitted discharge limits and parameters for effluent monitoring. On August 7, 2012, Ameren 

submitted a letter to MDNR asking for confirmation that the license extension would not violate 

Missouri’s Water Quality Standards. The letter also asked for confirmation on whether a new 

Clean Water Act Section 401 Water Quality Certification would be required by MDNR or 

whether a letter of approval, based on the existing Section 401 Water Quality Certification, 

coupled with the ongoing NPDES permit authorization, would be issued (Ameren 2012e). On 

October 8, 2013, Ameren received a letter from the Missouri Department of Natural Resources 

stating that the Department considers the permit to provide appropriate environmental 

protection under the Missouri Clean Water Law and compliance with the Clean Water Act 

(Ameren 2013d). However, a water quality control permit may still be required for specific 

projects at the facility for Clean Water Act Section 404 Permits.

An MDNR notice of violation is a formal, written notification of significant noncompliance. It is 

issued for violations of law, regulations, permits, certifications, licenses, or registrations that 

warrant legal action if not corrected (MDNR 2011).

There have been no MDNR NPDES notices of violation or similar infractions at Callaway within 

the last 5 years (Ameren 2012e).

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During this period, however, a permit exceedance for total residual chlorine was reported at 

Outfall #002 (Cooling Tower Blowdown) in 2008. This exceedance occurred because a chlorine 

shock treatment was used to mitigate a buildup of bioorganisms. To mitigate the discharge

exceedance, the shock treatment was halted (AmerenUE 2008). A similar exceedance was 

reported in 2005 (AmerenUE 2005).

2.2.4.1 Stormwater Retention Ponds

Callaway has eight stormwater runoff ponds. The smallest pond is 2 ac (0.8 ha) in size and the 

largest is 15 ac (6 ha). The depth of most of the ponds is generally less than 5 ft (1.5 m); 

however, several ponds have depths as great as 10 ft (3 m) (Ameren 2011d). All of the ponds 

support aquatic and terrestrial wildlife, and four of the ponds are open to public fishing. 

Stormwater overflow is discharged from the ponds at Outfalls 010, 011, 012, 014, and 015 

(Table 2–4). The receiving water bodies are an unnamed tributary of Logan Creek (Outfalls 010 

and 011), an unnamed tributary of Mud Creek (Outfall 012), and Cow Branch (Outfalls 014 

and 015).

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Table 2–4. Permitted Outfalls

Outfall and Effluent Type Permitted Discharge

(daily maximum 

flow) (a)

Effluent Monitoring Parameters

Discharge to Missouri River

#001 Radwaste Treatment System 0.298 mgd TSS, oil and grease, total residual 

chlorine

#002 Cooling Tower Blowdown 14.1 mgd Oil and grease, total residual 

chlorine

#003 Water Treatment Plant Wastes 1.645 mgd TSS, oil and grease, total residual 

chlorine

#007 3 Cell Sanitary Wastewater 

Lagoon 0.040 mgd Biochemical oxygen demand, TSS, oil and grease

#009 Intake Heater Blowdown 0.006 mgd TSS, oil and grease

#016 Cooling Tower Bypass 14.4 mgd TSS, oil and grease, total residual 

chlorine

#017 Ultimate Heat Sink No discharge outfall(b)

Stormwater Runoff

#010 Stormwater (to unnamed tributary 

of Logan Creek) 4.6 mgd N/A

#011 Stormwater (to unnamed tributary 

of Logan Creek) 19.7 mgd N/A

#012 Stormwater (to unnamed tributary 

of Mud Creek) 6.6 mgd N/A

#014 Stormwater (to unnamed tributary 

to Cow Branch) 4.8 mgd N/A

#015 Stormwater (to unnamed tributary 

to Cow Branch, 

http://www.dnr.mo.gov/pubs/WR72.pdf)

2.8 mgd N/A

(a) To convert million gallons per day (mgd) to cubic meters per day, multiply by 3,785.

(b) Outfall is the overflow from the ultimate heat sink to local runoff. 

Key:

TSS = Total suspended solids

Sources: MDNR 2010a, 2010d, 2012h, 2013b

2.2.5 Groundwater Resources

Groundwater in the Callaway vicinity is present in shallow glacial deposits often less than 30 ft 

(99 m) thick. These deposits typically yield less than 5 gpm (19 L/min) to domestic wells, but at 

the Callaway site the shallow glacial deposits are not productive enough to be used as a source 

of groundwater (Ameren 2011d). The glacial deposits are underlain by a thick, leaky confining 

aquifer that extends to a depth of approximately 350 ft (106.7 m) below ground surface 

(Ameren 2011d). This unit consists of chert, limestone, and sandstone. The low permeability of 

this unit makes it a poor producer of groundwater. At Callaway, its low yields of less than 1 gpm 

(4 L/min) (Ameren 2011d), prevent its use as a source of groundwater.

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The next underlying aquifer is the Cotter and Jefferson City Dolomites Aquifer at the plant site, 

which is encountered at a depth of approximately 350 ft (106.7 m) below ground surface and 

extends to a depth of 650 ft (198 m). It is laterally extensive and underlies the whole site, 

including the Missouri River and beyond (Figure 2–11). Under the plant site this aquifer is

confined and is unconfined where it is in contact with streams, the Missouri River alluvium, or 

the Missouri River itself. It is composed of dolomite and locally yields 10 to 15 gpm (38 to 

57 L/min) to domestic and agricultural wells (Ameren 2011d). The water quality of the aquifer is 

typically good (Miller and Vandike 1997).

Below this aquifer are a series of water-producing dolomites and sandstones that extend to a 

depth of approximately 2,000 ft (609.6 m). Recharge to the deep aquifer system is from 

precipitation at aquifer outcrop areas located at great distances from the site and, to some 

extent, from downward leakage of water from overlying aquifers (Ameren 2011d). The three 

onsite potable water supply wells and the wells near the Missouri River intake structure are 

completed into the Cotter and Jefferson City Dolomites Aquifer and some of the deeper 

water-producing dolomites and sandstones. Intake Well 2 is also open to the Missouri River 

Alluvial Aquifer. However, as discussed in Section 2.1.7.2, that well is rarely used.

The Missouri River Alluvial Aquifer is not laterally extensive at the site. It is located close to the 

Missouri River. It underlies the river and occurs on either side of it. It is considered to be a 

major regional aquifer in Missouri. In 2007, Ameren conducted a hydrogeological investigation 

of the Missouri River Alluvial Aquifer. Aquifer tests indicated that the aquifer is capable of 

sustained yields of 595 to 1,906 gpm (6,307 to 7,214 L/min) in the investigation area.

The Missouri River Alluvial Aquifer lies on top of the Cotter and Jefferson City Dolomites Aquifer

(Figure 2–12). Recharge to the Missouri River Alluvial Aquifer is derived from precipitation, the 

Missouri River, and from groundwater flowing upwards from the underlying Cotter and Jefferson 

City Dolomites Aquifer. For most of the year, the upward flow of groundwater from the Jefferson 

City Dolomites causes groundwater in the Missouri River Alluvial Aquifer to flow into the 

Missouri River. However, this direction of flow may be reversed when the water level in the river 

exceeds the water level in the Missouri River Alluvial Aquifer. At those times, water would flow 

from the river into the Missouri River Alluvial Aquifer (Ameren 2011d).

2-35
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Figure 2–11. Hydrogeologic Units Underlying the Callaway Plant

Source: Modified from Ameren 2009b

The nearest public water well is located approximately 1.9 mi (3.1 km) northwest of the plant 

site. It pumps water from the Cotter and Jefferson City Dolomites Aquifer and lower aquifers 

and supplies potable water to the Callaway No. 2 Water District (Ameren 2011d). The well is 

707 ft (215 m) deep and yields 100 gpm (378 L/min) (Ameren 2011d). The nearest private well 

to the Callaway site is located approximately 0.8 mi (1.3 km) north of the site and is used for 

agricultural irrigation (MDNR Well ID 018459). The well is 375 ft (114.3 m) deep and likely 

draws water from the Cotter and Jefferson City Dolomites Aquifer (Ameren 2011d). The nearest 

private well closest to Callaway’s river water intake structure (Intake Well #1) is located 

approximately 0.25 mi (0.4 km) southeast of the Callaway intake structure well. The private well 

is classified as a domestic well (MDNR Well ID 0134215A). The well is 375 ft (114 m) deep and 

had a test yield of 30 gpm (114 L/min) when it was installed in 1994 (Ameren 2011d).

Over the period of operations, some releases to the groundwater and geologic material have 

occurred. In 1994, Ameren discovered approximately 40,000 gal of diesel fuel oil had leaked 

into the construction fill near the reactor and turbine buildings (Ameren 2011d). Ameren 

reported the leak to the MDNR. Ameren installed a groundwater monitoring system and a 

groundwater sump. The groundwater sump was installed to collect the diesel fuel, which has 

now been removed from the groundwater in the construction fill. However, the sump continues 

to operate and is used to dewater the structural fill underlying the power block area (see 

Section 2.1.7.2).

In 2006, it was discovered that a small amount of water had leaked via air release valves in the 

blowdown pipeline that runs from the plant and discharges into the Missouri River. All of the 

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leaks were on-site leaks and did not leave the site. The water in the pipeline contains low levels 

of tritium. As a result tritium was discovered above background in manholes where the valves 

had leaked and in surface soil and groundwater along next to those manholes. Tritium 

concentrations in some of the pipeline manholes and near surface soil samples exceeded the 

EPA drinking water standard of 20,000 picocuries per liter. However, tritium concentrations in 

the groundwater were found to be well below EPA’s drinking water standard of 

20,000 picocuries per litre. The blowdown pipeline has been redesigned and replaced. From 

2006 through 2012, tritium concentrations in groundwater have continued to remain below the 

EPA drinking water standard. In 2012, all tritium concentrations reported for soil and 

groundwater samples were well below the EPA drinking water standard (Ameren 2007b, 2008a, 

2009d, 2010a, 2011a, 2011d, 2012a, 2013a).

On July 25, 2014, a groundwater sample was obtained from a newly installed well. The new 

well is within the plant property adjacent to a manhole where the plant’s discharge piping joins 

with the cooling tower blowdown piping. The sample contained 1.6 million pCi/L of tritium and 

12 pCi/L of Cobalt-60. The tritium concentrations exceed the U.S. Environmental Protection 

Agency’s safe level for public drinking water of 20,000 pCi/L. The Cobalt-60 concentration is 

well below the U.S. Environmental Protection Agency’s safe level for public drinking water of 

100 pCi/L. Releases from the plant discharge line were suspended. The cause and extent of 

contamination is currently being investigated by the licensee (NRC 2014).

2.2.6 Aquatic Resources

As the Callaway plant is located on a small plateau, few aquatic habitats other than the Missouri 

River occur within the developed portion of the site. Eight wastewater treatment and settling 

ponds that surround the plant offer some aquatic habitat for warm-water and wetland fauna. 

The main cooling water intake for Callaway is located on the Missouri River, at approximately 

Missouri RM 115.4 (Ameren 2011d). The blowdown water from the plant and associated 

stormwater discharges are discharged to the Missouri River several hundred feet downstream 

of the intake structure. Therefore, the Missouri River is the focus of the aquatic resources 

discussion. Several streams that are crossed by the transmission line are also discussed in 

Section 2.2.8, as they have the potential to contain Federally listed species.

The Missouri River is one of the largest rivers in North America; consequently, many accounts 

and characterizations of its aquatic resources are available (Galat et al. 2005a, 2005b; 

Pflieger and Grace 1987; Robison 1986; and other Federal reports). The U.S. Army Corps of 

Engineers (USACE) hosts an online database, the Missouri River Recovery Program 

(MRRP 2012), which contains information on the status and baseline conditions of the river, 

current and past monitoring activities, and mitigation programs that are leading the way to the 

restoration of the river and its floodplain. In 2010, the NRC assessed the baseline conditions of 

the Missouri River for the relicensing of the Cooper Nuclear Station, in Nemaha County, 

Nebraska, at Missouri RM 532.5 (NRC 2010). The NRC staff reproduces much of this recently 

conducted assessment in the description of the environment below. In addition, Ameren 

recently prepared an ER for the relicensing application that summarized baseline aquatic 

resource investigations for the Callaway plant (Ameren 2011d). Ameren also submitted a COLA 

to the NRC in 2008 for the proposed Callaway Plant, Unit 2 near the Unit 1 reactor

(Ameren 2009a). The COLA included the results of aquatic resource surveys of the Missouri 

River conducted in 2007 and 2008 in the vicinity of the existing intake and discharge structures. 

The description of the aquatic resources at the Callaway plant relied predominately on these 

plant-specific reports. Additional reports or investigations that the NRC deemed appropriate for 

the Callaway plant were reviewed and summarized as appropriate.

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Affected Environment

2.2.6.1 Description of Aquatic Habitats in the Missouri River System

The Missouri River basin is the second largest in the United States, draining about one-sixth of 

the country, as well as parts of Canada (Galat et al. 2005a). Historically, the Missouri River was 

a broad, slow-moving, shallow river with braided channels and a wide floodplain (FWS 2012a). 

However, damming of the river and the creation of a navigation channel throughout the lower 

river resulted in a self-scouring, maintained navigation channel and the elimination of side 

channels and fringing wetlands along the river. Before installation of the Missouri River 

mainstem dams, the government spent many years studying options for controlling the river to 

improve navigability, offer flood control and protection, and enhance other water-related uses of 

the Missouri River Basin (USACE 1947).

The Pick-Sloan Plan called for greatly expanding the amount of the river that was hydraulically 

controlled (USACE 1993). This plan also called for an evaluation of the costs and benefits of 

developing the river for irrigation, hydroelectric power, municipal water supply, and other 

miscellaneous purposes. Some of the Pick-Sloan Plan’s recommendations included developing 

the river for agricultural purposes through the creation of Federally controlled irrigation projects 

to give the greatest economic benefit to the largest number of people (USACE 1993). 

Eventually, the U.S. Bureau of Reclamation and the USACE both submitted plans for 

development projects, which were approved as the Flood Control Act of 1944, approved a 

coordinated plan, and authorized initial appropriations for construction (USBR 2012). In the 

upper and middle portions of the river, dams were constructed primarily to increase the amount 

of irrigable agricultural lands (USACE 1993). Crop production in this region focused on feed for 

livestock, including alfalfa, grass mixtures, and sugar beet byproducts. The lower river 

upstream of Sioux City, Iowa, was to be maintained for navigation.

In the regulated portion of the Missouri River, mainstem dams reduce the high variation in 

seasonal flows in the river, and the historic extreme high and low flows no longer occur. The 

upstream dams have reduced the sediment loads in the river, but channel degradation 

continues downstream of the dams in the free-flowing sections of the river. 

The furthest downstream dam constructed on the mainstem Missouri River is the Gavins Point 

Dam, which defines the upper limit of the lower Missouri River basin. The Callaway site is 

located within this unregulated portion of the lower Missouri River Basin, which extends to the 

Mississippi River. 

The Missouri River Basin extends through the Great Plains and Central Lowland physiographic 

provinces and contains unconsolidated alluvial deposits of various glacial aquifers. These 

glacial-origin channel sediments and landforms are highly erodible, creating a high degree of 

sediment loading and transport within the river system. To control the sediment loading and 

transport in the late nineteenth and twentieth centuries, the river was channelized with extensive 

placement of hard-engineered bank stabilization and floodplain levees, which modified natural 

riparian and floodplain areas. The river’s hydraulics are still controlled, primarily for navigation 

purposes, by several bar dikes, wing dams, and bank revetments, which have eliminated the 

braided channel characteristics of the river. In addition, dredging and channelization of the 

lower river have eliminated much of the temporal and spatial variation of the river, resulting in 

the widespread destruction of a variety of aquatic microhabitats. Microhabitats such as 

structures and velocity barriers offer cover, resting, and feeding areas, which are important 

habitats for a wide variety of aquatic organisms. The present-day channelized portion of the 

river is typically devoid of structure and trapezoidal in shape. Aquatic species are no longer 

able to use floodplains seasonally for spawning or feeding or as nursery areas for larvae and 

juveniles. The loss of floodplain connectivity has resulted in water, sediment, and nutrients 

remaining within the channel, with sediment and nutrients aggrading in the upstream reservoirs. 

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Affected Environment

Because of these changes, some aquatic species, such as the pallid sturgeon (Scaphirhynchus 

albus) and sauger (Sander canadensis), have experienced a large amount of habitat reduction 

and corresponding loss of population. Overall, the current environment of the lower Missouri 

River supports a less diverse habitat and lower biodiversity compared to pre-settlement times 

(National Research Council 2002).

Hydrology

The historic name of the Missouri River was the “Big Muddy,” as it was well-known that erosion 

could be extreme during high flows and the river was usually very turbid (National Research 

Council 2002). This resulted in a high sediment load, which was deposited on the river’s 

floodplains, and a river platform with high sinuosity and braided channels. A typical cross 

section of the lower river would show a deep channel, multiple side channels, sand bar dunes, 

and backwater habitats interspersed by areas of riparian habitats on higher ground.

Direct precipitation and snowmelt contribute to the flow, resulting in a seasonal succession of 

low and high flows (NRC 2010). Before the system of dams and flow regulation, river flows 

peaked twice a year: a smaller peak in March through April as snow and ice melted in the 

middle and upper basins and on the prairie; and a second, larger peak in June as a result of 

melting snows in the Rocky Mountains and precipitation over the prairie (Galat et al. 2005a). 

Overbank flooding was common during peak flows. Flows then declined in July and remained 

low until the following spring.

The hydrologic cycle of surficial flows are now highly regulated by the six mainstem dams on the 

river, each of which forms a reservoir, along with more than 1,000 smaller variable-use 

reservoirs (NRC 2010). Dredging, channelization, and the installation of dams have modified 

the natural flow of water and sediment in the river. Flow rates are now controlled by the storage 

of large volumes of water in the reservoirs, and sediment transport is impeded by dams. 

Ecosystems Services Offered

The Missouri River ecosystem shown in Figure 2-13 depicts the aquatic and riparian foodweb of 

the lower Missouri River. This conceptual model was used in the review of the Cooper nuclear 

plant which is also on the Missouri River, and was adapted from Karr et al. (1985), who 

determined that agriculture had the greatest effect on Midwestern fish communities. Agriculture 

was found to modify the floodplain and aquatic habitat in these large river systems, as well as 

reduce water quality (through nutrient enrichment), reduce oxygen levels, and add toxic 

contaminants and excess fine sediments (NRC 2010). These external forces alter the physical 

habitat and flow regime of a river, thereby changing the natural energy sources, nutrient cycling, 

and biotic interactions. Figure 2–12 shows the many linkages between aquatic and terrestrial 

biota. As the figure demonstrates, changes in either the aquatic or terrestrial habitats in the 

lower Missouri River also exert influences on the other resources.

The National Research Council (2002) described the Missouri River ecosystem services as: 

“...outdoor recreation, biomass fuels, wild game, timber, clean air and water, medicines, species 

richness, maintenance of soil fertility, and natural recharge of groundwater.”

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Affected Environment

Figure 2–12. Schematic of the Aquatic Food Web in the Lower Missouri River

These services are typically not quantified in terms of an economic benefit to society. Some 

current mandates are changing the way society values these ecosystem services (Scarlett and 

Boyd 2011). These programs allow for habitat restoration and preservation, which will offer 

economic benefits to society. On the lower Missouri River, these programs include the creation 

of the Big Muddy National Wildlife Refuge, which is preserving sections of the Missouri River 

and its floodplain to allow the river to attain a more natural ecosystem condition (FWS 2012a). 

Ultimately, programs that restore natural habitats in the Missouri River, preserve them, or both, 

will also protect these ecosystem services.

2.2.6.2 Description of Aquatic Biota of the Missouri River System

Historically, the Missouri River’s highly sinuous and expansive floodplain allowed for a diversity 

of aquatic habitats, ranging from lotic conditions (i.e., pertaining to flowing water) to braided 

channels and riffles, as well as lentic conditions (pertaining to still or standing water) within 

former channels and oxbow lakes. Most of the historic floodplain areas were lost because of 

the channelization of the river, which restricts most of the flow to within the channel, preventing 

fish from accessing the floodplain and seasonally important spawning and nursery areas. In 

addition, more warm-water and lentic species began to thrive and dominate the fishery through 

introductions in the upstream reservoirs and subsequent downstream drift into the lower 

Missouri River. The aquatic communities in the mainstem lower river are also influenced from 

species in the Mississippi River Basin, including invasive species, migrating up the Missouri 

River. As a result, many species that now live in the main river basin are not endemic, having 

evolved elsewhere and moved into the basin. 

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Affected Environment

Within the impounded river sections upstream of Callaway, water clarity is improved by the 

reservoir environment, as reduced flows allow for sediment deposition. The clearer water 

increases primary production of both submerged aquatic vegetation and algae. However, 

because of the excessive erosion rates through the alluvial materials downstream of the dams, 

the mainstem of the lower Missouri River still has high turbidity levels, including in the vicinity of 

Callaway. The construction of dikes and levees with hard structures for channelization of the 

flow has decreased the soft-bottom wetlands habitat with hard structures and rocky substrates. 

The reach of the Missouri River in the vicinity of Callaway is characteristic of the mainstem 

channel, with turbulent currents and minimal fringing wetlands or slackwater areas along the 

shoreline. 

Galat et al. (2005b) described changes to the fish community of the Missouri River from the 

1940s to the 1980s, as summarized in Pflieger and Grace (1987). The numbers of gizzard shad 

(Dorosoma cepedianum), a species that prefers slow-water habitat typical of reservoirs, 

substantially increased, as did the numbers of other species more typical of reservoir conditions, 

including goldeye (Hiodon alosoides), bluegill (Lepomis macrochirus), channel catfish 

(Ictalurus punctatus), white crappie (Pomoxis annularis), sauger, and freshwater drum 

(Aplodinotus grunniens). In addition, species more typical of large rivers were reduced in 

number, including river carpsucker (Carpiodes carpio), bigmouth buffalo (Ictiobus cyprinellus), 

and common carp (Carpio caprinus).

Aquatic Resources Near Callaway

Much of the project-specific information is summarized from Ameren’s ER for Callaway 

(Ameren 2011a) and the initial studies conducted to support development of a Unit 2 at 

Callaway (Ameren 2009a). Of primary importance in the aquatic community are the Federally 

and State-listed species, including the endangered pallid sturgeon, which are discussed in 

additional detail in Section 2.2.8.

The immediate area surrounding the Callaway intake structure is located within the mainstem of 

the lower Missouri River (Galat et al. 2005a). This section of the river is channelized and has 

many bank stabilization and channel-scouring features, which enable the river to self-scour and 

maintain a navigation channel (FWS 2012a). These conditions primarily offer migratory habitat,

as water velocities are strong and there is little structure in the main channel to offer cover or 

resting and feeding areas for fish or other aquatic biota. 

Ameren conducted some aquatic fauna surveys before and during operation of Callaway to 

document baseline conditions and to determine the degree to which operation of the nuclear 

plant has had an effect on aquatic communities (Ameren 2011d). Since the 1970s, Ameren has 

monitored phytoplankton, zooplankton, invertebrates, and multiple life stages of fish in the 

Missouri River near the intake and discharge structures, as well as at locations upstream and 

downstream of the structures. Most recently, Ameren conducted a comprehensive survey of 

fish and benthic invertebrate populations in the Missouri River, following similar methods as 

pre-operational surveys conducted in the late 1970s and early 1980s (Ameren 2009a). These 

survey methods included boat electrofishing, gill nets, hoop nets, and beach seine hauls along 

the shoreline of the Missouri River.

The following discussion gives a summary of the aquatic community structure and populations, 

including phytoplankton, zooplankton, benthic macroinvertebrates, fish, and aquatic plants 

located within the vicinity of the intake and discharge structures of Callaway. Protected species 

are discussed in Section 2.2.8.

Historically, the Missouri River supported phytoplankton and zooplankton populations of 

relatively low biomass and species diversity because of the turbulent, turbid water conditions 

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Affected Environment

and the lack of lentic habitats (Galat et al. 2005b). The installation of the six mainstem dams on 

the upper and middle Missouri River increased the abundance of both groups, as the creation of 

lentic habitats in the reservoirs produced habitat more suitable to many plankton species 

(Galat et al. 2005a). However, as Callaway is almost 700 mi (1,126.5 km) downstream of the 

Gavins Point Dam, the influence of the reservoir habitats on the plankton populations in vicinity 

of the intake is not readily apparent there. Preoperational surveys for phytoplankton at 

Callaway indicated low abundances, with diatoms and green algae representing the dominant 

groups of phytoplankton (CDM 1981; NRC 1975). Zooplankton abundances were also low, with 

rotifers displaying the highest densities. Ameren attributed the low plankton densities to the lack 

of suitable habitat conditions in the Missouri River caused by high turbidity, swift currents, and 

absence of slackwater areas (Ameren 2011d). No additional phytoplankton or zooplankton 

surveys were conducted during the Callaway Unit 2 studies in 2007 or 2008 (Ameren 2009a).

Suitable benthic macroinvertebrate habitat in the mainstem lower Missouri River is limited by 

turbulent flows, unstable fine sediment substrates, and turbidity (Galat et al. 2005a). Densities 

of benthic macroinvertebrates are higher in more stable, slow-water areas, such as in fringing 

wetlands or hard structures along riverbanks. At Callaway, preoperational surveys found low 

abundance and species diversity of benthos, with chironomid (midge) larvae, tubificid worms, 

and burrowing mayfly larvae being the dominant species. Mollusks (e.g., Corbicula spp.) were 

also found in low abundance (CDM 1981, 1982; NRC 1975). During the Callaway Unit 2 

surveys in 2007 and 2008, Ameren found similar species composition compared to the 

preoperational surveys (Ameren 2009a). Ameren also found higher abundances, taxa richness, 

and Ephemeroptera-Plecoptera-Trichoptera (EPT) richness (the number of EPT taxa are often 

used as an indicator of good water quality) in the drift samples than in the benthic samples. The 

results of these macroinvertebrate surveys suggest that existing water quality in the lower 

Missouri River supports a healthy macroinvertebrate community for a large, swift-flowing river.

As part of the permitting process for Callaway (and more recently, the proposed Callaway 

Unit 2), some fish surveys were conducted in the vicinity of the water intake structure on the 

mainstem of the Missouri River (Ameren 2009a, 2011d). The NRC (1975) summarized the 

results of the initial baseline fisheries studies conducted in the early 1970s, indicating that, of 

the 17 fish species captured, the 3 most abundant species in the river were gizzard shad, carp, 

and river carpsucker. In the early 1980s, Ameren conducted more comprehensive fish surveys 

related to the plant and the cooling water intake structure and discharge location 

(CDM 1981, 1982). Gizzard shad was the dominant species, followed by freshwater drum and 

goldeye. Additional species captured included shortnose gar (Lepisosteus platostomus), 

common carp, and river carpsucker. Forty-three species were collected from the Missouri River 

during this survey effort. In the most recent surveys, conducted in 2007 and 2008, 45 species 

were captured (Ameren 2009a), similar to the number reported during the early 1980s 

preoperational survey effort (CDM 1981). The most abundant species were the gizzard shad, 

red shiner (Cyprinella lutrensis), and emerald shiner (Notropis atherinoides). These results 

indicate that, over an approximate 30-year time period, the numbers of species, as well as some 

of the dominant species captured, remain similar to preoperational conditions. Even though 

Ameren’s studies did not find large changes in the numbers of the dominant species, other 

studies document significant changes to the aquatic community (National Research 

Council 2002; Galat et al. 2005a, 2005b; Pfleiger and Grace 1987).

2.2.7 Terrestrial Resources

2.2.7.1 Vegetation Communities and Resource Management

The Callaway site occupies approximately 7,354 ac (2,976 ha) in the Outer Ozark Border 

subsection of the Ozark Highlands Ecoregion of Missouri (Nigh and Schroeder 2002). This 

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ecoregion is characterized by a diverse mixture of topographic, geologic, soil, and hydrological 

conditions, which support a variety of habitats (USGS 2012e). The Outer Ozark Border 

subsection is a narrow region of deeply dissected hills and bluffs bordering the Missouri and 

Mississippi Rivers. Most of this region was historically covered in forest, ranging from oak 

savannas to mature oak and mixed hardwood forests. Current land cover is a mixture of row 

crops, pasture, and densely forested valleys (Nigh and Schroeder 2002).

The Outer Ozarks subsection has been further classified into ecological landtypes (ELTs). The 

southern half of the Callaway site is classified as Central Mississippi Oak Woodland/Forest Hills. 

This ELT consists of steep hills and bluffs that support a mixture of pasture, cropland, old field 

thickets, and secondary growth forests and glades. The northern half of the Callaway site is 

within the Central Missouri Savanna/Woodland Dissected Plain ELT. This ELT consists of flat 

uplands and valleys covered with pasture, scattered croplands, old field thickets, and secondary 

growth timber (Nigh and Schroeder 2002). 

Approximately 6,300 ac (2,550 ha) of the Callaway site is leased to the MDC and is designated 

as the Reform Conservation Area (Ameren and the Conservation Commission of the State of 

Missouri 2009). The MDC manages the Reform Conservation Area in accordance with the

Reform Conservation Area Management Plan, which is part of a management agreement 

between Ameren and the Conservation Commission of the State of Missouri. The MDC has 

managed the Reform Conservation Area since the mid-1970s to enhance fish, forest, and 

wildlife habitat (Ameren and the Conservation Commission of the State of Missouri 2009). The 

current management plan is effective from 2006 through 2016. In its response to RAI, Ameren 

indicated that it will meet with MDC before the end of 2016 to review the current and future 

proposed Reform Conservation Area Management Plan. Ameren will extend the current lease 

with MDC provided both parties agree to the terms and it is in the best interest of the Callaway 

Energy Center (Ameren 2012e). 

The public is allowed to use the Reform Conservation Area for recreational activities, including 

hiking, fishing, nature study, bird watching, and picnicking, in accordance with the management 

plan and Ameren’s security guidelines. Hunting is also allowed within the Reform Conservation 

Area in permitted areas and with approved weapon types. MDNR’s Katy Trail State Park 

(a rails-to-trails project) crosses the southern end of the Callaway property and offers hiking and 

biking paths (Ameren and the Conservation Commission of the State of Missouri 2009).

MACTEC Engineering and Consulting, Inc. (MACTEC), conducted a terrestrial vegetation 

assessment on the Callaway site in 2007, which included photo-interpretation and ground-truth 

reconnaissance of vegetation on the site (MACTEC 2007a). Based on this survey, vegetation 

cover types on the Callaway site include cropland (2,039 ac (825 ha)), grassland (481 ac 

(195 ha)), glade (4 ac (1.6 ha)), upland forest (5,134 ac (2,078 ha)), forested wetland (402 ac 

(163 ha)) and herbaceous wetland (32 ac (13 ha)) (Ameren 2009a). 

Cropland on the site includes land cultivated in row crops and non-cultivated land used as 

hayfields and pastureland. Most of the cropland occurs in the northern part of the site, 

surrounding Callaway, and in the southern part of the site on the Missouri River floodplain. 

Corn (Zea mays), wheat (Triticum aestivum), and soybeans (Glycine max) are the primary row 

crops on the site, while red clover (Trifolium pratense), alfalfa (Medicago sativa), and various 

grasses such as Timothy (Phleum pratense) and fescue (Festuca arundinacea) (Ameren 2009a) 

cover the pastureland and hayfields. MDC leases approximately 1,000 ac (405 ha) of the 

Reform Conservation Area to local farmers for row crops (Ameren 2011d). 

Grasslands on the Callaway site include both native warm-season grasslands and nonnative 

cool-season grasslands. The native warm-season grasslands occur on the relatively flat 

uplands surrounding the site and are dominated by big bluestem (Andropogon gerardii), 

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Affected Environment

broomsedge (A. virginicus), little bluestem (Schizachyrium scoparium), Indiangrass 

(Sorghastrum nutans), and switch grass (Panicum virgatum). Nonnative cool-season 

grasslands occur on the levees in the Missouri River floodplain and are dominated by fescue, 

Timothy, and Kentucky bluegrass (Poa pratensis) (Ameren 2009a). The MDC manages 

grasslands within the Reform Conservation Area to enhance plant diversity and offer a habitat 

for upland game and bird populations. MDC accomplishes this, in part, through prescribed 

burning to modify vegetation in the grassland system. All prescribed burns are closely 

coordinated with Ameren (Ameren and the Conservation Commission of the State of 

Missouri 2009).

Glades are open areas appearing on the landscape as treeless openings in woodlands. 

Limestone glades occur on the Callaway site on southwest-facing forested slopes. Common 

glade species on the site include side oats grama (Bouteloua curtipendula), big bluestem, little 

bluestem, purple prairie clover (Dalea purpurea), Missouri black-eyed Susan 

(Rudbeckia missouriensis), and fragrant sumac (Rhus aromatica). Limestone glades are listed 

in the Missouri Species and Communities of Conservation Concern (MDC 2014) as imperiled 

with a State Rank S2 (S2 = Imperiled in the State because of rarity, or because of some 

factor(s) making it especially vulnerable to extirpation from the State). The MDC periodically 

cuts and burns these areas to maintain the glades (Ameren and the Conservation Commission 

of the State of Missouri 2009).

Upland forest on the site consists predominantly of a deciduous forest cover type. Upland 

deciduous forest on the site is dominated primarily by white oak (Quercus alba), black oak 

(Q. velutina), northern red oak (Q. rubra), and shagbark hickory (Carya ovata). An upland 

evergreen forest comprising a pine plantation covers approximately 13 ac (5.3 ha) adjacent to 

and northwest of the restricted portion of the Callaway site. This area was planted with red pine 

(Pinus resinosa) and eastern white pine (P. strobus). The MDC generally limits active timber 

management on the site (other than prescribed cutting and burning in glade areas) to collection 

of forest inventory data (Ameren and the Conservation Commission of the State of 

Missouri 2009).

Forested wetlands on the Callaway site occur along the floodplains of Logan Creek, the 

Mollie Dozier Chute, and the Missouri River. Common forested wetland species include silver 

maple (Acer saccharinum), box elder (A. negundo), cottonwood (Populus deltoides), black 

willow (Salix nigra), peach-leaved willow (S. amygdaloides), and sycamore (Platanus 

occidentalis) (Ameren 2009a). The MDC manages the Missouri River floodplain within the 

Reform Conservation Area to enhance riparian forest communities and related forested 

wetlands (Ameren and the Conservation Commission of the State of Missouri 2009).

Herbaceous wetlands are scattered throughout the Callaway site, but are most concentrated in 

close proximity to the four treatment lagoons adjacent to and immediately south of the plant and 

along the fringe of the site’s stormwater runoff ponds. Vegetation in these wetlands is 

dominated by arrowhead (Sagittaria latifolia), narrow-leaf cattail (Typha angustifolia), and 

various sedge species (Carex spp.) in the herbaceous layer; and black willow, peach-leaved 

willow, and sandbar willow (Salix interior) in the shrub layer (Ameren 2009a). 

Invasive plant species known to exist on the Callaway site include autumn olive 

(Elaeagnus umbellata), sericea lespedeza (Lespedeza cuneata) and fescue (Ameren 2011d). 

These species primarily occur in areas of recent or past human disturbance, such as 

transmission line corridors, road ROWs, and fallow fields (Ameren 2009a). The MDC manages 

invasive plant species in the Reform Conservation Area portion of the site to minimize any 

negative effects the plants may have on native vegetation or wildlife. Management techniques 

include removal of autumn olive and replacement with native plums (Prunus americana) and 

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Affected Environment

dogwoods (Cornaceae); targeted annual treatment of sericea to reduce its presence; and 

control of fescue within grazing areas and other cover types through treatment and 

discouragement of fescue use in the grazing program (Ameren and the Conservation 

Commission of the State of Missouri 2009).

2.2.7.2 Wildlife

MACTEC conducted avian surveys on the Callaway site in 2007 and 2008 (MACTEC 2007a). 

MACTEC completed general site reconnaissance and observation, spring waterfowl spot 

counts, roadside bird surveys, and transect surveys in a variety of habitats. Common resident 

species present on the site are mourning dove (Zenaida macrooura), Northern cardinal 

(Cardinalis cardinalis), blue jay (Cyanocitta cristata), tufted titmouse (Baeolophus bicolor), 

red-bellied woodpecker (Melanerpes carolinus), American robin (Turdus migratorius), American 

crow (Corvus brachyrhynchos), killdeer (Charadrius vociferous), and Canada goose 

(Branta canadensis). Recreationally valuable species present on the site included bobwhite 

quail (Colinus virginianus), wild turkey (Meleagris gallopavo), and mourning dove 

(Ameren 2009a). The Callaway site is not located within an area designated as an Important 

Bird Area by the National Audubon Society (National Audubon Society 2012). 

MACTEC conducted surveys for mammal species on the Callaway site during 2007 and 2008. 

MACTEC completed the surveys through a combination of general site reconnaissance and 

observation, road kill analysis, and the use of small mammal traps (MACTEC 2007a). These 

surveys documented the presence of 17 mammalian species on site. Mammals commonly 

present on the site include white-tailed deer (Odocoileus virginianus), gray squirrel (Sciurus 

carolinensis), and eastern cottontail (Sylvilagus floridanus); mammals occasionally present on 

the site include coyote (Canis latrans), opossum (Didelphis marsupialis), groundhog (Marmota 

monax), striped skunk (Mephitis mephitis), raccoon (Procyon lotor), eastern chipmunk (Tamias 

striatus), white-footed mouse (Peromyscus leucopus), and deer mouse (P. maniculatus). Of 

these, white-tailed deer are considered recreationally valuable (Ameren 2009a). 

MACTEC completed surveys for reptile and amphibian species on the Callaway site during field 

studies in 2007 and 2008. MACTEC completed the surveys through a combination of general 

site reconnaissance and observation, spring nighttime audio surveys, live turtle traps, and 

transect surveys established within a variety of habitats (MACTEC 2007a). The surveys 

documented the presence of 32 species of amphibians and reptiles. Branchard’s cricket frogs 

(Acris crepitans blanchardii), eastern American toads (Bufo americanus), red-eared slider 

(Trachemys scripta elegans), common snapping turtle (Chelydra serpentine), and Northern 

water snake (Nerodia sipedon) were the most commonly observed species.

2.2.7.3 Transmission Line ROWs

A total of approximately 71 mi (114 km) of transmission corridors connect Callaway to the 

transmission system. Ameren maintains vegetation within the transmission line corridors in an 

herbaceous or shrubby condition to ensure the safety and reliability of the transmission system 

(see Section 2.1.5.2 for a description of vegetation management procedures on the 

transmission line ROWs). Vegetation communities surrounding the transmission line corridors 

are a mixture of deciduous forest, grassland, and cropland. Table 2–5 summarizes the 

vegetation cover types crossed by each transmission corridor. 

Other than the Reform Conservation Area lands within the Callaway site boundary, the 

transmission lines do not cross any critical habitats, Federal or State wildlife preserves, refuges, 

or parks.

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Affected Environment

Table 2–5. Vegetation Communities Crossed by the Transmission Line Corridors

Transmission Line ROW Length 

(mi)

Vegetation Cover Types

Deciduous 

Forest Grassland Cropland

Montgomery #1 and

Montgomery #2 Lines 23.2 53% 22% 16%

Bland Line 31.5 45% 32% 12%

Loose Creek Line 16.6 39% 35% 15%

Source: Ameren 2011

2.2.8 Protected Species and Habitats

The FWS and the National Marine Fisheries Service (NMFS) jointly administer the Endangered 

Species Act (ESA) of 1973 (16 U.S.C. 1531 et seq.). The FWS manages the protection of and 

recovery effort for listed terrestrial and freshwater species, while NMFS manages the protection 

of and recovery effort for listed marine and anadromous species. In Missouri, the MDC

oversees the protection of State-listed species. The MDC is responsible for maintaining an 

updated list of endangered species and providing protection for them under Section 4.111 of the 

Wildlife Code of Missouri (3 CSR 10-4.111).

The NMFS has not designated any essential fish habitat under the Magnuson–Stevens Fishery 

Conservation and Management Act, as amended, within the affected water bodies; therefore, 

this section does not discuss species with essential fish habitat. The FWS and NMFS have not 

designated any critical habitat under the ESA within the action area, nor has either agency 

proposed the listing or designation of any new species or critical habitat within the action area.

2.2.8.1 Action Area

For purposes of its protected species and habitat discussion and analysis, the NRC staff 

considers the action area, as defined by the ESA regulations at 50 CFR 402.02, to include the 

lands and water bodies described below. The following sections only consider terrestrial and 

aquatic species that occur, or have the potential to occur, within this action area.

For aquatic species, the action area is based on the biology of potentially each affected species 

and the extent of its home range. For terrestrial species, the following two action areas are 

defined as:

Callaway site and surrounding area within a 6-mi (10-km) radius. The Callaway site is 

located in Callaway County, approximately 10 mi (16.1 km) southeast of Fulton, Missouri. 

Transmission line corridors to the first substation and 0.5-mi (0.8-km) buffer on either 

side of the lines. The proposed license renewal would use the existing onsite switchyard and 

transmission facilities and would not require the construction or modification of the existing 

transmission system. At Callaway, an onsite switchyard lies southwest of the reactor building 

and connects lines from the plant to into the regional power distribution system. Lines beyond 

this switchyard have been integrated into the regional electric grid and would stay in service 

regardless of Callaway license renewal, and, thus, would not be affected by the proposed 

action. Thus, the in -scope transmission lines are contained within the footprint of the Callaway 

site. 

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Affected Environment

2.2.8.2 Aquatic Species and Habitats

No recent surveys for specific protected species have been conducted on the Callaway site. 

However, Ameren carried out various ecological field surveys on the Callaway site during 2007 

and 2008 as part of a COLA for Callaway Unit 2. Aquatic surveys included juvenile and adult 

fish surveys, as well as benthic macroinvertebrate surveys in the streams in the Reform 

Conservation Area and in the Missouri River (MACTEC 2007a; Ameren 2009a). The NRC staff 

obtained information from these surveys and other historic surveys at the plant on the presence 

of protected species on the Callaway site. The NRC staff did not find any ecological surveys or 

studies that include the transmission line corridors within the action area and that give additional 

information about the occurrence of protected species and habitats.

Table 2–6 identifies the Federally and State-listed aquatic species that occur, or have the 

potential to occur, in the action area based on the counties of occurrence. The six Federally 

listed species appear in bold. The NRC compiled this table from the FWS’s online species 

search by county (FWS 2012f), the Missouri Natural Heritage Program’s (NHP’s) online species 

search by county (MDC undated f), correspondence between the applicant and the FWS 

(FWS 2010) and between the applicant and the MDC (MDC 2010b), and the results of the field 

surveys described above. Only species listed on the Missouri NHP Web site with a State status 

of threatened or endangered are included in Table 2–6. Species with a State status only 

(i.e., S1 through S5) were not included as these species are not formally protected under 

Rule 3 CSR 10-4.111 of the Wildlife Code of Missouri.

Table 2–6. Federally and Missouri-Listed Aquatic Species

Scientific Name Common Name Federal 

Status(a)

State 

Status(b)

County(ies) of 

Occurrence(c)

Fish

Scaphirhynchus albus pallid sturgeon FE ME C, M, O, G

Acipenser fulvescens lake sturgeon — ME C, M, O, G

Etheostoma nianguae Niangua darter FT ME O

Notropis topeka Topeka shiner FE — C

Crystallaria asprella crystal darter — ME G

Platygobio gracilis flathead chub — ME G

Mussels

Lampsilis abrupta pink mucket FE ME O, G

Leptodea leptodon scaleshell FE ME O, G

Cumberlandia monodonta spectaclecase FE — O, G

Elliptio crassidens elephantear — ME O, G

Fusconaia ebena ebonyshell — ME O, G

(a) Federal status determined by the FWS under the authority of the Endangered Species Act and Bald and 

Golden Eagle Protection Act, FE = endangered, FT = threatened, — = not listed 

(b) State of Missouri status determined by the MDC, ME = endangered, — = not listed. State-ranked, but not 

listed, species reported near Callaway are not shown in the table and can be found in MDC 2012b.

(c) The Callaway site lies in Callaway County; the inscope transmission lines traverse Callaway (C), 

Montgomery (M), Gasconade (G), and Osage (O) Counties.

Sources: FWS 2010, 2012f; MDC 2010b, 2012b

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Affected Environment

Species Protected Under the Endangered Species Act

Three species of fish and three species of mussels listed under the ESA occur in the vicinity of 

Callaway. The endangered pallid sturgeon resides in the mainstem Missouri River and may 

occur in the vicinity of the water intake and discharge structures (FWS 1993, 2010). The two 

other fish species include the endangered Topeka shiner (Notropis topeka) and the threatened 

Niangua darter (Etheostoma nianguae), both of which may occur in small streams crossed by 

the Callaway transmission lines. The three species of endangered mussels include the 

spectaclecase (Cumberlandia monodonta), pink mucket (Lampsilis abrupta), and the scaleshell 

(Leptodea leptodon). Some of these species may inhabit water bodies ranging from small 

streams to larger rivers in Osage and Gasconade Counties that are crossed by the transmission 

line. 

Each of these species is discussed in additional detail below, with specific emphasis on the 

pallid sturgeon, as the potential exists for impingement and entrainment of this species.

Pallid Sturgeon (Scaphirhynchus albus) 

The pallid sturgeon is an extremely rare fish; it was listed as endangered by the FWS on 

September 6, 1990 (55 FR 36641), and may be close to extinction (FWS 1993). This species is 

native to the Mississippi and Missouri river drainages and inhabits a large range, although catch 

records are infrequent. The FWS reported that habitat modification, lack of natural 

reproduction, commercial harvesting, and hybridization with the shovelnose sturgeon 

(Scaphirhynchus platorynchus) are the likely causes in the decline of this species’ population. 

With the listing, FWS and State agencies attempted to rear pallid sturgeon in hatcheries with a 

goal of reestablishing a self-sustaining population. In 1997, the first pallid sturgeon were 

spawned through efforts between the FWS and the North Dakota and Montana State fisheries 

departments (AFS 2012), and stocking of pallid sturgeon in various portions of the Missouri 

River continues today.

The current known range of this species is the entire Missouri River system, as well as the 

Mississippi River, primarily downstream from the confluence with the Missouri. The FWS

Recovery Plan (FWS 1993) identified six Recovery Priority Management Areas (RPMAs). 

Callaway is located in RPMA 4, which includes the free-flowing section of the mainstem 

Missouri River from below Gavins Point Dam to the confluence with the Mississippi River.

The pallid sturgeon is adapted to living in large, warm-water river systems subject to high 

turbidity levels (FWS 1993). The pallid sturgeon is a benthic species, preferring bottom habitats 

with velocities ranging from 0.33 to 2.9 ft (10 to 90 cm) per second and reported depths ranging 

from 3 to 25 ft (1 to 8 m). Catch data show that most pallid sturgeon are captured in sandy 

bottom areas of the Missouri River.

Pallid sturgeon, as well as other members of the Acipenseridae family, are large, long-lived fish. 

Individual fish may reach lengths of 6 ft (1.8 m) and ages of 60 years or more (NRC 2010). 

However, data on the natural reproductive biology of this species is lacking (FWS 1993). The 

original recovery plan for this species (FWS 1993) indicated there was no known method 

available to distinguish between larval pallid and shovelnose sturgeon, contributing to the lack of 

knowledge about spawning characteristics; however, more specific genetic analyses have since 

been developed. For over 25 years, no successful reproduction of this species has been 

documented in the upper Missouri River (AFS 2012). In 2000, three confirmed larval pallid 

sturgeon were collected in a side channel (Lisbon Chute) in the lower Missouri River at Missouri 

RM 217, upstream of Callaway (FWS 2000). Additional larval sturgeon, species not confirmed, 

were reported captured below Gavins Point Dam in various parts of the lower Missouri River in 

the early 2000s. Most of these larval fish were assumed to be of hatchery origin, as limited 

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Affected Environment

natural reproduction is believed to occur in the river. Conversations with FWS biologists and the 

NRC staff during the preparation of the SEIS confirmed that egg and larval captures of pallid 

sturgeon are extremely rare (E & E 2012).

The pallid sturgeon prefers faster currents than the shovelnose sturgeon, and this difference 

possibly separates the two species’ spawning areas. A known congregation area for pallid 

sturgeon is located approximately 14.5 mi (23.3 km) upstream of the Callaway water intake 

structure, at the confluence with the Osage River. The FWS and MDC believe this to be a 

staging area for pallid sturgeon during the spawning season (E & E 2012; TetraTech 2012). 

Past surveys for pallid sturgeon in the lower river have shown that individual fish may be very 

mobile, traversing hundreds of miles in a year, whereas other individuals tend to seasonally 

occupy similar habitats from year to year.

Pallid sturgeon do not reach sexual maturity until age 5 to 7 for males and ages 15 to 20 for 

females (Keenlyne and Jenkins 1993). In addition, individuals spawn only every 2 to 3 years. 

Braaten et al. (2008) studied drift dynamics of larval pallid sturgeon and found that larvae 

primarily drifted in the lower 2 ft (0.6 m) of the river channel. Larvae drifted slightly slower than 

mean water column velocities and transitioned from the drift to benthic stage within 11 to 

17 days after release. Drift simulations predict that the average larval pallid sturgeon may drift 

between 152 to 329 mi (245 to 530 km) downstream before inhabiting benthic habitats. 

Adult pallid sturgeon are predominately piscivores (fish eaters), primarily consuming cyprinids 

(minnow family) (FWS 1993). Aquatic invertebrates also represent an important component of 

both juvenile and adult pallid sturgeon diets. An important component of the invertebrate prey 

was Trichopteran larvae, in particular Hydropsyche sp. Pallid sturgeon are suspected to be 

more piscivorous than the similar, congeneric shovelnose sturgeon.

Topeka Shiner (Notropis topeka) 

The FWS listed the Topeka shiner as an endangered species on December 15, 1998, as a 

result of habitat destruction, fragmentation resulting from siltation of stream substrates, reduced 

water quality, and tributary impoundment (63 FR 69008). This shiner is a small cyprinid, 

inhabiting small prairie (or former prairie) streams with good water quality (FWS 2012e). The 

preferred substrate typically includes gravel, cobble, or sand. Ameren’s (2011d) ER reports that 

Auxvasse Creek in Callaway County contained the Topeka shiner before 1945 and that more 

recent surveys in Auxvasse Creek have not resulted in the capture of this species. In 2010, 

MDNR prepared a Recovery Plan for the Topeka shiner in the State of Missouri with a goal of 

stabilizing populations in seven streams in Missouri. The recovery plan includes several 

reintroduction sites in Callaway County, including Logan Creek, which is located within the 

Reform Conservation Area surrounding the plant (MDC 2010a). 

Niangua Darter (Etheostoma nianguae) 

The FWS listed the Niangua darter as a threatened species on June 12, 1985, and included a 

Critical Habitat designation (50 FR 24649). The Callaway site plant is not located within its 

Critical Habitat. The major threats to its existence include reservoir construction, stream 

channelization, decreased water quality, and introduction of predators. This small fish is found 

in the Ozark uplands of west-central Missouri in streams with good water quality that are silt-free 

and have gravel substrates (FWS 2012g). Some of these streams are located in Osage County 

and are crossed by the transmission lines. The FWS reports that over 95 percent of the 

Niangua darter’s range is on privately owned land that is predominately used for cattle grazing.

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Affected Environment

Pink Mucket (Lampsilis abrupta)

The FWS listed the pink mucket as an endangered species on June 14, 1976 (41 FR 24062). 

This small mussel inhabits mud and sand in shallow riffles or on shoals that are free of silt 

(FWS 2012h). The life history of this species includes a phase where larvae attach to a fish 

host for development and distribution throughout the species’ range. The major reason for its 

decline is the creation of dams and reservoirs, which eliminated much of its native habitat. The 

pink mucket has been reported in streams and rivers in Osage and Gasconade Counties, 

including the Osage and Gasconade Rivers, which are crossed by the Callaway transmission 

lines. 

Scaleshell (Leptodea leptodon) 

The FWS listed the scaleshell as an endangered species in 2001 (66 FR 51322). This small 

mussel has a thin, fragile shell, making it more susceptible to changes in sediment loads and 

reductions in water quality. It lives in medium to large rivers with stable channels and good 

water quality (FWS 2012c). The major reasons for its decline are effects related to the creation 

of dams and reservoirs, sedimentation of water bodies, and overall reduction in water quality 

(FWS 2012c). The current distribution of the scaleshell is limited to only three rivers in Missouri: 

the Meramec, Bourbeuse, and Gasconade, and surveys indicate that the species is in decline 

throughout these areas (75 FR 17758). Callaway transmission lines cross over the Gasconade 

River in Gasconade County.

Spectaclecase (Cumberlandia monodonta) 

The FWS listed the spectaclecase as an endangered species on March 13, 2012 

(77 FR 14913). The major reasons for its decline are habitat degradation associated with the 

creation of dams and reservoirs, sedimentation of stream channels, and overall reductions in 

water quality (FWS 2012d). This large mussel inhabits larger rivers, typically residing in 

microhabitats that are sheltered from the main current. It has been reported in the Osage and 

Gasconade Rivers, both of which are crossed by the Callaway transmission lines. 

Species Protected by the State of Missouri

Flathead Chub (Platygobio gracilis)

The State of Missouri has listed the flathead chub as endangered. It is a slender minnow with 

small eyes, a pointed snout, and a large, slightly oblique mouth (MDC undated c). This species 

historically inhabited the mainstem Missouri River, some of its tributaries, and the Missouri and 

Arkansas portions of the Mississippi River. This species is thought to be a sight feeder, capable 

of sight feeding in turbid water, primarily on macroinvertebrates. The construction of the six 

mainstem dams and reservoirs altered the flow and sediment transport of the Missouri River, 

allowing other species, such as the emerald shiner, to outcompete the flathead chub 

(MDC undated c). The MDC Heritage Review Report (MDC 2010a) does not list the flathead 

chub as occurring in the action area. 

Lake Sturgeon (Acipenser fulvescens)

The State of Missouri has listed the lake sturgeon as endangered (MDC 2012b). It is a large, 

ancient species attaining lengths up to 8 ft (2.4 m) and weighing up to 300 lb (136 kg). The lake 

sturgeon has a subterminal, sucker-like mouth and is a benthic inhabitant of large rivers and 

their tributaries. Lake sturgeon prey upon a variety of aquatic organisms, including aquatic 

insects, crayfish, mussels, and small fish. Lake sturgeon are also scavengers of dead animal 

matter (MDC undated h). The lake sturgeon lives up to 150 years and has a slow reproductive 

rate, which has contributed to their decline. Adults become sexually mature at 15 to 20 years of 

age, and females spawn once every 3 to 5 years (MDC undated h). The decline of this species 

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Affected Environment

is related to historic overharvest by fishing, as well as habitat modifications to the mainstem 

Missouri River, which has destroyed historic spawning and rearing areas. The MDC Heritage 

Review Report (MDC 2012b) lists lake sturgeon as occurring within 0.5 mi (0.8 km) of Callaway, 

which is close enough to be considered within the action area.

Crystal Darter (Crystallaria asprella)

The State of Missouri has listed the crystal darter as endangered. It is a slender darter with four 

to five crossbars that extend along the back of the body (MDC undated b). This species 

inhabits open channels of large, clear-water streams with silt-free sand and gravel substrates. 

This species is believed to feed predominately upon the larval stages of aquatic invertebrates 

(MDC undated b). Anthropogenic factors contributing to its decline include channelization, 

sedimentation of channel substrates, and changes in land use that have reduced water quality. 

The MDC Heritage Review Report (MDC 2012b) does not list the crystal darter as occurring in 

the action area.

Elephantear (Elliptio crassidens)

The elephantear, also called the elephant’s ear, is a freshwater mussel belonging to the family 

Unionidae. Adults grow to 3 to 6 in. (7.5 to 15 cm) in length and eat algae and fine particles of 

decaying organic matter. Historically, this species has been found only in the Ozark region of 

Missouri, and today occurs only in the Meramac River, where it is found in mud, sand or fine 

gravel substrates. Like many freshwater mussels, the larvae, or glochidia, are discharged into 

the water and attach to a host fish, which is the skipjack herring (Alosa chrysochloris) in this 

case. The construction of dams has adversely affected populations of skipjack herring, and 

these adverse effects may have affected the species that depend on them, such as freshwater 

mussels. After living on the host, the small mussels break away and float to the bottom, where 

they mature into adults. Freshwater mussels are filter-feeders that help cleanse polluted waters 

and are an important food source for other aquatic species. The elephantear is listed as 

endangered by the State of Missouri and is a candidate for Federal listing as endangered 

(MDC 2013). Although its Counties of Occurrence include Callaway and Gasconade, it is not 

found in any water bodies crossed by Callaway transmission lines. 

Ebonyshell (Fusconaia ebena)

The ebonyshell is a freshwater mussel that typically inhabits large rivers. The range of the 

ebonyshell historically extended up the Mississippi River from Missouri into Minnesota and into 

other large rivers in Illinois, Indiana, and Ohio, where it inhabits fine to course gravel and cobble 

to sand and gravel to hard mud. Today the ebonyshell is rare and listed as either threatened or 

endangered throughout its range. Like many freshwater mussels, the larvae, or glochidia, are 

discharged into the water and attach to host fish, which include the black and white crappies, 

green sunfish, skipjack herring, and largemouth bass. Ebonyshell spawn in May and releases 

glochidia into September and after two to four weeks of attachment to their host fish, they break 

away and float to the bottom, where they mature into adults. Reasons for the decline of 

ebonyshell include commercial harvesting in the early 1900s for use as buttons, increases in 

pollution and siltation, declines in fish host species populations, dam construction, 

channelization projects, and continued non-point source pollution from both urban and 

agricultural areas (MDC 2000a).

2.2.8.3 Terrestrial Species and Habitats

No recent surveys for specific protected species have been completed on the Callaway site. 

However, MACTEC carried out various ecological field surveys on the Callaway site during 

2007 and 2008 as part of a COLA for Callaway Unit 2. The surveys included documentation of 

habitat and occurrence of avian, mammal, reptile, and amphibian species (Ameren 2009a; 

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Affected Environment

MACTEC 2007 a and b). The results from these surveys were used to note protected species 

on the Callaway site. The NRC staff did not find any ecological surveys or studies that include 

the transmission line corridors within the action area that might give additional information about 

the occurrence of protected species and habitats.

For the avian surveys, MACTEC conducted spring waterfowl spot counts, roadside bird surveys, 

and transect surveys established in upland forest, bottomland forest, grassland, and open field 

habitats. Five transects were surveyed on foot on two separate days during spring, summer, fall 

and winter.

MACTEC used a combination of road kill analysis and trapping for the mammal survey. 

Twenty Sherman live traps were set for two consecutive trap nights along five transects 

established in upland forest, bottomland forest, grassland, and old field habitat. Mammal 

trapping was completed during the spring and fall. 

MACTEC completed the reptile and amphibian surveys through a combination of spring 

nighttime audio surveys for calling frogs and toads, live turtle traps set at various ponds and 

streams, and transect surveys (MACTEC 2007 a and b). 

MACTEC completed a terrestrial vegetation survey during 2007 and 2008 by documentation of 

species along five transects established in old field forested areas, grassland and pastures, and 

the floodplain of Logan Creek (MACTEC 2007 a and b). 

Table 2–7 identifies the Federally and Missouri-listed terrestrial species that occur, or have the 

potential to occur, in the action area based on counties of occurrence. The three Federally 

listed species appear in bold. The NRC compiled this table from the FWS’s online species 

search by county (FWS 2012f), correspondence between the NRC and the FWS (NRC 2012), 

NRC and the MDC (MDC 2012b), the Missouri NHP’s online species search by county 

(MDC undated f), correspondence between Ameren and the FWS (FWS 2010) and between 

Ameren and the MDC (MDC 2010b); and the results of the field surveys described above. Only 

species listed on the Missouri NHP Web site with a State status of threatened or endangered 

are included in Table 2–7. Species with a State rank only (i.e., S1 through S5) were not 

included as these species are not formally protected under Rule 3CSR10-4.111 of the Wildlife 

Code of Missouri.

Table 2–7. Federally and Missouri-listed Terrestrial Species

Scientific Name Common Name Federal 

Status(a)

State 

Status(b)

County(ies) of 

Occurrence(c)

Amphibians

Cryptobranchus alleganiensis eastern hellbender — ME M, O, G

Birds

Circus cyaneus northern harrier — ME C, M, O, G

Mammals

Myotis grisescens gray bat FE ME C, O, G

Myotis sodalis Indiana bat FE ME C, M, O, G

Plants

Trifolium stoloniferum running buffalo 

clover FE ME C, M

(a) Federal status determined by the FWS under the authority of the Endangered Species Act and Bald and Golden 

Eagle Protection Act. FE = endangered, FT = threatened, — = not listed

(b) State of Missouri status determined by the MDC. ME = endangered

(c) The Callaway site lies in Callaway County; the inscope transmission lines traverse Callaway (C), 

Montgomery (M), Gasconade (G), and Osage (O) counties.

Sources: FWS 2010, 2012f; MDC 2010b, 2012a, 2012b; NRC 2012

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Affected Environment

Species and Habitats Protected Under the Endangered Species Act

Gray Bat (Myotis grisescens)

The FWS listed the gray bat, which occurs mainly in Alabama, northern Arkansas, Kentucky, 

Missouri, and Tennessee, as endangered under the ESA in 1976 (41 FR 17736). The FWS has 

not designated critical habitat for this species (FWS 2012h). 

Gray bats have unicolored grayish-brown fur on their backs. This is a distinguishing feature 

from other bats, as is the gray bats’ wing membrane, which connects to its ankle instead of at 

the toe; the wing membrane is connected at the toe in other Myotis species (FWS 2012i).

Adult female gray bats enter hibernacula during September and October and are followed by 

juveniles and adult males by early November. Adult females emerge in early March to 

mid-April, followed by juveniles and adult males in mid-April to mid-May. Pregnant females 

roost in maternity colonies separate from males and young females from late May to June. 

Gray bats give birth to a single young in late May or early June. The mothers and their young 

rejoin the bachelor colonies in July and August (FWS 1982).

With rare exceptions, gray bats live in caves year-round. During the winter gray bats hibernate 

in deep, vertical caves with cool, stable temperatures. Summer caves have domed ceilings and 

are warmer; they are typically located within 2 mi (3.2 km) of rivers or reservoirs. Foraging 

habitat consists of forest canopies along river edges. Gray bats also forage low over water on 

flying insects (FWS 1982). 

The habit of gray bats of living in larger numbers in only a few caves makes them highly

vulnerable to disturbance. The primary causes of their historical decline include natural flooding 

and human-related habitat destruction, including cave flooding or submergence during reservoir 

construction and cave tourism (FWS 2012h). 

Missouri contains approximately 20 percent of the total population of gray bats, most of which 

occur south of the Missouri River (MDC undated d). The FWS identifies the gray bat as 

occurring in 50 Missouri counties, including 3 of the 4 counties in the action area (Callaway, 

Gasconade, and Osage Counties) (FWS 2012h).

None of the ecological surveys completed on the Callaway site identified gray bats as occurring 

on the site; however, no specific surveys for gray bats were completed as part of these surveys. 

Gray bats have been documented near the Callaway site in a cave along Auxvasse Creek 

(Ameren 2009a). The MDC Heritage Review Report also indicates that gray bats could 

potentially occur along the banks of the Missouri River and along the river floodplain, although 

no specific records of gray bat in these areas within 1 mi (1.6 km) of the Callaway site is found 

in the MDC database (MDC 2010b). Based on the historic occurrence noted by Ameren and 

presence of suitable forage habitat, the gray bat may use portions of the Callaway site, 

particularly the riparian zones along Auxvasse Creek, Logan Creek, Mud Creek, Molly Dozier 

Slough, and the Missouri River. The gray bat may also use riparian zones along the 

transmission line corridors in Callaway County as foraging habitat. 

Indiana Bat (Myotis sodalis)

The FWS listed the Indiana bat as endangered under the ESA in 1967 (32 FR 4001) and 

designated critical habitat for the species on September 24, 1976 (41 FR 41914). The 

designated habitat includes 11 caves and 2 mines in 6 states where the Indiana bat was known 

to hibernate. None of the six caves and mines designated as critical habitat in Missouri are 

within the action area (FWS 2012i). 

Indiana bats have dark brown to black fur (FWS 2012i). They are similar in appearance to little 

brown bats (M. lucifugus) and Keen’s myotis (M. keenii), with the main identifying feature being 

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Affected Environment

a distinct keel on the supporting structure on the rear of the Indiana bat’s tail membrane 

(MDC undated g). 

Indiana bats hibernate during winter in cool caves with temperatures remaining near 40 °F 

(4 °C). Abandoned mines are also occasionally used for winter hibernation (FWS 2012h; 

MDC undated g). Indiana bats emerge from hibernation in early spring and migrate to summer 

roost and forage areas. Both male and female Indiana bats roost in forested areas under loose 

or peeling tree bark on dead or dying trees. Males roost alone or in small groups, while females 

roost in maternity colonies of up to 100 or more (FWS 2012i). Indiana bats primarily forage 

along stream and river corridors, associated floodplain forests, and in proximity to open bodies 

of water such as ponds or reservoirs. Flying insects are their primary food source (FWS 2012i). 

Indiana bats are vulnerable to disturbance because they hibernate in large numbers in a limited 

number of caves. Primary causes of their historical decline include cave commercialization and 

improper gating, summer habitat loss or degradation, and pesticides and environmental 

contaminants (FWS 2012i). The recent white-nose syndrome has also led to population 

declines. 

Over 85 percent of the approximately 65,000 Indiana bats in Missouri hibernate in eight 

locations. Three of these locations are in Shannon, Washington, and Iron Counties, which are 

immediately southeast of the action area. Summer roosting Indiana bats have been observed 

throughout the state (FWS 2012i; MDC undated g). 

None of the ecological surveys completed on the Callaway site identified Indiana bats as 

occurring on the site; however, no specific surveys for Indiana bats were completed as part of 

these surveys. The MDC Heritage Review Report indicates that Indiana bats could potentially 

occur along the banks of the Missouri River and along the river floodplain, although no specific 

records of Indiana bat in these areas within 1 mi (1.6 km) of the Callaway site is found in the 

MDC database (MDC 2010b). Based on the presence of suitable forage habitat, the Indiana bat 

may use portions of the Callaway site during the summer roost season. Areas on the Callaway 

site with the greatest potential to support foraging Indiana bats include the riparian zones of 

Auxvasse Creek, Logan Creek, Mud Creek, Molly Dozier Slough, and the Missouri River. The 

Indiana bat may also use riparian zones and upland forest along the transmission line corridors

in Callaway County as foraging habitat. 

Running Buffalo Clover (Trifolium stoloniferum)

The FWS listed the running buffalo clover as endangered in 1987 (52 FR 21478). No critical 

habitat has been designated for this species (FWS 2007). 

Running buffalo clover is a perennial species with white flower heads that grow on stems 2 to 

8 in. (5 to 20 cm) long; it flowers from late spring to early autumn (FWS 2012f). Running buffalo 

clover requires habitats that are somewhat open and exposed to regular periods of moderate 

disturbance, such as mowing, trampling, or grazing. It cannot tolerate full sun, full shade, or 

extensive disturbance. The plant has historically been reported in many habitats, including 

mesic woodlands, savannas, floodplains, stream banks, and sandbars. Disturbed habitats with 

historic species records include grazed woodlots, mowed paths, old logging roads, jeep trails, 

all-terrain vehicle trails, skid trails, and mowed wildlife openings within mature forest 

(FWS 2007). 

Once widespread in the Midwest, this species has declined drastically. It depended on bison to 

maintain its habitat and to disperse its seeds. Agriculture and other land-clearing activities have 

destroyed and fragmented its habitat. Nonnative invasive species compete for nutrients, space, 

moisture, and sunlight. Land management that permits open areas to become wooded, plus 

excessive grazing, also decreases this plant's chances for survival.

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Affected Environment

Missouri has three naturally occurring and four reintroduced populations of running buffalo 

clover. The largest known population, located at Graham Cave State Park in Montgomery 

County, consisted of 139 plants in 2003 (FWS 2007). The species is also listed by FWS and 

MDC as occurring in Callaway County (FWS 2012f; MDC undated f). 

The terrestrial vegetation survey completed on the Callaway site did not find any populations of 

running buffalo clover. In addition, the MDC indicated that no historical records note this 

species on the Callaway site or along the transmission line corridors (MDC 2010b), and the 

FWS did not find this species as potentially occurring in the action area in its correspondence 

with the NRC (FWS 2012b). However, the NRC conservatively concludes that the running 

buffalo clover could occur in areas of suitable habitat within the action area, particularly in 

disturbed areas.

Species Protected Under the Bald and Golden Eagle Protection Act

The Bald and Golden Eagle Protection Act of 1940, as amended, prohibits anyone from taking 

bald eagles (Haliaeetus leucocephalus) or golden eagles (Aquila chrysaetos), including their 

nests or eggs, without an FWS-issued permit. The term “take” in the Act is defined as to 

“pursue, shoot, shoot at, poison, wound, kill, capture, trap, collect, molest, or disturb” 

(50 CFR 22.3). “Disturb” means to take action that (1) causes injury to an eagle; (2) decreases 

its productivity by interfering with breeding, feeding, or sheltering behavior; or (3) results in nest 

abandonment (50 CFR 22.3).

Bald eagles in Missouri are commonly observed near lakes, rivers and marshes, where they 

forage for fish or carrion (MDC undated a). The MDC Heritage Review Report indicates that 

bald eagles may be present at the Callaway site along the banks of the Missouri River and 

within the adjacent floodplain; however, there are no current records of bald eagles in this area. 

The Heritage Review report also indicates that bald eagles may nest near streams or other 

water bodies along the transmission line corridors (MDC 2010b). MACTEC (2007a) observed 

bald eagles at the Callaway site near the Missouri River during the 2007 avian surveys. 

Species Protected Under the Migratory Bird Treaty Act

The FWS administers the Migratory Bird Treaty Act (MBTA) of 1918, as amended, which 

prohibits anyone from taking native migratory birds or their eggs, feathers, or nests. The MBTA 

definition of a “take” differs from that of the ESA and is defined as “to pursue, hunt, shoot, 

wound, kill, trap, capture, or collect, or any attempt to carry out these activities” (50 CFR 10.12). 

Unlike a take under the ESA, a take under the MBTA does not include habitat alteration or 

destruction. The MBTA protects a total of 1,007 migratory bird species (75 FR 9282). Of these 

the FWS allows for the legal hunting of 58 species as game birds (75 FR 9282). All Federally 

and Missouri-listed bird species that appear in Table 2–7 are protected under the MBTA. In 

addition, the MBTA protects all bird species native to the United States that belong to the 

families, groups, or species listed at 50 CFR 10.13.

Species Protected by the State of Missouri 

Eastern Hellbender (Cryptobranchus alleganiensis)

The eastern hellbender is listed by the State of Missouri as endangered. This large aquatic 

salamander is characterized by a wide, flat head and a broad, rudder-like tail. This species 

inhabits clean and cool perennial streams and rivers with fast-flowing water. They feed almost 

entirely on crayfish, with small fish and insects also composing a small portion of their diet 

(MDC undated e). Habitat degradation from dam construction, gravel mining, stream siltation, 

and introduction of contaminants are the primary causes in the population decline of the species 

(MDC undated i). 

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Affected Environment

The eastern hellbender is not listed as occurring within Callaway County and was not identified 

during any of the ecological surveys completed on the site; therefore, it is unlikely to occur on 

the Callaway site. The MDC Heritage Review Report indicates that a population of eastern 

hellbender or suitable habitat is known to occur upstream of the Bland transmission line 

corridor, which crosses the Gasconade River (MDC 2010b). Suitable habitat and, therefore, 

populations of eastern hellbender may also be present along the other transmission line 

corridors in Montgomery and Osage Counties. 

Northern Harrier (Circus cyaneus) 

The northern harrier is listed by the State of Missouri as endangered. This medium-sized raptor 

inhabits a variety of habitats, including open fields, prairies, native grass plantings, and shallow 

marshes (MDC 2000b). Northern harriers are present in Missouri as both a breeding and 

migrating species, although breeding in the State is rare. Nesting occurs in low areas such as 

undisturbed marshes, prairies, and pastures, or on elevated ground in shrubby vegetation, tall 

weeds, or reeds. Northern harriers forage for small mammals, birds, large insects, and 

amphibians from perch sites on the ground or on stumps or posts. The species has declined 

because of loss of habitat, in particular wetland drainage, reforestation of grasslands, 

conversion of native prairies to agricultural land, and mowing or haying of grassland nesting 

areas during the breeding season (MDC 2000b).

The northern harrier is not listed in the MDC Heritage Review Report as occurring in the action 

area. However, MACTEC observed two harriers along the Missouri River floodplain in cropland 

on the Callaway site during the 2007 avian surveys (MACTEC 2007a).

2.2.9 Socioeconomics

This section describes current socioeconomic factors that have the potential to be directly or 

indirectly affected by changes in operations at Callaway. Callaway and the communities that 

support it can be described as a dynamic socioeconomic system. The communities offer the 

people, goods, and services required to operate the nuclear power plant. Power plant 

operations, in turn, offer wages and benefits for people and dollar expenditures for goods and 

services. The measure of a community’s ability to support Callaway operations depends on the 

ability of the community to respond to changing environmental, social, economic, and 

demographic conditions.

The socioeconomics region of influence (ROI) is defined by the area where Callaway 

employees and their families reside, spend their income, and use their benefits, thereby 

affecting the economic conditions of the region. The ROI consists of a three-county area 

(Boone, Callaway, and Cole Counties), where approximately 84 percent of Ameren employees 

reside (Ameren 2011d).

Ameren employs a permanent workforce of approximately 860 workers at Callaway, 

approximately 84 percent of whom live in Boone, Callaway, and Cole Counties (see Table 2–8). 

Most of the remaining 16 percent of the workforce are divided among 21 counties across 

Missouri and other states, with numbers ranging from 1 to 31 employees per county 

(Ameren 2011d). Given the residential locations of Callaway employees, the most significant 

effects of plant operations are likely to occur in Boone, Callaway, and Cole Counties. The focus 

of the socioeconomic impact analysis in this SEIS is, therefore, on the effects of continued 

Callaway operations on these three counties.

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Affected Environment

Table 2–8. Callaway Employee Residence, by County

County Number of Employees Percentage of Total

Callaway 410 47.7

Boone 173 20.1

Cole 142 16.5

Other 134 15.6

Total 859 100

Source: Ameren 2011d

Refueling outages at Callaway normally occur at 18-month intervals. During refueling outages, 

site employment increases by as many as 800 temporary workers for approximately 30 to 

40 days (Ameren 2011d). Most of these workers are assumed to be located in the same 

geographic areas as Callaway employees. The following sections describe the housing, public 

services, offsite land use, visual aesthetics and noise, population demography, and the 

economy in the ROI surrounding Callaway.

2.2.9.1 Housing

Table 2–9 lists the total number of occupied and vacant housing units, vacancy rates, and 

median value in the socioeconomic ROI. According to the 2010 Census, there were 

120,397 housing units in the ROI, of which 110,132 were occupied. The median values of 

owner-occupied housing units in Boone, Callaway, and Cole Counties were $158,500, 

$129,900, and $141,400 respectively. Boone County had a lower vacancy rate (7.9 percent) 

than Callaway County (11.8 percent) and Cole County (8.0 percent) (USCB 2010).

Table 2–9. Housing in Boone, Callaway, and Cole Counties in 2010

Boone Callaway Cole ROI

Total housing units 69,551 18,522 32,324 120,397

Occupied housing units 64,077 16,333 29,722 110,132

Vacant units 5,474 2,189 2,602 10,265

Vacancy rate (percent) 7.9 11.8 8.0 8.5

Median value (dollars) a 158,500 129,900 141,400 143,267 a estimated

Source: USCB 2010: 2010 Demographic Profile Data, American Community Survey 1-Year Estimates (Boone and 

Cole Counties); 2008–2010 American Community Survey 3-Year Estimates (Callaway)

2.2.9.2 Public Services

This section presents information about public services, including water supply, education, and 

transportation.

Water Supply

Boone, Callaway, and Cole Counties are located in east-central Missouri. Information about 

public water suppliers in these counties; supply capacities; average daily consumption; and 

population served are presented in Table 2–10. MDNR Division of Environmental Quality 

divides Missouri into five regions (Kansas City, Northeast, Southeast, Southwest, and St. Louis 

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Affected Environment

Regional Offices). Boone, Callaway, and Cole Counties are 3 of 30 counties served by the 

Northeast Regional Office located in Macon (MDNR 2012a).

Approximately 11 percent of the state’s 2010 population resides in this region (USCB 2010). As 

seen in Table 2–10, the Columbia community water system serves the largest population 

(100,733 persons) and has the highest average daily consumption (12.0 mgd 

(45.4 million L/day)). The Centralia community water system serves the smallest population 

(4,027 persons) and has the lowest average daily consumption (less than 500,000 gpd 

(1,893,000 L/day)) (MDNR 2012a).

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Table 2–10. Select Public Water Supply Systems in Boone, Callaway, and Cole Counties

Water Supplier Primary Water 

Source

Average Daily 

Consumption 

(mgd)

Supply 

Capacity 

(mgd)

Population 

Served

Boone County

Boone County 

Consolidated Water 

Supply District 1

GW 1.8 9.4 19,500

Boone County 

Consolidated Water 

Supply District 4

GW 0.5 1.7 6,152

Boone County 

Consolidated Water 

Supply District 9

GW 1.0 2.9 11,250

Boone County 

Consolidated Water 

Supply District 10

GW 0.5 1.8 4,550

Centralia GW 0.5 1.4 4,027

Columbia GW 12.0 32.0 100,733

University of Missouri, 

Columbia GW 2.2 6.5 40,319

Callaway County

Callaway 2 Water 

District GW 0.9 6.4 13,080

Callaway County 

Public Water Supply 

District 1

GW 0.9 3.2 9,615

Fulton GW 1.7 4.4 12,128

Cole County

Cole County Public 

Water Supply District 1 GW 1.6 4.0 12,357

Cole County Public 

Water Supply District 2 GW 0.0 0.0 12,265

Cole County Public 

Water Supply District 4 GW 0.8 0.0 6,367

Missouri American 

Jefferson City SW 2.9 6.5 27,377

Key:

SW = surface water; GW = groundwater; mgd = million gallons per day

Source: MDNR 2012a

Onsite groundwater is currently used as the source of potable water for Callaway; Callaway 

does not use water from a municipal water supplier. Three water supply wells (Wells 1, 2, 

and 3) are installed at depths ranging from 1,100 to 1,510 ft (335.4 to 460.4 m) below ground 

surface; however, Wells 1 and 2 are inactive. Groundwater from Well 3 supplies the potable 

water, water for process water makeup, and water for fire protection. The maximum 

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groundwater use at Well 3 is approximately 400 gpm (1,514 L/min) for 2 hours a day. Well 3 is 

located about 0.2 mi (0.32 km) northeast of Callaway.

Education

Boone County has 6 school districts consisting of 49 schools distributed among grades 

prekindergarten through 12. During the 2009–2010 school year, enrollment was 22,516 

(NCES 2011).

Callaway County has 5 school districts consisting of 18 schools distributed among grades 

prekindergarten through 12. The Missouri School for the Deaf is one of the five public school 

districts located within Callaway County. During the 2009–2010 school year, enrollment was 

5,029 (NCES 2011).

Cole County has seven school districts consisting of 124 schools distributed among grades 

prekindergarten through 12. Of the seven public school districts within Cole County, three are 

State districts, including the Department of Corrections, Division of Youth Services, and the 

Missouri Schools for the Severely Disabled. During the 2009–2010 school year, enrollment was 

12,940 (NCES 2011).

Transportation

Major arterials in Callaway County include Interstate 70 (I-70), which has an east-west 

orientation and traverses the northern third of the county, and U.S. Highway 54, which intersects 

I-70 north of Fulton.

The Callaway site has six entrances, A through F. County Roads 428, 459, and 448, 

collectively encircle the site. Most plant employees use Entrances A, B, and C, on the 

southwest side of the site. These entrances intersect County Road 428, west of the site 

(Ameren 2011d).

Most Callaway employees reside in and around the cities of Fulton, Jefferson City, and 

Columbia, Missouri. Ameren assumes that the roadways between these cities and the 

Callaway site are those most traveled by plant employees. Employees living in Fulton and 

Columbia generally use State Highway O from Fulton to the plant site. Those traveling from 

Columbia may use I-70 to U.S. Highway 54 or State Highways WW and F to reach Fulton. 

Employees in Jefferson City use State Highways 94 and CC to reach the plant site. The few 

employees who live northeast of the plant use I-70 and State Highways D and O. Employees 

living east of the plant site use State Highways 94, D, and O. Callaway employees report that 

there are no congestion issues during shift changes or normal refueling outages 

(Ameren 2011d).

Table 2–11 lists commuting routes to Callaway and average annual daily traffic (AADT) volume. 

The AADT values represent traffic volume during the average 24-hour day during 2010. These 

values are calculated by dividing the total annual traffic volumes along the major commuting 

routes for Callaway employees by 365 days at various segments along the route.

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Table 2–11. Major Commuting Routes in the Vicinity of Callaway and 2010 AADT Counts

Major Commuting Routes Average Annual Daily Traffic (AADT)a

State Highway O from Fulton to the plant site 710

I-70 to U.S. Highway 54 37,035 / 38,951

State Highways WW and F 3,168 / 9,168

State Highways 94 and CC 1,858 / 2,162 a All AADT values represent traffic volume during the average 24-hour day during 2010.

Source: MoDOT 2010

2.2.9.3 Offsite Land Use

This section presents information about offsite land uses.

Callaway County

Land area in Callaway County amounts to 835 square miles (mi2) (2,163 square kilometers 

(km2

)). Agricultural land and forestland are the predominant land uses, with urban lands 

composing approximately 1.3 percent of the total county land area (USCB 2010). Major 

agricultural products grown in the county include corn, soybeans, wheat, and sorghum. 

Livestock and their products compose approximately 60 percent of the market value of all 

agricultural products sold. Livestock in the county includes predominately hogs and cattle, and 

to a lesser extent, poultry (NASS 2009). The number of farms in Callaway County increased by 

1 percent from 2002 to 2007. During the same period, farmland acreage in the county 

decreased by 10 percent, from 357,517 ac (144,682 ha) to 322,929 ac (130,685 ha), and the 

average size of a farm decreased by 10 percent, from 239 ac (97 ha) to 215 ac (87 ha) 

(NASS 2009).

Between 2000 and 2010, the total population of Callaway County increased by approximately 

3,600 people, or 8.7 percent (USCB 2000, 2010). The County’s rate of growth was marginally 

faster than that of the State, which grew by 7 percent during the same period (USCB 2000, 

2010). Population growth is projected to continue, and the county’s urban and rural land 

resources are expected to accommodate the anticipated growth over the next 20 years. Land 

use in the county has not changed significantly over the last several decades (Ameren 2011d). 

Agriculture will likely remain the primary land use in the county over the next 20 years.

Callaway County is a member of the Mid-Missouri Regional Planning Commission, which 

includes Boone, Callaway, Cole, Cooper, Howard, and Moniteau Counties. Neither the 

Mid-Missouri Regional Planning Commission nor Callaway County has a comprehensive land 

use plan. Furthermore, Callaway County does not have zoning or planning commissions, nor 

does it have a zoning ordinance. The City of Fulton, which is the largest city in Callaway 

County, has a zoning ordinance (Ameren 2011d).

Boone County

Land area in Boone County amounts to 685 mi2 (1,774 km2). Agricultural land and forestland 

are the predominant land uses, with urban lands composing approximately 9.6 percent of the 

total county land area (E & E 2012; USCB 2012). Agricultural products in the county include 

soybeans, corn, wheat, and sorghum. Livestock and their products compose approximately 

36 percent of the market value of all agricultural products sold. Livestock in the county primarily 

includes cattle and hogs, and to a lesser extent, horses and chickens (NASS 2009). The 

number of farms in Boone County decreased by 5 percent from 2002 to 2007. During the same 

period, farmland acreage in the county decreased by 4 percent, from 269,605 ac (109,105 ha) 

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to 258,734 ac (104,705 ha), and the average size of a farm increased by 1 percent, from 194 ac 

(79 ha) to 196 ac (79 ha) (NASS 2009).

Between 2000 and 2010, the total population in Boone County increased by approximately 

27,200 people, or 20.1 percent (USCB 2000, 2010). The county’s rate of growth was nearly 

three times faster than that of the State, which had a growth rate of 7 percent during the same 

period (USCB 2000, 2010). Population growth is projected to continue. An increasing 

population has been a factor in the loss of open space and the conversion of agricultural lands 

(E & E 2012). If the population of Boone County continues to grow as significantly as it has over 

the last several decades, it is possible that agriculture and forestland will not remain the 

predominant land uses in the county over the next 20 years (E & E 2012). 

Boone County has a comprehensive land use plan, which was originally approved by the 

County Commission in 1973 and revised in 1996. The county does not have plans to update 

this document (E & E 2012). The county also has a planning and zoning commission, which 

administers and enforces the county’s zoning ordinance and other land use regulations. The 

Boone County cities of Ashland, Centralia, Columbia, Hallsville, and Rocheport have zoning 

ordinances. Much of the population growth in Boone County is concentrated around the City of 

Columbia, the largest city in the county (E & E 2012).

Cole County

Land area in Cole County amounts to 394 mi2 (1,020 km2). Agricultural land and forestland 

make up most land uses within the county. Agricultural products include soybeans, corn, field 

and grass seed crops, and wheat. Livestock and their products compose approximately 

76 percent of the market value of all agricultural products sold. Livestock in the county primarily 

includes turkeys, cattle, and swine (NASS 2009). The number of farms in Cole County 

decreased by less than 1 percent from 2002 to 2007. During the same period, farmland 

acreage in the county decreased by 3 percent, from 185,689 ac (75,146 ha) to 180,840 ac 

(73,183 ha), and the average size of a farm decreased by 3 percent, from 169 ac (68 ha) to 

164 ac (66 ha) (NASS 2009).

Between 2000 and 2010, the total population in Cole County increased by approximately 

4,600 people, or 6.4 percent (USCB 2000, 2010). The county’s rate of growth was marginally 

lower than that of the State, which grew by 7 percent during the same period (USCB 2000, 

2010). Population growth is projected to continue, although the county’s urban and rural land 

resources are expected to accommodate the anticipated growth over the next 20 years. Land 

use in the county has not changed significantly over the last several decades; however, it has 

become more urbanized, particularly around Jefferson City, the State capital. Agriculture will 

likely remain the primary land use in the county over the next 20 years (E & E 2012).

Cole County has a comprehensive land use plan, which was approved by the County 

Commission in December 2010. The county also has a planning commission, which primarily 

oversees subdivision and floodplain regulations. At the county level, there is no zoning 

commission; however, the county is in the preliminary stages of developing a zoning ordinance 

that would apply to unincorporated areas. Jefferson City, the State capital and the largest city in 

Cole County, has a zoning ordinance. Other Cole County municipalities that have a zoning 

ordinance include the Village of Wardsville, City of St. Martins, and City of Taos (E & E 2012).

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2.2.9.4 Visual Aesthetics and Noise

The Callaway site boundary encloses approximately 7,354 ac 

(2,976 ha) and is composed of three main areas: the power 

plant site area, the corridor area, and a peripheral area. The 

power plant site area contains the major power generation 

facilities, including the containment building and related 

structures, a switchyard, the ultimate heat sink retention pond 

and cooling tower, a water treatment plant, administration 

buildings, warehouses, and other features. Within this power 

plant site area, 512 ac (207 ha) are used for power production. 

The approximately 2,135 ac (864 ha) corridor area includes the 

intake and blowdown pipelines between the plant and the river 

intake structure. The approximately 2,454 ac (993 ha) 

peripheral area is undeveloped and is not used for power 

generation. Ameren has made approximately 6,300 ac (2,551 ha) of the total 7,354 ac 

(2,976 ha) available for public access under an agreement with the MDC. Known as the Reform 

Conservation Area, this portion of the property is managed by the MDC (Ameren 2011d).

The Callaway site straddles the boundary between the Dissected Till Plains physiographic 

section to the north and the Ozark Highlands physiographic province to the south. The site is 

situated on a small plateau of gently rolling hills and has an average elevation of approximately 

850 ft (259 m) above MSL. The land between the site and the river, which contains the corridor 

area, drops approximately 325 ft (99 m) and is highly dissected by streams. The section of the 

Missouri River in the vicinity of the site has an average elevation of approximately 525 ft 

(160 m). The land surrounding the site is a mix of forestland, farmland, and rural residences. 

The elevation of the area surrounding the site out to about 0.6 mi (0.97 km) is slightly lower than 

that of the plant area. Therefore, the 555-ft high (169-m high) cooling tower at Callaway is a 

prominent feature of the area and is clearly visible from Interstate I-70, which is more than 11 mi 

(18 km) north of Callaway (Ameren 2012d).

Given the industrial nature of Callaway, noise emissions from the site are generally an 

intermittent minor nuisance. Sources of noise at Callaway include the turbines and large pump 

motors. Noise levels may sometimes exceed the 55-dBA level that EPA uses as a threshold to 

protect against excess noise during outdoor activities (EPA 1974). However, according to EPA, 

this threshold does “not constitute a standard, specification, or regulation,” but was intended to 

give a basis for state and local governments in establishing noise standards.

2.2.9.5 Demography

According to data obtained from the 2010 Census, an estimated 73,131 people live in the 

census blocks within 20 mi (32 km) of Callaway, which equates to a population density of 

37 persons per square mile (14.3 persons per square kilometer). An estimated 601,190 people 

live in the census blocks within 50 mi (80 km) of Callaway, for a population density of 

65 persons per square mile (25 persons per square kilometer) (USCB 2012). 

Using the population characterization technique used in the Generic Environmental Impact 

Statement (GEIS) for License Renewal of Nuclear Plants (NUREG–1437, Appendix C), 

population can be characterized based on two factors: “sparseness,” which describes 

population density and city size within 20 mi (32 km) of a site; and “proximity,” which describes 

population density and city size within 50 mi (80 km). According to the GEIS, if there are less 

than 40 persons per square mile and there is no community with 25,000 or more people within 

20 mi (32 km) of a site, the population is sparseness Category 1 (most sparse). Also according 

to the GEIS, if there are one or more cities with 100,000 or more people and less than 

The EPA generally uses 

55 decibels adjusted (dBA) as 

the noise threshold level to 

protect against excess noise 

during outdoor activities. 

However, according to the 

EPA this threshold does “not 

constitute a standard, 

specification, or regulation,” 

but was intended to provide a 

basis for state and local 

governments establishing 

noise standards.

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190 persons per square mile within 50 mi (80 km) of the site, the population is considered a 

proximity Category 3 (not close). A matrix is then used to rank the population as low, medium 

or high. Based on the regional population classifications of sparseness Category 1 and 

proximity Category 3, Callaway lies in a medium population area (NRC 1996).

Table 2–12 shows population projections and growth rates from 1990 to 2050 in Boone, 

Callaway, and Cole Counties, Missouri. The growth rate in Boone County showed an increase 

of approximately 20.1 percent for the period from 2000 to 2010. Population in Callaway and 

Cole Counties also increased between 2000 and 2010, though less than in Boone County, at 

8.7 percent and 6.4 percent, respectively. The population of all three counties is expected to 

continue to increase in the next decades and through 2050.

Table 2–12. Population and Percent Growth in Boone, Callaway, and Cole Counties From 

1980 to 2010 and Projected for 2020 to 2050

Year Boone Percent 

Change Callaway Percent Change Cole Percent Change

1980 100,376 NA 32,252 NA 56,663 NA

1990 112,379 12.0 32,809 1.7 63,579 12.2

2000 135,454 20.5 40,766 24.3 71,397 12.3

2010 162,642 20.1 44,332 8.7 75,990 6.4

2020 183,101 12.6 50,140 13.1 79,333 4.4

2030 204,264 11.6 55,096 9.9 83,583 5.4

2040 228,993 12.1 60,813 10.4 89,160 6.7

2050 252,135 10.1 66,208 8.9 93,954 5.4

Sources: Population data for 1980–1990 (MCDC 2005); population data for 2000–2010 (USCB 2000, 2010); data 

forecasted from 2020 through 2030 (OSEDA and MCDC 2011); data calculated for 2040–2050

Demographic Profile

The 2010 demographic profiles of the three counties in the ROI are presented in Table 2–13. In 

2010, minorities (race and ethnicity combined) composed 16.9 percent of the total three-county 

population (USCB 2010). The minority population is largely Black or African-American 

(9.0 percent), with the next largest minority populations being Asian and Hispanic or Latino 

(2.6 percent) (USCB 2010).

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Table 2–13. Demographic Profile of the Population in the Callaway 

Three-County Socioeconomic ROI in 2010

Boone Callaway Cole Region of Influence

Total Population 162,642 44,332 75,990 282,964

Race (Not Hispanic or Latino) - percent of total population

White 81.0 91.0 83.2 83.1

Black or African American 9.2 4.5 11.1 9.0

American Indian and Alaska 

Native 0.3 0.5 0.3 0.3

Asian 3.8 0.5 1.3 2.6

Native Hawaiian and Other 

Pacific Islander 0.1 0.0 0.1 0.0

Some other race 0.2 0.1 0.1 0.1

Two or more races 2.5 1.7 1.6 2.2

Ethnicity

Hispanic or Latino 4,895 707 1,795 7,397

Percent of total population 3.0 1.6 2.4 2.6

Total minority 30,965 3,982 12,743 47,690

Percent minority 19.0 9.0 16.8 16.9

Source: USCB 2010

Transient Population 

Within 50 mi (80 km) of Callaway, colleges and recreational opportunities attract daily and 

seasonal visitors who create demand for temporary housing and services. In 2010, 

approximately 63,450 students attended colleges and universities within 50 mi (80 km) of 

Callaway (NCES 2012).

Migrant Farm Workers

Migrant farm workers are individuals whose employment requires travel to harvest agricultural 

crops. These workers may or may not have a permanent residence. Some migrant workers 

follow the seasonal harvesting of crops throughout rural areas of the United States. Other farm 

workers may be permanent residents near Callaway who travel from farm to farm to harvest 

crops.

Migrant workers may be members of minority or low-income populations. Because they travel 

and may spend a significant amount of time in an area without being actual residents, migrant 

workers may be unavailable for counting by census takers. If uncounted, these workers would 

be underrepresented in USCB minority and low-income population counts.

The Census of Agriculture defines migrant workers as farm workers whose employment 

required travel that prevented them from returning to their permanent place of residence on the 

same day. A total of 27 farms in the socioeconomic ROI reported hiring migrant workers in the 

2007 Census of Agriculture. Boone and Callaway Counties reported the most farms employing 

migrant workers (10 and 13, respectively), followed by Cole County (four farms) (NASS 2009).

The Census of Agriculture defines temporary farm workers as those workers hired to work for 

fewer than 150 days. According to the 2007 Census of Agriculture, 764 temporary farm workers 

were employed on 485 farms in the ROI. The county with the largest number of temporary farm 

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workers (433 temporary workers employed on 181 farms) was Boone County, followed by 

Callaway County (331 temporary workers employed on 158 farms) (NASS 2009). Data on the 

number of temporary farm workers employed on the 146 farms that hired temporary workers in 

Cole County and the 97 farms that hired temporary workers in Crawford County were withheld 

to avoid disclosure for individual farms (NASS 2009).

Table 2–14 gives information on temporary farm workers and migrant farm workers for the 

22 counties located entirely or partly within 50 mi (80 km) of Callaway.

Table 2–14. Migrant Farm Workers and Temporary Farm Workers in Counties 

Located Within 50 Mi of Callaway

County

Number of 

Farms With 

Hired Farm 

Workers

Number of 

Farms Hiring 

Workers for Less 

Than 150 Days

Number of Farm 

Workers Working 

for Less Than 

150 Days

Number of Farms 

Reporting 

Migrant Farm 

Workers

Boone 217 181 433 10

Callaway 188 158 331 13

Cole 158 146 Data Withheld 4

Cooper 176 139 277 3

Howard 133 109 284 8

Moniteau 255 219 549 7

Miller 166 143 334 15

Maries 166 144 292 8

Phelps 147 128 245 11

Crawford 108 97 Data Withheld 6

Franklin 254 215 437 18

St. Charles 150 67 126 6

Warren 112 78 276 8

Lincoln 165 135 301 9

Montgomery 148 118 208 5

Pike 171 136 324 13

Rails 117 101 190 1

Monroe 158 131 285 5

Randolph 135 118 325 4

Audrain 208 163 348 11

Osage 197 173 397 9

Gasconade 138 126 238 2

Total 3,667 3,025 6,200 176

Source: 2007 Census of Agriculture – County Data (NASS 2009) 

In 2010, 0.5 percent of all housing units in Boone County were considered temporary housing 

for seasonal, recreational, or occasional use (USCB 2010). During the same period, in 

Callaway County seasonal housing accounted for 3.1 percent of total housing units, and in Cole 

County seasonal housing accounted for 1.3 percent of total housing (USCB 2010). Table 2–15 

gives information on seasonal housing for the 22 counties located entirely or partly within 50 mi 

(80 km) of Callaway.

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Table 2–15. Seasonal Housing in Counties Located Within 50 Mi of Callaway

County Housing Units

Vacant Housing Units 

Available for Seasonal, 

Recreational, or 

Occasional Use Percent

Boone 69,551 380 0.5

Callaway 18,522 582 3.1

Cole 32,324 430 1.3

Cooper 7,463 70 0.9

Howard 4,582 114 2.5

Moniteau 6,176 66 1.1

Miller 12,758 1,264 9.9

Maries 4,611 324 7.0

Phelps 19,533 294 1.5

Crawford 11,955 1,061 8.9

Franklin 43,419 1,013 2.3

St. Charles 141,016 632 0.4

Warren 14,685 1,381 9.4

Lincoln 21,011 403 1.9

Montgomery 6,130 502 8.2

Pike 7,875 436 5.5

Rails 5,183 609 11.7

Monroe 4,798 618 12.9

Randolph 10,714 167 1.6

Audrain 10,852 83 0.8

Osage 6,533 532 8.1

Gasconade 8,205 991 12.1

Total 467,896 11,952 2.6

Source: USCB 2010 

2.2.9.6 Economy

This section contains a discussion of the economy of the ROI, including employment and 

income, unemployment, and taxes. 

Employment and Income

From 2000 to 2010, the civilian labor force in Boone County increased 17.7 percent, from 

77,099 to 90,748. During the same period, the civilian labor force in Callaway County increased 

12.2 percent, from 20,526 to 23,031, and the civilian labor force in Cole County increased 

3.1 percent, from 37,523 to 38,670 (USCB 2000, 2010). Major employers in Callaway County 

are identified in Table 2–16.

According to the 2008 to 2010 American Community Survey 3-Year Estimates, the educational, 

health, and social services industry employs the most workers in the socioeconomic ROI 

(31.1 percent), followed by retail trade (11.5 percent). A list of employment by industry in the 

ROI is presented in Table 2–17.

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Table 2–16. Major Employers in Callaway County

Company Name Type of Business

Number of 

Employees

Fulton State Hospital Healthcare - Hospital 1,490

AmerenUE Callaway Nuclear Plant Utilities - Power Generation 923

ABB Power T&D, Co. Manufacturing 850

Dollar General Distribution Center Distribution 650

Fulton Reception and Diagnostic Center Correctional Institution 450

Fulton Public Schools Education – Elementary/Secondary 450

Wal-Mart SuperCenter Retail – Discount Store 240

Source: Missouri Core 2009

Table 2–17. Employment by Industry in ROI

Industry Boone Callaway Cole Total Percent

Total employed civilian workers 84,918 21,597 36,791 143,306 100

Agriculture, forestry, fishing and 

hunting, and mining 685 543 389 1,617 1.1

Construction 4,230 1,834 2,394 8,458 5.9

Manufacturing 4,461 1,473 2,059 7,993 5.6

Wholesale trade 1,834 173 598 2,605 1.8

Retail trade 10,477 2,280 3,768 16,525 11.5

Transportation, warehousing, and 

utilities 2,423 1,347 1,513 5,283 3.7

Information 2,040 520 1,145 3,705 2.6

Finance, insurance, 

real estate, rental, and leasing 6,276 1,238 2,694 10,208 7.1

Professional, scientific, management, 

administrative, and waste management 

services

6,299 1,635 3,281 11,215 7.8

Educational, health, and social services 31,478 5,975 7,109 44,562 31.1

Arts, entertainment, recreation, 

accommodation, and food services 7,859 1,440 2,469 11,768 8.2

Other services (except public 

administration) 3,368 801 1,863 6,032 4.2

Public administration 3,488 2,338 7,509 13,335 9.3

Source: USCB 2010: 2008–2010 American Community Survey 3-Year Estimates

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Estimated income information for the socioeconomic ROI is presented in Table 2–18. 

According to the U.S. Census Bureau, Callaway and Cole Counties had higher median 

household incomes than the State average, while Boone and Cole Counties had higher per 

capita incomes than the State average (USCB 2010). An estimated 19.4, 9.4, and 9.2 percent 

of the population in Boone, Callaway, and Cole Counties, respectively, were living below the 

official poverty level. The State of Missouri as a whole had a higher percentage of persons 

living below the poverty level (14.5 percent) than Callaway and Cole Counties, but the 

percentage was lower than in Boone County. The percentage of families living below the 

poverty level in Boone, Callaway, and Cole Counties (10.1, 6.9, and 6.5 percent, respectively) 

was lower than the State of Missouri average (10.2 percent) (USCB 2010).

Table 2–18. Estimated Income Information for the Callaway ROI

Boone Callaway Cole Missouri

Median household income (dollars) a 45,227 51,110 55,151 45,829

Per capita income (dollars) a 25,078 23,092 25,694 24,496

Individuals living below the poverty level 

(percent) 19.4 9.4 9.2 14.5

Families living below the poverty level 

(percent) 10.1 6.9 6.5 10.2

a in 2010 inflation-adjusted dollars

Source: USCB 2010 (2008-2010 American Community Survey 3-Year Estimates) 

Unemployment

According to the Bureau of Labor Statistics, unemployment rates in Boone, Callaway, and Cole 

Counties were 7.3, 7.5, and 9.3 percent, respectively, in 2011. During the same period, the 

State’s overall unemployment rate was 8.6 percent (Missouri DOLIR 2012a, 2012b).

Taxes

All privately owned property in Missouri is subject to taxation by the county and school district in 

which it is located, unless specifically exempted by the Missouri Constitution. Most private 

property owners in Missouri also pay property taxes to local jurisdictions (e.g., cities and special 

districts) within whose boundaries they reside. Consequently, property tax revenues are the 

major source of tax revenue for counties and cities and the sole source of tax revenue for 

school districts. Exemptions from these standard practices are governed by the State. County 

appraisal districts determine the value of properties, and local jurisdictions set the tax rates. 

After an assessment, private property owners make a consolidated payment to the county tax 

assessor, who retains the county’s portion and distributes funds to the special districts as 

appropriate. From 2004 through 2011, Callaway County collected between $29.3 and 

$36.2 million annually in property tax revenues (see Table 2–19) (Ameren 2011d; Callaway 

County 2012a). Each year, Callaway County collects these taxes and disburses them to, 

among others, the county school districts, the Callaway County General Fund, road and bridge 

maintenance funds, several fire districts, the county library, several municipalities, the county 

ambulance service, a handicapped/sheltered workshop, and the State of Missouri. The majority 

of Ameren’s payment goes to the South Callaway County R-II School District, which has a tax 

rate of 2.75 percent (Callaway County 2012b). Generally, for the years 2004 through 2011, the 

property taxes paid by Callaway have remained relatively constant and have represented 26.6 

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to 30.6 percent of Callaway County’s total property tax revenues (Ameren 2011d; Callaway 

County 2012a).

Table 2–19. Comparison of Ameren Missouri Property Tax Payments for Callaway as a 

Percentage of Callaway County Property Tax Revenues (2004–2011)

Year Callaway County Tax 

Revenues ($ millions)

Payments

($ millions)

Percent of County Property 

Tax Revenue

2004 29.3 8.9 30.4

2005 30.7 9.4 30.6

2006 30.5 8.7 28.5

2007 31.8 8.5 26.6

2008 32.8 8.9 27.2

2009 34.0 9.8 28.8

2010 35.3 10.2 28.9

2011 36.2 10.7 29.6

Sources: Callaway County 2010, 2012a, and 2012b.

Table 2–20 presents tax data for the South Callaway County R-II School District. From 

2004 through 2010, Callaway County collected $9.7 to $10.4 million annually in property tax 

revenues for the South Callaway County R-II School District (Ameren 2011d; MDESE 2012). 

For the same years, Callaway property taxes represented 58.3 to 64.7 percent of the South 

Callaway County R-II School District’s total property tax revenues (Ameren 2011d; 

MDESE 2012).

Table 2–20. South Callaway County R-II School District Tax Information (2004–2010)

Year

South Callaway County 

R-II School District 

Property Tax Revenues 

($ millions)1

Callaway

Portion of Ameren Property 

Tax Payment Forwarded to 

South Callaway R-II School 

District ($ millions)

Percent of South 

Callaway County R-II 

School District Property 

Tax Revenues

2004 9.7 6.0 62.2

2005 10.3 6.4 62.0

2006 10.0 5.9 58.5

2007 10.2 5.9 58.3

2008 10.3 6.3 60.6

2009 10.4 6.4 61.1

2010 10.2 6.6 64.7

Sources: Ameren 2011d; Callaway County 2012b; MDESE 2012

In addition to tax payments made to Callaway County, Ameren makes support payments to the 

State Emergency Management Agency (SEMA) and other counties within the 50 mi (80 km) 

emergency planning zone. In 2011, SEMA received approximately $266,000 out of a total of 

$1.3 million to be paid by Ameren between September 2011 and July 2013. During the same 

year, Callaway County received support payments totaling $260,000, while Osage, 

Montgomery, and Gasconade Counties each received $48,000 (Ameren 2012d).

The State of Missouri has not taken action in the last several years with respect to utility 

deregulation; therefore, the potential effects of deregulation are currently unknown. Ameren’s 

tax payments for Callaway could be affected if utilities are deregulated in Missouri. Any 

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changes to the property tax rates for Callaway caused by deregulation would be independent of 

license renewal (Ameren 2011d).

2.2.10 Historic and Archaeological Resources

This section discusses the cultural background and the known historic and archaeological 

resources at Callaway and in the surrounding area. The discussion is based on a review of 

reports for cultural resources investigations conducted within the Ameren property and the 

Callaway site that are on file at the Missouri State Historic Preservation Office (SHPO), as well 

as other background information for historic and archaeological resources within or near the 

Callaway site.

2.2.10.1 Cultural Background

Human occupation in the vicinity of the Callaway site is generally characterized according to the 

following chronological sequence (MAS 2011):

 Paleo-Indian Period (12,000 to 10,000 years before present (BP)),

 Archaic Period (10,000 to 3,000 BP),

 Woodland Period (3,000 BP to 1,100 BP (ca. anno Domini (A.D.) 900)),

 Mississippian Period (ca. A.D. 900 to 1600), and

 Protohistoric/Historic Period (ca. A.D. 1600 to present).

Paleo-Indian Period (12,000 to 10,000 BP)

The earliest evidence of people living in Missouri dates to the Paleo-Indian Period. Paleo-Indian 

sites are generally found upland or on river terraces and are characterized by specific types of 

projectile points (i.e., fluted Clovis points) and stone tools such as gravers, scrapers, or large 

blades. These artifacts often occur in association with mastodon remains, suggesting a reliance 

on megafauna (e.g., mammoth, ground sloth, and saber-tooth tiger) for subsistence, along with 

plants, small game, birds, and amphibians. Social organization consisted of small, highly 

nomadic bands of hunter-gathers, leaving Paleo-Indian sites with little detailed archaeological

information (American Resources Group, Ltd. 1984, 1985; MACTEC 2007b, 2008, 2009).

In Missouri, a distinct cultural tradition appeared in the transition from the Paleo-Indian to 

Archaic cultural periods: the Dalton Complex. Lasting approximately 1,000 years, from 10,000 

to 9,000 BP, the overall settlement pattern of this period remained nomadic; settlement appears 

to be influenced by modern climatic conditions rather than glacial conditions. Archaeological 

sites tend to be located in areas that crosscut major resource zones, suggesting a change in 

subsistence strategies from primarily hunting large mammals to hunting smaller mammals, 

gathering plant resources, and exploiting marine resources such as mussels. Artifact 

assemblages from Dalton sites are characterized by distinct narrow, oval-shaped, unfluted 

projectile points (American Resources Group, Ltd. 1984, 1985; MACTEC 2007b, 2008, 2009).

Archaic Period (10,000 to 3,000 BP)

The Archaic Period was a time of major climatic shifts as colder environments transitioned to 

warmer environments similar to modern conditions. In response to this shift, new technologies 

and subsistence strategies were developed during this time. The Archaic Period is often divided 

into early, middle, and late subperiods. The Early Archaic Period is characterized by a shift 

from nomadic to sedentary settlement patterns, with central base camps located on river 

terraces and smaller hunting camps located in upland areas. This subperiod also shows an 

increased reliance on wild plant foods, small game, and aquatic resources. The Middle Archaic 

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Period is characterized by an increased number of settlement sites on high stream terraces, 

which may reflect population increases. While subsistence and settlement patterns remained 

fairly similar to the Early Archaic Period, artifact assemblages suggest increased exploitation of 

aquatic resources. Also in evidence are new artifacts such as pecked and ground stone tools,

used for intensive processing of nuts; banner stones that signaled the innovation of a new 

projectile technology called the atlatl, or spear-thrower; and grooved axes. The Late Archaic 

Period is characterized by an increase in the number and size of settlement sites, which 

indicates an increase in population and a more sedentary lifestyle. New features of Late 

Archaic artifact assemblages, such as crude ceramic vessels, represent a shift towards 

increased reliance on horticulture as a subsistence strategy, although hunting and gathering 

would have continued (American Resources Group, Ltd. 1984, 1985; MACTEC 2007b, 2008, 

2009).

Woodland Period (3,000 BP to 1,100 BP (ca. A.D. 900))

The Woodland Period is also often divided into early, middle, and late periods. Early Woodland 

Period sites are not well represented in the archaeological record for Missouri; however, where 

present, they tend to be large base camps located in major river valleys, with smaller logistical 

camp sites located on terraces of smaller water bodies. While Early Woodland Period 

subsistence appears to have relied on hunting and gathering, there is evidence for cultivating 

plants such as sunflowers and cucurbits (i.e., squashes, gourds, melons, etc.). During the 

Middle Woodland Period, the large and complex Hopewell Culture emerged in the 

United States, including Missouri. This culture is characterized by settlement in villages, 

increased reliance on intensive horticulture, burial mounds, and long-distance trade networks. 

These long-distance networks allowed the trade of exotic materials far outside their original 

locations, such as marine shells from the Gulf Coast, obsidian from the Rocky Mountains, 

copper from Lake Superior, and mica from the Appalachian Mountains. Middle Woodland 

artifact assemblages are dominated by ceramics, suggesting an increased reliance on cultivated 

plants. The Late Woodland Period is characterized by an increase in settlement sites, which 

suggests a rise in population, a change in settlement patterns from large, centralized village 

sites to smaller, dispersed habitation sites, or both. Late Woodland Period artifact assemblages 

are characterized by an increase in thin-walled plain ceramic types and stemmed and 

side-notched projectile points. The sudden appearance of very small, thin triangular projectile 

points between 1,300 and 1,400 BP indicates the invention of bow-and-arrow technology and 

suggests a corresponding change in hunting techniques (American Resources Group, 

Ltd. 1984, 1985; MACTEC 2007b, 2008, 2009).

Mississippian Period (ca. A.D. 900 to 1600)

The Mississippian Period is characterized by major changes in settlement, subsistence patterns, 

and social structure. Large, highly centralized permanent settlements supported by many 

satellite villages emerged during this period. The archaeological record associated with these 

settlements suggests they were organized as chiefdoms with considerable social stratification. 

A new type of ceremonial earthen mound, the platform mound, appeared in association with 

these permanent settlements. Platform mounds, burial mounds, and defensive structures such 

as moats and palisades were often constructed in clusters in settlements of this period and were 

common in the larger river valleys of the Midwest, particularly the central and lower Mississippi 

River valley. Mississippian Period subsistence relied heavily on maize agriculture, as well as 

hunting and gathering. Craft specialists appeared in the social structure of the Mississippian 

Period, producing highly specialized lithic and ceramic artifacts, beadwork and shell pendants. 

In addition to these specialized artifacts, characteristic Mississippian Period artifacts include 

small triangular, side-notched and bi-pointed projectile points and slipped and painted pottery 

(American Resources Group, Ltd. 1984, 1985; MACTEC 2007b, 2008, 2009).

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Protohistoric/Historic Period (A.D. 1600 to present)

The end of the Mississippian Period is characterized by severe social, political, and 

demographic changes that resulted from indirect and direct contact with Europeans. In 

particular, it is believed that the introduction of European infectious diseases such as smallpox, 

yellow fever, typhoid, and influenza severely decimated Native American populations, which had 

no immunity to these diseases. The spread of these diseases, which were fatal to large 

numbers of Native Americans, resulted in the widespread abandonment of villages and a 

concurrent collapse of Native American socioeconomic networks, such that by the time of 

widespread European contact and settlement, the Mississippian chiefdoms were gone 

(American Resources Group, Ltd. 1984, 1985; MACTEC 2007b, 2008, 2009).

The Missouri and Osage tribes have been documented as occupying Missouri immediately 

before major European exploration of the Middle Mississippi River basin in the late 17th century. 

However, these tribes were eventually removed from their lands as a result of expanding 

westward exploration and settlement by Europeans and Americans of European descent 

(Euro-Americans). Tribes that had traditionally occupied lands east of Missouri, such as the 

Pottawatomie, Miami, Kickapoo, Iowa, Sauk, Fox, Delaware, Shawnee, and Illinois, were 

experiencing the same pressures from westward Euro-American expansion, and briefly settled 

in Missouri as they, too, were removed from their lands (American Resources Group, Ltd. 1984, 

1985). 

The first major European expedition to Missouri was conducted by French Catholic missionaries 

sometime in the late 17th to early 18th centuries (MACTEC 2007b, 2008, 2009). Missouri (then 

called Upper Louisiana) was seen by the French as a place for new economic opportunity, and 

they established St. Louis as a center for fur trade in the area. By 1719, most of the interior of 

Missouri had been explored for fur trade and exploitation of mineral resources such as silver 

and lead. While Spain gained control over eastern Missouri between 1763 and 1803, followed 

by a brief return to ownership by the French under Napoleon, Missouri became part of the 

United States in 1821. Historically, eastern Missouri retained a primarily French character that 

was later supplanted by Euro-Americans and, to a smaller degree, German immigrants 

(MACTEC 2007b, 2008, 2009).

Euro-American settlement of eastern Missouri began under Spanish control and grew after the 

Louisiana Purchase in 1803. The steamboat, developed in the 1820s, facilitated water 

transportation along ports on the Mississippi River. Settlement of the interior of Missouri was 

further encouraged by railroad construction during the 1830s. Early Euro-American subsistence 

in Missouri focused on processing local raw materials into finished goods for local consumption, 

mostly done at the household level or in small, locally operated mills. However, the St. Louis 

area eventually attracted most manufacturing activities in Missouri in the mid-19th century, 

including processing resources and manufacturing materials such as flour and meal, sawed 

lumber, tobacco, machinery, cordage, malt and distilled liquors, and metals and metal goods 

(MACTEC 2007b, 2008, 2009).

Consistent with the historic settlement of Missouri, the first permanent European settlement of 

Callaway County, Cote Sans Dessein, was established in 1808 by French-Canadian trappers 

who had relocated from St. Louis. The settlement was founded at the convergence of the 

Missouri and Osage Rivers, southwest of the Callaway site, to control river-based trade and 

access trading networks with local Native American groups. Euro-American settlement in 

Callaway County increased with construction of Boone’s Lick Road in 1815 across the northern 

portion of the county, providing direct overland access into interior portions of the county. The 

influx of Euro-American settlers resulted in the establishment of new towns, including the Town 

of Reform, now within the boundaries of the Ameren property, and the community of Elizabeth 

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(now Fulton) to the northwest of the Callaway site (UEC 1978; American Resources Group, 

Ltd. 1981a, 1981b).

Farming continued to be the primary economic activity in Callaway County throughout the 19th 

and into the 20th century. By the late 1890s, industrial activities began to increase, and the 

town of Fulton had developed into a local center of economic growth by the beginning of the 

20th century. Steamboat traffic along the Mississippi River and statewide railroad networks 

increased trade and development in Callaway County, allowing the formation of river port towns 

east of the Callaway site. During the Civil War, Callaway County residents supported the 

Confederates, though the town of Fulton was occupied by Union troops for most of the war. 

In the first half of the 20th century, population in the county began to decline as people moved 

from rural to urban communities. However, agriculture continues to be the economic basis of 

the county (MACTEC 2007b, 2008, 2009).

The area surrounding the Callaway site remained rural farmland until it was acquired by UEC 

(the owner of Callaway before Ameren) in the 1970s and Callaway was constructed. The 

approximately 7,354-ac (2,976-ha) property containing the Callaway site is owned by Ameren. 

Callaway’s facilities are located within a 512-ac (207-ha) area of the Ameren property that is 

enclosed by a fence. The fenced area is managed by Ameren. The remaining areas of the 

Ameren property are managed by the MDC as the Reform Conservation Area (Ameren 2011d; 

CCSM 2011).

2.2.10.2 Historic and Archaeological Resources

A review of databases maintained by the National Park Service indicates that 17 properties 

listed in the National Register of Historic Places (NRHP) are located within Callaway County, 

including 2 that have been designated National Historic Landmarks (NHLs) (National Trails 

System Act (P.L. 90-543); NPS 2012b). These historic properties reflect the prehistoric and 

historic cultural contexts of the Ameren property and include prehistoric archaeological sites, 

historic archaeological sites, and historic buildings, structures, and districts dating from the 

mid-18th through mid-20th centuries. However, none of the 17 historic properties is located 

within the boundaries of the Callaway site; the nearest NRHP-listed historic property is 

approximately 1 mi (1.6 km) from Callaway.

A portion of an additional cultural resource, the approximately 3,700-mi (6,000-km) long Lewis 

and Clark National Historic Trail, is also located in Callaway County, south of the Callaway site 

(LCTHF 2009a, 2009b; National Trails System Act). This trail reflects the path taken by the 

Lewis and Clark Expedition of 1804–1806 to explore the Missouri River in an effort to find a 

passage to the Pacific Ocean. The Lewis and Clark National Historic Trail was designated to 

protect the historic route and its historic remnants and artifacts for public use, and it follows as 

closely as practicable the original trails or routes of travel of national historic significance 

(NPS 2012c).

A portion of the Katy Trail is also located in Callaway County. The Katy Trail is a 200-mi 

(321-km) long rails-to-trails project developed by MDNR and operated as a State park 

(MDNR 2012b; RTC 2007). The biking and hiking trail follows the bed of the former 

Missouri-Kansas-Texas (M-K-T, or ‘Katy’) railroad, located along the northern edge of the 

floodplain of the Missouri River. The portion of the Katy Trail that is south of the Callaway site 

has also been designated an official segment of the Lewis and Clark National Historic Trail 

(MDNR 2012b).

The Ameren property, including the Callaway site and the area managed by the MDC, has been 

subject to previously conducted cultural resources investigations and consultations with the 

Missouri SHPO. In addition to the historic properties and cultural resources identified above for 

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Callaway County, research at the Missouri SHPO confirmed that a total of 129 previously 

identified cultural resources are located on Ameren property, as reported in Ameren’s ER for 

Callaway (Ameren 2011d; Missouri SHPO 2012). Of these, 108 are archaeological sites and 

21 are architectural resources. Of the 108 archaeological sites, 79 are prehistoric, 28 are 

historic and one is multicomponent (prehistoric and historic). All of the 21 architectural 

resources are dated to between the mid-19th to early 20th centuries (Missouri SHPO 2012).

A total of 104 historic and architectural resources have been recommended not eligible for 

listing in the NRHP (57 prehistoric and 26 historic archaeological sites, and all of the 

21 architectural resources). The remaining 25 archaeological resources have been determined 

eligible, or potentially eligible, for listing in the NRHP. Table 2–21 lists the 25 NRHP-eligible or 

potentially eligible archaeological resources identified on the Ameren property. 

Twenty-two archaeological resources (19 prehistoric sites, 2 historic sites, and 

1 multicomponent site (prehistoric and historic)) were recommended as potentially 

NRHP-eligible but have not been subject to Phase II site evaluations. The remaining three 

archaeological sites (23CY20, 23CY352, and 23CY359) have been subject to Phase II site 

evaluations and have been recommended eligible for inclusion in the NRHP. Site 23CY20 was 

identified on Ameren property. The other two NRHP-eligible archaeological sites (23CY352 and 

23CY359) were identified within transmission line ROWs.

Site 23CY20 is described as an occupation site likely used as a camp for relatively short periods 

of time in the Late Archaic, and in the Middle and Late Woodland periods to obtain specific food 

resources. Site 23CY352 is described as a large residential or village site that was occupied for 

long periods of time from the end of the Middle Woodland period through the end of the Late 

Woodland Period, with evidence of gardening, fishing, and hunting activities. Site 23CY359 is 

described as a multi-component site containing prehistoric era material. The site was occupied 

repeatedly for short periods of time during the Early and Middle Archaic periods and the Middle 

and Late Woodland periods, likely for obtaining seasonal food resources (American Resources 

Group, Ltd. 1985).

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Table 2–21. NRHP-Eligible or Potentially Eligible Historic or Archaeological Resources 

on the Ameren Property

Site Number Type NRHP Eligibility 

Recommendation Status

23CY20

Prehistoric 

archaeological site 

(Later Archaic, Middle 

Woodland, Late 

Woodland)

Eligible

Phase II was conducted 

on site. Site is 

managed for 

preservation.

23CY74

Prehistoric 

archaeological site 

(Middle or Late 

Woodland)

Potentially eligible

Site is managed for 

preservation; a Phase II 

would be necessary if 

the site is threatened.

23CY256

Prehistoric 

archaeological site 

(Middle Archaic)

Potentially eligible

Site is managed for 

preservation; a Phase II

would be necessary if 

the site is threatened

23CY257

Multi-component 

archaeological site (Late 

Archaic and Historic 

(unspecified time 

period))

Potentially eligible

Site is managed for 

preservation; a Phase II 

would be necessary if 

the site is threatened.

23CY261

Historic archaeological

site (unspecified time 

period)

Potentially eligible

Site is managed for 

preservation; a Phase II 

would be necessary if 

the site is threatened.

23CY267

Prehistoric 

archaeological site 

(Paleo-Indian)

Potentially eligible

Site is managed for 

preservation; a Phase II 

would be necessary if 

the site is threatened.

23CY291

Prehistoric 

archaeological site 

(unidentified cultural 

period)

Potentially eligible

Site is managed for 

preservation; a Phase II 

would be necessary if 

the site is threatened.

23CY303

Prehistoric 

archaeological site 

(Early Archaic)

Potentially eligible

Site is managed for 

preservation; a Phase II 

would be necessary if 

the site is threatened.

23CY304

Prehistoric 

archaeological site (Late 

Woodland/Mississippian)

Potentially eligible

Site is managed for 

preservation; a Phase II 

would be necessary if 

the site is threatened.

23CY309

Prehistoric 

archaeological site (Late 

Archaic)

Potentially eligible

Site is managed for 

preservation; a Phase II 

would be necessary if 

site is threatened.

23CY314

Prehistoric 

archaeological site 

(unidentified cultural 

period)

Potentially eligible

Site is managed for 

preservation; a Phase II 

would be necessary if 

the site is threatened.

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Site Number Type NRHP Eligibility 

Recommendation Status

23CY321

Prehistoric 

archaeological site 

(unidentified cultural 

period)

Potentially eligible

Site is managed for 

preservation; a Phase II 

would be necessary if 

the site is threatened.

23CY322

Prehistoric 

archaeological site (Late 

Woodland/Mississippian)

Potentially eligible

Site is managed for 

preservation; a Phase II 

would be necessary if 

the site is threatened.

23CY328

Prehistoric 

archaeological site 

(unidentified cultural 

period)

Potentially eligible

Site is managed for 

preservation; a Phase II 

would be necessary if 

the site is threatened.

23CY334

Prehistoric 

archaeological site 

(unidentified cultural 

period)

Potentially eligible

Site is managed for 

preservation; a Phase II 

would be necessary if 

the site is threatened.

23CY339

Historic archaeological

site (unspecified time 

period)

Potentially eligible

Site is managed for 

preservation; a Phase II 

would be necessary if 

the site is threatened.

23CY345

Prehistoric 

archaeological site 

(Middle Archaic)

Potentially eligible

Site is managed for 

preservation; a Phase II 

would be necessary if 

the site is threatened.

23CY346

Prehistoric 

archaeological site 

(Dalton)

Potentially eligible

Site is managed for 

preservation; a Phase II 

would be necessary if 

the site is threatened.

23CY349

Prehistoric 

archaeological site 

(unidentified cultural 

period)

Potentially eligible

Site is managed for 

preservation; a Phase II 

would be necessary if 

the site is threatened.

23CY350

Prehistoric 

archaeological site (Late 

Woodland)

Potentially eligible

Site is managed for 

preservation; a Phase II 

would be necessary if 

the site is threatened.

23CY351

Prehistoric 

archaeological site 

(unidentified cultural 

period)

Potentially eligible

Site is managed for 

preservation; a Phase II 

would be necessary if 

the site is threatened.

23CY352

Prehistoric 

archaeological site 

(Middle and Late 

Woodland)

Eligible

A Phase II was 

conducted on site. Site 

is managed for 

preservation.

23CY353

Prehistoric 

archaeological site 

(Middle-Late Archaic, 

Late Woodland)

Potentially eligible

Site is managed for 

preservation; a Phase II 

would be necessary if 

the site is threatened.

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Site Number Type NRHP Eligibility 

Recommendation Status

23CY356

Prehistoric 

archaeological site 

(Middle Archaic, Late 

Woodland)

Potentially eligible

Site is managed for 

preservation; a Phase II 

would be necessary if 

the site is threatened.

23CY359

Prehistoric 

archaeological site 

(Early and Middle 

Archaic, Middle and Late 

Woodland)

Eligible

A Phase II was 

conducted on site. Site 

is managed for 

preservation.

Source: Missouri SHPO 2012

2.3 Related Federal and State Activities

The NRC staff assessed the possibility that activities of other Federal agencies might affect the 

renewal of the operating license for Callaway. Any such activity could result in cumulative 

environmental effects and the possible need for a Federal agency to become a cooperating 

agency in the preparation of the NRC’s SEIS for Callaway. There are no Federal projects that 

would make it necessary for another Federal agency to become a cooperating agency in the 

preparation of this SEIS.

There are no known Native American lands within 50 mi (80 km) of Callaway (NPS 2012a). The 

NRC is required, under Section 102(2)(c) of the National Environmental Policy Act

(42 U.S.C. 4321 et seq.), to consult with and obtain the comments of any Federal agency that 

has jurisdiction by law or special expertise with respect to any environmental effect involved. 

The NRC has consulted with the FWS and the State of Missouri SHPO. Federal Agency 

consultation correspondence is presented in Appendix D.

2.4 References

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

protection against radiation.”

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic licensing of 

production and utilization facilities.” 

10 CFR Part 61. Code of Federal Regulations, Title 10, Energy, Part 61, “Licensing 

requirements for land disposal of radioactive waste.” 

10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, “Packaging and 

transportation of radioactive material.” 

40 CFR Part 81. Code of Federal Regulations, Title 40, Protection of Environment, Part 81, 

“Designation of areas for air quality planning purposes.”

40 CFR Parts 239–299. Code of Federal Regulations, Title 40, Protection of Environment, 

Parts 239 to 299, the Resource Conservation and Recovery Act regulations.

50 CFR Part 10. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 10, “General 

Provisions,” Section 10.12, “Definitions.”

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50 CFR Part 22. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 22, “Eagle 

Permits,” Section 22.3, “Definitions.”

50 CFR Part 402. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 402, 

“Interagency Cooperation-Endangered Species Act of 1973, as amended,” Section 402.02, 

“Definitions.”

3 CSR 10-4.111. Missouri Code of State Regulations, Title 10, Department of Conservation. 

Division 10, “Conservation Commission,” Chapter 4, “Wildlife Code: General Provisions.”

4 CSR 240-23.020. Missouri Code of State Regulations, Title 4, Department of Economic 

Development, Division 240, “Public Service Commission,” Chapter 23, “Electric Utility 

Operational Standards,” Subchapter 20, “Electrical Corporation Infrastructure Standards.”

10 CSR 20–7.031. Missouri Code of State Regulations, Title 10, Department of Natural 

Resources, Division 20, “Clean Water Commission,” Chapter 7, “Water Quality Standards.”

10 CSR 25. Missouri Code of State Regulations, Title 10, Department of Natural Resources,

Division 25, “Hazardous Waste Management Commission.”

10 CSR 26. Missouri Code of State Regulations, Title 10, Department of Natural Resources,

Division 26, “Petroleum and Hazardous Substance Storage Tanks.” 

10 CSR 80. Missouri Code of State Regulations, Title 10, Department of Natural Resources,

Division 80, “Solid Waste Management.” 

32 FR 4001. U.S. Fish and Wildlife Service. “Endangered Species.” Federal 

Register 32(48):4001. March 11, 1967.

41 FR 17736. U.S. Fish and Wildlife Service. “Determination that Two Species of Butterflies are 

Threatened Species and Two Species of Mammals are Endangered Species.” Federal 

Register 41(83):17736-17740. April 28, 1976.

41 FR 24062. U.S. Fish and Wildlife Service. “Endangered and threatened wildlife and plants; 

endangered status for 159 taxa of animals.” Federal Register 41(115):24062–24067. 

June 14, 1976.

41 FR 41914. U.S. Fish and Wildlife Service. “Determination of critical habitat for American 

crocodile, California condor, Indiana bat, and Florida manatee.” Federal 

Register 41(187):41914-41916. September 24, 1976.

50 FR 24649. U.S. Fish and Wildlife Service. “Endangered and threatened wildlife and plants; 

determination of threatened status and critical habitat for the Niangua darter (Etheostoma 

nianguae).” Federal Register 50(113):24649–24654. June 12, 1985. 

52 FR 21478. U.S. Fish and Wildlife Service. “Endangered and threatened wildlife and plants; 

determination of endangered status for Trifolium stoloniferum (running buffalo clover).” Federal 

Register 52(108):21478–21481. June 5, 1987.

55 FR 36641. U.S. Fish and Wildlife Service. “Endangered and threatened wildlife and plants; 

determination of endangered status for the pallid sturgeon.” Federal 

Register 55(173):36641–36647. September 6, 1990.

63 FR 31268. U.S. Environmental Protection Agency. “Emergency planning and community 

right-to-know programs; amendments to hazardous chemical reporting thresholds, streamlining 

requirements.” Federal Register 63(109):31268–31217. June 8, 1998.

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63 FR 69008. U.S. Fish and Wildlife Service. “Endangered and threatened wildlife and plants; 

final rule to list the Topeka shiner as endangered.” Federal Register 63(240):69008–69021. 

December 15, 1998.

66 FR 51322. U.S. Fish and Wildlife Service. “Endangered and threatened wildlife and plants; 

determination of endangered status for the scaleshell mussel.” 

Federal Register 66(195):51322–51339. October 9, 2001.

75 FR 9282. U.S. Fish and Wildlife Service. “50 CFR Parts 10 and 21, general provisions; 

migratory birds, revised list and permits; final rules.” Federal Register 75(39):9282. 

March 1, 2010.

75 FR 17758. U.S. Fish and Wildlife Service. “Approved recovery plan for the scaleshell 

mussel.” Federal Register 75(66):17758–17760. April 7, 2010.

77 FR 14913. U.S. Fish and Wildlife Service. “Endangered and threatened wildlife and plants; 

determination of endangered status for the sheepnose and spectaclecase mussels throughout 

their range; final rule.” Federal Register 77(49):14913–14949. March 13, 2012.

78 FR 37282. U.S. Nuclear Regulatory Commission. “Revisions to environmental review for 

renewal of nuclear power plant operating licenses.” Federal Register 78(119):37282–37324. 

June 20, 2013.

16 U.S.C. 1531 et seq. U.S. Congress. Endangered Species Act. December 28, 1973.

[AFS] American Fisheries Society. 2012. “Montana’s Fish Species of Special Concern – Pallid 

Sturgeon.” Available at 

<http://www.fisheriessociety.org/AFSmontana/SSCpages/Pallid%20status.htm> (accessed 

6 July 2012).

Ameren and the Conservation Commission of the State of Missouri. 2009. Management 

Agreement for the Public Use of Lands, Reform Conservation Area Plan, 2006–2016. 

[Ameren] Ameren Missouri. 2007a. Ameren Transmission Vegetation Management Program.

Fulton, MO: Ameren. 2007. Agencywide Documents Access and Management System 

(ADAMS) No. ML12244A575.

[Ameren] Ameren Missouri. 2007b. 2006 Annual Radiological Environmental Operating Report. 

Fulton, MO: Ameren. April 30, 2007. ADAMS Nos. ML071230726.

[Ameren] Ameren Missouri. 2008a. 2007 Annual Radiological Environmental Operating Report. 

Fulton, MO: Ameren. April 30, 2008. ADAMS Nos. ML081300232, ML081300233, and 

ML081300236.

[Ameren] Ameren Missouri. 2008b. Emissions Inventory Questionnaire for 2007. St. Louis, MO: 

Ameren. May 27, 2008. ADAMS No. ML12271A442.

[Ameren] Ameren Missouri. 2008c. Letter from Mr. Luke H. Graessle, Ameren, to Mr. Robert K. 

Morrison, MDNR; Subject: Callaway Plant Groundwater Monitoring Program, dated 

October 8, 2008. Adams No. ML083150703

[Ameren] Ameren Missouri. 2008d. Missouri Department of Natural Resources Water 

Resources Center, Major Water Use Registration Form. Water Year 2008. ADAMS 

No. ML12271A472.

[Ameren] Ameren Missouri. 2009a. Callaway Plant Unit 2 Combined License Application – 

Part 3: Environmental Report. Revision 1. February 25, 2009. ADAMS No. ML090710402.

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[Ameren] Ameren Missouri. 2009b. Callaway Plant Unit 2 Combined License Application – 

Part 2: Final Safety Analysis Report, Revision 2, Section 02.04. March 27, 2009. ADAMS 

No. ML090710344.

[Ameren] Ameren Missouri. 2009c. 2008 Annual Radiological Environmental Operating Report. 

Fulton, MO: Ameren. April 30, 2009. ADAMS Nos. ML12208A310 and ML092040384.

[Ameren] Ameren Missouri. 2009d. Emissions Inventory Questionnaire for 2008. St. Louis, MO: 

Ameren. May 26, 2009. ADAMS No. ML12271A459.

[Ameren] Ameren Missouri. 2010a. 2009 Annual Radiological Environmental Operating Report. 

Fulton, MO: Ameren. April 29, 2010. ADAMS No. ML101230142.

[Ameren] Ameren Missouri. 2010b. Emissions Inventory Questionnaire for 2009. St. Louis, MO: 

Ameren. May 14, 2010. ADAMS No. ML12271A460.

[Ameren] Ameren Missouri. 2010c. Callaway Plant Unit 1, Final Safety Analysis Report, 

Standard Plant and Site Addendum, Revision OL–18, and Technical Specification Bases, 

Revision 9. Fulton, MO: Ameren. December 10, 2010. ADAMS No. ML103470201.

[Ameren] Ameren Missouri. 2010d. Letter from S Maglio, Regulatory Affairs Manager, to the 

NRC. Subject: Revised NPDES Discharge Permit. May 7, 2010, ADAMS No. ML101310076.

[Ameren] Ameren Missouri. 2011a. 2010 Annual Radiological Environmental Operating Report 

for the Callaway Plant. ULNRC–05785. April 29, 2011. ADAMS No. ML111220243.

[Ameren] Ameren Missouri. 2011b. Emissions Inventory Questionnaire for 2010. St. Louis, MO: 

Ameren. April 27, 2011. ADAMS No. ML12271A461.

[Ameren] Ameren Missouri. 2011c. Facility Summary Reports (quarterly) for 2010. Fulton, MO: 

Ameren. Quarterly reports dated May 13, 2010; August 6, 2010; November 15, 2010; and 

January 31, 2011. ADAMS No. ML12271A463.

[Ameren] Ameren Missouri. 2011d. License Renewal Application, Callaway Plant Unit 1, 

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Ameren. December 15, 2011. ADAMS Nos. ML113540349, ML113540352, and ML113540354.

[Ameren] Ameren Missouri. 2011e. Tier Two Emergency and Hazardous Chemical Inventory for 

2010. St. Louis, MO: Ameren. Not specifically dated. ADAMS No. ML12271A466.

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Inc. Fulton, MO: Ameren. Docket Number 50–483, Callaway Plant Unit 1, Union Electric Co.,

Facility Operating License NPF-30. April 27, 2012. ADAMS Nos. ML12121A029 and 

ML13119A142. 

[Ameren] Ameren Missouri. 2012b. Callaway Energy Center Radioactive Waste Management 

Plan. Fulton, MO: Ameren. Revision 4, May 2012. ADAMS No. ML12271A468.

[Ameren] Ameren Missouri. 2012c. Emissions Inventory Questionnaire for 2011. St. Louis, MO: 

Ameren. April 25, 2012. ADAMS No. ML12271A462.

[Ameren] Ameren Missouri. 2012d. Facility Summary Reports (quarterly) for 2011. Fulton, MO: 

Ameren. Quarterly reports dated May 9, 2011; August 8, 2011; November 15, 2011; and 

January 24, 2012. ADAMS No. ML12271A464.

[Ameren] Ameren Missouri. 2012e. Responses to Environmental RAI Set #1 to the Callaway 

LRA. Fulton, MO: Ameren. Docket Number 50–483, Callaway Plant Unit 1, Union Electric Co., 

Facility Operating License NPF-30. August 13, 2012. ADAMS No. ML12271A423.

2-81
Affected Environment

[Ameren] Ameren Missouri. 2012f. Responses to Environmental RAI Set #2 to the Callaway 

LRA. Fulton, MO: Ameren. Docket Number 50–483, Callaway Plant Unit 1, Union Electric Co., 

Facility Operating License NPF-30. August 30, 2012. ADAMS No. ML12244A571.

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2011. St. Louis, MO: Ameren. February 23, 2012. ADAMS No. ML12271A481.

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ML12271A451

[Ameren] Ameren Missouri. 2013a. 2012 Annual Radiological Environmental Operating Report

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Streams, April 22, 2013, ADAMS Nos. ML13240A302, ML1324A303, and ML13240A304.

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NRC. Subject: NPDES Permit Renewal Application. August 27, 2013. ADAMS Nos. 

ML13240A305 (information submittal to NRC) and ML13240A306 (application to the Missouri). 

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October 9, 2013. ADAMS No. ML13283A18. 

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ADAMS No. ML14154A493. 

[Ameren] Ameren Missouri. 2014c. Letter from Greg Bradely, Director Engineering Systems to 

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AmerenUE. 2008. Letter from Gail Gary, Consulting Chemist, to Irene Crawford, Director, 

Missouri Department of Natural Resources. Subject: AmerenUE Callaway Power Plant, File 

No. 3.500, Callaway County, NPDES Permit No. MO–009801, NPDES Reportable Event 

November 2008. November 28, 2008.

2-82
Affected Environment

American Resources Group, Ltd. 1981a. Final Report, A Cultural Resources Survey and 

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Affected Environment

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Affected Environment

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Affected Environment

National Audubon Society. 2012. Audubon Important Bird Areas. Washington, DC: National 

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No. ML12271A443.

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(accessed 31 August 2012).

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<http://waterdata.usgs.gov/usa/nwis/uv?site_no=06934500>(accessed 27 May 2014). 

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3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT

As a result of its SSC evaluation, the applicant did not identify the need to undertake any major 

refurbishment or replacement actions associated with license renewal to support the continued 

operation of Callaway beyond the end of the existing operating license (Ameren 2011). The 

applicant has already replaced the steam generators and the reactor head is scheduled to be 

replaced 10 years before the period of extended operation (license renewal), for which the staff 

had considered the environmental impacts in the initial licensing of Callaway. Therefore, the 

staff does not assess refurbishment activities in this supplemental environmental impact 

statement.

3.1 References

[Ameren] Ameren Missouri. 2011. “License Renewal Application, Callaway Plant, Unit 1, 

Appendix E, Applicant’s Environmental Report, Operating License Renewal Stage.” Fulton, MO: 

Ameren. December 15, 2011. Agencywide Documents Access and Management System 

(ADAMS) Nos. ML113540349, ML113540352, and ML113540354.

3-1 

4.0 ENVIRONMENTAL IMPACTS OF OPERATION

This chapter addresses potential environmental impacts related to the period of extended 

operation of Callaway Plant, Unit 1 (Callaway). These impacts are grouped and presented 

according to resource. Generic issues (Category 1) rely on the analysis presented in the 

Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants

(NRC 1996, 1999, 2013). Site-specific issues (Category 2) have been analyzed for Callaway 

and assigned a significance level of SMALL, MODERATE, or LARGE, accordingly. Some 

issues are not applicable to Callaway because of site characteristics or plant features. For an 

explanation of the criteria for Category 1 and Category 2 issues, as well as the definitions of 

SMALL, MODERATE, and LARGE, refer to Section 1.4. As also described in Section 1.4, the 

U.S. Nuclear Regulatory Commission (NRC) has published a final rule (78 FR 37282, 

June 20, 2013) revising its environmental protection regulation, Title 10 of the Code of Federal 

Regulations (10 CFR) Part 51, “Environmental protection regulations for domestic licensing and 

related regulatory functions.” The final rule consolidates similar Category 1 and 2 issues, 

changes some Category 2 issues into Category 1 issues, and consolidates some of those 

issues with existing Category 1 issues. The final rule also adds new Category 1 and 2 issues. 

The staff evaluates these new issues in Sections 4.3.1, 4.5.2.3, 4.6.1, 4.7.1.1, 4.7.2, 4.9.1.1, 

and 4.10.7 of this SEIS. 

As described in Section 1.5, Ameren submitted its Environmental Report (ER) under NRC’s 

1996 rule governing license renewal environmental reviews (61 FR 28467, June 5, 1996, as 

amended), as codified in NRC’s environmental protection regulation, 10 CFR 51. The 1996 

GEIS (NRC 1996) and Addendum 1 to the GEIS (NRC 1999) provided the technical basis for 

the list of National Environmental Policy Act (NEPA) issues and associated environmental 

impact findings for license renewal contained in Table B–1 in Appendix B to Subpart A of 10 

CFR Part 51. For Callaway, the NRC staff initiated its environmental review in accordance with 

the 1996 rule and GEIS (NRC 1996, 1999) and documented its findings in this chapter of the 

SEIS. General references within this SEIS that refer to the “GEIS” without stipulation are 

inclusive of the 1996 and 1999 GEIS (NRC 1996, 1999). Information and findings specific to the 

June 2013 final rule (78 FR 37282) or the June 2013 GEIS (NRC 2013) are appropriately 

referenced as such. 

4.1 Land Use

Land use in the vicinity of Callaway could be affected by the license renewal decision. 

However, as discussed in the GEIS, onsite land use and powerline right-of-way (ROW) 

conditions are expected to remain unchanged during the license renewal term at all nuclear 

plants, and any impacts would therefore be SMALL. These issues were classified as 

Category 1 issues in the GEIS and are listed in Table 4–1. Section 2.2.1 of this supplemental 

environmental impact statement (SEIS) describes land use conditions in the vicinity of Callaway.

Table 4–1. Land Use Issues

Issue GEIS Section Category

Onsite land use 4.5.3 1

Powerline ROW 4.5.3 1

Sources: 61 FR 28467, June 5, 1996

4-1 
Environmental Impacts of Operation

The ER submitted by Union Electric Company, a subsidiary of Ameren Corporation and doing 

business as Ameren Missouri (Ameren or the applicant) (Ameren 2011a), was reviewed and 

evaluated for new and significant information. Also reviewed were scoping comments and other 

available information about land use in the vicinity of Callaway. The review included a 

data-gathering site visit to Callaway. No new and significant information was identified during 

this review that would change the conclusions in the GEIS. Therefore, for these Category 1 

issues, effects during the renewal term are not expected to exceed those discussed in the 

GEIS.

4.2 Air Quality

As summarized in Section 4.0, the NRC has approved a revision to its environmental protection 

regulation, 10 CFR Part 51. With respect to air quality, the final rule amends Table B-1 in 

Appendix B to 10 CFR Part 51, Subpart A, by changing the “Air quality during refurbishment

(nonattainment and maintenance areas)” issue from a Category 2 to a Category 1 issue and 

renames it, “Air quality impacts (all plants).” This Category 1 issue, “Air quality impacts (all 

plants),” has an impact level of SMALL. There was no change to the Category 1, “Air quality 

effects of transmission lines” issue, which also has an impact level of SMALL. The NRC staff 

performed its review, as discussed below, of air quality issues in accordance with the 1996 

GEIS (NRC 1996) for this SEIS. 

Section 2.2.2 of this SEIS describes the meteorology and air quality at and near the Callaway

site. Table 4–2 notes the one Category 1 issue that is applicable to Callaway during the 

renewal term. There are no applicable Category 2 issues for air quality because there is no 

planned refurbishment associated with the license renewal. As described in Section 2.1.6.1, 

Ameren anticipates 4 to 5 sedimentation additional ponds will be needed. Pond construction 

will result in fugitive dust generation related to excavation and construction activities and 

exhaust emissions from motorized equipment and vehicles of temporary workers. However, as 

discussed in Section 2.1.6.1, dust suppression will be utilized and best-management practices 

will be implemented. Additionally, emissions will be temporary and short-term since 

construction of each pond will be infrequent and is estimated to be completed within 6 months. 

Therefore, emission associated with pond construction will be limited. The U.S. Nuclear 

Regulatory Commission staff (NRC staff or staff) did not identify any new and significant 

information during the review of the applicant’s ER (Ameren 2011a), the staff’s site audit, the 

scoping process, or the evaluation of other available information. Therefore, there are no 

impacts related to these issues beyond those discussed in the GEIS. For these issues, the 

GEIS concluded that the impacts are SMALL, and additional site-specific mitigation measures 

are not likely to be sufficiently beneficial to warrant implementation.

Table 4–2. Air Quality Issues

Issue GEIS Section Category

Air quality effects of transmission lines 4.5.2 1

Sources: 61 FR 28467, June 5, 1996

4-2 
Environmental Impacts of Operation

4.3 Geologic Environment

4.3.1 Geology and Soils

As summarized in Section 4.0, the NRC has approved a revision to its environmental protection 

regulation, 10 CFR Part 51. With respect to the geologic environment of a plant site, the final 

rule amends Table B-1 in Appendix B to 10 CFR Part 51, Subpart A, by adding a new 

Category 1 issue, “Geology and soils.” Under NEPA, the NRC staff needs to consider the new 

Category 1 issue. This new issue has an impact level of SMALL. This new Category 1 issue 

considers geology and soils from the perspective of those resource conditions or attributes that 

can be affected by continued operations during the renewal term. An understanding of geologic 

and soil conditions has been well established at all nuclear power plants and associated 

transmission lines during the current licensing term, and these conditions are expected to 

remain unchanged during the 20-year license renewal term for each plant. The impact of these 

conditions on plant operations and the impact of continued power plant operations and 

refurbishment activities on geology and soils are SMALL for all nuclear power plants and not 

expected to change appreciably during the license renewal term. Operating experience shows 

that any impacts to geologic and soil strata would be limited to soil disturbance from 

construction activities associated with routine infrastructure renovation and maintenance 

projects during continued plant operations. Implementing best management practices would 

reduce soil erosion and subsequent impacts on surface water quality. Information in plantspecific SEISs prepared to date and reference documents have not identified these impacts as 

being significant.

Section 2.2.3 of this SEIS describes the local and regional geologic environment relevant to 

Callaway. The NRC staff did not identify any new and significant information with regard to this 

Category 1 (generic) issue based on its review of the ER (Ameren 2011a), the public scoping

process, or as a result of the environmental site audit. As discussed in Chapter 3 of this SEIS 

and as identified in the ER (Ameren 2011a), Ameren has no plans to conduct refurbishment or 

replacement actions associated with license renewal to support the continued operation of 

Callaway. Further, Ameren anticipates ground-disturbing activities, changes in operations and 

operation and maintenance activities would be confined to previously disturbed areas or existing 

ROWs. As described in Section 2.1.6.1, new sedimentation pond construction would be 

confined to previously disturbed areas and best management soil erosion practices will be used. 

Based on this information, the staff has determined that any incremental impacts on geology 

and soils during the license renewal term would be SMALL. 

4.4 Surface Water Resources

Sections 2.1.7.1 and 2.2.4 of this SEIS describe the surface water resources in the vicinity of 

Callaway. Table 4–3 notes the surface water issues that are applicable to Callaway during the 

license renewal term.

4-3 
Environmental Impacts of Operation

Table 4–3. Surface Water Use and Quality Issues

Issue GEIS Section Category

Altered current patterns at intake and discharge structures 4.2.1.2.1 1

Temperature effects on sediment transport capacity 4.2.1.2.3 1

Scouring caused by discharged cooling water 4.2.1.2.3 1

Eutrophication 4.2.1.2.3 1

Discharge of chlorine or other biocides 4.2.1.2.4 1

Discharge of sanitary wastes and minor chemical spills 4.2.1.2.4 1

Discharge of other metals in wastewater 4.2.1.2.4 1

Water use conflicts (plants with cooling ponds or cooling towers using 

makeup water from a small river with low flow)

4.3.2.1

4.4.2.1 2 

Sources: 61 FR 28467, June 5, 1996

4.4.1 Generic Surface Water Issues

The NRC staff did not find any new and significant information with regard to Category 1 

(generic) surface water issues based on its review of the applicant’s ER, the staff’s site audit, 

the scoping process, or the evaluation of other available information. As a result, no information 

or impacts related to these issues were found that would change the conclusions presented in 

the GEIS. Therefore, the NRC staff expects that there would be no impacts related to these 

Category 1 issues during the renewal term beyond those discussed in the GEIS. For these 

surface water issues, the GEIS concludes that the impacts are SMALL. 

4.4.2 Surface Water Use Conflicts

The State of Missouri is a riparian water state, which means that all landowners whose property 

is crossed by or is adjacent to a body of water have the legal right to access and use the water, 

also referred to as making reasonable use of it. In evaluating the potential impacts resulting 

from surface water use conflicts associated with license renewal, the NRC staff uses as its 

baseline the existing surface water resource conditions described in Sections 2.1.7.1 and 2.2.4 

of this SEIS. These baseline conditions encompass the existing hydrologic (flow) regime of the 

surface water(s) potentially affected by continued operations as well as the magnitude of 

surface water withdrawals for cooling and other purposes (as compared to relevant 

appropriation and permitting standards). The baseline also considers other downstream uses 

and users of surface water. As stated in Section 2.2.4, Callaway uses the Missouri River as the 

source of water for its cooling tower makeup water. No major users of Missouri River water are 

located within 5 mi (8 km) of Callaway (MDNR 2010a). 

As described in Section 2.2.4, at the Hermann, Missouri, gaging station annual Missouri River 

discharge rates from 1958 through 2013 averaged 87,922 cubic feet per second (cfs) (2,490 

cubic meters per second (m3/s)). However, to characterize the impact of surface water

withdrawals by the plant on other users of Missouri River water, surface water consumption by 

the plant was compared to times when there was a lot less water in the river. It is during these 

extreme periods of low flow that the impacts of plant consumption would be greatest. The 

lowest recorded daily mean flow of the Missouri River past the Callaway river intake structure is 

estimated to be 5,605 cfs (159 m3/sec). This estimate is an average of the lowest daily mean 

flows at the nearest upstream U.S. Geological Survey (USGS) gaging station (Boonville gaging 

station, 5,000 cfs (142 m3

/sec)) and the nearest downstream USGS gaging station (Hermann 

4-4 
Environmental Impacts of Operation

gaging station, 6,210 cfs (176 m3

/sec)) (Ameren 2011a). Callaway withdraws water from the 

Missouri River at 56 cfs (1.59 m3

/sec). Of this volume, 7.5 cfs (0.21 m3/sec) is returned to the 

river and 48.5 cfs (1.4 m3

/sec) is lost to the atmosphere from drift and evaporation. The 48.5 cfs 

(1.4 m3

/sec) represents approximately 0.9 percent of the lowest daily mean flow at the Missouri 

River intake structure (5,605 cfs (159 m3

/sec)). There would be no increase in consumptive 

water use during the license renewal period and the projected consumptive use would continue 

to have a very small impact on Missouri River flows; therefore, the impacts associated with 

license renewal on downstream water users and on in-stream and riparian communities would 

be SMALL.

4.5 Groundwater Resources

Sections 2.1.7 and 2.2.3 present an overview of groundwater use and quality at the Callaway 

site.

Table 4–4 identifies the three Category 2 issues related to groundwater that would be applicable 

to the Callaway site during the renewal term.

Table 4–4. Groundwater Use and Quality Issues

Issue GEIS Section Category

Groundwater use conflicts (potable and service water, and 

dewatering; plants that use >100 gpm) 4.8.1.1, 4.8.2.1 2 

Groundwater use conflicts (plants using cooling towers withdrawing 

makeup water from a small river) 4.8.1.3, 4.4.2.1 2 

Radionuclides released to groundwater 4.5.1.2 (a) 2

(a) NRC 2013 GEIS

Sources: 61 FR 28467, June 5, 1996

4.5.1 Generic Groundwater Issues

There are no Category 1 (generic) groundwater issues applicable to Callaway. The NRC staff 

did not identify any new and significant information with regard to Category 1 groundwater 

issues listed in Table B-1 of Appendix B to 10 CFR 51, Subpart A, based on its review of the 

applicant’s ER, the staff’s site audit, the scoping process, or the evaluation of other available 

information. As a result, no information or impacts related to these issues were identified that 

would change the conclusions presented in the GEIS. 

4.5.2 Groundwater Use and Quality Conflicts

4.5.2.1 Potable Water, Service Water, and Dewatering; Plants That Use More Than 100 Gallons 

per Minute

In evaluating the potential impacts resulting from groundwater use conflicts associated with 

license renewal, the NRC staff uses as its baseline the existing groundwater resource 

conditions described in Sections 2.1.7.2 and 2.2.5 of this SEIS. These baseline conditions 

encompass the existing hydrogeologic framework and conditions (including aquifers) potentially 

affected by continued operations as well as the nature and magnitude of groundwater 

withdrawals for cooling and other purposes (as compared to relevant appropriation and 

4-5 
Environmental Impacts of Operation

permitting standards). The baseline also considers other downgradient or in-aquifer uses and 

users of groundwater. Potable groundwater is supplied to the plant at a rate of 33 gpm 

(124 liters per minute (L/min)). Groundwater used to lubricate intake structure pump bearings is 

consumed at a rate of 120 gpm (454 L/min) (Ameren 2011b). Groundwater is also withdrawn by 

a sump pump at a rate of 65 gpm (246 L/min) (Ameren 2008a). Total groundwater consumption 

is estimated to be 218 gpm (825 L/min, which is more than 100 gpm (379 L/min)).

The sump pump does not remove water from an aquifer. It removes water from fill material that 

was placed around the reactor containment structure and adjacent buildings. The fill material is 

in hydraulic communication with a largely water-filled excavation that was made for a second 

reactor that was never built. Rain water collects in this excavation. From the excavation, the 

water flows through the fill material to the sump pump. As a result, water removed by the sump 

pump does not impact the availability of groundwater resources (Ameren 2012e). The waterfilled excavation is being filled in with earthen fill and should be completely full sometime in 2015 

(Ameren 2014).

Near the plant, groundwater use is sparse, supports rural activities, and is likely to remain so 

during the license renewal term. The groundwater resources of the Cotter and Jefferson City 

Dolomites Aquifer near the plant are adequate to support Callaway’s current and future 

groundwater demands and those of other groundwater users. Callaway should continue to 

have little impact on groundwater use as a result of the relatively small amount of groundwater 

consumed and the good aquifer yields in the area. Therefore, the impact of groundwater 

consumption on groundwater availability is SMALL.

4.5.2.2 Plants Using Cooling Towers Withdrawing Makeup Water from a Small River

This issue is concerned with the impact on groundwater supplies from the withdrawal of river 

water. For this groundwater use conflicts-related issue, the NRC staff uses the same baseline 

as noted in Section 4.4.2.1. 

The only aquifer that could be impacted by the use of Missouri River water is the Missouri River 

Alluvial Aquifer. The hydrologic interaction between the Missouri River and the Missouri River 

Alluvial Aquifer is described in Section 2.2.5, and the amount of water used by the facility as 

well as its impact on river flows is described in Sections 2.1.7 and 4.4.2, respectively.

The consumption of Missouri River water by Callaway has little impact on the volume of water 

flowing in the river and is therefore unlikely to impact water levels in the Missouri River Alluvial 

Aquifer. Furthermore, the Missouri River Alluvial Aquifer receives significant amounts of water 

from the Cotter and Jefferson City Dolomites Aquifer, and, as a result, the aquifer usually 

contributes water to the river instead of being recharged by it. Therefore, the impact of surface 

water consumption on groundwater use is SMALL.

4.5.2.3 Radionuclides Released to Groundwater

As summarized in Section 4.0, the NRC has approved a revision to its environmental protection 

regulation, 10 CFR Part 51. With respect to groundwater quality, the final rule amends 

Table B–1 in Appendix B to 10 CFR Part 51, Subpart A, by adding a new Category 2 issue, 

“Radionuclides released to groundwater.” Under NEPA, the NRC needs to consider this new 

Category 2 issue. The NRC has determined that the new issue has an impact level range of 

SMALL to MODERATE, to evaluate the potential impact of discharges of radionuclides from 

plant systems into groundwater. This new Category 2 issue has been added to evaluate the 

potential impact to groundwater quality from the discharge of radionuclides from plant systems, 

piping, and tanks. This issue was added because, within the past several years, there have 

been events at nuclear power reactor sites that involved unknown, uncontrolled, and 

unmonitored releases of radioactive liquids into the groundwater. In evaluating the potential 

4-6 
Environmental Impacts of Operation

impacts on groundwater quality associated with license renewal, the NRC staff uses as its 

baseline the existing groundwater conditions described in Section 2.2.5 of this SEIS. These 

baseline conditions encompass the existing quality of groundwater potentially affected by 

continued operations (as compared to relevant state or U.S. Environmental Protection Agency

(EPA) primary drinking water standards) as well as the current and potential onsite and offsite 

uses and users of groundwater for drinking and other purposes. The baseline also considers 

other downgradient or in-aquifer uses and users of groundwater.

As described in Section 2.2.5, leaks have occurred in Callaway’s blowdown pipeline that runs 

from the plant and discharges water to the Missouri River. The blowdown pipeline has since 

been redesigned and replaced. In 2012, all tritium concentrations in groundwater samples were 

well below the EPA drinking water standard of 20,000 picocuries per liter. However, as 

discussed in Section 2.2.5, samples of groundwater obtained from a new well located within the 

plant property, yielded tritium concentrations of 1.6 million pCi/L. This exceeds the EPA 

drinking water standard. The extent and cause of the contamination is currently being 

investigated by the licensee.

In 2007, the nuclear power industry began implementing its “Industry Ground Water Protection 

Initiative” (NEI 2007). Since 2008, the staff has been monitoring implementation of this initiative 

at licensed nuclear reactor sites. The initiative identifies actions to improve utilities’ 

management and response to instances in which the inadvertent release of radioactive 

substances may result in low but detectible levels of plant-related (Callaway operation related) 

materials in subsurface soils and water. It also seeks to identify those actions necessary for 

implementation of a timely and effective groundwater protection program. As described in 

Section 2.2.5, tritium contamination in the new well was discovered as part of the licensee’s 

participation in this initiative. The NRC will continue to monitor the effectiveness of the “Industry 

Ground Water Protection Initiative” at Callaway. With continued NRC attention and action by 

Callaway, the NRC staff concludes that groundwater quality impacts would remain SMALL 

during the license renewal term.

4.6 Aquatic Resources

Sections 2.1.6 and 2.2.6 describe Callaway’s cooling system and aquatic environment, 

respectively. Table 4–5 notes the Category 1 issues listed in Table B-1 in Appendix B to 

10 CFR Part 51, Subpart A, related to aquatic resources that are applicable to Callaway during 

the renewal term. These issues are considered generic (Category 1) for facilities with 

cooling-tower-based heat-dissipation systems. No site-specific (Category 2) issues are related 

to aquatic resources for Callaway, as the plant has a cooling tower and a closed-cycle cooling 

system (NRC 1996). The NRC staff did not find any new and significant information during its 

review of the applicant’s ER, the site visit, the scoping process, or the evaluation of other 

available information (including Ameren 2011a, 2012b; Galat et al. 2005a, 2005b; National 

Research Council 2002; USACE and FWS 2011). All of the issues listed in Table 4–5 are 

considered generic for facilities with cooling-tower-based heat-dissipation systems. This type of 

cooling system substantially reduces the volume of water withdrawn by the plant and 

substantially reduces entrainment, impingement, and thermal discharge effects (heat shock

potential). For these issues, the GEIS concludes that the impact levels are SMALL.

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Environmental Impacts of Operation

Table 4–5. Aquatic Resource Issues

Issues GEIS Section Category

For all plants

Accumulation of contaminants in sediments or biota 4.2.1.2.4 1

Entrainment of phytoplankton and zooplankton 4.2.2.1.1 1

Cold shock 4.2.2.1.5 1

Thermal plume barrier to migrating fish 4.2.2.1.6 1

Distribution of aquatic organisms 4.2.2.1.6 1

Premature emergence of aquatic insects 4.2.2.1.7 1

Gas supersaturation (gas bubble disease) 4.2.2.1.8 1

Low dissolved oxygen in the discharge 4.2.2.1.9 1

Losses from predation, parasitism, and disease among organisms 

exposed to sub-lethal stresses 4.2.2.1.10 1 

Stimulation of nuisance organisms 4.2.2.1.11 1

Exposure of aquatic organisms to radionuclides 4.6.1.2 (a) 1

For plants with cooling tower-based heat-dissipation systems

Entrainment of fish and shellfish in early life stages 4.3.3 1

Impingement of fish and shellfish 4.3.3 1

Thermal shock 4.3.3 1

(a) NRC 2013 (GEIS)

Sources: 61 FR 28467, June 5, 1996

4.6.1 Exposure of Aquatic Organisms to Radionuclides

As summarized in Section 4.0, the NRC has approved a revision to its environmental protection 

regulation, 10 CFR Part 51. With respect to the aquatic organisms, the final rule amends 

Table B-1 in Appendix B to 10 CFR Part 51, Subpart A, by adding a new Category 1 issue, 

“Exposure of aquatic organisms to radionuclides,” among other changes. This new Category 1 

issue considers the impacts to aquatic organisms from exposure to radioactive effluents 

discharged from a nuclear power plant during the license renewal term. An understanding of 

the radiological conditions in the aquatic environment from the discharge of radioactive effluents 

within NRC regulations has been well-established at nuclear power plants during their current 

licensing term. Based on this information, the NRC concluded that the doses to aquatic 

organisms are expected to be well below exposure guidelines developed to protect these 

organisms and assigned this issue an impact level of SMALL.

The NRC staff has not identified any new and significant information related to the exposure of 

aquatic organisms to radionuclides during its independent review of the applicant’s ER, the site 

audit, the scoping process, or the evaluation of other available information. Section 2.1.2 of this 

SEIS describes the applicant’s radioactive waste management program to control radioactive 

effluent discharges to ensure that they comply with NRC regulations in 10 CFR Part 20. 

Section 4.9.3 of this SEIS contains the NRC staff’s evaluation of Callaway’s radioactive effluent 

and radiological environmental monitoring programs. Callaway’s radioactive effluent and 

radiological environmental monitoring programs provide further support for the conclusion that 

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Environmental Impacts of Operation

the impacts of aquatic organisms from radionuclides are SMALL. The NRC staff concludes that 

there would be no impacts to aquatic organisms from radionuclides beyond those impacts 

contained in Table B-1 in Appendix B to 10 CFR Part 51, Subpart A, of the final rule and 

therefore, the impacts to aquatic organisms from radionuclides are SMALL.

4.7 Terrestrial Resources

The Category 1 and Category 2 issues related to terrestrial resources associated with the 

Callaway license renewal are discussed in the following sections and listed in Table 4–6. 

Section 2.2.7 provides a description of the terrestrial resources at the Callaway site and in the 

surrounding area. 

Table 4–6. Terrestrial Resource Issues

Issue GEIS Section Category

Cooling tower impacts on crops and ornamental vegetation 4.3.4 1

Cooling tower impacts on native plants 4.3.5.1 1

Bird collisions with cooling towers 4.3.5.2 1

Powerline right-of-way management (cutting and herbicide application) 4.5.6.1 1

Bird collision with powerlines 4.5.6.1 1

Impacts of electromagnetic fields on flora and fauna (plants, agricultural 

crops, honeybees, wildlife, livestock) 4.5.6.3 1 

Floodplains and wetland on powerline right of way 4.5.7 1

Exposure of terrestrial organisms to radionuclides 4.6.1.1 (a) 1

Effects on terrestrial resources (non-cooling system impacts) 4.6.1.1 (a) 2

(a) NRC 2013 (GEIS)

Sources: 61 FR 28467, June 5, 1996

4.7.1 Generic Terrestrial Resource Issues

For the Category 1 terrestrial resources issues listed in Table 4–6, the NRC staff did not identify 

any new and significant information during the review of the applicant’s ER (Ameren 2011a), the 

NRC staff’s site audit, the scoping process, or the evaluation of other available information. 

Therefore, there are no impacts related to these issues beyond those discussed in the GEIS

and the final rule (NRC 2012e). For these issues, the GEIS and the final rule concluded that the 

impacts are SMALL.

4.7.1.1 Exposure of Terrestrial Organisms to Radionuclides

As summarized in Section 4.0, the NRC has approved a revision to its environmental protection 

regulation, 10 CFR Part 51. With respect to terrestrial organisms, the final rule amends 

Table B-1 in Appendix B to 10 CFR Part 51, Subpart A, by adding a new Category 1 issue, 

“Exposure of terrestrial organisms to radionuclides,” among other changes. This new issue has 

an impact level of SMALL. This new Category 1 issue considers the impacts to terrestrial 

organisms from exposure to radioactive effluents discharged from a nuclear power plant during 

the license renewal term. An understanding of the radiological conditions in the terrestrial 

environment from the discharge of radioactive effluents within NRC regulations has been well 

established at nuclear power plants during their current licensing term. Based on this 

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Environmental Impacts of Operation

information, the NRC concluded that the doses to terrestrial organisms are expected to be well 

below exposure guidelines developed to protect these organisms and assigned this issue an 

impact level of SMALL.

The NRC staff has not identified any new and significant information related to the exposure of 

terrestrial organisms to radionuclides during its independent review of the applicant’s ER, the 

site audit, the scoping process, or the evaluation of other available information. Section 2.1.2 of 

this SEIS describes the applicant’s radioactive waste management program to control 

radioactive effluent discharges to ensure that they comply with NRC regulations in 

10 CFR Part 20. Section 4.9.3 of this SEIS contains the NRC staff’s evaluation of Callaway’s 

radioactive effluent and radiological environmental monitoring programs. Callaway’s radioactive 

effluent and radiological environmental monitoring programs provide further support for the 

conclusion that the impacts from radioactive effluents are SMALL.

Therefore, the NRC staff concludes that there would be no impact to terrestrial organisms to

radionuclides beyond those impacts contained in Table B-1 in Appendix B to 10 CFR Part 51, 

Subpart A, of the final rule and therefore, the impacts to terrestrial organisms from radionuclides 

are SMALL.

4.7.2 Effects on Terrestrial Resources (Non-cooling System Impacts)

As summarized in Section 4.0, the NRC has approved a revision to its environmental protection 

regulation, 10 CFR Part 51. With respect to terrestrial organisms, the final rule amends 

Table B-1 in Appendix B to 10 CFR Part 51, Subpart A, by expanding the Category 2 issue, 

“Refurbishment impacts,” among others, to include normal operations, refurbishment, and other 

supporting activities during the license renewal term. This issue remains a Category 2 issue 

with an impact level range of SMALL to LARGE; however, the final rule renames this issue 

“Effects on terrestrial resources (non-cooling system impacts).” Under NEPA, the NRC staff 

needs to consider this expanded Category 2 issue. The geographic scope for the assessment 

of this issue is the Callaway site and the area near the site. The baseline is the condition of the 

terrestrial resources under the no-action alternative. Section 2.2.7 describes the terrestrial 

resources on and in the vicinity of the Callaway site, and Section 2.2.8 describes protected 

species and habitats. As described in the applicant’s ER (Ameren 2011a), and noted in 

Section 2.2.1 of this SEIS, about 7 percent of the Callaway site (512 acres (ac) (207 hectares 

(ha))) has been permanently disturbed for power-generation infrastructure, with an additional 

30 percent (2,135 ac (864 ha)) of the site maintained for supporting infrastructure. The majority 

of the site remains in undeveloped uses, with forested areas comprising 5,536 ac (2,240 ha). 

As discussed in Chapter 3 of this SEIS and according to the applicant’s ER (Ameren 2011a), 

Ameren has no plans to conduct refurbishment or replacement actions associated with license 

renewal to support the continued operation of Callaway. Further, Ameren anticipates that 

operation and maintenance activities would primarily be confined to previously disturbed areas 

or existing ROWs. Based on the staff’s independent review, the staff has verified that operation 

and maintenance activities that the applicant might undertake during the renewal term, such as 

maintenance and repair of plant infrastructure (e.g., new sedimentation pond construction, 

roadways, piping installations, onsite transmission lines, fencing, and other security 

infrastructure), likely would be confined to previously disturbed areas of the site. Therefore, the 

staff expects non-cooling system impacts on terrestrial resources during the license renewal 

term to be SMALL.

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4.8 Protected Species and Habitats

Section 2.2.6 of this SEIS describes protected species and habitats in the vicinity of Callaway. 

Table 4–7 lists the one Category 2 issue related to protected species and habitats that is 

applicable to Callaway.

Table 4–7. Protected Species and Habitat Issues

Issue GEIS Section Category

Threatened or endangered species 4.1 2

Sources: 61 FR 28467, June 5, 1996

4.8.1 Correspondence with Federal and State Agencies

As part of its National Environmental Policy Act of 1969, as amended (NEPA) and Endangered 

Species Act of 1973, as amended (ESA), reviews, the NRC consulted the U.S. Fish and Wildlife 

Service (FWS) and the Missouri Department of Conservation (MDC) to gather information on 

protected species and habitats that may occur in the action area.

The NRC sent a letter to FWS on April 20, 2012 (NRC 2012a), requesting concurrence with the 

NRC’s list of Federally protected species in the vicinity of Callaway. The FWS replied by e-mail 

on September 10, 2012 (FWS 2012a). In that e-mail, the FWS indicated that two Federally 

listed species may occur within the vicinity of Callaway: the Indiana bat (Myotis sodalis) and the 

pallid sturgeon (Scaphirhynchus albus). The NRC sent a letter to MDC on June 1, 2012 

(NRC 2012b), requesting a heritage review for Federally and State-protected species, critical 

habitat, and other areas of conservation concern in the action area. The MDC replied to this 

request with a heritage review report on November 16, 2012 (MDC 2012b).

The report indicated that the pallid sturgeon, as well as several State-listed species, occur in the 

vicinity of Callaway. The staff used the information received from the FWS and MDC to assess 

potential impacts on protected species and habitats in the following sections. Additionally, 

representatives from both the FWS and MDC attended the NRC staff’s environmental site audit 

in May 2012 to gain an understanding of the license renewal review process and to share 

information with NRC staff on potential effects of the proposed license renewal on protected 

species and habitats (NRC 2012f).

Following the publication of the draft SEIS and in accordance with the ESA section 7 regulations 

in 50 CFR 402.13(a), the NRC (2014) sent FWS a letter dated February 24, 2014, that requests

the FWS’s concurrence with the NRC’s effect determinations for the species that may be 

affected by the proposed license renewal of Callaway, which are discussed below. 

4.8.2 Aquatic Species and Habitats

Species and Habitats Protected Under the Federal Endangered Species Act

Pallid Sturgeon (Scaphirhynchus albus)

Section 2.2.8 concludes that the pallid sturgeon could occur in the main stem Missouri River in 

the vicinity of the Callaway water intake and discharge structures. The pallid sturgeon is native 

to the Missouri River, as well as the lower Mississippi River (FWS 1993). The decline of the 

species was originally attributed to overfishing and the lack of recruitment, which was likely 

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Environmental Impacts of Operation

greatly accelerated by habitat destruction through the development of dams and reservoirs on 

the river and conversion of the lower river into a channelized, self-scouring navigation channel 

(FWS 1993). The construction of dams and channelization of the river resulted in (1) physical 

blockage of migration corridors and (2) alteration of natural flows, which affected the availability 

of spawning habitats, potential timing of reproduction, and the availability and distribution of 

prey. The creation of reservoir habitats and modified flow releases into the lower river further 

degraded the large river environment in which the pallid sturgeon had evolved (55 FR 36641). 

The presence of Callaway’s intake and discharge structures on the lower Missouri River could 

adversely affect the pallid sturgeon and its habitats. 

Following license renewal, Callaway would continue to withdrawal water and discharge

blowdown water to the Missouri River during the extended operating period; thus, the potential 

exists for pallid sturgeon to be impinged or entrained in Callaway’s water intake structure. As 

described in Section 4.5, the design, location, and operation of the intake and discharge 

structures for Callaway in the Missouri River have not been found to adversely affect aquatic 

organisms in the lower Missouri River (Ameren 2011a). Entrainment studies conducted in the 

1980s stated that the Callaway intake structure was designed to minimize entrainment and 

impingement of aquatic organisms, including the pallid sturgeon (UEC 1986). In addition, 

Ameren’s studies documented a low projected impingement for Callaway. No pallid sturgeon or 

other listed species has been captured during any of the fish surveys conducted at Callaway 

(Ameren 2011a; UEC 1986), and the current National Pollutant Discharge Elimination System

(NPDES) permit for Callaway authorizes continued operation of the intake structure.

Both Ameren and the NRC have contacted FWS to request information on the presence of and 

potential impacts on Federally protected species. The FWS did not state the pallid sturgeon to 

be of particular concern in its June 14, 2010, letter to Ameren (FWS 2010), or its 

September 10, 2012, e-mail to NRC (FWS 2012a). However, more recent and future recovery 

efforts will create the potential for pallid sturgeon larvae or juveniles to be present in the vicinity 

of the Callaway intake structure as the population increases and expands its range, resulting in 

the potential for adverse effects associated with impingement or entrainment into the intake 

structure. 

The staff concludes that the present and future operation of Callaway through 2044 may affect, 

but is not likely to jeopardize the continued existence of the pallid sturgeon and that any adverse 

effects would accrue primarily through direct mortality caused by entrainment and impingement

of larvae and juveniles. The NRC staff has prepared a biological assessment pursuant to 

section 7 of the ESA (16 U.S.C. 1531 et seq.) (see Appendix H). 

Topeka Shiner (Notropis topeka) 

Section 2.2.8 states that the Topeka shiner has the potential to occur or may be re-introduced 

into streams in Callaway County that are crossed by the Callaway transmission lines. These 

streams contain moderately clear water with sand and gravel substrates. Areas on the 

Callaway site with the greatest potential to support Topeka shiner include Auxvasse Creek, 

Logan Creek, and other small streams within Callaway County. 

Following license renewal, streams crossed by the Callaway transmission lines could be 

disturbed during the extended operating period by the clearing and removal of riparian 

vegetation within the transmission line corridors. Because a majority of the Callaway 

transmission line corridors contain low-growing plant communities dominated by grasses, herbs, 

and small shrubs, Ameren’s continued maintenance generally would not alter existing habitats. 

Occasionally, Ameren’s clearing of vegetation within the riparian zones of streams, including 

those with the potential to contain the Topeka shiner, could result in the disturbance of water 

quality through the introduction of sediment or contaminants into the stream channel.

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Environmental Impacts of Operation

Both Ameren and the NRC have contacted FWS to request information on the presence of and 

potential impacts on Federally protected species. The FWS did not state the Topeka shiner to 

be of particular concern in its June 14, 2010, letter to Ameren (FWS 2010) or its 

September 10, 2012, e-mail to NRC (FWS 2012a).

The NRC concludes that the proposed Callaway license renewal may affect, but is not likely to 

adversely affect, the Topeka shiner because effects on the species would be insignificant. 

Niangua Darter (Etheostoma nianguae) 

Section 2.2.8 indicates that the Niangua darter has the potential to occur in streams in Osage 

County that are crossed by the Callaway transmission lines. These streams have good water 

quality and gravel substrates and are silt-free. Areas on the Callaway site with the greatest 

potential to support the Niangua darter are several tributaries of the Osage River.

Following license renewal, streams crossed by the Callaway transmission lines could be 

disturbed during the extended operating period by the clearing and removal of riparian 

vegetation within the transmission line corridors. Because a majority of the Callaway 

transmission line corridors contain low-growing plant communities dominated by grasses, herbs, 

and small shrubs, Ameren’s continued maintenance generally would not alter existing habitats. 

Occasionally, Ameren’s clearing of vegetation within the riparian zones of streams in Osage 

County, including those potentially containing the Niangua Darter, could result in the 

disturbance of water quality through the introduction of sediment or contaminants into the 

stream channel.

Both Ameren and the NRC have contacted the FWS to request information on the presence of 

and potential impacts on Federally protected species. The FWS did not indicate the Niangua 

darter to be of particular concern in its June 14, 2010, letter to Ameren (FWS 2010) or its 

September 10, 2012, e-mail to NRC (FWS 2012a). 

The NRC concludes that the proposed Callaway license renewal may affect, but is not likely to 

adversely affect, the Niangua darter because effects on the species would be insignificant. 

Pink Mucket (Lampsilis abrupta) 

Section 2.2.8 indicates that the pink mucket freshwater mussel has the potential to occur in 

streams and rivers in Osage and Gasconade Counties that are crossed by the Callaway 

transmission lines. These streams have good water quality and cobble, gravel, and sand 

substrates. Areas on the Callaway site with the greatest potential to support the pink mucket 

are the Gasconade and Osage rivers and several of their tributaries.

Following license renewal, streams crossed by the Callaway transmission lines could be 

disturbed by the clearing and removal of riparian vegetation within the transmission line 

corridors. Because a majority of the Callaway transmission line corridors contain low-growing 

plant communities dominated by grasses, herbs, and small shrubs, Ameren’s continued 

maintenance generally would not alter existing habitats. Occasionally, Ameren’s clearing of 

vegetation within the riparian zones of streams in Osage and Gasconade Counties, including 

those potentially containing the pink mucket, could result in the disturbance of water quality 

through the introduction of sediment or contaminants into the stream channel.

Both Ameren and the NRC have contacted FWS to request information on the presence of and 

potential impacts on Federally protected species. The FWS did not indicate the pink mucket to 

be of particular concern in its June 14, 2010, letter to Ameren (FWS 2010) or its 

September 10, 2012, e-mail to NRC (FWS 2012a). 

The NRC concludes that the proposed Callaway license renewal may affect, but is not likely to 

adversely affect, the pink mucket because effects on the species would be insignificant.

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Environmental Impacts of Operation

Scaleshell (Leptodea leptodon) 

Section 2.2.8 indicates that the scaleshell freshwater mussel has the potential to occur in 

streams and rivers in Osage and Gasconade Counties that are crossed by the Callaway 

transmission lines. These streams have good water quality and stable cobble, gravel, and sand 

substrates. Areas on the Callaway site with the greatest potential to support the scaleshell are 

the Gasconade River and its tributaries.

Following license renewal, streams crossed by the Callaway transmission lines could be 

disturbed by the clearing and removal of riparian vegetation within the transmission line 

corridors. Because a majority of the Callaway transmission line corridors contain low-growing 

plant communities dominated by grasses, herbs, and small shrubs, Ameren’s continued 

maintenance generally would not alter existing habitats. Occasionally, Ameren’s clearing of 

vegetation within the riparian zones of rivers and streams in Gasconade County, including those 

potentially containing the scaleshell, could result in the disturbance of water quality through the 

introduction of sediment or contaminants into the stream channel.

Both Ameren and the NRC have contacted FWS to request information on the presence of and 

potential impacts on Federally protected species. The FWS did not indicate the scaleshell to be 

of particular concern in its June 14, 2010, letter to Ameren (FWS 2010) or its 

September 10, 2012, e-mail to the NRC (FWS 2012a). 

The NRC concludes that the proposed Callaway license renewal may affect, but is not likely to 

adversely affect, the scaleshell because effects on the species would be insignificant.

Spectaclecase (Cumberlandia monodonta) 

Section 2.2.8 indicates that the spectaclecase freshwater mussel has the potential to occur in 

streams and rivers in Osage and Gasconade Counties that are crossed by the Callaway 

transmission lines. These medium to large rivers have good water quality and boulder, cobble, 

gravel, and sand substrates. Areas on the Callaway site with the greatest potential to support 

the spectaclecase are the Gasconade River and its tributaries.

Following license renewal, streams crossed by the Callaway transmission lines could be 

disturbed by the clearing and removal of riparian vegetation within the transmission line 

corridors. Because a majority of the Callaway transmission line corridors contain low-growing 

plant communities dominated by grasses, herbs, and small shrubs, Ameren’s continued 

maintenance generally would not alter existing habitats. Occasionally, Ameren’s clearing of 

vegetation within the riparian zones of rivers and streams, including those potentially containing 

the spectaclecase mussel, could result in the disturbance to water quality through the 

introduction of sediment or contaminants into the stream channel.

Both Ameren and the NRC have contacted FWS to request information on the presence of and 

potential impacts on Federally protected species. The FWS did not indicate the spectaclecase 

mussel to be of particular concern in its June 14, 2010, letter to Ameren (FWS 2010) or its 

September 10, 2012, e-mail to NRC (FWS 2012a). 

The NRC concludes that the proposed Callaway license renewal may affect, but is not likely to 

adversely affect, the spectaclecase mussel because effects on the species would be 

insignificant.

Conclusion

The FWS has listed three species of freshwater mussels that may inhabit surface waters in 

counties near Callaway as endangered: the pink mucket, the spectaclecase, and the scaleshell. 

In all cases, these species would live in the Gasconade River, which is crossed by transmission 

lines associated with Callaway. Two Federally listed fish species may also occur in tributaries 

4-14
Environmental Impacts of Operation

to the Missouri River crossed by transmission lines associated with Callaway: the Niangua 

darter and Topeka shiner. The proposed Callaway license renewal would not affect the location 

or maintenance of these lines. The proposed Callaway license renewal may affect, but is not 

likely to adversely affect, these three mussel species or two fish species.

Based on the occurrence of larval and juvenile pallid sturgeon in the lower Missouri River and 

the design and operation of the Callaway intake and discharge structure, this Federally listed 

species might be impinged, entrained, or affected by the thermal effluent. The NRC staff has 

prepared a biological assessment for the pallid sturgeon, which is in Appendix H of this SEIS 

and which finds that the proposed license renewal may affect, but is not likely to jeopardize the 

continued existence of the endangered pallid sturgeon.

The section 7 consultation with FWS is in progress. By letter dated September 18, 2014, the 

NRC staff requested additional information from FWS for clarification regarding continuing the 

ESA section 7 consultation. The staff also requested, and FWS provided, additional information 

to help determine possible adverse effects of plant operation on the endangered pallid sturgeon. 

In its letter dated September 29, 2014, FWS (2014) indicated that it had insufficient information 

to conclude that the risk to pallid sturgeon is insignificant or discountable. As such, the NRC’s 

section 7 consultation with FWS related to the pallid sturgeon continues. NRC staff continues to 

engage with FWS to complete the consultation. If a biological opinion on pallid sturgeon has not 

been issued by the time that the NRC completes its licensing action, the staff will condition the 

license, as appropriate. 

In addition, by letter of September 29, 2014, FWS concurred with NRC's “may affect, but not 

likely to adversely affect” determination for the pink mucket (Lampsilis abrupta), scaleshell 

(Leptodea leptodon), spectacle case (Cumberlandia monodonta), and Indiana bat (Myotis 

sodalis). FWS found that the determination for running buffalo clover (Trifolium stoloniferum), 

Topeka shiner (Notropis Topeka), Niangua darter (Etheostoma cragini), and gray bat (Myotis 

grisescens) should be “no effect” because these species do not occur in the proposed license 

renewal project area and would not be directly or indirectly affected by the project action.

4.8.3 Terrestrial Species and Habitats 

Species and Habitats Protected Under the Endangered Species Act

Gray Bat (Myotis grisescens) 

Section 2.2.8 concludes that the gray bat could occur in suitable foraging habitat within the 

action area. Foraging habitat consists of forest canopies along river edges, as well as low overwater, where gray bats forage on flying insects (FWS 1982). On the Callaway site, gray bats 

would most likely occur within the Reform Conservation Area along the riparian zones of 

Auxvasse Creek, Logan Creek, Mud Creek, Molly Dozier Slough, and the Missouri River. The 

gray bat may also use riparian zones along the transmission line corridors as foraging habitat. 

The Callaway license renewal would not result in the disturbance or alteration of any natural

habitats within the Callaway site. Thus, no direct or indirect adverse effects would result from 

continued operation and maintenance of the plant. If the gray bat occurs on the Callaway site, 

continued operation of the plant and management of the Reform Conservation Area by the MDC

would be beneficial to the species because it would preserve riparian zone habitat that might 

otherwise be developed or converted to some other land use.

Because a majority of the Callaway transmission line corridors contain low-growing plant 

communities dominated by grasses, herbs, and small shrubs, Ameren’s continued maintenance 

of the lines generally would not alter the existing habitat. Occasionally, Ameren may need to 

remove trees that either grow tall enough to interfere with the lines or die and could fall on the 

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Environmental Impacts of Operation

lines. In such cases, Ameren may need to remove trees that offer summer foraging habitat for 

gray bats. In its response to requests for additional information (RAI) concerning transmission 

line maintenance, Ameren indicated that, “if Ameren observes Federally listed species, 

vegetation maintenance will not be performed in that area” (Ameren 2012d). In addition, the 

ESA would require Ameren to coordinate with the FWS if impacts on the species could result 

from the removal of any habitat. Ameren could also perform such maintenance in the fall or 

winter months when the gray bat has migrated to hibernation sites. However, Ameren has not 

indicated that such measures are implemented to reduce the risk of impacts on gray bats or 

other protected species.

Both Ameren and the NRC have contacted the FWS to request information on the presence of 

and potential impacts on Federally protected species. The FWS did not indicate the gray bat to 

be of particular concern in its June 14, 2010, letter to Ameren (FWS 2010) or its 

September 10, 2012, e-mail to the NRC (FWS 2012a). 

The NRC concludes that the proposed Callaway license renewal may affect, but is not likely to 

adversely affect, the gray bat because effects to the species would be insignificant.

Indiana Bat (Myotis sodalis) 

Section 2.2.8 concludes that the Indiana bat could occur in suitable habitat within the action 

area. The types of Indiana bat habitat that potentially occur in the action area include summer 

roosting habitat and foraging habitat. Summer roosting habitat includes forested areas with 

loose or peeling tree bark on dead or dying trees. Foraging habitat includes stream and river 

corridors, associated floodplain forests, and open bodies of water such as ponds or reservoirs 

(FWS 2012b). 

Areas on the Callaway site with the greatest potential to support summer roosting and foraging 

Indiana bats include the riparian zones of Auxvasse Creek, Logan Creek, Mud Creek, 

Molly Dozier Slough, and the Missouri River. The Indiana bat may also use riparian zones and 

upland forest along the transmission line corridors as summer roosting and foraging habitat. 

The Callaway license renewal would not result in the disturbance or alteration of any natural 

habitats within the Callaway site. Thus, no direct or indirect adverse effects would result from 

continued operation and maintenance of the plant. If the Indiana bat occurs on the Callaway 

site, continued operation of the plant and management of the Reform Conservation Area by the 

MDC would be beneficial to the species because it would preserve riparian zone and other 

forest habitat that might otherwise be developed or converted to some other land use.

Because a majority of the Callaway transmission line corridors contain low-growing plant 

communities dominated by grasses, herbs, and small shrubs, Ameren’s continued maintenance 

of the lines generally would not alter the existing habitat. Occasionally, Ameren may need to 

remove trees that either grow tall enough to interfere with the lines or die and could fall on the 

lines. In such cases, Ameren may need to remove trees that offer summer roosting habitat for 

Indiana bats. In its response to RAI concerning transmission line maintenance, Ameren stated 

that “if Ameren observes Federally listed species, vegetation maintenance will not be performed 

in that area” (Ameren 2012d). In addition, the ESA would require Ameren to coordinate with the 

FWS if impacts on the species could result from removal of any habitat. Ameren could also 

perform such maintenance in the fall or winter months when the Indiana bat has migrated to 

hibernation sites. However, Ameren has not indicated that such measures are implemented to 

reduce the risk of impacts on Indiana bats or other protected species. 

Both Ameren and the NRC have contacted the FWS to request information on the presence of 

and potential impacts on Federally protected species. The FWS did not indicate the Indiana bat 

to be of particular concern in its June 14, 2010, letter to Ameren (FWS 2010). However, in its 

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Environmental Impacts of Operation

correspondence with the NRC (FWS 2012a), the FWS stated that the Indiana bat may occur in 

the action area. The FWS requested that the following types of habitat and trees be avoided 

during maintenance activities:

 shagbark hickories, oaks, and other trees (dead or alive) with peeling or 

exfoliating bark, split tree trunks or branches, or cavities that could serve as 

maternity roost areas; and

 foraging habitat such as stream corridors, riparian areas, and upland 

woodlots.

The FWS recommended further coordination with its office if trees larger than 9 in. (23 cm) in 

diameter at breast height need to be removed (FWS 2012a). 

Since a majority of the transmission line corridors on the Callaway site contain low-growing 

vegetation and removal of trees is generally limited to individual trees that present safety risks, 

tree removal is not likely to reach the scale where a take occurs. Therefore, the staff concludes 

that the proposed Callaway license renewal may affect, but is not likely to adversely affect, the 

Indiana bat because effects on the species would be insignificant.

Running Buffalo Clover (Trifolium stoloniferum) 

Section 2.2.8 indicates that Missouri has three naturally occurring and four reintroduced 

populations of running buffalo clover, and the largest known population is located at Graham 

Cave State Park in Montgomery County (FWS 2007). The species is also listed by the FWS 

and MDC as occurring in Callaway County (FWS 2012c; MDC undated b). Thus, Section 2.2.8 

conservatively concludes that the running buffalo clover could occur in areas of suitable habitat 

within the action area.

The running buffalo clover requires habitats that are somewhat open and exposed to regular 

periods of moderate disturbance, such as mowing, trampling, or grazing. Disturbed habitats 

with historic records of this species include grazed woodlots, mowed paths, old logging roads, 

jeep trails, all-terrain vehicle trails, skid trails, and mowed wildlife openings within mature forest 

(FWS 2007). Thus, the species could occur within the onsite transmission line corridors as it is 

subject to regular vegetation management to control the growth of woody vegetation. If present, 

the species could experience direct adverse effects such as trampling caused by worker foot 

traffic, crushing caused by vehicles and equipment, or herbicide application when workers spray 

adjacent vegetation. Although vegetation maintenance could have beneficial impacts by 

maintaining open habitat that the running buffalo clover could inhabit, it could also damage 

established plant populations.

Both Ameren and the NRC have contacted the FWS to request information on the presence of 

and potential impacts on Federally protected species. The FWS did not indicate the running 

buffalo clover to be of particular concern in its June 14, 2010, letter to Ameren (FWS 2010) or its 

September 10, 2012, e-mail to NRC (FWS 2012a). 

The NRC concludes that the proposed Callaway license renewal may affect, but is not likely to 

adversely affect, the running buffalo clover because effects on the species would be 

insignificant.

Designated Critical Habitat

The NRC did not find any Federally designated critical habitat for terrestrial species within the 

action area during its review (see Section 2.2.7). Additionally, in its correspondence with 

Ameren (FWS 2010) and the NRC (FWS 2012a), the FWS did not find any designated critical 

habitat. Thus, the staff concludes that the proposed license renewal would have no effect on 

designated critical habitat.

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Proposed Species and Proposed Critical Habitat

The NRC did not find any Federally proposed terrestrial species or proposed critical habitat for 

terrestrial species within the action area during its review. Additionally, in its correspondence 

with Ameren (FWS 2010) and NRC (FWS 2012a), the FWS did not find any proposed species 

or proposed critical habitat. Thus, the NRC concludes that the proposed license renewal would 

have no effect on Federally proposed species or proposed critical habitat.

Species Protected Under the Bald and Golden Eagle Protection Act

Bald eagles (Haliaeetus leucocephalus) have been observed in the action area and suitable 

habitat is present; however, no known nests are close to any of the Callaway site buildings, 

parking lots, or other structures or along the transmission line corridors that could be disturbed 

by operations or maintenance activities associated with the proposed license renewal. The 

proposed license renewal would not affect bald eagle habitat quantity or quality because it does 

not involve construction or land disturbances. Bald eagles would experience similar effects as 

other terrestrial resources on and in the vicinity of the Callaway site. In Section 4.7, the NRC 

staff concluded that all effects to terrestrial resources would be SMALL. The NRC staff does not 

anticipate that the impacts from these effects on bald eagles would be greater or that there 

would be any additional impacts to bald eagles not addressed in Section 4.7. Additionally, if 

Ameren identified potential effects to the bald eagle from Callaway operations, the Bald and 

Golden Eagle Protection Act would require Ameren to consult with the FWS to determine if an 

eagle take permit was necessary. This consultation process would help mitigate any adverse 

effects to the species. Thus, the NRC staff concludes that the impacts of the proposed 

Callaway license renewal on bald eagles would be SMALL.

Species Protected Under the Migratory Bird Treaty Act

As discussed in Section 2.2.7, a variety of migratory birds inhabit the Callaway site and 

surrounding region. The proposed license renewal would not affect migratory bird habitat 

quantity or quality because it does not involve construction or land disturbances. Migratory 

birds would experience similar effects as other terrestrial resources on and in the vicinity of the 

Callaway site. In Section 4.7, the NRC staff concluded that all effects to terrestrial resources 

would be SMALL. The NRC staff does not anticipate that the impacts from these effects on 

migratory birds would be greater or that there would be any additional impacts to migratory birds 

not addressed in Section 4.7. Thus, the NRC staff concludes that the impacts of the proposed 

Callaway license renewal on migratory birds would be SMALL.

Species Protected by the State of Missouri 

Section 2.2.8 discusses species protected by the State of Missouri. One Missouri-listed bird 

species, the northern harrier (Circus cyaneus) has been observed on the Callaway site. The 

proposed license renewal would not affect northern harrier habitat quantity or quality because it 

does not involve construction or land disturbances. Northern harriers would experience similar 

effects as other terrestrial resources on and in the vicinity of the Callaway site. In Section 4.7, 

the NRC staff concluded that all effects to terrestrial resources would be SMALL. The NRC staff 

does not anticipate that the impacts from these effects on northern harriers would be greater or

that there would be any additional impacts to the species not addressed in Section 4.7. Thus, 

the NRC staff concludes that the impacts of the proposed Callaway license renewal on northern 

harriers would be SMALL.

One Missouri-listed amphibian, the eastern hellbender (Cryptobranchus alleganiensis), may be 

present along the transmission line corridors in Montgomery, Osage, and Gasconade Counties. 

This species inhabits clean and cool perennial streams and rivers with fast-flowing water. The 

transmission lines associated with Callaway cross rivers and streams that have the potential to 

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offer eastern hellbender habitat. Ameren must maintain the transmission lines and associated 

structures and manage vegetation along the transmission line corridors to prevent interference 

with the lines. Ameren’s Transmission Vegetation Management Program (Ameren 2012d) 

indicates that only EPA-approved herbicides are used to manage vegetation growth on the 

transmission line ROWs. Disturbance of water bodies where the eastern hellbender may occur 

would be limited primarily to minor foot traffic during vegetation maintenance operations. 

Consequently, the NRC staff concludes that the impacts of the proposed Callaway license 

renewal on the eastern hellbender would be SMALL.

The NRC contacted the MDC to request information on the presence of and potential impacts 

on State-protected species. The MDC (2012b) provided the NRC with a heritage review report 

in November 2012. The heritage review report did not identify any State-protected terrestrial 

species as having the potential to be affected by the proposed license renewal. 

Conclusion

The conclusions for species and habitats protected by each Act are stated above in terms 

appropriate for those Acts.

4.9 Human Health

Table 4–8 lists the Category 1 and 2 issues related to human health that are applicable to the 

proposed Callaway license renewal.

Table 4–8. Human Health Issues

Issue GEIS Section Category

Microbiological organisms (occupational health) 4.3.6 1

Microbiological organisms (public health) 4.3.6 2

Noise 4.3.7 1

Radiation exposures to public (license renewal term) 4.6.2 1

Occupational radiation exposures (license renewal term) 4.6.3 1

Electromagnetic fields – acute effects (electric shock) 4.5.4.1 2

Electromagnetic fields – chronic effects 4.5.4.2 Uncategorized

Human health impact from chemicals 4.9.1.1.2 (a) 1

Physical occupational hazards 4.9.1.1.5 (a) 1

(a) NRC 2013 (GEIS) 

Sources: 61 FR 28467, June 5, 1996

4.9.1 Generic Human Health Issues

The NRC staff did not identify any new and significant information during the review of the 

applicant’s ER, the staff’s site audit, the scoping process, or the evaluation of other available 

information. Therefore, there are no impacts related to Category 1 human health issues beyond 

those discussed in the GEIS. For these issues, the GEIS concluded that the impacts are 

SMALL.

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4.9.1.1 New Category 1 Human Health Issues

As summarized in Section 4.0, the NRC has approved a revision to its environmental protection 

regulation, 10 CFR Part 51. With respect to the human health, the final rule amends Table B-1 

in Appendix B to 10 CFR Part 51, Subpart A, by adding two new Category 1 issues, “Human 

health impact from chemicals” and “Physical occupational hazards.” Under NEPA, the NRC 

staff needs to consider these new Category 1 issues. The first issue considers the impacts from 

chemicals to plant workers and members of the public. The second issue only considers the 

nonradiological occupational hazards of working at a nuclear power plant. An understanding of 

these nonradiological hazards to nuclear power plant workers and members of the public has 

been well established at nuclear power plants during those plants’ current licensing terms. The 

impacts from chemical hazards are expected to be minimized through the applicant’s use of 

good industrial hygiene practices as required by permits and Federal and State regulations. 

Also, the impacts from physical hazards to plant workers will be of small significance if workers 

adhere to safety standards and use protective equipment as required by Federal and State 

regulations. Therefore, the impacts to human health for each of these new issues from 

continued plant operations are SMALL.

The NRC staff has not identified any new and significant information related to these 

nonradiological issues during its independent review of the applicant’s ER, the site audit, the 

scoping process, or the evaluation of other available information. Therefore, the NRC staff 

concludes that there would be no impact to human health from chemicals or physical hazards 

beyond those impacts described in Table B-1 in Appendix B to 10 CFR Part 51, Subpart A, of 

the final rule and, therefore, the impacts are SMALL.

4.9.2 Radiological Impacts of Normal Operations 

4.9.2.1 Radiological Impacts of Normal Operations 

The NRC staff did not identify any new and significant information during its independent review 

of the applicant’s ER, the site audit, the scoping process, or its evaluation of other available 

information. Therefore, the NRC staff concludes that there would be no impact from radiation 

exposures to the public or to workers during the renewal term beyond those discussed in the 

GEIS, which states:

 Radiation exposures to public (license renewal term). Radiation doses to 

the public will continue at current levels associated with normal operations.

 Occupational radiation exposures (license renewal term). Projected 

maximum occupational doses during the license renewal term are within the 

range of doses experienced during normal operations and normal 

maintenance outages, and would be well below regulatory limits.

In Chapter 5.0 of its ER, Ameren considered the issue of tritium in groundwater on the plant site 

and concluded that it is not a new and significant issue. Based on its review, the NRC staff 

agrees that there is no new and significant information related to tritium in groundwater on the 

plant site. Information on tritium in groundwater at Callaway is discussed in Sections 2.2.5 and 

4.5.2.3.

There are no Category 2 issues related to the radiological impacts of routine operations. 

The information presented below is a discussion of representative radiological programs 

conducted at Callaway.

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4.9.2.2 Callaway Radiological Environmental Monitoring Program

Callaway conducts a radiological environmental monitoring program (REMP) to assess the 

radiological impact, if any, on its employees, the public, and the environment around the plant 

site. Ameren issues an annual radiological environmental operating report that discusses the 

results of the REMP. The report contains data on the monitoring performed for the most recent 

year and graphs that show data trends from prior years and, in some cases, provide a 

comparison to pre-plant operation baseline data. The REMP provides measurements of 

radiation and of radioactive materials for the exposure pathways and the radionuclides that lead 

to the highest potential radiation exposures to the public. The REMP supplements the 

Radioactive Effluent Monitoring Program by verifying that any measurable concentrations of 

radioactive materials and levels of radiation in the environment are not higher than those 

calculated using the radioactive effluent release measurements and transport models.

The REMP provides an independent mechanism for determining the levels of radioactivity in the 

environment to ensure that any accumulation of radionuclides released into the environment will

not become significant as a result of station operations. While in-plant radiation monitoring 

programs are used to ensure that the doses to members of the public from radioactive effluents 

are within the dose limits in 10 CFR Part 20 and the “as low as is reasonably achievable” 

(ALARA) design criteria in Appendix I to 10 CFR Part 50, the REMP provides direct verification 

of any environmental impact that may result from plant effluents.

An annual radiological environmental operating report is issued, which contains numerical data 

and a discussion of the results of the monitoring program for the past year. The REMP collects 

samples of environmental media to measure the radioactivity levels that may be present. The 

locations of most monitoring stations have been selected based on an exposure pathway 

analysis. The exposure pathway analysis considers factors such as weather patterns, 

anticipated radioactive emissions, likely receptors, and land use in the surrounding areas. 

Samples collected from monitoring stations located in areas that are likely to be influenced by 

Callaway operations are used as indicators; samples collected from locations that are not likely 

to be influenced by Callaway operations serve as controls. Results from indicator monitoring 

stations are compared to the results from control monitoring stations and to the results obtained 

during the previous operational and pre-operational years of the program to assess the impact 

that Callaway operations may be having on the environment. The media samples are 

representative of the radiation exposure pathways that may affect the public. 

The REMP measures the aquatic, terrestrial, and atmospheric environments for radioactivity, as 

well as ambient radiation levels on and off site. Ambient radiation pathways include radiation 

from radioactive material inside buildings and plant structures and airborne material that may be 

released from the plant. In addition, the REMP measures background radiation (i.e., cosmic 

sources, global fallout, industrial and medical radioactive wastes, and naturally occurring 

radioactive material, including radon). Thermoluminescence dosimeters are used to measure 

ambient radiation. The atmospheric environmental monitoring consists of sampling and 

analyzing the air for particulates and radioiodine. Terrestrial environmental monitoring consists 

of analyzing samples of local vegetable crops, groundwater, surface water, fish, airborne 

particulates, sediment, vegetation, and milk. An annual land use census is conducted to 

determine if the REMP needs to be revised to reflect changes in the environment or population 

that might alter the radiation exposure pathways.

Callaway has an onsite groundwater protection program designed to monitor the onsite plant 

environment near the reactor building for early detection of leaks from plant systems and pipes 

containing radioactive liquid. Information on the groundwater protection program is presented in 

Sections 2.2.5 and 4.4.2.3 of this SEIS.

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Environmental Impacts of Operation

The NRC staff reviewed five years of annual radiological environmental monitoring data: 2008 

through 2013 (Ameren 2009a, 2009b, 2010a, 2010b, 2011c, 2011d, 2012a, 2012b 2013a, 

2013b). A five-year period provides a representative data set that covers a broad range of 

activities that occur at a nuclear power plant such as refueling outages, routine operation, and 

maintenance work that can affect the generation and release of radioactive effluents into the 

environment. The NRC staff reviewed the data to look for indication of adverse trends 

(i.e., buildup of radioactivity in the environment) over the period of 2008 through 2012.

The NRC staff’s review of Ameren’s REMP data showed no indication of an adverse trend in 

radioactivity levels in the environment. The data showed that there was no measurable impact 

to the environment from operations at Callaway.

4.9.2.3 Callaway Radioactive Effluent Release Program 

All nuclear plants are licensed with the expectation that they will release radioactive material to 

both the air and water during normal operation. However, NRC regulations require that 

radioactive gaseous and liquid releases from nuclear power plants must meet radiation 

dose-based limits, as specified in 10 CFR Part 20, the ALARA criteria, contained in Appendix I 

to 10 CFR Part 50, and the EPA’s regulations at 40 CFR Part 190. Regulatory limits are placed 

on the radiation dose that members of the public can receive from radioactive material released 

by a nuclear power plant. In addition, nuclear power plants are required to file an annual report 

with the NRC that lists the types and quantities of radioactive effluents released into the 

environment. The radioactive effluent release reports are available for review by the public 

through the Agencywide Documents Access and Management System (ADAMS) electronic 

reading room, available through the NRC Web site.

The NRC staff reviewed the annual radioactive effluent release reports for 2008 through 2012 

(Ameren 2009b, 2010b, 2011d, 2012a, 2013a). The review focused on the calculated doses to 

a member of the public from radioactive effluents released from Callaway. The doses were 

compared to the radiation protection standards in 10 CFR 20.1301, “Dose limits for individual 

members of the public,” and the ALARA dose design objectives in Appendix I to 

10 CFR Part 50. Dose estimates for members of the public are calculated based on radioactive 

gaseous and liquid effluent release data and atmospheric and aquatic transport models. The 

2012 effluent release report (Ameren 2013a) was provided to NRC staff during the site 

inspection and contains a detailed presentation of the radioactive discharges and the resultant 

calculated doses. The following list summarizes the calculated hypothetical maximum dose to a 

member of the public located outside the Callaway site boundary from radioactive gaseous and 

liquid effluents released during 2012:

 The maximum whole body dose to an offsite member of the public from 

radioactive liquid effluents is 8.55×10-3 millirem (mrem) (8.55×10-5 millisievert 

(mSv)), which is below the 3-mrem (0.03-mSv) dose criterion in Appendix I to 

10 CFR Part 50.

 The maximum organ dose to an offsite member of the public from radioactive 

liquid effluents is 1.23×10-2 mrem (1.23×10-4 mSv), which is below the 

10-mrem (0.1-mSv) dose criterion in Appendix I to 10 CFR Part 50.

 The maximum air dose at the site boundary from gamma radiation in gaseous 

effluents is 1.03×10-4 milliradiation absorbed dose (mrad) (1.03×10-6 milligray 

(mGy)), which is below the 10-mrad (0.1-mGy) dose criterion in Appendix I to 

10 CFR Part 50.

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Environmental Impacts of Operation

 The maximum air dose at the site boundary from beta radiation in gaseous 

effluents is 2.79×10-4 mrad (2.79×10-6 mGy), which is below the 20-mrad 

(0.2-mGy) dose criterion in Appendix I to 10 CFR Part 50.

 The maximum organ dose to an offsite member of the public at the site 

boundary from radioactive iodine, tritium, carbon-14, and radioactive material 

in particulates with greater than an 8-day half-life is 1.56×10-2 mrem 

(1.56×10-4 mSv), which is below the 15-mrem (0.15-mSv) dose criterion in 

Appendix I to 10 CFR Part 50.

 The maximum whole-body dose to an offsite member of the public from the 

combined radioactive releases (i.e., gaseous, liquid, and direct radiation) is 

7.71×10-3 mrem (7.71×10-5 mSv), which is below the 25-mrem (0.25-mSv) 

dose standard in 40 CFR Part 190, “Environmental Radiation Protection 

Standards for Nuclear Power Operations.” 

Routine plant operational and maintenance activities currently performed will continue during 

the license renewal term. Based on the past performance of the radioactive waste management 

system in maintaining the dose from radioactive effluents at ALARA levels, similar performance 

is expected during the license renewal term.

The radiological impacts from the current operation of Callaway are not expected to change 

significantly. Continued compliance with regulatory requirements is expected during the license 

renewal term; therefore, the impacts from radioactive effluents would be SMALL.

4.9.3 Microbiological Organisms—Human Health

Table B–1 of Appendix B to 10 CFR Part 51, Subpart A, lists the effects of thermophilic 

microbiological organisms on public health as a Category 2 issue that applies to nuclear plants 

that discharge to cooling ponds, lakes, canals, or small rivers (i.e., those with an annual average 

flow rate of less than 3.15 trillion cubic feet (ft3

)/year (89.2 billion cubic meters (m3)/year)). This 

is applicable to Callaway because it uses a cooling tower that receives its makeup from the 

Missouri River and discharges blowdown back to the river. The Missouri River has a flow rate 

of 2.72 trillion ft3

/year (77.0 billion m3/year) and thus meets the criterion for a small river 

(Ameren 2011a).

The Category 2 designation is based on the magnitude of the potential public health impacts 

associated with thermal enhancement of enteric pathogens such as Salmonella spp. and

Shigella spp., the Pseudomonas aeruginosa bacterium, the pathogenic strain of the free-living 

amoebae Naegleria spp., and Legionella spp. bacteria (NRC 1996). Thermophilic 

microorganisms thrive within a range of water temperatures, but can tolerate a broader range of 

temperatures. In general, these organisms occur at temperatures of 77 °F to 158 °F (25 °C to 

70 °C), exhibit optimal growth at temperatures of 122 °F to 150 °F (50 °C to 66 °C), and have 

minimum and maximum temperature tolerances of 68 °F (20 °C) and 176 °F (80 °C); however, 

thermal preferences and tolerances vary across bacterial groups. Pathogenic thermophilic 

microbiological organisms of concern during nuclear reactor operation typically have optimal 

growing temperatures of approximately 99 °F (37 °C) (Joklik and Smith 1972). 

Pseudomonas aeruginosa is an opportunistic pathogen that causes serious and sometimes fatal 

infections in immuno-compromised individuals. The organism produces toxins harmful to 

humans and animals. It has an optimal growth temperature of 99 °F (37 °C) (Todar 2007). 

Legionella spp. consists of at least 46 species and 70 serogroups. It is responsible for 

Legionnaires’ disease, with the onset of pneumonia in the first 2 weeks of exposure. Risk 

groups for Legionella spp. include the elderly, cigarette smokers, persons with chronic lung or 

immuno-compromising disease, and persons receiving immuno-suppressive drugs. 

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Environmental Impacts of Operation

Heated-water discharges into water bodies used by the public can expose members of the 

public to these organisms. Public exposures are limited to the small area of the Missouri River 

near the blowdown discharge. The river in the vicinity of Callaway is not commonly used for 

recreational purposes. Thermophilic organisms are not expected in the blowdown water 

because the circulating water system is periodically chlorinated. There have been no known 

occurrences of Naegleria fowleri or Legionella infection in the vicinity of Callaway. As discussed 

in Section 2.1.6.1 of this SEIS, during the summer when temperatures exceed 60 °F (16 °C), 

Callaway’s water treatment plant adds bleach to the river water taken into the facility. In the 

summer, the discharged heated water rarely exceeds 90 °F (32 °C). The combination of the use 

of bleach, molluscicide, and discharged water rarely exceeding 90 °F (32 °C) are effective 

growth inhibitors for thermophilic organisms. Therefore, the NRC staff concludes that the risk to 

public health from thermophilic microorganisms associated with the potential discharge of 

heated effluent to the Missouri River is SMALL.

4.9.4 Electromagnetic Fields—Acute Effects (Electric Shock)

Based on the GEIS (NRC 1996), the NRC staff found that electric shock resulting from direct 

access to energized conductors or from induced charges in metallic structures has not been 

found to be a problem at most operating plants and, generally, is not expected to be a problem 

during the license renewal term. However, site-specific review is required to determine the 

significance of the electric shock potential along the portions of the transmission lines that are 

within the scope of this SEIS.

In the GEIS (NRC 1996), the NRC staff found that, without a review of the conformance of each 

nuclear plant transmission line with National Electrical Safety Code® (NESC®) criteria, it was 

not possible to determine the significance of the electric shock potential. Evaluation of 

individual plant transmission lines is necessary because the issue of electric shock safety was 

not addressed in the licensing process for some plants. For other plants, land use near 

transmission lines may have changed or power distribution companies may have chosen to 

upgrade line voltage. To comply with 10 CFR 51.53(c)(3)(ii)(H), the applicant must supply an 

assessment of the impact of the proposed action on the potential shock hazard from the 

transmission lines if the transmission lines that were constructed for the specific purpose of 

connecting the plant to the transmission system do not meet the recommendations of the NESC 

for preventing electric shock from induced currents. The NRC uses the NESC criteria as its 

baseline to assess the potential human health impact of the induced current from an applicant’s 

transmission lines. As discussed in the GEIS, the issue of electric shock is of small significance 

for transmission lines that are operated in adherence with the NESC criteria.

In the case of Callaway, there have been no previous NRC or NEPA analyses of 

transmission-line-induced current hazards. Therefore, Ameren has given an analysis, based on 

computer modeling, of the conformance of the plant’s transmission lines with the NESC 

standard of inducing no more than 5 milliamps in a vehicle located under a transmission line.

Four 345-kV lines were specifically constructed to distribute power from Callaway to the electric 

grid. Ameren’s analysis of these transmission lines began by identifying the worst-case ruling 

span for each line. The limiting case is the configuration along each line for which the potential 

for current-induced shock would be greatest. Once the limiting case was identified, Ameren 

calculated the electric field strength for each transmission line and then calculated the induced 

current. Ameren calculated electric field strength and induced current using the computer code 

FIELDS 2.0 produced by Southern California Edison. The input parameters included the design 

features of the limiting-case scenario and the maximum vehicle size under the lines (a 

tractor-trailer). All of the transmission lines conform to the NESC’s electrical shock standard of 

inducing no more than 5 milliamps.

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Environmental Impacts of Operation

The NRC staff reviewed the available information, and, based on this information, the staff 

concludes that because Callaway’s transmission lines are within the NESC’s electrical shock 

standard of 5 milliamps, the potential impacts from electric shock during the renewal period 

would be SMALL.

4.9.5 Electromagnetic Fields—Chronic Effects

In the GEIS, the effects of chronic exposure to 60-hertz electromagnetic fields from powerlines 

were not designated as Category 1 or 2 (i.e., categorization and impact finding definitions do not 

apply to this chronic effect issue, or not applicable) and will remain uncategorized until a 

scientific consensus is reached on the health implications of these fields.

The potential effects of chronic exposure from these fields continue to be studied and are not 

known at this time. The National Institute of Environmental Health Sciences (NIEHS) directs 

related research through the U.S. Department of Energy (DOE).

The report by NIEHS (NIEHS 1999) presents the following conclusion:

The NIEHS concludes that ELF-EMF (extremely low frequency electromagnetic 

field) exposure cannot be recognized as entirely safe because of weak scientific 

evidence that exposure may pose a leukemia hazard. In our opinion, this finding 

is insufficient to warrant aggressive regulatory concern. However, because 

virtually everyone in the United States uses electricity and therefore is routinely 

exposed to ELF-EMF, passive regulatory action is warranted such as continued 

emphasis on educating both the public and the regulated community on means 

aimed at reducing exposures. The NIEHS does not believe that other cancers or 

non-cancer health outcomes provide sufficient evidence of a risk to currently 

warrant concern.

This statement is not sufficient to cause the staff to change its position with respect to the 

chronic effects of electromagnetic fields. The staff considers the GEIS finding of “UNCERTAIN” 

still appropriate and will continue to follow developments on this issue.

4.10 Socioeconomics

The socioeconomic issues applicable to the Callaway license renewal are shown in Table 4–9 

for Category 1 and Category 2 issues. Section 2.2.9 of this SEIS describes the socioeconomic 

conditions near Callaway.

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Table 4–9. Socioeconomic Issues

Issues GEIS Section Category

Housing impacts 4.7.1 2

Public services: public safety, social services, and tourism and 

recreation

4.7.3, 4.7.3.3, 

4.7.3.4, 4.7.3.6 1 

Public services: public utilities 4.7.3.5 2

Public services: education (license renewal) 4.7.3.1 1

Offsite land use (license renewal term) 4.7.4 2

Public Services: transportation 4.7.3.2 2

Historic and archaeological resources 4.7.7 2

Aesthetic impacts (license renewal term) 4.7.6 1

Aesthetic impacts of transmission lines (license renewal term) 4.5.8 1

Environmental justice 4.10 (a) 2

(a) NRC 2013 (GEIS) 

Sources: 61 FR 28467, June 5, 1996

4.10.1 Generic Socioeconomic Issues

The Ameren ER (Ameren 2011a), scoping comments, and other available data records on 

Callaway were reviewed and evaluated for new and significant information. The review included 

a data-gathering site visit to Callaway. No new and significant information was found during this 

review that would change the conclusions presented in the GEIS. Therefore, for these 

Category 1 issues, impacts during the renewal term are not expected to exceed those 

discussed in the GEIS, which are evaluated as SMALL. For the Callaway license renewal, the 

NRC incorporates these GEIS conclusions by reference. Impacts for Category 2 and the 

uncategorized issue (environmental justice) are discussed in Sections 4.9.2 through 4.9.7. In 

evaluating the potential socioeconomic impacts resulting from license renewal, the NRC uses as 

its baseline the existing socioeconomic conditions described in Section 2.2.9 of this SEIS. 

These baseline socioeconomic conditions include existing housing, transportation, offsite land 

use, demographic, public services, and economic conditions affected by ongoing operations at 

the nuclear power plant.

4.10.2 Housing Impacts

Appendix C (Section C.1.4) of the GEIS (NRC 1996) and Section 2.2.9 of this SEIS present a 

population characterization method used to describe the remoteness of the plant based on two 

factors, sparseness and proximity. Sparseness describes population density and city size within 

20 mi (32 km) of a site, and proximity describes population density and city size within 50 mi 

(80 km). According to the GEIS, if there are fewer than 40 persons per square mile and there is 

no community with 25,000 or more people within 20 mi (32 km) of a site, the population is 

sparseness Category 1 (most sparse). Also according to the GEIS, if there are one or more 

cities with 100,000 or more people and fewer than 190 persons per square mile within 50 mi 

(80 km) of the site, the population is considered a proximity Category 3 (not close to the site).

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An estimated 46,804 people live within 20 mi (32 km) of Callaway, which equates to a 

population density of 37 persons per square mile, or sparseness Category 1 (most sparse). An 

estimated 601,200 people live within 50 mi (80 km) of Callaway, with a population density of 

65 persons per square mile. The City of Columbia is within 50 mi (80 km) of Callaway and has 

a population of over 100,000. Thus, the population is a proximity Category 3 (not close to the 

site) (USCB 2012a).

A matrix is used to combine the categories for sparseness and proximity into a single descriptor 

of the remoteness of the plant based on a population characterization of low, medium, or high 

(NRC 1996, Figure C.1). “Low” corresponds to the most sparse population category and sites 

not in close proximity to large cities, whereas “high” corresponds to the least sparse population 

category and sites that are in close proximity to large cities. Based on the sparseness and 

proximity categories 1 and 3, respectively, the combined population descriptor for the 

remoteness of Callaway is “medium.” 

Table B–1 of Appendix B to 10 CFR Part 51, Subpart A, states housing impacts are expected to 

be of small significance. Since Ameren has no planned refurbishment activities and the 

socioeconomic region of influence (ROI) (Boone, Callaway, and Cole Counties) is not subject to 

growth-control measures that would limit housing development, any changes in employment at 

Callaway would have little noticeable effect on housing availability in these counties. Since 

Ameren has no plans to add non-outage employees during the license renewal period, 

employment levels at Callaway would remain relatively constant, and there would be no 

additional demand for permanent housing during the license renewal term. Based on this 

information, the NRC staff concludes that there would be no additional impact on housing during 

the license renewal term beyond what is already being experienced.

4.10.3 Public Services: Public Utilities

Impacts on public utility services (e.g., water, sewer) are considered SMALL if the public utility 

has the ability to respond to changes in demand and would have no need to add or modify 

facilities. Impacts are considered MODERATE if service capabilities are overtaxed during 

periods of peak demand. Impacts are considered LARGE if additional system capacity is 

needed to meet ongoing demand.

Analysis of impacts on the public water systems considered both plant demand and 

plant-related population growth. Section 2.1.7 describes the permitted withdrawal rate and 

actual use of water for reactor cooling at Callaway.

Since Ameren has no plans to add non-outage employees during the license renewal period, 

employment levels at Callaway would remain relatively unchanged, resulting in no additional 

demand for public water services. Public water systems in the socioeconomic ROI are currently 

adequate to meet the demands of residential and industrial customers in the area 

(Ameren 2011a). Therefore, the NRC staff concludes that there would be no additional impact 

on public water services during the license renewal term beyond what is already being 

experienced. 

4.10.4 Public Services: Transportation Impacts

Table B–1 of Appendix B to 10 CFR Part 51, Subpart A, states transportation impacts (level of 

service) of highway traffic generated during plant refurbishment and during the term of the 

renewed license are generally expected to be of small significance. Since Ameren has no plans 

to add non-outage employees during the license renewal period, traffic volume and levels of 

service on roadways in the vicinity of Callaway would not change. Therefore, the NRC staff 

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concludes that there would be no transportation impacts during the license renewal term beyond 

those already being experienced.

4.10.5 Offsite Land Use—License Renewal Term

Table B–1 of Appendix B to 10 CFR Part 51, Subpart A, states that offsite land use impacts 

resulting from license renewal are expected to be of small significance. As discussed in 

Sections 4.10.2, 4.10.3, and 4.10.4, it is not expected that there would be any change in the 

staffing levels at Callaway or increased demand for additional housing, public services related to 

public utilities, and transportation during the license renewal period. Based on this information, 

the NRC staff concludes that there would be no additional impact on housing during the license 

renewal term beyond what is already being experienced.

4.10.5.1 Population-Related Impacts

Since Ameren has no plans to add non-outage employees during the license renewal period, 

there would be no plant operations-driven population increase in the vicinity of Callaway. 

Therefore, the NRC staff concludes that there would be no additional population-related offsite 

land use impacts during the license renewal term beyond those already being experienced.

4.10.5.2 Tax Revenue-Related Impacts

As discussed in Chapter 2, Ameren pays property taxes for Callaway to Callaway County and 

the South Callaway R-II School District. Since Ameren started making property tax payments to 

local jurisdictions, population levels and land use conditions in Callaway County have remained 

relatively unchanged (Ameren 2011a). Therefore, tax revenue from Callaway has had little or 

no effect on land use conditions within the county.

Since employment levels at Callaway would remain relatively unchanged and there would be no 

increase in the assessed value of Callaway, annual property tax payments would also be 

expected to remain relatively unchanged throughout the license renewal period. Based on this 

information, the NRC staff concludes that there would be no additional tax-revenue-related 

offsite land use impacts during the license renewal term beyond those already being 

experienced.

4.10.6 Historic and Archaeological Resources

The National Historic Preservation Act (NHPA) requires Federal agencies to take into account 

the potential effects of their undertakings on historic properties. Historic properties are defined 

as resources that are listed or eligible for listing on the National Register of Historic Places 

(NRHP). The criteria for eligibility include the following (NPS 1997):

 association with significant events in history;

 association with the lives of persons significant in the past;

 embodiment of distinctive characteristics of type, period, or construction; and

 association with or potential to yield important information on history or 

prehistory.

The historic preservation review process, mandated by Section 106 of the NHPA, is outlined in 

regulations issued by the Advisory Council on Historic Preservation (ACHP) in 36 CFR Part 800 

(ACHP 2004). The issuance of a renewed operating license for a nuclear power plant is a 

Federal undertaking that could possibly affect either known or potential historic properties 

located on or near the plant and its associated transmission lines. In accordance with the 

provisions of the NHPA, the NRC is required to make a reasonable effort to find historic 

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properties in the area of potential effect (APE). If no historic properties are present or affected, 

the NRC is required to notify the State Historic Preservation Office (SHPO) before proceeding. 

If it is determined that historic properties are present, the NRC is required to assess and resolve 

possible adverse effects of the undertaking.

In accordance with 36 CFR 800.8(c), the NRC initiated Section 106 consultation with the ACHP

and the Missouri SHPO in April 2012 by notifying them of the agency’s intent to conduct a 

review of a request from Ameren to renew Callaway’s operating license (NRC 2012c, 2012d). 

Documentation for consultation with the ACHP and the Missouri SHPO is presented in 

Appendix D. On February 14, 2013, the Missouri SHPO responded to the NRC with the 

determination that the proposed renewal of the operating license for Callaway would have no 

adverse effect on any properties that are listed in or that have been determined eligible for 

listing on the NRHP. 

The NRC also initiated consultation with 29 Federally recognized Native American tribes, 

notifying them of the proposed action and requesting comments and concerns (NRC 2012e). 

To date, two of the tribes, the Osage Nation and the Choctaw Nation of Oklahoma, have 

responded (Choctaw Nation of Oklahoma 2012; Osage Nation 2012). The Choctaw Nation of 

Oklahoma indicated that the Callaway site is outside its area of interest. The Osage Nation 

indicated its interest in the undertaking and consultation and has been in contact with the NRC 

during the reviewing process. Documentation for tribal consultation is presented in Appendix D. 

As of the time of publication of this SEIS, the other 27 tribes contacted have not responded to 

the NRC.

Ameren currently has no planned changes or refurbishment activities associated with the 

license renewal of Callaway. However, given the number of cultural resources already located 

on Ameren property and the high potential for discovery of additional historic and archaeological 

resources during normal operational and maintenance activities; Ameren has developed formal 

guidelines for protecting archaeological resources in its cultural resources management plan 

(CRMP), entitled A Cultural Resource Management Plan for Residual Lands at the Callaway 

Plant, Callaway County, Missouri. Ameren’s guidelines include the following procedures for the 

management of historic and archaeological resources: (1) posting resources for protective 

purposes, (2) fencing resources that are in locations with the potential for inadvertent 

disturbance during plant operation or maintenance activities, (3) avoiding resources during plant 

operation or maintenance that have the potential to result in ground disturbance, and 

(4) monitoring sites to ensure that they are not impacted. However, in accordance with the 

Callaway CRMP, certain activities are allowed at resource locations, depending on the NRHPeligibility status of the resource. For example, low-profile or shallow plowing and discing is 

permitted at the locations of certain archaeological sites that have been determined not eligible 

for listing in the NRHP if these are areas that have been historically farmed and are currently 

used for farming (Ameren 2011a).

The CRMP also requires that all proposed activities with the potential to disturb historic and 

archaeological resources within the boundaries of the Ameren property be reviewed by 

Ameren’s Cultural Resources Manager, regardless of their NRHP-eligibility or whether the 

activities are within the fenced area managed by Ameren or within the Reform Conservation 

Area. Ameren’s Cultural Resources Manager must indicate approval of all activities or must 

work with the proponents of the activity to ensure that any resources that are present are 

protected and avoided (e.g., through the use of fencing and establishing buffer zones). Any 

new construction or change in operating procedures requires an assessment of whether there 

will be a physical change to the Callaway site or an excavation of Ameren property outside the 

owner-controlled fenced area that is the Callaway site. If the answer is yes to either of these 

queries, then a Final Environmental Evaluation is required, including a full evaluation of potential 

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cultural resources impacts. In the event that a resource cannot be avoided, regardless of 

previous NRHP-eligibility determinations, Ameren will consult with the Missouri SHPO before 

implementing the proposed activity (Ameren 2011a).

Ameren also has procedures for the inadvertent discovery of cultural resources during 

construction projects. These procedures have been incorporated into Ameren’s Excavation 

Construction and Safety Standards and include instructions for supervisors to notify Ameren’s 

Environmental Services Department immediately upon an inadvertent discovery 

(Ameren 2011a).

As discussed in Section 2.2.10, there are 129 known historic and archaeological resources on 

the Ameren property, including 25 archaeological resources that have been determined eligible, 

or potentially eligible, for listing in the NRHP. All of these resources have been located and 

posted and are protected and managed in accordance with the CRMP, including those 

resources located in areas managed by the MDC. 

Based on the NRC staff’s review of Missouri SHPO files and records for the Ameren property 

(including the Callaway site and the areas managed by the MDC), published literature for the 

region, Ameren’s cultural resource protection procedures and activities, and the Callaway site 

visit, the NRC staff concludes that potential impacts from the license renewal of Callaway on 

historic and archaeological resources would be SMALL. In accordance with the NHPA, the 

NRC has determined that there would be no effect on historic properties per 

36 CFR 800.4(d)(1).

4.10.7 Environmental Justice

In Executive Order 12898, Federal Actions to Address Environmental Justice in Minority

Populations and Low-Income Populations, 59 FR 7629 (Feb. 11, 1994), as amended in 

60 FR 6381 (Jan. 30, 1995), the President ordered that each Federal agency shall make 

achieving environmental justice part of its mission by identifying and addressing, as appropriate,

disproportionately high and adverse human health or environmental effects of its programs,

policies, and activities on minority populations and low-income populations. In 2004, the 

Commission issued a Policy Statement on the Treatment of Environmental Justice Matters in 

NRC Regulatory and Licensing Actions (69 FR 52040), which states, “The Commission is 

committed to the general goals set forth in E.O. 12898, and strives to meet those goals as part 

of its NEPA review process.”

The following summarizes the information provided by the Council on Environmental Quality

(CEQ) in Environmental Justice: Guidance under the National Environmental Policy Act

(CEQ 1997):

Disproportionately High and Adverse Human Health Effects.

Adverse health effects are measured in risks and rates that could result in latent cancer 

fatalities, as well as other fatal or nonfatal adverse impacts on human health. Adverse 

health effects may include bodily impairment, infirmity, illness, or death. 

Disproportionately high and adverse human health effects occur when the risk or rate of 

exposure to an environmental hazard for a minority or low-income population is 

significant (as employed by NEPA) and appreciably exceeds the risk or exposure rate for 

the general population or for another appropriate comparison group.

Disproportionately High and Adverse Environmental Effects.

A disproportionately high environmental impact that is significant (as employed by 

NEPA) refers to an impact or risk of an impact on the natural or physical environment in 

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a low-income or minority community that appreciably exceeds the environmental impact 

on the larger community. Such effects may include ecological, cultural, human health, 

economic, or social impacts. An adverse environmental impact is an impact that is 

determined to be both harmful and significant (as employed by NEPA). In assessing 

cultural and aesthetic environmental impacts, impacts that uniquely affect geographically 

dislocated or dispersed minority or low-income populations or American Indian tribes are 

considered.

The environmental justice analysis assesses the potential for disproportionately high and 

adverse human health or environmental effects on minority and low-income populations that 

could result from the operation of Callaway during the renewal term. In assessing the impacts, 

the following definitions of minority individuals and populations and low-income population were 

used (CEQ 1997):

Minority individuals

Individuals who identify themselves as members of the following population groups: 

Hispanic or Latino, American Indian or Alaskan Native, Asian, Black or 

African-American, Native Hawaiian or Other Pacific Islander, or two or more races, 

meaning individuals who identified themselves on a Census form as being a member of 

two or more races, for example, Hispanic and Asian.

Minority populations

Minority populations are identified when (1) the minority population of an affected area 

exceeds 50 percent or (2) the minority population percentage of the affected area is 

meaningfully greater than the minority population percentage in the general population 

or other appropriate unit of geographic analysis.

Low-income population

Low-income populations in an affected area are identified with the annual statistical 

poverty thresholds from the Census Bureau's Current Population Reports, Series P-60, 

on Income and Poverty.

4.10.7.1 Minority Population within 50 Miles of Callaway 

According to 2010 Census data, 11.2 percent of the approximately 601,200 persons residing 

within a 50-mi (80-km) radius of Callaway identified themselves as minority individuals. The 

largest minority group was Black or African-American (5.4 percent), followed by Hispanic or 

Latino (2.2 percent) (USCB 2012b).

Of the 388 block groups located within a 50-mi (80-km) radius of Callaway, 121 block groups 

had minority populations that exceeded 11.2 percent (USCB 2012b). Twenty-three of the 

388 census block groups located within the 50-mi (80-km) radius of Callaway had minority 

populations exceeding 31.2 percent. Using 2010 Census data, Figure 4–1 shows minority 

population block groups within a 50-mi (80-km) radius of Callaway (USCB 2012b).

Minority population block groups within the 50-mi (80-km) radius are concentrated in Boone and 

Cole Counties, primarily in the cities of Jefferson and Columbia, respectively. The minority 

population nearest to Callaway is located in the City of Jefferson.

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Figure 4–1. 2010 Census Minority Block Groups Within a 50-Mile Radius

of the Callaway Plant

Source: USCB 2012b

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4.10.7.2 Low-Income Population within 50 Miles of Callaway 

According to 2010 American Community Survey Census data, approximately 12.7 percent of 

individuals residing in the 388 block groups within 50 mi (80 km) of Callaway were found to live 

below the Federal poverty threshold in 2010. The 2010 Federal poverty threshold was $22,314

for a family of four (USCB 2012a).

Of the 388 block groups located within 50 mi (80 km) of Callaway, 147 block groups had 

percentages of individuals living in poverty exceeding 12.7 percent. Thirty-six of these block 

groups had percentages of individuals living in poverty greater than 32.7 percent. Figure 4–2 

identifies low-income block groups within a 50-mi (80-km) radius of Callaway. 

The majority of low-income population block groups are located in Boone and Cole Counties, 

and smaller concentrations of low-income population block groups are located in Callaway 

County. The low-income population nearest to Callaway is located in Callaway County in West 

Fulton and Caldwell, which are over 15 mi (24 km) from the site.

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Figure 4–2. 2010 Census Low-Income Block Groups Within a 50-Mile Radius

of the Callaway Plant

Source: USCB 2012b

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4.10.7.3 Analysis of Impacts

The NRC addresses environmental justice matters for license renewal through (1) finding the 

location of minority and low-income populations that may be affected by the continued operation 

of the nuclear power plant during the license renewal term, (2) determining whether there would 

be any potential human health or environmental impacts on these populations and special 

pathway receptors, and (3) determining whether any of the effects may be disproportionately 

high and adverse.

Figures 4–1 and 4–2 identify the location of minority and low-income block group populations 

within a 50-mi (80-km) radius of Callaway. This area of impact is consistent with the impact 

analysis for public and occupational health and safety, which also focuses on populations within 

a 50-mi (80-km) radius of the plant. Chapter 4 presents an assessment of environmental and 

human health impacts for each resource area. The analyses of impacts for all environmental 

resource areas indicated that the impact from license renewal would be SMALL.

Potential adverse human health or environmental impacts on minority and low-income 

populations (including migrant workers and Native Americans) would mostly consist of 

radiological effects; however, radiation doses from continued operations during the license 

renewal term are expected to continue at current levels and would remain within regulatory 

limits. Chapter 5 of this SEIS discusses the environmental impacts from postulated accidents

that might occur during the license renewal term, which include both design-basis and severe 

accidents. In both cases, the Commission has generically determined that impacts associated 

with design-basis accidents are small because nuclear plants are designed and operated to 

successfully withstand such accidents, and the probability-weighted consequences of severe 

accidents are small.

Therefore, based on this information and the analysis of human health and environmental 

impacts presented in Chapters 4 and 5 of this SEIS, there would be no disproportionately high 

and adverse impacts on minority and low-income populations from the continued operation of 

Callaway during the license renewal term.

As part of addressing environmental justice concerns associated with license renewal, the NRC 

also assessed the potential radiological risk to special population groups (e.g., migrant workers 

or Native Americans) from exposure to radioactive material received through their unique 

patterns of consumption and interaction with the environment, including subsistence 

consumption of fish, native vegetation, surface waters, sediments, and local produce; 

absorption of contaminants in sediments through the skin; and inhalation of airborne radioactive 

material released from the plant during routine operation. This analysis is presented below.

4.10.7.4 Subsistence Consumption of Fish and Wildlife

The special pathway receptors analysis is an important part of the environmental justice

analysis because consumption patterns may reflect the traditional or cultural practices of 

minority and low-income populations in the area, such as migrant workers or Native Americans. 

Section 4–4 of E.O. 12898 (1994) (59 FR 7629) directs Federal agencies, whenever practicable 

and appropriate, to collect and analyze information on the consumption patterns of populations 

that rely principally on fish and/or wildlife for subsistence and to communicate the risks of these 

consumption patterns to the public. In this SEIS, NRC considered whether there were any 

means for minority or low-income populations to be disproportionately affected by examining 

impacts on Native Americans, Hispanics, migrant workers, and other traditional lifestyle special 

pathway receptors. The special pathways took into account the levels of radiological and 

nonradiological contaminants in native vegetation, crops, soils and sediments, groundwater, 

surface water, fish, and game animals on or near Callaway.

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The following is a summary of the discussion presented in Section 4.8.2 of this SEIS regarding 

the evaluation of the REMP that assesses the potential impacts associated with subsistence 

consumption of fish and wildlife near Callaway.

Ameren has an ongoing comprehensive REMP to assess the impact of Callaway operations on 

the environment. To assess the impact of nuclear power plant operations, samples are 

collected annually from the environment and analyzed for radioactivity. An affect associated 

with plant operations would be indicated if the level of radioactivity detected in a sample was 

significantly greater than the background levels. Two types of samples—control samples and 

indicator samples—are collected. Control samples are collected from areas that are beyond the 

measurable influence of the nuclear power plant or any other nuclear facility. The analytical 

results of these samples are used as reference data to determine normal background levels of 

radiation in the environment. These sample results are then compared to the analytical results 

of indicator samples, which are collected near the nuclear power plant. Indicator samples are 

collected from areas where any contribution from the nuclear power plant will be at its highest 

concentration. The analytical results of these samples are then used to evaluate the 

contribution of nuclear power plant operations to radiation or radioactivity levels in the 

environment. An effect would be indicated if the radioactivity level detected in an indicator 

sample was significantly greater than the level detected in the control sample or background 

levels.

Ameren collects samples of environmental media from the aquatic and terrestrial pathways in 

the vicinity of Callaway. The aquatic pathways include groundwater, surface water, drinking 

water, fish, and shoreline sediment. The terrestrial pathways include airborne particulates, milk, 

edible vegetation (i.e., leafy vegetables such as cabbage, collards, and Swiss chard), and 

broad-leaf vegetation. During 2011, analyses performed on samples of environmental media at 

Callaway showed no significant or measurable radiological impact above background levels 

from site operations (Ameren 2011c).

Based on the radiological environmental monitoring data from Callaway, the NRC finds that no 

disproportionately high and adverse human health impacts would be expected in special 

pathway receptor populations in the region as a result of subsistence consumption of water, 

local food, fish, and wildlife.

4.11 Evaluation of New and Potentially Significant Information

New and significant information is: (1) information that identifies a significant environmental 

issue not covered in the GEIS and codified in Table B-1 of 10 CFR Part 51, Subpart A, 

Appendix B, or (2) information that was not considered in the analyses summarized in the GEIS 

and that leads to an impact finding that is different from the finding presented in the GEIS and 

codified in 10 CFR Part 51.

Ameren's assessment of potentially new and significant information conducted during the 

preparation of this license renewal application included: (1) interviews with Ameren and 

Callaway staff on the validity of the conclusions in the GEIS as they relate to Callaway, 

(2) review of Callaway’s environmental management systems to determine if the Callaway staff 

would be made aware of new and significant information, (3) review of documents related to 

environmental issues at Callaway and the site and regional environs, (4) coordination with 

Federal and State agencies, (5) contracting with industry experts to perform an independent 

review of environmental impacts, and (6) review of any issues that arose during preparation of 

the proposed Unit 2 combined license application.

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The NRC’s process for identifying new and significant information includes: (1) review of an 

applicant’s ER and the process for discovering and evaluating the significance of new 

information; (2) review of records of public comments; (3) review of environmental quality 

standards and regulations; (4) coordination with Federal, state, and local environmental 

protection and resource agencies, and (5) review of the technical literature. New information 

discovered by the staff is evaluated for significance using the criteria set forth in the GEIS. For 

Category 1 issues where new and significant information is identified, reconsideration of the 

conclusions for those issues is limited in scope to the assessment of the relevant new and 

significant information; the scope of the assessment does not include other facets of an issue 

that are not affected by the new information. 

The staff has not identified any new and significant information on environmental issues listed in 

Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, related to the operation of Callaway 

during the period of license renewal. Ameren stated in its ER for Callaway that it is not aware of 

any new and significant information regarding the environment or plant operations. However, as 

part of its investigation for new and significant information, Ameren evaluated information about 

tritium in the groundwater beneath the Callaway site. Based on that evaluation, Ameren 

concluded that the review did not identify any information that would affect the NRC’s 

Category 1 findings in the GEIS. Based on this information, the staff concludes that there is no 

new and significant information on environmental issues related to the operation of Callaway 

during the period of license renewal.

4.12 Cumulative Impacts

As summarized in Section 4.0, the NRC has approved a revision to its environmental protection 

regulation, 10 CFR Part 51. With respect to cumulative impacts, the final rule amends 

Table B–1 in Appendix B to 10 CFR Part 51, Subpart A by adding a new Category 2 issue, 

“Cumulative impacts,” to evaluate the potential cumulative impacts of license renewal. 

The NRC considered potential cumulative impacts in the environmental analysis of continued 

operation of Callaway during the 20-year license renewal period. Cumulative impacts may 

result when the environmental effects associated with the proposed action are overlaid or added 

to temporary or permanent effects associated with other past, present, and reasonably 

foreseeable future actions. Cumulative impacts can result from individually minor, but 

collectively significant, actions taking place over a period of time. It is possible that an impact 

that may be SMALL by itself could result in a MODERATE or LARGE cumulative impact when 

considered in combination with the impacts of other actions on the affected resource. Likewise, 

if a resource is regionally declining or imperiled, even a SMALL individual impact could be 

important if it contributes to or accelerates the resource’s overall decline.

For the purposes of this cumulative analysis, past actions are those before the receipt of the 

license renewal application, present actions are those related to the resources at the time of 

current operation of the power plant, and future actions are those that are reasonably 

foreseeable through the end of plant operation, including the period of extended operation. 

Therefore, the analysis considers potential impacts through the end of the current license terms 

as well as the 20-year renewal license term. The geographic area over which past, present, 

and reasonably foreseeable future actions would occur is dependent on the type of action 

considered and is described below for each resource area.

To evaluate cumulative impacts, the incremental impacts of the proposed action, as described 

in Sections 4.1 to 4.9, are combined with other past, present, and reasonably foreseeable future 

actions regardless of what agency (Federal or non-Federal) or person undertakes such actions. 

The staff used the information provided in the ER (Ameren 2011a); responses to RAI; 

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information from other Federal, State, regional and local agencies; scoping comments; and 

information gathered during the visits to the Callaway site to identify other past, present, and 

reasonably foreseeable future actions. To be considered in the cumulative analysis, the staff 

determined whether the project would occur within the noted geographic areas of interest and 

within the period of extended operation, was reasonably foreseeable, and whether there would 

be potential overlapping effect(s) with the proposed project. For past actions, consideration 

within the cumulative impacts assessment is resource- and project-specific. In general, the 

effects of past actions are included in the description of the affected environment in Chapter 2, 

which serves as the baseline for the cumulative impacts analysis. However, past actions that 

continue to have an overlapping effect on a resource potentially affected by the proposed action 

are considered in the cumulative analysis.

Ameren gave the following information on the status of construction plans for a Unit 2:

In 2008, Ameren submitted to the NRC an application for a combined license for 

a U.S. Evolutionary Power Reactor designed as Callaway Unit 2. However, in 

2009, Ameren suspended its efforts to build this new plant, and requested that 

the NRC staff suspend all activities relating to the application. In 2010, Ameren 

informed the NRC that it would instead pursue an early site permit (ESP). 

Consequently, Ameren is currently not proposing to construct or operate a new 

unit at the site. Cumulative impacts of any future project for a new unit will be 

addressed in the ESP application. (Ameren 2011a).

Ameren has no current plans to construct a Unit 2; therefore, this project is not reasonably 

foreseeable and consequently was not analyzed during the license renewal application review. 

Ameren also has shown interest in the development of small modular reactors (SMRs). These 

reactors generally have generating capacities less than 300 megawatts (MW) (IAEA 2009). On 

April 12, 2012, Ameren announced that it had entered into an agreement with Westinghouse 

Electric Company to exclusively support Westinghouse’s application for DOE’s SMR investment 

funds. However, because none of the current design concepts are commercially available, an 

SMR project is not reasonably foreseeable during the license renewal term and was not 

analyzed during the license renewal application review (see Section 8.5.6).

Other actions and projects that were identified during this review and considered in the staff’s 

independent analysis of the potential cumulative effects are shown on Figure 4–3 and described 

in Appendix G. These actions and projects include the following:

 Ameren’s plans for future projects (not shown on Figure 4-3), including:

― reactor vessel head replacement (onsite project), 

― proposed construction of an independent spent fuel storage installation

(ISFSI, onsite project), and 

― maintenance of transmission line corridors; 

 transportation projects, including:

― Callaway County Connector and

― future of Interstate 70;

 Missouri River Mitigation Project;

 Big Muddy National Fish and Wildlife Refuge; and

 MDC Natural/Conservation Areas.

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Figure 4–3. Projects and Actions With Potential for Cumulative Impacts

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4.12.1 Air Quality

This section addresses the direct and indirect effects of license renewal on air quality when 

added to the aggregate effects of other past, present, and reasonably foreseeable future 

actions. In evaluating the potential impacts on air quality associated with license renewal, the 

NRC staff uses as its baseline the existing air quality conditions described in Section 2.2.2.1 of 

this SEIS. These baseline conditions encompass the existing air quality conditions (EPA’s 

National Ambient Air Quality Standards county designations) potentially affected by air 

emissions from license renewal. Air quality in Callaway County is under the jurisdiction of the 

Missouri Department of Natural Resources (MDNR) and Region 7 of EPA. There are no 

counties designated by EPA as nonattainment or maintenance counties for any of the criteria 

pollutants within a 50-mi (80-km) radius of the Callaway site. The closest nonattainment area is 

the St. Louis-St. Charles–Farmington, MO–IL ozone nonattainment area. The counties closest 

to Callaway within this area are Franklin and Warren Counties. Within the nonattainment area, 

air pollutant emission sources, both stationary and mobile sources, are prevalent. 

As discussed in Section 2.2.2.1, “Air Quality,” the Missouri Air Pollution Control Program of the 

MDNR has primary responsibility for regulating air emission sources within the State of 

Missouri. The MDNR carries out ambient air monitoring in the State, operating 52 sites 

throughout the State with approximately 72 monitors.

Greenhouse Gas and Climate Change. In April 2012, EPA published the official U.S. inventory 

of greenhouse gas (GHG) emissions, which finds and quantifies the primary anthropogenic 

sources and sinks of GHGs. The EPA GHG inventory is an essential tool for addressing climate 

change and participating with the United Nations Framework Convention on Climate Change to 

compare the relative global contribution of different emission sources and GHGs to climate 

change. EPA estimates that energy-related activities in the United States account for 

three-quarters of human-generated GHG emissions, mostly in the form of carbon dioxide 

emissions from burning fossil fuels. More than half of the energy-related emissions come from 

major stationary sources such as power plants, and approximately one-third comes from 

transportation. Industrial processes (production of cement, steel, and aluminum), agriculture, 

forestry, other land use, and waste management are also important sources of GHG emissions 

in the United States (EPA 2012b). EPA reported that, in 2010, the total amount of carbon 

dioxide equivalent (CO2e) emissions related to electricity generation was 2,277.3 teragrams 

(2,277.3 million metric tons (MMT)) (EPA 2012b). The U.S. Energy Information Administration

(EIA) reported that, in 2010, electricity production in Missouri was responsible for 78.8 MMT of 

CO2e emissions, or 3.46 percent of the national total (EIA 2012). Greenhouse gas emission 

sources at Callaway include an auxiliary boiler and emergency power supply diesel generators. 

The NRC staff estimates that annual CO2e emissions from operation at Callaway amount to 

5,100 tons (4,600 metric tons).

The U.S. Global Climate Research Program (USGCRP) reports that from 1895 to 2012, 

U.S. average surface temperatures have increased by 1.3 to 1.9 °F (Walsh et al. 2014). Climate 

change research indicates that the cause of the observed warming is the buildup of GHGs in the 

atmosphere, resulting from human activities (Walsh et al. 2014). For the Midwest, where 

Callaway is located, average air temperatures from 1900 to 2010 increased by 1.5 °F, and 

warming in recent decades has been increasing at a faster rate (Pryor et al. 2014). For the 

license renewal period of Callaway, climate models indicate an increase in annual mean 

temperature for the Midwest of 2.5 to 3.5 °F (between 2021 and 2050 relative to the reference 

period (1971 to 1999)) (NOAA 2013; Pryor et al. 2014). The predicted increase in temperature 

during this time period occurs for all seasons, with the largest increase occurring in the 

summertime (June, July, and August). From 1958 to 2012, the Midwest experienced a 

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37-percent increase in heavy precipitation; projected future changes in precipitation patterns 

have been difficult to quantify on a regional scale. Climate model simulations (for the time 

period 2021 to 2050) suggest spatial differences in annual mean precipitation changes for 

Missouri with northern areas experiencing an increase in precipitation and the southern areas 

experiencing a decrease in precipitation. However, these changes in precipitation are not 

significant, and the models indicate changes that are less than normal year-to-year variations 

(NOAA 2013). Model projections, however, do indicate continued increases in heavy 

precipitation events (Walsh et al. 2014).

Climate Change and Air Quality. Changes in climate can impact air quality as a result of the 

changes in meteorological conditions. The formation, transport, dispersion, and deposition of 

air pollutants are sensitive to winds, temperature, humidity, and precipitation. Sunshine, high 

temperatures, concentration of precursors, and air stagnation are favorable meteorological 

conditions to higher levels of ozone (Luber et al. 2014). The emission of ozone precursors 

(nitrogen oxides and volatile organic compounds) also depends on temperature, wind, and solar 

radiation (IPCC 2007). The combination of higher temperatures, stagnant air masses, sunlight, 

and emissions of precursors may make the task of meeting the ozone National Ambient Air 

Quality Standards (Karl et al. 2009; Pryor et al. 2014) difficult. The affected states, however, 

must continue to comply with the Clean Air Act and ensure air quality standards are met.

The staff noted that regional air quality modeling indicates that the Northern regions of the U.S. 

can experience a decrease in ozone concentration by the year 2050 (Tagaris, 2009). Air quality 

projections (particularly ozone) indicate that concentrations are driven primarily by emissions 

rather than by physical climate change (IPCC 2013).

Missouri is a member of the Midwestern Governors Association, which coordinates activities in 

the participating states to use their diverse resources to address public policy issues of 

significance to the region, including energy. Energy activities focus on practical, workable 

solutions to developing the Midwest’s wind potential, biofuels, and carbon storage and 

enhanced oil recovery capabilities. Missouri is also a part of the Central Regional Air Planning 

Association, which was established in 1998 and consists of State and tribal members to address 

regional haze and visibility issues and strategies.

Existing emission sources at Callaway are regulated under Operating Permit No. OP2008-045. 

This operating permit expired on September 17, 2013. A renewal application was submitted to 

the department on February 22, 2013, and is under review. The facility will operate under the 

previous permit until the department issues a new operating permit. As discussed in 

Section 2.2.2.1, “Air Quality,” regulated air pollutants—including sulfur dioxide, carbon 

monoxide, nitrogen oxide, lead, and particulates—are emitted at the Callaway site from five 

existing standby diesel-powered generators, four new permanent diesel-powered standby 

generators, two diesel-powered fire protection emergency fire-water pumps, the cooling tower 

(particulates only), and one auxiliary boiler. Emissions during the last 5 years (2007–2011) are 

provided in Section 2.2.2.1, Table 2–1. For each pollutant, Callaway is classified as a minor 

emission source. A minor source classification indicates the facility has little to no potential for 

contributing to a cumulative impact in conjunction with projects described in Appendix G.

Within a 50-mi (80-km) radius of Callaway, land use is primarily rural. A few minor emission 

sources are widely distributed in the area. The closest existing major emission source was the 

Chamois Power Plant, located approximately 6 mi (10 km) south of Callaway. However, on 

September 17, 2013, the Chamois Power Plant was closed (AECI 2013). In 2012, Chamois 

emitted 1,409 tons of nitrogen oxide and 999 tons of sulfur dioxide and is the dominant emission 

source in the region (MDNR 2014). Emissions resulting from operation of the Chamois Power 

Plant from 2005 to 2009 are presented in Appendix G.

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There are no plans for refurbishment of structures or components at the Callaway site for 

license renewal. As discussed in Section 2.1.6.1, new sedimentation pond construction 

activities would be infrequent and of short duration and as noted in Section 4.2, emissions 

associated with construction of these ponds will be minor and limited to the duration of pond 

construction (6 months). Therefore, there would be no other additional air emissions associated 

with Callaway’s license renewal because there is no planned site refurbishment and there are 

no changes to existing operating emissions sources (Ameren 2011b).

Because of the small quantity of emissions from Callaway’s existing sources, and limited 

emissions from sedimentation pond construction, the potential for Callaway to contribute to a 

cumulative impact with other air pollutant sources is SMALL. The staff concludes that, 

combined with the emissions from other past, present, and reasonably foreseeable future 

actions, cumulative impacts on air quality from hazardous and criteria air pollutant emissions 

from Callaway-related actions would be SMALL.

4.12.2 Water Resources 

This section addresses the direct and indirect effects of license renewal on water resources 

when added to the aggregate effects of other past, present, and reasonably foreseeable future 

actions. As described in Sections 4.4 and 4.5, the impacts on water resources from continued 

operations of Callaway during the license renewal term would be SMALL. The geographic area 

considered for the surface water resources component of the cumulative impacts analysis 

spans the Missouri River Basin. For groundwater, the area considered encompasses the 

regional groundwater aquifer from which Callaway withdraws groundwater. As such, this review 

focused on those projects and activities that would withdraw water from or discharge

wastewater to the Missouri River or would withdraw water from the regional aquifer used by 

Callaway.

4.12.2.1 Surface Water Resources

Callaway discharges to and uses the Missouri River as a source of cooling water (see 

Sections 2.1.6 and 2.1.7). The volume and quality of water that flows past the intake structure 

on the Missouri River is the result of natural events and human actions taken upstream in the 

Missouri Basin. The volume of water in the river that flows past the Callaway river intake is the 

result of drainage from more than 98 percent of the watershed area (USGS 2009, 2014a, 

2014b).

The Missouri River basin has been extensively developed for irrigation, flood control, river 

commerce, and the generation of hydroelectric power. Fifteen major dams impound the main 

stem of the river. All major dams are in the upper half of the river basin above Sioux City, 

South Dakota, while the lower section of the river is uninterrupted due to its longstanding use as 

a commercial shipping channel. In effect, the Missouri River is a managed river (EPA 2013; 

USACE 2006). This was the case prior to the construction of Callaway, is still the case and will 

likely continue to be the case in the reasonably foreseeable future. The U.S. Army Corps of 

Engineers (USACE) has the responsibility under Congressional Authorization for construction, 

operation and maintenance of the Missouri River for navigation, flood control, irrigation, 

recreation, and other related purposes (USACE 1947).

The resolution of conflicting water demands will impact future water flow in the Missouri River. 

For example, the State of Colorado is exploring the transportation of water out of the Missouri 

River watershed and into the Colorado River watershed (Barringer 2012; Finley 2012). This 

could reduce the volume of water in the Missouri River system. Oil shale development is being 

considered in some areas of the watershed (Bjerga 2012). The water required for this activity 

could also reduce the volume of water in the watershed for other uses. Over the past 30 years, 

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there has been a measurable downward trend in snow accumulation in the Rocky Mountains. If 

this trend continues, less water would supply the Missouri River system in spring and summer 

(Mote 2005; Pederson et al. 2011; USBR 2011). The State of Missouri would like to increase 

barge traffic. This might require larger surface water releases during the commercial river traffic 

season, which could reduce the volume of water available for other uses. Alternatively, if the 

historical trend of decreasing commercial river traffic continues (Baumel and 

Van Der Kamp 2003), there may come a time when barge traffic no longer needs to be 

supported.

The Missouri River serves as a drinking water supply for a little less than half of the public water 

supplied in the State of Missouri (DuCharme and Miller 1996). Prior to the impact of reservoir 

construction, the river obtained its nickname, the Big Muddy, from the amount of sediment in the 

water. With the construction of reservoirs and the implementation of soil conservation 

measures, sediment loads in the Missouri River have continued to decrease (Blevins 2006; 

Heimann et al. 2011; MDNR 2006). A more serious problem before adequate water treatment 

was waterborne diseases such as typhoid. Today, the water quality of the Missouri River has 

much improved. Large-scale garbage dumping has been eliminated, and all wastewater must 

be treated before discharge (MDNR 2006).

Climate change can impact surface water as a result of changes in temperature and 

precipitation. As discussed in Section 4.12.1, the Midwest is projected to experience an 

increase in surface temperatures. Higher temperatures increase evaporation that contributes to 

dry conditions and can reduce the amount of water available for surface runoff and streamflow 

(Karl et al. 2009). Runoff and streamflow at a regional scale for the Midwest indicated no clear 

trend during the last half-century (Georgakakos et al. 2014). In the future, however, the 

Missouri River Basin is projected to experience little change in runoff through the middle of this 

century (Georgakakos et al. 2014). Furthermore, as discussed in Section 4.12.1, heavy rainfall 

events are projected to increase, and, while this may increase future river floods, river floods are 

also dependent on other factors such as soil moisture and channel conditions (Georgakakos 

et al. 2014).

The general water quality of the Missouri River was improving prior to the construction of 

Callaway. This continuing trend should reasonably be expected to continue over the license 

renewal period. It is reasonable to assume that the Corps of Engineers will continue to manage 

the river to maintain adequate river flows for downstream uses. Therefore, the NRC staff 

concludes that cumulative surface water resource impacts resulting from existing and 

reasonably foreseeable future actions coupled with Callaway license renewal would be SMALL.

4.12.2.2 Groundwater Resources

Groundwater resources are abundant in Callaway County (Miller and Vandike 1997). Callaway 

does not discharge chemical or plant effluents to groundwater. However, Callaway does 

consume groundwater from the Cotter and Jefferson City Dolomites Aquifer and deeper sand 

and dolomite aquifers. The Cotter and Jefferson City Dolomites Aquifer and the deeper sand 

and dolomite aquifers are part of the regional Cambrian–Ordovician Aquifer. As discussed in 

Sections 2.1.7.2, 2.2.5, and 4.5.7, the Cotter and Jefferson City Dolomites Aquifer is in hydraulic 

communication with the Missouri River through the Missouri River Alluvial Aquifer. The bulk of 

the water consumed by the plant from the Cotter and Jefferson City Dolomites Aquifer is from

two wells immediately adjacent to the river. At this location, the river would act as a hydraulic 

boundary (constant head or pressure boundary) on groundwater levels. As a result any water 

levels in the Cotter and Jefferson City Dolomites Aquifer would be maintained by the river. Any 

impacts from pumping of these wells on groundwater resources would not extend south across 

the river and should be restricted to the immediate vicinity of the wells. 

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Climate change can impact groundwater water resources as a result of changes in precipitation 

and runoff. Climate change impacts on groundwater availability depends on basin geology, 

frequency and intensity of high-rainfall periods, recharge, soil moisture, and groundwatersurface water interactions (Georgakakos et al. 2014). However, responses of groundwater 

storage and flow to climate change are not well-understood, and only recently are groundwater 

projections starting to be analyzed in response to climate change (Georgakakos et al. 2014). 

The staff concludes that, combined with other past, present, and reasonably foreseeable future 

actions, the cumulative impacts on groundwater resources would be SMALL. 

4.12.3 Aquatic Resources

This section addresses the direct and indirect effects of license renewal on aquatic resources 

when added to the aggregate effects of other past, present, and reasonably foreseeable future 

actions. As described in Section 4.5, the incremental impacts on aquatic biota from the 

proposed license renewal would be SMALL. The geographic area considered in the cumulative 

aquatic resources analysis is the lower Missouri River, which extends from below Gavins Point 

Dam to the confluence with the Mississippi River. This area is considered a migratory pathway 

by the FWS (E & E 2012) and suitable habitat for the Federally listed pallid sturgeon. 

Consistent with the NRC Environmental Standard Review Plan, the staff considers the 

preoperational environment for its review. Section 2.2.6 presents an overview of the condition 

of the Missouri River ecosystem and the history and factors that led to its condition. At present, 

the Missouri River is a degraded ecosystem that the National Research Council (2002) has said 

may be close to or perhaps past the point of irreparable change. Land use changes, 

channelization, and construction of levees and dikes have altered almost 3 million ac 

(1.2 million ha) of natural riverine and floodplain habitats. These changes and more influence 

primary productivity and the energy sources for aquatic communities, alter or eliminate natural 

habitat and habitat diversity required to support some species, and change invertebrate 

communities and food webs essential to fish. The National Research Council (2002) also noted 

that 51 of 67 native fish species living on the main stem Missouri River are now listed as rare, 

uncommon, or decreasing across all or parts of their ranges. 

Three of the reasonably foreseeable future actions described in Appendix G have the potential 

to result in cumulative impacts on aquatic resources in the geographic area of concern: the 

Missouri River Mitigation Project, activities planned at the Big Muddy National Wildlife Refuge, 

and MDC Natural/Conservation Areas. Surface water withdrawals in the Missouri River would

also further affect aquatic resources within the geographic area of interest.

Surface Water Withdrawals. The USACE (2004) reported the number of surface water

withdrawals in the Missouri River at over 1,600 intakes, with 18 power plant intakes on the lower 

Missouri River. Similar to Callaway, these other power plant intakes directly affect the Missouri 

River’s aquatic communities, primarily through adverse effects related to impingement, 

entrainment, and heat shock. The cumulative stress from the large number of intakes spread 

across the length of the river depends on many factors that the NRC staff cannot quantify, but 

which may be significant when added to all the other stresses on the aquatic communities.

4.12.3.1 Missouri River Mitigation Project

The USACE (2007) issued a biological opinion (BO) under the ESA for the operation and 

maintenance of the Missouri River Bank Stabilization and Navigation Project. As a result of this 

opinion, the USACE, in conjunction with the FWS, is tasked with the design, implementation, 

and maintenance of a number of restoration projects on the Missouri River and within its 

floodplain. One goal of these projects is to improve habitats for the least tern 

(Sternula antillarum), piping plover (Charadrius melodus), and pallid sturgeon. The ultimate 

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goal is to restore and acquire for permanent easement over 166,750 ac (67,481 ha) of land 

throughout the four states traversed by the lower Missouri River (Nebraska, Iowa, Kansas, and 

Missouri). Two projects in the vicinity of Callaway, Tate Island (423 ac (171 ha)) and Heckman 

Island (543 ac (220 ha)), are designed to preserve and restore existing side-channel, wetland, 

riparian, and adjoining lands. These actions will provide some level of benefit to the Missouri 

River aquatic ecosystem.

4.12.3.2 Actions Planned at Big Muddy National Wildlife Refuge and MDC Natural/Conservation 

Areas

The NRC found that a number of land preservation or restoration activities are planned in 

conjunction with the expansion of the Big Muddy National Wildlife Refuge and at a number of 

MDC Natural/Conservation Areas. Both of these projects involve restoring and preserving 

portions of the lower Missouri River’s aquatic ecosystem. These actions will also provide some 

level of benefit to the aquatic resources in the vicinity of Callaway.

4.12.3.3 Climate Change

The potential cumulative effects of climate change on the lower Missouri River, whether caused 

by natural cycles or anthropogenic activities, could result in a variety of environmental 

alterations that would affect aquatic resources. The environmental changes that could affect 

large river systems include temperature increases, hydrologic cycles, and sediment transport. 

Water temperature increases can affect spawning patterns or success, or influence species 

distributions, as water temperatures may surpass an individual species’ thermal tolerance 

levels. Changes in hydrologic cycles could result from alterations to precipitation patterns, 

which could alter the levels of seasonal discharges to the river. These changes could alter the 

current sediment transport cycles, including more severe weather events resulting in greater 

input of sediment from undammed tributaries or from the main stem channel. Thus, the extent 

and magnitude of climate change impacts may make this process an important contributor to 

cumulative impacts on the aquatic resources of the Missouri River system.

4.12.3.4 Final Assessment of Cumulative Impacts on Aquatic Resources

Aquatic resources of the Missouri River are cumulatively affected to varying degrees by multiple 

activities and processes that have occurred in the past, are occurring currently, and are likely to 

occur in the reasonably foreseeable future. The Missouri River’s aquatic ecosystem has been 

noticeably altered and continues to require considerable resources to curtail the destabilizing 

factors that jeopardize the existence of some aquatic species or adversely affect their habitat in 

the reasonably foreseeable future. Although the incremental direct and indirect impacts from 

Callaway are SMALL because of the use of a closed-cycle cooling system, the cumulative 

stress from all the alterations to the aquatic habitat spread over the geographic area of interest 

have destabilized the aquatic resources in the Missouri River. The destabilizing factors that 

have influenced the current condition of the Missouri River existed before the construction and 

operation of the plant and will likely continue. The ongoing and future restoration and 

preservation activities planned along the lower Missouri River will likely provide some level of 

benefit to the aquatic resources in the vicinity of Callaway. Because of the noticeable 

destabilization of aquatic resources in the area of interest because of the cumulative effects of 

many former and ongoing actions, the NRC staff concludes that the cumulative impacts from the 

proposed license renewal and other past, present, and reasonably foreseeable future projects 

would be LARGE.

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4.12.4 Terrestrial Resources

This section addresses past, present, and reasonably foreseeable future actions that could 

result in adverse cumulative impacts on terrestrial resources, including vegetation cover, wildlife 

populations, and protected species. For purposes of this analysis, the geographic area 

considered in the evaluation includes the Callaway site and transmission line ROWs. 

On the Callaway site, 512 ac (207 ha) of the 7,354 ac (2,976 ha) of land are developed and 

maintained for operation of the plant (Ameren 2011a). The developed area contains sparse 

areas of maintained vegetation cover and, thus, provides limited ecological value for terrestrial 

wildlife species. The developed portion of the Callaway site was historically part of Coats’ 

Prairie. This area was settled in the early 1800s, after which the native prairie was converted to 

agricultural land use and other developed areas (AmerenUE and the Conservation Commission 

of the State of Missouri 2009). Consequently, initial development of Callaway primarily affected 

areas that were previously converted to agricultural and residential uses. The southern, 

undeveloped portion of the Callaway site, which is currently part of the Reform Conservation 

Area, was settled in the 1860s. Some of the natural forestland and prairie has been preserved 

in this area, while other portions have been converted to agriculture and other uses similar to 

the northern portion of the Callaway site (AmerenUE and the Conservation Commission of the 

State of Missouri 2009). 

Construction of the transmission lines required the clearing of forestland and may have resulted 

in habitat fragmentation of natural areas. Subsequent maintenance of the transmission line 

ROWs to eliminate the growth of mature woody vegetation and promote low-growing or shrubby 

vegetation has resulted in changes to wildlife and plant species present in the vicinity of these 

ROWs. The cumulative effect of ROW maintenance activities, such as mowing, has likely 

limited the natural successional stages of surrounding vegetation communities and may have 

led to the introduction of or increases in invasive species populations. The use of motorized 

vehicles and equipment on the ROW to conduct maintenance activities may also have caused 

accumulation of oil and other contaminants in sensitive habitats, such as riparian areas and 

wetlands. 

As described in Section 4.12.1, the Midwest will likely experience rising temperatures and 

heavier precipitation events during the proposed license renewal period. As the climate 

changes, terrestrial resources will need to be able to tolerate the new physical conditions or shift 

their population range to new areas with a more suitable climate. Some species may readily 

adapt to a changing climate, others may be more prone to experience adverse effects. Species 

that are most vulnerable to climate change are those that have specific habitat requirements, 

occur in isolated habitats, and have low reproductive rates (Pryor et al. 2014). For many 

Midwest species, migration to changed habitats is projected to be slow due to fragmented 

habitats, flat topography, and high latitudes (Pryor et al. 2014).

Two additional reasonably foreseeable future actions that have the potential to result in 

cumulative impacts on terrestrial resources in the geographic area of concern are the planned 

construction of an ISFSI at the Callaway site and the construction of portions of the proposed 

Callaway County Connector in Fulton County, which may traverse the Ameren property. 

Ground-disturbing activities associated with these projects that might occur during the Callaway 

license renewal term could result in the loss of vegetation cover, displacement of wildlife, and 

impacts on protected species. Ameren plans to build the ISFSI on the portion of the site that 

was previously excavated for the construction of an additional nuclear unit that was never built, 

so no terrestrial habitats would be directly affected by construction. The Callaway County 

Connector would also be built on existing developed areas of the site. Thus, it is not expected 

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that either of these reasonably foreseeable future projects would result in a significant loss of 

vegetation cover or associated impacts on terrestrial resources. 

The NRC staff concludes that the continued operation of Callaway, including the operation and 

maintenance of the in-scope transmission lines and the construction of new sedimentation 

ponds, would not contribute to the overall decline in the condition of terrestrial resources. The 

numerous vegetation communities within the Reform Conservation Area portion of the site will 

continue to provide habitat to protected species and other wildlife. The NRC staff concludes 

that the cumulative impacts of other present and reasonably foreseeable future actions on 

terrestrial habitat and associated species, when combined with continued operation of Callaway 

during the term of license renewal, would be SMALL to MODERATE.

4.12.5 Human Health

Radiological dose limits for protection of the public and workers have been developed by the 

NRC and EPA to address the cumulative impact of acute and long-term exposure to radiation 

and radioactive materials. These dose limits are codified in 10 CFR Part 20 and 

40 CFR Part 190. For the purpose of this analysis, the area within a 50-mi (81-km) radius of the 

Callaway site was included. Ameren carries out a REMP in the vicinity of the Callaway site to 

measure radiation and radioactive materials from all sources (e.g., hospitals and others licensed 

users of radioactive material); therefore, the monitoring program measures cumulative 

radiological impacts. Within the 50-mi (81-km) radius of the Callaway site, there are no other 

nuclear power reactors or uranium fuel cycle facilities.

Radioactive effluent and environmental monitoring data for the 6–year period from 2006 to 2011 

were reviewed as part of the cumulative impacts assessment. In Section 4.9.1 of this SEIS, the 

NRC staff concluded that the impacts of radiation exposure on the public and workers 

(occupational) from operation of Callaway during the renewal term would be SMALL.

The planned October 2014 replacement of the reactor vessel head is covered under the current 

operating license to maintain radiation doses to members of the public and plant workers within 

NRC radiation protection standards in 10 CFR Part 20. The replacement is essential for 

continued safe operation of Callaway and would be necessary even if the plant did not seek 

license renewal (Ameren 2011b). The replacement is independent of the license renewal 

application. The work will be done in accordance with Callaway’s radiation protection program 

to ensure compliance with NRC dose limits.

The applicant currently stores its spent fuel in a spent fuel pool facility. Ameren estimates that 

by approximately 2020, the spent fuel pool will not have enough capacity to receive an entire 

core of spent fuel. An ISFSI is proposed for the plant because the pool does not have adequate 

storage capacity to take the plant to the end of its current operating license. Ameren plans to 

build the ISFSI on the portion of the site that was previously excavated for the construction of an 

additional nuclear unit that was never built. The installation and monitoring of an ISFSI is 

governed by NRC requirements in Subpart K, “General License for Storage of Spent Fuel at 

Power Reactor Sites,” to 10 CFR Part 72, “Licensing Requirements for the Independent Storage 

of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than 

Class C Waste.” Radiation exposures and radioactive effluents from an ISFSI, as well as from 

the operation of Callaway, are required to be within the radiation dose limits in 10 CFR Part 20, 

40 CFR Part 190, and 10 CFR Part 72. The NRC does periodic inspections to verify 

compliance with its licensing and regulatory requirements.

The NRC and the State of Missouri would regulate any future actions near the Callaway site that 

could contribute to cumulative radiological impacts. The environmental monitoring done by 

Ameren would measure the cumulative impacts from any future nuclear operations. For these 

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reasons, the NRC staff concludes that cumulative radiological impacts would be SMALL, as are 

the contributions to radiological impacts from continued operation of Callaway and its 

associated future dry fuel storage facility.

For electromagnetic fields, the NRC staff determined that the Callaway transmission lines are 

operating within design specifications and meet current NESC criteria; therefore, the 

transmission lines do not significantly affect the overall potential for electric shock from induced 

currents within the analyzed area of interest. Therefore, the NRC staff has determined that the 

cumulative impacts of continued operation of the Callaway transmission lines, with the addition 

of impacts from other transmission lines in the affected area, would be SMALL.

4.12.6 Socioeconomics

4.12.6.1 Socioeconomic Factors 

This section addresses socioeconomic factors that have the potential to be directly or indirectly 

affected by changes in operations at Callaway in addition to the aggregate effects of other past, 

present, and reasonably foreseeable future actions. The primary geographic area of interest 

considered in this cumulative analysis is Boone, Callaway, and Cole Counties, within which 

approximately 84 percent of Callaway employees reside (see Table 2–1). This is where the 

economy, tax base, and infrastructure would most likely be affected since Callaway workers and 

their families reside, spend their income, and use their benefits within these counties.

Reactor Vessel Head Replacement

Ameren indicated that the reactor vessel head would be replaced before the license renewal 

term. Ameren estimates that vessel head replacement would require a one-time increase of 

140 outage workers for less than 30 days. These additional workers would create a short-term 

increase in the demand for temporary (rental) housing, an increased use of public water and 

sewer services, and transportation impacts on access roads in the immediate vicinity of 

Callaway. Given the short amount of time needed to replace the vessel head, the additional 

number of refueling outage workers and truck deliveries needed to support this one-time 

replacement of the vessel head could have a temporary cumulative effect on socioeconomic 

conditions in the vicinity of the nuclear plant. However, since the number of non-outage workers 

at Callaway would not change after reactor vessel head replacement, there would be no 

long-term cumulative socioeconomic impacts in the region.

Independent Spent Fuel Storage Installation

Ameren plans to construct and operate an ISFSI for the storage of spent fuel at Callaway. 

Potential socioeconomic impacts from ISFSI construction include temporary increases in the 

size of the workforce at Callaway and associated increased demand for public services, 

housing, and increased traffic in the region. The ISFSI could also increase tax payments 

because of increased income and assessed value.

The volume of construction and worker vehicles on roads and the demand for rental housing 

and other commercial and public services would increase during construction of the ISFSI. The 

contributory cumulative effect on socioeconomic conditions of this action would be limited to the 

period of construction in the immediate vicinity of Callaway. Since the number of non-outage 

workers at Callaway would not change appreciably after installation of the ISFSI, there would be 

no long-term cumulative socioeconomic impacts in the region.

Conclusion

As discussed in Section 4.10 of this SEIS, continued operation of Callaway would have no 

impact on socioeconomic conditions in the region during the license renewal term beyond what 

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Environmental Impacts of Operation

is already being experienced. Since Ameren has no plans to hire additional workers during the 

license renewal term, overall expenditures and employment levels at Callaway would remain 

relatively unchanged, and there would be no additional or increased demand for permanent 

housing and public services. In addition, since employment levels and tax payments would not 

change, there would be no population or tax revenue-related land use impacts beyond what is 

already being experienced. Based on this and other information presented in Chapter 4 of this 

SEIS, the staff concludes that there would be no contributory effect from the continued 

operation of Callaway on socioeconomic conditions in the region beyond what is currently being 

experienced. The only incremental contributory effects would come from the other planned 

activities at Callaway (i.e., vessel head replacement and ISFSI construction and operation) and 

other reasonably foreseeable planned offsite activities in Boone, Callaway, and Cole Counties. 

However, even with respect to the other planned activities at Callaway, since the total number of 

non-outage workers at Callaway would not change appreciably after vessel head replacement 

and ISFSI installation, the staff concludes that there would be no new long-term incremental 

contributory effects on cumulative socioeconomic conditions in the region during the Callaway 

license renewal term beyond what is already being experienced. 

4.12.6.2 Environmental Justice

The environmental justice cumulative impact analysis assesses the potential for 

disproportionately high and adverse human health and environmental effects on minority and 

low-income populations that could result from past, present, and reasonably foreseeable future 

actions, including Callaway operations during the renewal term. Adverse health effects are 

measured in terms of the risk and rate of fatal or nonfatal adverse impacts on human health. 

Disproportionately high and adverse human health effects occur when the risk or rate of 

exposure to an environmental hazard for a minority or low-income population is significant and 

exceeds the risk or exposure rate for the general population or for another appropriate 

comparison group. Disproportionately high environmental effects refer to impacts or risk of 

impact on the natural or physical environment in a minority or low-income community that are 

significant and appreciably exceed the environmental impact on the larger community. Such 

effects may include biological, cultural, economic, or social impacts. Some of these potential 

effects have been identified in the resource areas presented in Chapter 4 of this SEIS. As 

previously discussed in this chapter, the impact from license renewal for all resource areas 

(i.e., land, air, water, ecology, and human health) would be SMALL.

As discussed in Section 4.10.7 of this SEIS, there would be no disproportionately high and 

adverse impacts on minority and low-income populations from the continued operation of 

Callaway during the license renewal term. Since Ameren has no plans to hire additional 

workers during the license renewal term, employment levels at Callaway would remain relatively 

unchanged, and there would be no additional or increased demand for housing or increased 

traffic. Based on this information and the analysis of human health and environmental impacts 

presented in Chapters 4 and 5, the NRC staff concludes that it is not likely that there would be 

any disproportionately high and adverse contributory effect on minority and low-income 

populations from the continued operation of Callaway during the license renewal term.

Potential impacts on minority and low-income populations from the other planned activities at 

Callaway, specifically the vessel head replacement and the construction and operation of the 

ISFSI would mostly consist of environmental and socioeconomic effects (e.g., noise, dust, 

traffic, employment, and housing impacts). Radiation doses from plant operations after reactor

vessel head replacement are expected to continue at current levels, and, along with the ISFSI at 

Callaway, be well below regulatory limits.

4-49
Environmental Impacts of Operation

Noise and dust impacts during ISFSI construction would be short-term and limited to onsite 

activities at Callaway. Minority and low-income populations residing along site access roads 

could experience increased commuter vehicle traffic during shift changes. Increased demand 

for rental housing during the refueling outages, during the vessel head replacement, and during 

the construction of the ISFSI at the Callaway site could disproportionately affect low-income 

populations. However, because of the short duration of the work and the availability of rental 

housing, impacts on minority and low-income populations would be short-term and limited.

Based on this information and the analysis of human health and environmental impacts 

presented in this SEIS, the NRC staff concludes that the vessel head replacement activities and 

the construction and operation of the ISFSI would not have disproportionately high and adverse 

human health and environmental effects on minority and low-income populations residing in the 

vicinity of Callaway. Furthermore, the NRC staff concludes that, since the operational effects at 

Callaway would not change appreciably after vessel head replacement and ISFSI installation, 

there would be no new long-term incremental contributory human health and environmental 

effects from Callaway on cumulative conditions in the region during the license renewal term. 

4.12.7 Historic and Archaeological Resources

This section evaluates the cumulative impacts of the continued operation of Callaway on historic 

and archaeological resources. The geographic area considered in this analysis is the APE 

associated with the proposed undertaking, as discussed in Section 2.2.10.

As stated in Section 4.10.6, the NRC has concluded that license renewal would have a SMALL 

impact on historic and cultural resources at Callaway. However, future ground-disturbing 

maintenance and operations activities during the license renewal term could affect undiscovered 

historic and archaeological resources. In addition, three reasonably foreseeable planned future 

actions could also affect historic and archaeological resources at Callaway. These include the 

reactor vessel head replacement of Callaway; construction of a proposed ISFSI; and portions of 

the proposed Callaway County Connector in Fulton County, which may traverse the Ameren 

property. Descriptions of these actions are presented in Appendix G of this SEIS.

Given the number of archaeological sites already identified within the APE and the high 

potential for the discovery of additional sites, Ameren has developed a CRMP for the 

management and protection of cultural resources within the APE. Ameren also has procedures 

for dealing with the inadvertent discovery of cultural resources during construction projects, 

which have been incorporated into Ameren’s Excavation Construction and Safety Standards

procedures (Ameren 2011a). A discussion of these procedures can be found in Section 4.10.6 

of this SEIS.

Any future ground-disturbing activities during the license renewal term, including reasonably 

foreseeable future actions at Callaway, would be done in accordance with the CRMP and 

Excavation Construction and Safety Standards. These guidelines and procedures are designed 

to ensure that archaeological sites and cultural resources at Callaway are adequately protected. 

With these measures in place, continued operation of Callaway during the license renewal term 

would not incrementally contribute to cumulative impacts on historic and archaeological 

resources within the APE and in the surrounding area. Therefore, the NRC staff has 

determined that the cumulative impact on historic and archaeological resources at Callaway for 

the renewal term would be SMALL.

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Environmental Impacts of Operation

4.12.8 Summary of Cumulative Impacts

The staff considered the potential impacts resulting from the operation of Callaway during the 

renewal term and other past, present, and reasonably foreseeable future actions near Callaway. 

The final determination of this SEIS is that the potential cumulative impacts would range from 

SMALL to LARGE, depending on the resource. Table 4–10 summarizes the cumulative impacts 

on resource areas.

4-51
Environmental Impacts of Operation

Table 4–10. Summary of Cumulative Impacts on Resource Areas

Resource Area Cumulative Impact

Air Quality

As discussed in Section 4.2, continued operation of Callaway during the license 

renewal term would have no impacts on air quality beyond the issues discussed in 

the GEIS. There are no applicable Category 2 issues related to air quality and 

only one Category 1 issue with an impact of SMALL is applicable. Combined with 

other past, present, and reasonably foreseeable future air emission sources within 

the geographic area of concern, the potential cumulative impacts on air quality 

would be SMALL.

Water Resources

Based upon surface water use rates by Callaway, the daily average discharge

rates of the Missouri River, and the proximity and water use of other major users, 

the cumulative surface water use impacts of existing and reasonably foreseeable 

projects with Callaway would be SMALL. Based on the well depths, water use 

volumes, aquifer yields, and proximity of other wells to the site, the continued 

extraction of groundwater would have SMALL cumulative impacts on this resource.

Aquatic Ecology

Although the incremental impacts from Callaway are small, the cumulative stress 

from all the alterations to the aquatic habitat spread across the geographic area of 

interest have destabilized the aquatic resources in the Missouri River. Therefore, 

the potential cumulative impacts from the proposed license renewal and other 

past, present, and reasonably foreseeable projects would be LARGE. 

Terrestrial 

Ecology

The continued operation of Callaway, including the operation and maintenance of 

the in-scope transmission lines, would not contribute to the overall decline in the 

condition of terrestrial resources. The many vegetation communities within the 

Reform Conservation Area portion of the site will continue to provide habitat to 

protected species and other wildlife. The cumulative impacts of other present and 

future actions on terrestrial habitat and associated species, when combined with 

continued operation of Callaway during the term of license renewal, would be 

SMALL to MODERATE.

Human Health

The REMP carried out by Ameren near the Callaway site measures radiation and 

radioactive materials from all sources (e.g., hospitals and other licensed users of 

radioactive material); therefore, the monitoring program measures cumulative 

radiological impacts. In Section 4.9.1 of this SEIS, the NRC staff concluded that 

the impacts of radiation exposure on the public and workers (occupational) from 

the operation of Callaway during the renewal term would be SMALL. The NRC 

and the State of Missouri would regulate any future actions near Callaway that 

could contribute to cumulative radiological impacts. Therefore, the NRC staff 

concludes that the cumulative radiological impacts from continued operation of 

Callaway for the renewal term would be SMALL.

Socioeconomics

As discussed in Section 4.10, continued operation of Callaway during the license 

renewal term would have no impact on socioeconomic conditions in the region 

beyond those already experienced. In addition, there would be no 

disproportionately high and adverse impacts on minority and low-income 

populations from the continued operation of Callaway during the license renewal 

term. Therefore, the NRC staff concludes that the cumulative effects on 

socioeconomic conditions and environmental justice populations in the region from 

past, present, and reasonably foreseeable future actions at Callaway combined 

with other planned activities in the region is not expected to increase appreciably 

beyond what is currently being experienced. 

4-52
Environmental Impacts of Operation

Resource Area Cumulative Impact

Cultural 

Resources

As discussed in Section 4.10.6, continued operation of Callaway during the license 

renewal term would have a SMALL impact on historic and archaeological 

resources. Combined with other past, present, and reasonably foreseeable future 

ground-disturbing activities or construction of new buildings or structures within the 

geographic area of concern, the potential cumulative impacts on historic and 

archaeological resources would be SMALL.

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4-61

5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS

This chapter describes the environmental impacts from postulated accidents that Callaway 

Plant, Unit 1 (Callaway) might experience during the license renewal period. The term 

“accident” refers to any unintentional event outside the normal plant operational envelope that 

results in a release or the potential for release of radioactive materials into the environment. 

NUREG–1437, the Generic Environmental Impact Statement for License Renewal of Nuclear 

Plants (GEIS), evaluates two classes of postulated accidents (NRC 1996). These are 

design-basis accidents (DBAs) and severe accidents. Table 5–1 notes the issues and 

categories related to these postulated accidents.

Table 5–1. Issues Related to Postulated Accidents

Issue Category

DBAs 1

Severe accidents 2

5.1 Design-Basis Accidents

To receive U.S. Nuclear Regulatory Commission (NRC) approval to operate a nuclear power 

facility, an applicant for an initial operating license must include a safety analysis report (SAR) 

as part of its application. The SAR discusses various hypothetical accident situations and the 

safety features that are provided to prevent and mitigate accidents. The NRC staff reviews the 

application to determine whether the plant design meets the Commission’s regulations and 

requirements and includes, in part, the nuclear plant design and its anticipated response to an 

accident.

Accidents classified as DBAs are those accidents that both the licensee and the NRC staff 

evaluate to ensure that the plant can withstand normal and abnormal transients, and a broad 

spectrum of postulated accidents, without undue hazard to the health and safety of the public. 

Many of these postulated accidents are not expected to occur during the life of the plant, but are 

evaluated to establish the design basis for the preventive and mitigative safety systems of the 

facility. Callaway maintains safe operation (i.e., the ability to withstand transients and 

postulated accidents) by meeting the requirements in Title 10 of the Code of Federal 

Regulations (10 CFR) Part 50, “Domestic licensing of production and utilization facilities,” and 

Part 100, “Reactor site criteria.”

The environmental impacts of DBAs were considered by the NRC during the initial licensing 

process,before issuance of the operating license. The results of the evaluations are found in 

licensee documentation such as the applicant’s final SAR, safety evaluation report, and final 

environmental statement (FES). A licensee is required to maintain the acceptable design and 

performance criteria throughout the life of the plant, including any extended-life operation. The 

potential consequences of these DBAs are evaluated for the hypothetical maximum exposed 

individual (maximum or bounding postulated accident conditions). As such, changes in the 

plant environment will not affect these evaluations.

Because of the requirements that continuous acceptability of the consequences and aging 

management programs be in effect for the period of extended operation, the environmental 

impacts as calculated for DBAs should not differ significantly from initial licensing assessments 

5-1 
Environmental Impacts of Postulated Accidents

over the life of the plant, including the period of extended operation. Accordingly, the design of 

the plant relative to DBAs during the renewal period is considered to remain acceptable, and the 

environmental impacts of those accidents were not examined further in the GEIS. 

The Commission has determined that the environmental impacts of DBAs are of SMALL 

significance for all plants because the plants were designed to successfully withstand these 

accidents. Therefore, for the purposes of license renewal, DBAs are designated as a 

Category 1 issue. The early resolution of the DBAs makes them a part of the current licensing 

basis of the plant, which is to be maintained by the licensee under its current license and, 

therefore, under the provisions of 10 CFR 54.30, “Matters not subject to a renewal review,” is 

not subject to review under license renewal.

No new and significant information related to DBAs was identified during the review of the 

applicant’s Environmental Report (ER) (Ameren 2011a), the site audit, the scoping process, or 

the evaluation of other available information. Therefore, there are no impacts related to these 

issues beyond those discussed in the GEIS. 

5.2 Severe Accidents

Severe nuclear accidents are those that are more severe than DBAs because they could result 

in substantial damage to the reactor core, whether or not there are serious offsite 

consequences. In the GEIS, the staff assessed the impacts of severe accidents during the 

license renewal period, using the results of existing analyses and site-specific information to 

conservatively predict the environmental impacts of severe accidents for each plant during the 

renewal period.

Severe accidents initiated by external phenomena such as tornadoes, floods, earthquakes,

fires, and sabotage have not traditionally been discussed in quantitative terms in FESs and 

were not specifically considered for the Callaway site in the GEIS (NRC 1996). However, the 

GEIS did evaluate existing impact assessments performed by the NRC and by the nuclear 

industry at 44 nuclear plants in the United States and concluded that the risk from beyond 

design-basis earthquakes at existing nuclear power plants is SMALL. The GEIS for license 

renewal performed a discretionary analysis of terrorist acts in connection with license renewal, 

and concluded that the core damage and radiological release from such acts would be no worse 

than the damage and release expected from internally initiated events. In the GEIS, the 

Commission concludes that the risk from sabotage and beyond design-basis earthquakes at 

existing nuclear power plants is small and, additionally, that the risks from other external events 

are adequately addressed by a generic consideration of internally initiated severe accidents 

(NRC 1996).

Based on information in the GEIS, the Commission found the following to be true (10 CFR 51): 

The probability weighted consequences of atmospheric releases, fallout onto 

open bodies of water, releases to ground water, and societal and economic 

impacts from severe accidents are small for all plants. However, alternatives to 

mitigate severe accidents must be considered for all plants that have not 

considered such alternatives.

The staff identified no new and significant information related to severe accidents during the 

review of the applicant’s ER (Ameren 2011a), the site audit, the scoping process, or the 

evaluation of other available information. Therefore, there are no impacts related to these 

issues beyond those discussed in the GEIS. However, in accordance with 

10 CFR 51.53(c)(3)(ii)(L), the staff has reviewed severe accident mitigation alternatives (SAMA) 

for Callaway. The results of the review are discussed in Section 5.3.

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Environmental Impacts of Postulated Accidents

5.3 Severe Accident Mitigation Alternatives

In accordance with 10 CFR 51.53(c)(3)(ii)(L), license renewal applicants are to consider 

alternatives to mitigate severe accidents if the staff has not previously evaluated SAMA for the 

applicant’s plant in an environmental impact statement or related supplement or in an 

environmental assessment. The purpose of this consideration is to ensure that plant changes 

(e.g., hardware, procedures, and training) with the potential for improving severe accident safety 

performance are identified and evaluated. The SAMA have not been previously considered for 

Callaway; therefore, the remainder of Chapter 5 addresses those alternatives.

5.3.1 Overview of SAMA Process

This section presents a summary of the SAMA evaluation for Callaway conducted by the 

applicant, Union Electric Company, a subsidiary of Ameren Corporation and doing business as 

Ameren Missouri (Ameren or the applicant), and the NRC staff’s review of that evaluation. The 

NRC staff performed its review with contract assistance from Pacific Northwest National 

Laboratory. The NRC staff's review is available in full in Appendix F, and Ameren’s SAMA 

evaluation is available in full in Attachment F of the Ameren ER and in subsequent responses to 

the NRC staff’s requests for additional information (Ameren 2012a, 2012b, 2013a, 2013b).

The SAMA evaluation for Callaway was conducted with a four-step approach. In the first step, 

Ameren quantified the level of risk associated with potential reactor accidents using the plantspecific probabilistic risk assessment (PRA).

In the second step, Ameren examined the major risk contributors and identified possible ways 

(SAMA) of reducing that risk. Common ways of reducing risk are changes to components, 

systems, procedures, and training. Ameren identified 189 potential SAMA for Callaway. 

Ameren performed an initial screening to determine if any SAMA could be eliminated because 

they are not applicable to Callaway because of design differences, have already been 

implemented at Callaway, could be combined with other SAMA candidates, have estimated 

implementation costs that would exceed the dollar value associated with completely eliminating 

all severe accident risk at Callaway, or have a very low benefit. This screening reduced the list 

of potential SAMA to 76 candidate SAMA for further evaluation.

In the third step, Ameren estimated the benefits and the costs associated with each of the 

remaining SAMA. Estimates were made of how much each alternative could reduce risk. 

Those estimates were developed in terms of dollars in accordance with NRC guidance for 

performing regulatory analyses. The cost of implementing the proposed SAMA was also 

estimated.

In the fourth step, the cost and benefit of each of the remaining SAMA were compared to 

determine whether the alternative was cost-beneficial, meaning the benefits of the SAMA were 

greater than the cost (a positive cost-benefit ratio). Ameren concluded in its ER, as 

supplemented, that 16 of the SAMA evaluated would be potentially cost-beneficial. 

Finally, the 16 potentially cost-beneficial SAMA are evaluated to determine if they are in the 

scope of license renewal, i.e., are they subject to aging management. This evaluation considers 

whether the systems, structures, and components (SSCs) associated with these SAMA: 

(1) perform their intended function without moving parts or without a change in configuration or 

properties and (2) that these SSCs are not subject to replacement based on qualified life or 

specified time period. The 16 potentially cost-beneficial SAMA do not relate to adequately 

managing the effects of aging during the period of extended operation; therefore, they need not 

be implemented as part of license renewal in accordance with 10 CFR Part 54, “Requirements 

5-3 
Environmental Impacts of Postulated Accidents

for renewal of operating licenses for nuclear power plants.” Ameren’s SAMA analyses and the 

NRC’s review are discussed in more detail below.

5.3.2 Estimate of Risk

Ameren submitted an assessment of SAMA for Callaway as part of its ER. This assessment 

was based on the most recent Callaway PRA available at that time; a plant-specific offsite 

consequence analysis performed using the MELCOR Accident Consequence Code System 2 

(MACCS2) computer program; and insights from the Callaway individual plant examination 

(IPE) (Union Electric 1992) and individual plant examination of external events (IPEEE) 

(Union Electric 1995).

The Callaway core damage frequency (CDF) for internal events from the Callaway PRA is 

approximately 2.6×10-5 per year, which includes the contribution from internal flooding. The 

baseline CDF from the Callaway PRA for the purposes of the SAMA evaluation is approximately 

1.7×10-5 per year for internal events excluding the contribution from internal flooding. Ameren 

accounted for the potential risk reduction benefits associated with external events and internal 

flooding by applying a multiplier to the estimated benefits for internal events. Ameren used a 

multiplier of 4.57 to account for external events and internal flooding, which assumes a seismic

CDF of 5.0×10-6 per year, a fire CDF of 2.0×10-5 per year, a high winds, tornadoes, external 

floods, and other external events CDF of 2.5×10-5 per year, and an internal flooding CDF of 

9.1×10-6 per year (Ameren 2011a).

The breakdown of CDF for internal events by initiating event is provided in Table 5–2. As 

shown in this table, events initiated by internal flooding, small loss of coolant accidents (LOCAs) 

and loss of offsite power (LOSP) are the dominant contributors to the CDF. 

In response to an NRC staff request for additional information (RAI), Ameren provided the CDF

for accident sequences including station blackout (SBO) and anticipated transients without 

scram (ATWS). Ameren identified that SBO contributes 3 percent to the total internal events 

and internal flooding CDF, while ATWS sequences contribute 1.2 percent of the total CDF. 

In response to an NRC staff RAI concerning the SBO frequency, Ameren stated that the LOSP 

frequency, and consequently the SBO frequency, did not include consequential LOSP events 

occurring as a result of other plant transients. The RAI response states that for the new 

Revision 5 PRA model, consequential LOSP events account for 28 percent of the SBO 

frequency and only 2.5 percent of the CDF (Ameren 2012a). Based on this information, the 

NRC staff determined that the benefit from an SBO or LOSP mitigating alternative should be 

increased to account for the omission of consequential LOSP. The impact on the evaluation of 

cost-beneficial SAMA is discussed in Sections 5.3.4 and 5.3.5 below.

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Environmental Impacts of Postulated Accidents

Table 5–2. Callaway Core Damage Frequency for Internal Events

Initiating Event CDF

(per year)

Percent 

Contribution 

to CDF

Internal Flooding(a) 9.1×10-6 35

Small LOCA 5.9×10-6 23

LOSP 5.6×10-6 21

Steam Generator Tube Rupture (SGTR) 2.3×10-6 9

Turbine Trip with Main Feedwater Available 1.1×10-6 4

Intermediate LOCA 3.6×10-7 1

Main Steamline Break Outside Containment 3.5×10-7 1

Reactor Vessel Rupture 3.0×10-7 1

Very Small LOCA 2.1×10-7 1

Loss of Main Feedwater 1.9×10-7 1

Interfacing System LOCA 1.7×10-7 1

Loss of Component Cooling Water (CCW) 1.2×10-7 1

Loss of Service Water 1.2×10-7 <1

Feedwater Line Breaks 9.8×10-8 <1

Loss of Direct-Current (DC) Vital Buses 8.0×10-8 <1

Large LOCA 4.2×10-8 <1

Main Steamline Break Inside Containment 1.5×10-8 <1

Total (internal events)(b) 2.6×10-5 100

(a) The Level 1 internal events PRA used for the SAMA analysis does not include internal flooding.

(b) Column totals may be different because of rounding.

Source: Table 1.a of RAI responses (Ameren 2012a)

In the ER, Ameren estimated the dose to the population within 80 km (50 mi) of the Callaway 

site to be approximately 0.0460 person-sievert (Sv) (4.60 person-roentgen equivalent man 

(rem)) per year (Ameren 2011a). The breakdown of the total population dose by containment 

release mode is summarized in Table 5–3. Containment bypass events (such as 

SGTR-initiated large early release frequency accidents) and late containment failures without 

feedwater dominate the population dose risk at Callaway.

5-5 
Environmental Impacts of Postulated Accidents

Table 5–3. Breakdown of Population Dose by Containment Release Mode

Containment Release Mode Population Dose

(Person–Rem(a) Per Year)

Percent 

Contribution

Steam Generator Rupture (Noninduced) 2.13 47

Containment Over-pressure (Late) 1.72 37

Interfacing System LOCA 0.35 7.1

Induced SGTR 0.27 5.7

Basemat Melt-through (Late) 0.10 2.2

Containment Intact 0.02 <1

Early Containment Failure 0.01 <1

Containment Isolation Failure negligible negligible

Total(b) 4.60 100

(a) One person-rem = 0.01 person-Sv.

(b) Column totals may be different because of rounding.

Sources: Table E.3-14 of the ER and Table 4.f-1 of RAI responses (Ameren 2011a, 2012a)

The NRC staff has reviewed Ameren’s data and evaluation methods and, after accounting for 

the consequential LOSP issue by conservatively increasing the benefit of SBO and LOSP 

mitigating SAMA as discussed above, concludes that the quality of the risk analyses is 

adequate to support an assessment of the risk reduction potential for candidate SAMA. 

Accordingly, the NRC staff based its assessment of offsite risk on the CDF and offsite doses 

reported by Ameren, with a correction to account for the impact of consequential LOSP events.

5.3.3 Potential Plant Improvements

Ameren’s process for identifying potential plant improvements (SAMA) consisted of the following 

elements:

• review of the most significant basic events from the current, plant-specific 

PRA,

• review of potential plant improvements identified in the Callaway IPE and 

IPEEE,

• review of generic SAMA candidates from NEI 05-01 (NEI 2005) as well as 

cost-beneficial SAMA identified for license renewal applications for 

representative pressurized-water reactor plants,

• input from the Callaway plant staff,

• review of the important contributors to the internal flooding risk from an 

updated internal flooding analysis, and

• review of the important contributors to the internal fire risk from the results of 

a new fire PRA performed in support of Callaway's transition to the National 

Fire Protection Association (NFPA) 805 performance-based fire protection 

program.

Based on this process, an initial set of 189 candidate SAMA was identified. Ameren performed 

a qualitative screening of the initial list of SAMA using the following criteria:

5-6 
Environmental Impacts of Postulated Accidents

• The alternative is not applicable to Callaway plant design.

• The alternative has already been implemented or intent met at Callaway.

• The alternative is similar in nature and could be combined with another 

alternative.

• The alternative requires extensive changes that would exceed the maximum 

benefit.

• The alternative has a very low benefit.

Based on this screening, 113 SAMA were eliminated, leaving 76 for further evaluation. Ameren 

performed a detailed cost-benefit evaluation for each of the remaining SAMA candidates.

The NRC staff concludes that Ameren followed the guidance of NEI 05-01 (NEI 2005), using a 

systematic and comprehensive process for identifying potential plant improvements for 

Callaway, and that the set of SAMA evaluated in the ER, together with those evaluated in 

response to NRC staff inquiries, is reasonably comprehensive and, therefore, acceptable.

5.3.4 Evaluation of Risk Reduction and Costs of Improvements

Ameren evaluated the risk-reduction potential of the remaining 76 SAMA. The majority of the 

SAMA evaluations were performed in a bounding fashion in that the SAMA was assumed to 

completely eliminate the risk associated with the events mitigated by the proposed 

enhancement. This bounding approach overestimates the benefit and is conservative. In some 

cases, an alternative was determined to be cost-beneficial without a quantitative assessment of 

the risk reduction.

The NRC staff reviewed Ameren’s bases for calculating the risk reduction for the various plant 

improvements and concludes that the rationale and assumptions for estimating risk reduction 

followed the guidance of NEI 05-01 (NEI 2005) and are reasonable and generally conservative 

(i.e., the estimated risk reduction is higher than what would actually be realized). Accordingly, 

the NRC staff based its estimates of averted risk for the various SAMA on Ameren’s risk 

reduction estimates. However, for certain SBO- or LOSP-mitigating SAMA, the NRC staff 

increased Ameren’s risk reduction estimates by a factor to account for consequential LOSP 

events, as discussed in Section 5.3.2.

Ameren estimated the costs of implementing the candidate SAMA primarily through the use of 

an expert panel. General categories of costs considered by Ameren in the development of 

these estimates were materials, analyses to support implementation and feasibility, procedure 

development, replacement power costs, and the costs of ongoing training and surveillance. The 

cost estimates performed by Ameren conservatively did not account for inflation or contingency 

costs. In some cases, Ameren considered an alternative to be cost-beneficial without 

performing a cost estimate. 

The staff reviewed the bases for the applicant’s cost estimates. The staff also compared cost 

estimates to estimates developed elsewhere for similar improvements, including estimates 

developed as part of other licensees’ analyses of SAMA for other operating reactors. The staff 

found the cost estimates to be reasonable and generally consistent with estimates provided in 

support of other plants’ analyses.

The staff concludes that Ameren used conservative assumptions and followed the guidance in 

NEI 05-01 (NEI 2005) to develop risk reduction and cost estimates, as qualified above, and that 

these estimates are sufficient and appropriate for use in the SAMA evaluation.

5-7 
Environmental Impacts of Postulated Accidents

5.3.5 Cost-Benefit Comparison

The cost-benefit analysis performed by Ameren was based primarily on NUREG/BR-0184, the 

Regulatory Analysis Technical Evaluation Handbook (NRC 1997). The guidance involves 

determining the net value for each alternative. If the net value of an alternative is negative, the 

cost of implementing the SAMA is larger than the benefit associated with the SAMA and it is not 

considered cost-beneficial. Ameren’s derivation of each of the associated costs and benefits is 

summarized in Appendix F. Revision 4 of NUREG/BR-0058, the Regulatory Analysis 

Guidelines of the U.S. Nuclear Regulatory Commission, states that two sets of estimates should 

be developed, one at a 3 percent discount rate and one at a 7 percent discount rate 

(NRC 2004). Ameren provided a base set of results using the 7 percent discount rate and a 

sensitivity study using the 3 percent discount rate (Ameren 2011a, 2013a).

Ameren performed additional analyses to evaluate the impact of parameter choices and 

uncertainties on the results of the SAMA assessment. In this assessment Ameren increased 

the benefits by an additional factor of 2.11 to account for uncertainties (Ameren 2011a, 2013a).

Ameren also determined several SAMA to be cost-beneficial without a cost-benefit evaluation.

The potentially cost-beneficial SAMA are:

• SAMA 11 – Improve 4.16-kilovolt bus cross-tie ability.

• SAMA 29 – Provide capability for alternate injection via diesel-driven fire 

pump.

• SAMA 64 – Implement procedure and hardware modifications to allow 

manual alignment of the fire water system to component cooling water (CCW) 

system, or install a CCW header cross-tie.

• SAMA 80 – Provide a redundant train or means of ventilation (Develop 

procedures to open doors or provide temporary ventilation for the emergency 

diesel generators (EDGs), motor-driven auxiliary feedwater (MDAFW) pumps, 

and charging pumps).

• SAMA 160 – Modifications to lessen impact of internal flooding path through 

Control Building dumbwaiter.

• SAMA 162 – Install a large volume EDG fuel oil tank at an elevation greater 

than the EDG fuel oil day tanks.

• SAMA 178 – Improvements to ultimate heat sink (UHS) cooling tower 

electrical room heating, ventilation, and air conditioning (HVAC). 

(Implementation of temporary ventilation or opening doors).

• SAMA 179 – Modify procedures such that the water loop seals in the reactor

cooling system (RCS) cold legs are not cleared following core damage.

• SAMA 180 – Install lower amperage fuses for various 14 American wire 

gauge (AWG) control circuits in the main control room (MCR). The majority 

of the modification centers around the trip circuit fuses on NB, NG, PA, PB, 

and PG system breakers.

• SAMA 181 – Install redundant fuses and isolation switches for MCR 

evacuation procedure OTOZZ–00001.

5-8 
Environmental Impacts of Postulated Accidents

• SAMA 182 – To protect against multiple spurious operation scenarios, cable 

runs will be changed to run a single wire in a protected metal jacket such that 

spurious valve opening because of a hot short affecting the valve control 

circuit is eliminated for the fire area. This modification will be implemented in 

multiple fire areas.

• SAMA 183 – Quick response sprinkler heads in cable chases A–11, C–30, 

and C–31 will be modified to be in accordance with the applicable 

requirements of NFPA 13, 1976 edition.

• SAMA 185 – Automate initiation of CCW flow to the residual heat removal 

heat exchangers.

• SAMA 187 – Install modification to power the normal charging pump from an 

existing spare breaker from the alternate emergency power system.

• SAMA 188 – Install a permanent, dedicated generator for the normal 

charging pump and a MDAFW pump and battery charger to address SBO 

events in which the turbine-driven auxiliary feedwater pump (TDAFP) is 

unavailable.

• SAMA 189 – Perform analysis to determine if it is possible to modify current 

plant doors to withstand higher flood heights. Either perform modifications to 

install improved doors or revise flooding analysis to incorporate results that 

doors will withstand higher flooding heights without propagating the flood.

As discussed in Section 5.3.4, the benefit for SAMA specifically mitigating LOSP and SBO 

sequences was increased to account for the impact of consequential LOSP events that were not 

included in the Callaway PRA. This did not result in any additional cost-beneficial SAMA.

Ameren stated that the potentially cost-beneficial SAMA will be entered into Callaway’s 

long-range plan development process for further implementation consideration (Ameren 2011a).

The NRC staff concludes that, with the exception of the potentially cost-beneficial SAMA

discussed above, the costs of the other SAMA evaluated would be higher than the associated 

benefits.

5.3.6 Conclusions

The NRC staff reviewed Ameren’s analysis and concludes that the methods used and the 

implementation of those methods followed the guidance of NEI 05-01 (NEI 2005). The 

treatment of SAMA benefits and costs supports the general conclusion that the SAMA 

evaluations performed by Ameren are reasonable and sufficient for the license renewal 

submittal.

Based on its review of the SAMA analysis, the NRC staff agrees with Ameren’s identification of 

areas in which risk can be further reduced in a cost-beneficial manner through the 

implementation of the identified, potentially cost-beneficial SAMA. Given the potential for 

cost-beneficial risk reduction, the NRC staff agrees that further evaluation of these SAMA by 

Ameren is warranted. However, the NRC staff concludes that these SAMA do not relate to 

adequately managing the effects of aging during the period of extended operation. Therefore, 

they need not be implemented as part of license renewal in accordance with 10 CFR Part 54.

5-9 
Environmental Impacts of Postulated Accidents

5.4 References

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic licensing of 

production and utilization facilities.”

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

protection regulations for domestic licensing and related regulatory functions.”

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for 

renewal of operating licenses for nuclear power plants.”

10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, “Reactor site 

criteria.”

[Ameren] Ameren Missouri. 2011a. Callaway Plant Unit 1 – License Renewal Application, 

Applicant’s Environmental Report; Operating License Renewal Stage. Fulton, MO. 

December 15, 2011. Agencywide Documents Access and Management System (ADAMS) 

Nos. ML113530372 and ML113540354.

[Ameren] Ameren Missouri. 2011b. Letter from Scot Maglio to NRC Document Control Desk. 

Subject: Docket Number 50-483, Callaway Plant Unit 1, Union Electric Co., Facility Operating 

License NPF-30, Request for License Amendment to Adopt NFPA 805, “Performance-Based 

Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition),” (License 

Amendment Request LDCN 11-0012). August 9, 2011. ADAMS Nos. ML112420022.

[Ameren] Ameren Missouri. 2012a. Letter from L.H. Kanuckel to NRC Document Control Desk. 

Subject: Docket Number 50-483, Callaway Plant Unit 1, Union Electric Co., Facility Operating 

License NPF-30, Responses to SAMA RAI Set #1 to the Callaway LRA. September 24, 2012. 

ADAMS Nos. ML12269A163 and ML12269A164.

[Ameren] Ameren Missouri. 2012b. Letter from L.H. Kanuckel to NRC Document Control Desk. 

Subject: “Docket Number 50-483, Callaway Plant Unit 1, Union Electric Co., Facility Operating 

License NPF-30, Supplemental Response to SAMA RAI Set #1 for the Callaway LRA. 

October 17, 2012. ADAMS Nos. ML12292A403 and ML12292A404.

[Ameren] Ameren Missouri. 2013a. Letter from L.H. Kanuckel to NRC Document Control Desk. 

Subject: Docket Number 50-483, Callaway Plant Unit 1, Union Electric Co., Facility Operating 

License NPF-30, Clarification of Responses to SAMA RAIs to the Callaway LRA. 

January 15, 2013. ADAMS Nos. ML113016A170 and ML113016A171.

[Ameren] Ameren Missouri. 2013b. Letter from L.H. Kanuckel to NRC Document Control Desk. 

Subject: “Docket Number 50-483, Callaway Plant Unit 1, Union Electric Co., Facility Operating 

License NPF-30, Clarification of Responses to SAMA RAIs to the Callaway LRA.” April 2, 2013. 

ADAMS No. ML13094A020.

[NEI] Nuclear Energy Institute. 2005. Severe Accident Mitigation Alternative (SAMA) Analysis 

Guidance Document. NEI 05-01, Revision A. Washington, DC: NEI. November 2005. ADAMS 

No. ML060530203.

[NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG–1437. Available at 

<http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1437/> (accessed 20 June 2013).

[NRC] U.S. Nuclear Regulatory Commission. 1997. Regulatory Analysis Technical Evaluation 

Handbook. Washington, DC: NRC. NUREG/BR–0184. ADAMS No. ML050190193.

5-10
Environmental Impacts of Postulated Accidents

[NRC] U.S. Nuclear Regulatory Commission. 2004. Regulatory Analysis Guidelines of the 

U.S. Nuclear Regulatory Commission. Washington, DC: NRC. NUREG/BR–0058, Revision 4. 

Available at <http://www.nrc.gov/reading-rm/doc-collections/nuregs/brochures/br0058/> 

(accessed 20 June 2013.)

[NRC] U.S. Nuclear Regulatory Commission. 2005. EPRI/NRC-REC Fire PRA Methodology for 

Nuclear Power Facilities. NUREG/CR–6850 / EPRI 1011989, Volumes 1 and 2. 

September 2005. ADAMS Nos. ML052580075 and ML052580118.

[Union Electric] Union Electric Company. 1992. Letter from D.F. Schnell to NRC Document 

Control Desk. Subject: Docket Number 50-483 Callaway Plant Individual Plant Examination. 

September 29, 1992. ADAMS No. ML080150292.

[Union Electric] Union Electric Company. 1995. Letter from D.F. Schnell to NRC Document 

Control Desk. Subject: Docket Number 50-483 Callaway Plant response to Generic 

Letter 88-20, Supplement No. 4, Individual Plant Examination of External Events (IPEEE). 

June 30, 1995. ADAMS No. ML080150355.

5-11

6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE,

SOLID WASTE MANAGEMENT, AND GREENHOUSE GAS EMISSIONS

6.1 The Uranium Fuel Cycle

This section addresses issues related to the uranium fuel cycle and solid waste management 

during the period of extended operation (listed in Table 6–1). The uranium cycle includes 

uranium mining and milling, the production of uranium hexafluoride, isotopic enrichment, fuel 

fabrication, reprocessing of irradiated fuel, transportation of radioactive materials, and 

management of low-level wastes and high-level wastes related to uranium fuel cycle activities. 

The generic potential impacts of the radiological and nonradiological environmental impacts of 

the uranium fuel cycle and transportation of nuclear fuel and wastes are described in detail in 

the Generic Environmental Impact Statement (GEIS) (NRC 1996, 1999, 2013). They are based, 

in part, on the generic impacts described in Title 10, Part 51.51(b) of the Code of Federal 

Regulations (10 CFR 51.51(b)), Table S–3, “Table of Uranium Fuel Cycle Environmental Data”; 

and in 10 CFR 51.52(c), Table S–4, “Environmental Impact of Transportation of Fuel and Waste 

to and from One Light-Water-Cooled Nuclear Power Reactor.”

Table 6–1. Issues Related to the Uranium Fuel Cycle and Solid Waste Management.

There are nine generic issues related to the fuel cycle and waste management. 

There are no site-specific issues (Sources: 61 FR 28467, June 5, 1996).

Issues GEIS sections Category

Offsite radiological impacts (individual effects 

from other than the disposal of spent fuel and 

high-level waste)

6.1; 6.2.1; 6.2.2.1; 6.2.2.3; 

6.2.3; 6.2.4; 6.6

1 

Offsite radiological impacts (collective effects) 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6 1 

Offsite radiological impacts (spent fuel and 

high-level waste disposal)

6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6 1 

Nonradiological impacts of the uranium fuel 

cycle 

6.1; 6.2.2.6; 6.2.2.7; 6.2.2.8; 

6.2.2.9; 6.2.3; 6.2.4; 6.6

1 

Low-level waste storage and disposal 6.1; 6.2.2.2;6.4.2; 6.4.3; 6.4.3.1; 

6.4.3.2; 6.4.3.3; 6.4.4; 6.4.4.1; 

6.4.4.2; 6.4.4.3; 6.4.4.4; 6.4.4.5; 

6.4.4.5.1; 6.4.4.5.2; 6.4.4.5.3; 

6.4.4.5.4; 6.4.4.6;6.6

1 

Mixed waste storage and disposal 6.4.5.1; 6.4.5.2; 6.4.5.3; 6.4.5.4; 

6.4.5.5; 6.4.5.6; 6.4.5.6.1; 

6.4.5.6.2; 6.4.5.6.3; 6.4.5.6.4; 

6.6

1 

Onsite spent fuel 6.1; 6.4.6; 6.4.6.1; 6.4.6.2; 

6.4.6.3; 6.4.6.4; 6.4.6.5; 6.4.6.6; 

6.4.6.7; 6.6

1 

Nonradiological waste 6.1; 6.5; 6.5.1; 6.5.2; 6.5.3; 6.6 1 

Transportation 6.1; 6.3.1; 6.3.2.3; 6.3.3; 6.3.4; 

6.6, Addendum 1 

1 

6-1 
Environmental Impacts of the Uranium Fuel Cycle, 

Solid Waste Management, and Greenhouse Gas Emissions

The NRC staff’s evaluation of the environmental impacts associated with spent nuclear fuel 

(SNF) was addressed in two issues in Table 6–1, “Offsite radiological impacts (spent fuel and 

high-level waste disposal)” and “Onsite spent fuel.” However, as explained later in this section, 

the evaluation of these two issues are not evaluated in this SEIS. In addition, for the issue, 

“Onsite spent fuel,” the staff only evaluates the environmental impacts during the license 

renewal term. 

For the term of license renewal, the staff did not find any new and significant information related 

to “Onsite spent fuel” and the remaining uranium fuel cycle and solid waste management issues 

listed in Table 6–1 during its review of the Callaway Plant, Unit 1 environmental report (ER) 

(Ameren 2011), the site visit, and the scoping process. Therefore, there are no impacts related 

to these issues beyond those discussed in the GEIS. For these Category 1 issues, the GEIS 

concludes that the impacts are SMALL, except for the issue, “Offsite radiological impacts 

(collective effects),” which the NRC has not assigned an impact level. This issue assesses the 

100-year radiation dose to the U.S. population (i.e., collective effects or collective dose) from 

radioactive effluents released as part of the uranium fuel cycle for a nuclear power plant during 

the license renewal term compared to the radiation dose from natural background 

exposure. It is a comparative assessment for which there is no regulatory standard to base an 

impact level.

For the offsite radiological impacts resulting from spent fuel and high-level waste disposal and 

the onsite storage of spent fuel, which will occur after the reactor has been permanently shut 

down, the NRC’s Waste Confidence Decision and Rule historically represented the 

Commission’s generic determination that spent fuel can continue to be stored safely and without 

significant environmental impacts for a period of time after the end of the licensed life for 

operation. This generic determination meant that the NRC did not need to consider the storage 

of spent fuel after the end of a reactor’s licensed life for operation in National Environmental 

Policy Act (NEPA) documents that support its reactor and spent fuel storage application 

reviews.

The NRC first adopted the Waste Confidence Decision and Rule in 1984. The NRC amended

the decision and rule in 1990, reviewed them in 1999, and amended them again in 2010, as 

published in the Federal Register (FR)(49 FR 34694, 55 FR 38474, 64 FR 68005, and 

75 FR 81032 and 81037). The Waste Confidence Decision and Rule are codified in 

10 CFR 51.23.

On December 23, 2010, the Commission published in the FR a revision of the Waste 

Confidence Decision and Rule to reflect information gained from experience in the storage of 

spent fuel and the increased uncertainty in the siting and construction of a permanent geologic 

repository for the disposal of SNF and high-level waste (75 FR 81032 and 81037). In response 

to the 2010 Waste Confidence Decision and Rule, the States of New York, New Jersey, 

Connecticut, and Vermont, along with several other parties, challenged the Commission’s NEPA

analysis in the decision, which provided the regulatory basis for the rule. On June 8, 2012, the 

United States Court of Appeals, District of Columbia Circuit in New York v. NRC, 681 F.3d 471 

(D.C. Cir. 2012) vacated the NRC’s Waste Confidence Decision and Rule, after finding that it 

did not comply with NEPA.

In response to the court’s ruling, the Commission, in CLI-12-16 (NRC 2012a), determined that it 

would not issue licenses that rely upon the Waste Confidence Decision and Rule until the issues 

identified in the court’s decision are appropriately addressed by the Commission. In CLI-12-16, 

the Commission also noted that the decision not to issue licenses only applied to final license 

issuance; all licensing reviews and proceedings should continue to move forward. 

6-2 
Environmental Impacts of the Uranium Fuel Cycle, 

Solid Waste Management, and Greenhouse Gas Emissions

In addition, the Commission directed in SRM-COMSECY-12-0016 (NRC 2012b) that the NRC 

staff proceed with a rulemaking that includes the development of a generic environmental 

impact statement (EIS) to support a revised Waste Confidence Decision and Rule and to 

publish both the EIS and the revised decision and rule in the Federal Register within 24 months 

(by September 2014). The Commission indicated that both the EIS and the revised Waste 

Confidence Decision and Rule should build on the information already documented in various 

NRC studies and reports, including the existing environmental assessment that the NRC 

developed as part of the 2010 Waste Confidence Decision and Rule. The Commission directed 

that any additional analyses should focus on the issues identified in the court’s decision. The 

Commission also directed that the NRC staff provide ample opportunity for public comment on 

both the draft EIS and the proposed Waste Confidence Decision and Rule.

The revised rule and supporting EIS are expected to provide the necessary NEPA analyses of 

waste confidence-related human health and environmental issues. As directed by the 

Commission, the NRC would not issue a renewed license before the resolution of waste 

confidence-related issues. This would ensure that there would be no irretrievable or irreversible 

resource commitments or potential harm to the environment before waste confidence impacts 

have been addressed. 

On August 26, 2014, the Commission approved a revised rule at 10 CFR 51.23 and associated 

Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel

(NUREG-2157, ADAMS Accession No. ML14237A092). Subsequently, on 

September 19, 2014, the NRC published the revised rule (79 FR 56238) in the Federal Register 

along with NUREG-2157 (NRC 2014a). The revised rule adopts the generic impact 

determinations made in NUREG-2157 and codifies the NRC’s generic determinations regarding 

the environmental impacts of continued storage of spent nuclear fuel beyond a reactor’s 

operating license (i.e., those impacts that could occur as a result of the storage of spent nuclear 

fuel at at-reactor or away-from-reactor sites after a reactor’s licensed life for operation and until 

a permanent repository becomes available). By rule (10 CFR 51.23) those impacts are deemed 

incorporated into this SEIS.

In CLI-14-08 (NRC 2014b), the Commission held that the revised 10 CFR 51.23 and associated 

NUREG-2157 cure the deficiencies identified by the court in New York v. NRC, 681F.3d 471 

(D.C. Cir. 2012) and stated that the rule satisfies the NRC’s NEPA obligations with respect to 

continued storage for initial, renewed, and amended licenses.

If the results of the Continued Storage Rule and its supporting EIS lead to information that 

requires a supplement to this SEIS, the NRC staff will perform any appropriate additional NEPA

review for those issues before the NRC makes a final licensing decision.

6.2 Greenhouse Gas Emissions

This section discusses the potential impacts from greenhouse gases (GHGs) emitted from the 

uranium fuel cycle. The GEIS does not directly address these emissions, and its discussion is 

limited to an inference that substantial carbon dioxide (CO2) emissions may occur if coal- or 

oil-fired alternatives to license renewal are carried out.

6.2.1 Existing Studies

Since the development of the GEIS, the relative volumes of GHGs emitted by nuclear and other 

methods of generating electricity have been widely studied. However, estimates and 

projections of the carbon footprint of the nuclear power plant life cycle vary depending on the 

6-3 
Environmental Impacts of the Uranium Fuel Cycle, 

Solid Waste Management, and Greenhouse Gas Emissions

type of study done. In addition, there is considerable debate among researchers on the relative 

effects of nuclear and other forms of electricity generation on GHG emissions. Existing studies 

on GHG emissions from nuclear power plants generally take one of two forms:

(1) qualitative discussions of the potential to use nuclear power to reduce GHG 

emissions and mitigate global warming and

(2) technical analyses and quantitative estimates of the actual amount of GHGs 

generated by the uranium fuel cycle or entire nuclear power plant life cycle and 

comparisons to the operational or life-cycle emissions from other energy generation 

alternatives. 

6.2.1.1 Qualitative Studies

The qualitative studies consist primarily of broad evaluations, large-scale public policy 

evaluations, or investment evaluations of whether an expansion of nuclear power is likely to be 

a technically, economically, or politically workable means of achieving global GHG reductions. 

Studies found by the NRC staff during the subsequent literature search include the following:

 Evaluations to determine if investments in nuclear power in developing 

countries should be accepted as a flexibility mechanism to assist 

industrialized nations in achieving their GHG reduction goals under the Kyoto 

Protocol (IAEA 2000, NEA and OECD 2002, Schneider 2000). Ultimately, the 

parties to the Kyoto Protocol did not approve nuclear power as a component 

under the clean development mechanism (CDM) because of safety and 

waste disposal concerns (NEA and OECD 2002).

 Analyses developed to assist governments, including the U.S. Government, 

in making long-term investment and public policy decisions in nuclear power 

(Hagen et al. 2001, Keepin 1988, MIT 2003).

Although the qualitative studies sometimes reference and critique the existing quantitative 

estimates of GHGs produced by the nuclear power plant life cycle, their conclusions generally 

rely heavily on discussions of other aspects of nuclear policy decisions and investment, such as 

safety, cost, waste generation, and political acceptability. Therefore, these studies typically are 

not directly applicable to an evaluation of GHG emissions associated with the proposed license 

renewal for a given nuclear power plant.

6.2.1.2 Quantitative Studies

A large number of technical studies, including calculations and estimates of the amount of 

GHGs emitted by nuclear and other power generation options, are available in the literature and 

were useful to the NRC staff’s efforts in addressing relative GHG emission levels. Examples of 

these studies include—but are not limited to—Mortimer (1990), Andseta et al. (1998), 

Spadaro et al. (2000), Storm van Leeuwen and Smith (2008), Fritsche (2006), Parliamentary 

Office of Science and Technology (POST) (2006), Atomic Energy Authority (AEA) (2006), 

Weisser (2006), Fthenakis and Kim (2007), and Dones (2007). In addition, Sovacool (2008) 

provides a review and synthesis of studies in existence through 2008. However, the Sovacool 

synthesis ultimately uses only 19 of the 103 studies initially considered. The remaining 84 were 

excluded because they were (1) more than 10 years old; (2) not publicly available; (3) available 

only in a language other than English; or (4) they presented methodological challenges by 

relying on inaccessible data, provided overall GHG estimates without allocating relative GHG 

impacts to different parts of the nuclear power plant life cycle, or they were otherwise not 

methodologically explicit.

6-4 
Environmental Impacts of the Uranium Fuel Cycle, 

Solid Waste Management, and Greenhouse Gas Emissions

Comparing these studies and others like them is difficult because the assumptions and 

components of the life cycles the authors evaluate vary widely. Examples of areas in which 

differing assumptions make comparing the studies difficult include the following:

 energy sources that may be used to mine uranium deposits in the future, 

 reprocessing or disposal of SNF, 

 current and potential future processes to enrich uranium and the energy 

sources that will power them,

 estimated grades and quantities of recoverable uranium resources,

 estimated grades and quantities of recoverable fossil fuel resources,

 estimated GHG emissions other than CO2, including the conversion to 

CO2-equivalent per unit of electric energy produced,

 performance of future fossil-fuel power systems,

 projected capacity factors for alternative means of generation, and

 current and potential future reactor technologies.

In addition, studies may vary with respect to whether all or parts of a power plant’s life cycle are 

analyzed. A full life-cycle analysis will typically address plant construction, operations, resource 

extraction (for fuel and construction materials), and decommissioning, whereas a partial 

life-cycle analysis primarily focuses on operational differences. In addition, as Sovacool (2008) 

noted, studies vary greatly in terms of age, data availability, and methodological transparency.

In the case of license renewal, a GHG analysis for the portion of the nuclear power plant’s life 

cycle attributable to license renewal (operation for an additional 20 years) would not involve 

GHG emissions associated with construction because construction activities have already been 

completed at the time of relicensing. Nor would the proposed action of license renewal involve 

additional GHG emissions associated with facility decommissioning, because decommissioning 

must occur whether the facility is relicensed or not. However, in many studies, the specific 

contribution of GHG emissions from construction, decommissioning, or other portions of a 

nuclear power plant’s life cycle cannot be clearly separated from one another. In such cases, 

an analysis of GHG emissions would overestimate the GHG emissions attributed to a specific 

portion of a nuclear power plant’s life cycle. As Sovacool (2008) noted, many of the available 

analyses provide markedly lower GHG emissions per unit of plant output when one assumes 

that a power plant operates for a longer period of time than in its original license. Nonetheless, 

available studies supply some meaningful information with respect to the relative magnitude of 

the emissions among nuclear power plants and other forms of electric generation, as discussed 

in the following sections.

In Tables 6–2, 6–3, and 6–4, the NRC staff presents the results of the above-mentioned 

quantitative studies to supply a weight-of-evidence evaluation of the relative GHG emissions 

that may result from the proposed license renewal as compared to the potential alternative use 

of coal-fired, natural gas–fired, and renewable generation. Most studies from Mortimer (1990) 

through Sovacool (2008) indicate that uranium ore grades and uranium enrichment processes 

are leading determinants in the ultimate GHG emissions attributable to nuclear power 

generation. These studies show that the relatively lower order of magnitude of GHG emissions 

from nuclear power, when compared to fossil-fueled alternatives (especially natural gas), could 

potentially disappear if available uranium ore grades drop sufficiently while enrichment 

processes continued to rely on the same technologies.

6-5 
Environmental Impacts of the Uranium Fuel Cycle, 

Solid Waste Management, and Greenhouse Gas Emissions

Sovacool’s synthesis of 19 existing studies found that nuclear power generation causes carbon 

emissions in a range of 1.4 grams of carbon-equivalent per kilowatt-hour (g Ceq/kWh) to 

288 g Ceq/kWh, with a mean value of 66 g Ceq/kWh. The results of his synthesis and the results 

of others’ efforts are included in the tables in this section.

6.2.1.3 Summary of Nuclear Greenhouse Gas Emissions Compared to Coal

Given that coal-fired generation comprises the largest share of electricity in the United States 

and that it results in the largest emissions of GHGs for any of the likely alternatives to nuclear 

power generation, many of the available quantitative studies focused on comparisons of the 

relative GHG emissions of nuclear- and coal-fired generation. The quantitative estimates of the 

GHG emissions associated with the uranium fuel cycle (and, in some cases, the nuclear power 

plant life cycle), as compared to an equivalent coal-fired plant, are presented in Table 6–2. 

The NRC staff considered the best available information for its independent analysis. The 

following table does not include all existing studies, but it provides a range of estimates 

developed from various sources.

Table 6–2. Nuclear Greenhouse Gas Emissions Compared to Coal

Source GHG emission results

Mortimer (1990) Nuclear: 230,000 tons CO2 

Coal: 5,912,000 tons CO2

Note: Future GHG emissions from nuclear are expected to increase 

because of declining ore grade.

Andseta et al. (1998) Nuclear power plants produce 1.4% of the GHG emissions produced 

by coal-fired plants.

Note: Future reprocessing and use of nuclear-generated electrical 

power in the mining and enrichment steps are likely to change the 

projections of earlier authors, such as Mortimer (1990).

Spadaro et al. (2000) Nuclear: 2.5–5.7 g Ceq/kWh

Coal: 264–357 g Ceq/kWh

Fritsche (2006) (values 

estimated from graph in 

Figure 4)

Nuclear: 33 g Ceq/kWh

Coal: 950 g Ceq/kWh

POST (2006) (nuclear 

calculations from AEA 2006

Nuclear: 5 g Ceq/kWh

Coal: >1,000 g Ceq/kWh

Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 

6.8 g Ceq/kWh. Future improved technology and carbon capture and 

storage could reduce coal-fired GHG emissions by 90%. 

Weisser (2006) (compilation

of results from other studies)

Nuclear: 2.8–24 g Ceq/kWh

Coal: 950–1,250 g Ceq/kWh

Sovacool (2008) (adopted 

from other studies)

Nuclear: 66 g Ceq/kWh

Coal: 960–1,050 g Ceq/kWh

6-6 
Environmental Impacts of the Uranium Fuel Cycle, 

Solid Waste Management, and Greenhouse Gas Emissions

6.2.1.4 Summary of Nuclear Greenhouse Gas Emissions Compared to Natural Gas

Table 6–3 presents the quantitative estimates of the GHG emissions associated with the 

uranium fuel cycle (and, in some cases, the nuclear power plant life cycle), as compared to an 

equivalent natural gas–fired plant. In considering the best available information for its 

independent analysis, the NRC staff noted that the following table does not include all existing 

studies; however, it provides a range of estimates developed from various sources.

Table 6–3. Nuclear Greenhouse Gas Emissions Compared to Natural Gas

Source GHG emission results

Spadaro et al. (2000) Nuclear: 2.5–5.7 g Ceq/kWh

Natural Gas: 120–188 g Ceq/kWh

Storm van Leeuwen and 

Smith (2005)

Nuclear fuel cycle produces 20–33% of the GHG emissions compared 

to natural gas (at high ore grades).

Note: Future nuclear GHG emissions are expected to increase 

because of declining ore grade.

Fritsche (2006) (values 

estimated from graph in 

Figure 4)

Nuclear: 33 g Ceq/kWh

Cogeneration Combined-Cycle Natural Gas: 150 g Ceq/kWh

POST (2006) (nuclear 

calculations from AEA 2006)

Nuclear: 5 g Ceq/kWh

Natural Gas: 500 g Ceq/kWh

Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 

6.8 g Ceq/kWh. Future improved technology and carbon capture and 

storage could reduce natural gas GHG emissions by 90%. 

Weisser (2006) (compilation

of results from other studies)

Nuclear: 2.8–24 g Ceq/kWh

Natural Gas: 440–780 g Ceq/kWh

Dones (2007) Author critiqued methods and assumptions of Storm van Leeuwen and 

Smith (2005) and concluded that the nuclear fuel cycle produces 

15–27% of the GHG emissions of natural gas.

Sovacool (2008) (adopted 

from other studies)

Nuclear: 66 g Ceq/kWh 

Natural Gas: 443 g Ceq/kWh 

6.2.1.5 Summary of Nuclear Greenhouse Gas Emissions Compared to Renewable Energy 

Sources

The quantitative estimates of the GHG emissions associated with the uranium fuel cycle (and, in 

some cases, the nuclear power plant life cycle), as compared to equivalent renewable energy 

sources, are presented in Table 6–4. Calculation of GHG emissions associated with these 

sources is more difficult than the calculations for nuclear energy and fossil fuels because of the 

large variation in efficiencies and capacity factors caused by their different technologies, 

sources, and locations. For example, the efficiency of solar and wind energy is highly 

dependent on the wind or solar resource in a particular location. Similarly, the range of GHG 

emissions estimates for hydropower varies greatly, depending on the type of dam or reservoir 

involved (if used at all). Therefore, the GHG emissions estimates for these energy sources 

have a greater range of variability than the estimates for nuclear and fossil-fuel sources. The 

following table gives an illustrative range of estimates developed by various sources.

6-7 
Environmental Impacts of the Uranium Fuel Cycle, 

Solid Waste Management, and Greenhouse Gas Emissions

Table 6–4. Nuclear Greenhouse Gas Emissions Compared to Renewable Energy Sources

Source GHG emission results

Mortimer (1990) Nuclear: 230,000 tons CO2 

Hydropower: 78,000 tons CO2 

Wind power: 54,000 tons CO2 

Tidal power: 52,500 tons CO2

Note: Future GHG emissions from nuclear are expected to increase 

because of declining ore grade.

Spadaro et al. (2000) Nuclear: 2.5–5.7 g Ceq/kWh

Solar PV: 27.3–76.4 g Ceq/kWh

Hydroelectric: 1.1–64.6 g Ceq/kWh

Biomass: 8.4–16.6 g Ceq/kWh

Wind: 2.5–13.1 g Ceq/kWh

Fritsche (2006) (values 

estimated from graph in 

Figure 4)

Nuclear: 33 g Ceq/kWh

Solar PV: 125 g Ceq/kWh

Hydroelectric: 50 g Ceq/kWh

Wind: 20 g Ceq/kWh

POST (2006) (Nuclear 

calculations from AEA 2006)

Nuclear: 5 g Ceq/kWh

Biomass: 25–93 g Ceq/kWh

Solar PV: 35–58 g Ceq/kWh

Wave/Tidal: 25–50 g Ceq/kWh

Hydroelectric: 5–30 g Ceq/kWh

Wind: 4.64–5.25 g Ceq/kWh

Note: Decrease of uranium ore grade to 0.03% would raise nuclear to 

6.8 g Ceq/kWh.

Weisser (2006) (Compilation 

of results from other studies)

Nuclear: 2.8–24 g Ceq/kWh

Solar PV: 43–73 g Ceq/kWh

Hydroelectric: 1–34 g Ceq/kWh

Biomass: 35–99 g Ceq/kWh

Wind: 8–30 g Ceq/kWh

Fthenakis and Kim (2007) Nuclear: 16–55 g Ceq/kWh

Solar PV: 17–49 g Ceq/kWh

Sovacool (2008) (adopted 

from other studies)

Nuclear: 66 g Ceq/kWh 

Wind: 9–10 g Ceq/kWh 

Hydroelectric (small, distributed): 10–13 g Ceq/kWh

Biogas digester: 11 g Ceq/kWh

Solar Thermal: 13 g Ceq/kWh

Biomass: 14–35 g Ceq/kWh

Solar PV: 32 g Ceq/kWh

Geothermal (hot, dry rock): 38 g Ceq/kWh

6.2.2 Conclusions: Relative Greenhouse Gas Emissions

The results of the studies presented in Tables 6–2, 6–3, and 6–4 demonstrate the challenges of 

any attempt to determine the specific amount of GHG emissions attributable to nuclear power 

generation, as different assumptions and calculation methods yield different results. The 

6-8 
Environmental Impacts of the Uranium Fuel Cycle, 

Solid Waste Management, and Greenhouse Gas Emissions

differences and complexities in these assumptions and analyses will further increase when they 

are used to project future GHG emissions. Nevertheless, several conclusions can be drawn 

from the information presented.

First, the general consensus of the studies is that nuclear power currently produces fewer GHG 

emissions than electrical generation based on fossil fuels. The studies also gave estimates of 

GHG emissions from renewable energy sources based on current and available technology. 

The range of these estimates is wide, but the general conclusion is that current GHG emissions 

from nuclear power generation are of the same order of magnitude as from these renewable 

energy sources.

Second, the studies show no consensus on future relative GHG emissions from the nuclear 

power plant life cycle and other sources of electricity. There is substantial disagreement among 

the various authors about the GHG emissions associated with declining uranium ore 

concentrations, future uranium enrichment methods, and other factors, including changes in 

technology. Similar disagreement exists about future GHG emissions associated with coal and 

natural gas for electricity generation. Even the most conservative studies conclude that the 

nuclear power plant life cycle currently produces fewer GHG emissions than sources based on 

fossil fuels and is expected to continue to do so in the near future. The primary difference 

between the authors is the projected cross-over date (the time at which GHG emissions from 

the nuclear power plant life cycle exceed those sources based on fossil fuels) or whether 

cross-over will actually occur.

Given these current estimates and future uncertainties, it appears that GHG emissions 

associated with the proposed relicensing action for Callaway Plant, Unit 1 (Callaway), are likely 

to be lower than those associated with energy sources based on fossil fuels. The NRC staff 

bases this conclusion on the following:

 As shown in Tables 6–2 and 6–3, the current estimates of GHG emissions 

from the nuclear power plant life cycle are far below those for energy sources 

based on fossil fuels.

 License renewal of a nuclear power plant such as Callaway may involve 

continued GHG emissions because of uranium mining, processing, and 

enrichment, but it will not result in increased GHG emissions associated with 

plant construction or decommissioning (as the plant will have to be 

decommissioned at some point whether the license is renewed or not).

 Few studies predict that nuclear power plant life-cycle emissions will exceed 

those of fossil fuels within a time frame that includes the Callaway period of 

extended operation. Several studies suggest that future extraction and 

enrichment methods, the potential for higher-grade resource discovery, and 

technology improvements could extend this time frame.

With respect to the comparison of GHG emissions among the proposed Callaway license 

renewal action and renewable energy sources:

 It appears likely that there will be future technology improvements and 

changes in the type of energy used for mining, processing, manufacturing, 

and constructing facilities of all types.

 Currently, the GHG emissions associated with the nuclear power plant life 

cycle and renewable energy sources are within the same order of magnitude.

6-9 
Environmental Impacts of the Uranium Fuel Cycle, 

Solid Waste Management, and Greenhouse Gas Emissions

 Because nuclear fuel production is the most significant contributor to potential 

future increases in GHG emissions from nuclear power—and because most 

renewable energy sources lack a fuel component—it is likely that GHG 

emissions from renewable energy sources will be lower than those 

associated with Callaway at some point during the period of extended 

operation.

The NRC staff also supplies an additional discussion about the contribution of GHG to 

cumulative air quality impacts in Section 4.11.2 of this EIS.

6.3 References

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

protection regulations for domestic licensing and related regulatory functions.”

75 FR 81032. U.S. Nuclear Regulatory Commission. Consideration of environmental impacts of 

temporary storage of spent fuel after cessation of reactor operation. Federal 

Register 75(246):81032–81037. December 23, 2010.

75 FR 81037. U.S. Nuclear Regulatory Commission. Waste confidence decision update. 

Federal Register 75(246):81037–81076. December 23, 2010.

79 FR 56238. U.S. Nuclear Regulatory Commission. “Continued Storage of Spent 

Nuclear Fuel.” Federal Register 79(182):56238–56263. September 19, 2014.

[AEA] AEA Technology. 2006. “Carbon Footprint of the Nuclear Fuel Cycle, Briefing Note.” 

East Kilbride, UK: British Energy Group. March 2006. Available at 

<http://www.british-energy.com/documents/carbon_footprint.pdf> (accessed 7 May 2012).

[Ameren] Ameren Missouri. 2011. License Renewal Application, Callaway Plant Unit 1, 

Appendix E, Applicant’s Environmental Report, Operating License Renewal Stage. Fulton MO:

Ameren. December 15, 2011. Agencywide Documents Access and Management System 

(ADAMS) Nos. ML113540349, ML113540352, and ML113540354.

Andseta S, Thompson MJ, Jarrell JP, Pendergast DR. 1998. CANDU reactors and greenhouse

gas emissions. In: Proceedings of the 19th Annual Conference. Canadian Nuclear Society; 

1998 October 18–21; Toronto, ON. Available at 

<http://computare.org/Support%20documents/Publications/Life%20Cycle.htm> (accessed 

7 May 2012).

Dones R. 2007. Critical Note on the Estimation by Storm Van Leeuwen JW and Smith P of the 

Energy Uses and Corresponding CO2 Emissions for the Complete Nuclear Energy Chain. 

Villigen, Switzerland: Paul Sherer Institute. April 2007. Available at 

<http://gabe.web.psi.ch/pdfs/Critical%20note%20GHG%20PSI.pdf> (accessed 7 May 2012).

Fritsche UR. 2006. Comparison of Greenhouse-Gas Emissions and Abatement Cost of Nuclear 

and Alternative Energy Options from a Life-Cycle Perspective. Freiburg, Germany: Oko-Institut. 

January 2006. Available at <http://www.oeko.de/oekodoc/315/2006-017-en.pdf> (accessed 

7 May 2012).

Fthenakis VM, Kim HC. 2007. Greenhouse-gas emissions from solar-electric and nuclear 

power: A life-cycle study. Energy Policy 35(4):2549–2557.

Hagen RE, Moens JR, Nikodem ZD. 2001. “Impact of U.S. Nuclear Generation on Greenhouse 

Gas Emissions.” International Atomic Energy Agency, Vienna, Austria. November 2001.

6-10
Environmental Impacts of the Uranium Fuel Cycle, 

Solid Waste Management, and Greenhouse Gas Emissions

[IAEA] International Atomic Energy Agency. 2000. Nuclear Power for Greenhouse Gas 

Mitigation under the Kyoto Protocol: The Clean Development Mechanism (CDM). 

Vienna, Austria: IAEA. November 2000. Available at 

<http://www.iaea.org/Publications/Booklets/GreenhouseGas/greenhousegas.pdf> (accessed 

7 May 2012).

Keepin B. 1988. “Greenhouse Warming: Efficient Solution of Nuclear Nemesis?” Rocky 

Mountain Institute, Joint Hearing on Technologies for Remediating Global Warming. 

Subcommittee on Natural Resources. Agriculture Research and Environment and 

Subcommittee on Science, Research and Technology, U.S. House of Representatives. 

June 1988.

[MIT] Massachusetts Institute of Technology. 2003. “The Future of Nuclear Power: 

An Interdisciplinary MIT Study.”

Mortimer N. 1990. “World Warms to Nuclear Power.” SCRAM Safe Energy Journal

December 1989/January 1990. Available at 

<http://www.no2nuclearpower.org.uk/articles/mortimer_se74.php> (accessed 7 May 2012).

[NEA and OECD] Nuclear Energy Agency and Organisation for Economic Co-operation and 

Development. 2002. Nuclear Energy and the Kyoto Protocol. Paris, France: OECD. 53 p. 

Available at <http://www.oecd-nea.org/ndd/reports/2002/nea3808-kyoto.pdf> (accessed 

14 January 2014).

[NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG–1437, Volumes 1 and 2, 

May 1996. ADAMS Nos. ML040690705 and ML040690738.

[NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3–Transportation, Table 9.1, 

Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic 

Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: 

NRC. NUREG–1437, Volume 1, Addendum 1. August 1999. ADAMS No. ML04069720.

[NRC] U.S. Nuclear Regulatory Commission. 2012a. “Commission, Memorandum and Order 

CLI-12-16.” August 7, 2012. ADAMS No. ML12220A094.

[NRC] U.S. Nuclear Regulatory Commission. 2012b. “SRM-COMSECY-12-0016—Approach for 

Addressing Policy Issues Resulting from Court Decision To Vacate Waste Confidence Decision 

and Rule.” September 6, 2012. ADAMS No. ML12250A032. Pehnt M. 2006. Dynamic life cycle 

assessment (LCA) of renewable energy technologies. Renewable Energy 31(2006)55–71. 

Available at <http://www.ifeu.de/energie/pdf/

Environmental%20Impacts%20of%20Distributed%20Power%20Generation.pdf> (accessed 

2 November 2012).

[NRC] U.S. Nuclear Regulatory Commission. 2013. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. Washington, DC: Office of Nuclear Reactor Regulation. 

NUREG 1437, Revision 1, Volumes 1, 2, and 3. June 2013. ADAMS Accession 

Nos. ML13106A241, ML13106A242, and ML13106A244.

[NRC] U.S. Nuclear Regulatory Commission. 2014a. Generic Environmental Impact Statement

for Continued Storage of Spent Nuclear Fuel. Washington, DC: NRC, Office of Nuclear Material 

Safety and Safeguards. NUREG–2157, Volumes 1 and 2. September 2014. ADAMS 

Accession Nos. ML14196A105 and ML14196A107.

6-11
Environmental Impacts of the Uranium Fuel Cycle, 

Solid Waste Management, and Greenhouse Gas Emissions

[NRC] U.S. Nuclear Regulatory Commission. 2014b. “Commission, Memorandum and 

Order CLI-14-08.” August 26, 2014. ADAMS Accession No. ML14238A242. 

[POST] Parliamentary Office of Science and Technology. 2006. Carbon footprint of electricity 

generation. Postnote 268. October 2006. Available at 

<http://www.parliament.uk/documents/post/postpn268.pdf> (accessed 7 May 2012).

Schneider M. 2000. Climate Change and Nuclear Power. Gland, Switzerland: WWF–World 

Wildlife Fund for Nature. April 2000. Available at 

<http://assets.panda.org/downloads/fullnuclearreprotwwf.pdf> (accessed 7 May 2012).

Sovacool BK. 2008. Valuing the greenhouse gas emissions from nuclear power: A critical 

survey. Energy Policy 36:2940–2953.

Spadaro JV, Langlois L, Hamilton B. 2000. “Greenhouse Gas Emissions of Electricity 

Generation Chains: Assessing the Difference.” Vienna, Austria: International Atomic Energy 

Agency. Available at <http://www.iaea.org/Publications/Magazines/Bulletin/Bull422/article4.pdf> 

(accessed IAEA Bulletin, Vol. 42, No. 2, Vienna, 2000).

Storm van Leeuwen JW, Smith P. 2008. Nuclear Power—The Energy Balance. Chaam, 

Netherlands: Ceedata Consultancy. February 2008. Available at <http://www.stormsmith.nl/> 

(accessed 7 May 2012).

Weisser D. 2006. A guide to life-cycle greenhouse gas (GHG) emissions from electric supply 

technologies. Energy 32(9):1543–1559. Available at <http://www.iaea.org/OurWork/ST/

NE/Pess/assets/GHG_manuscript_pre-print_versionDanielWeisser.pdf> (accessed 

7 May 2012).

6-12
7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING

Environmental impacts from the activities associated with the decommissioning of any reactor

before or at the end of an initial or renewed license are evaluated in Supplement 1 of 

NUREG–0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear 

Facilities Regarding the Decommissioning of Nuclear Power Reactors (NRC 2002). The 

U.S. Nuclear Regulatory Commission (NRC) staff’s evaluation of the environmental impacts of 

decommissioning—presented in NUREG–0586, Supplement 1—notes a range of impacts for 

each environmental issue.

Additionally, the incremental environmental impacts associated with decommissioning activities 

resulting from continued plant operation during the renewal term are discussed in 

NUREG–1437, Generic Environmental Impact Statement (GEIS) for License Renewal of 

Nuclear Plants (NRC 1996, 1999). The GEIS includes a determination of whether the analysis 

of the environmental issue could be applied to all plants and whether additional mitigation

measures would be warranted. Issues were then assigned a Category 1 or a Category 2 

designation. As set forth in the GEIS, Category 1 issues are those that meet all of the following 

criteria:

 The environmental impacts associated with the issue have been determined 

to apply either to all plants or, for some issues, to plants having a specific 

type of cooling system or other specified plant or site characteristics.

 A single significance level (i.e., SMALL, MODERATE, or LARGE) has been 

assigned to the impacts (except for collective offsite radiological impacts from 

the fuel cycle and from high-level waste and spent fuel disposal).

 Mitigation of adverse impacts associated with the issue has been considered 

in the analysis, and it has been determined that additional plant-specific 

mitigation measures are not likely to be sufficiently beneficial to warrant 

implementation.

For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 

required unless new and significant information is identified.

Category 2 issues are those that do not meet one or more of the criteria for Category 1; 

therefore, additional plant-specific review of these issues is required. There are no Category 2 

issues related to decommissioning.

7.1 Decommissioning

Table 7–1 lists the Category 1 issues in Table B–1 of Part 51, “Environmental protection 

regulations for domestic licensing and related regulatory functions,” of Title 10 of the Code of 

Federal Regulations (10 CFR Part 51), Subpart A, “National environmental policy act—

regulations implementing Section 102(2),” Appendix B, “Environmental effect of renewing the 

operating license of a nuclear power plant,” that are applicable to Callaway Plant, Unit 1 

(Callaway) decommissioning following the renewal term.

7-1 
Environmental Impacts of Decommissioning

Table 7–1. Issues Related to Decommissioning

Issues GEIS Section Category

Radiation doses 7.3.1; 7.4 1

Waste management 7.3.2; 7.4 1

Air quality 7.3.3; 7.4 1

Water quality 7.3.4; 7.4 1

Ecological resources 7.3.5; 7.4 1

Socioeconomic impacts 7.3.7; 7.4 1

Decommissioning would occur whether Callaway were shut down at the end of its current 

operating license or at the end of the period of extended operation. There are no site-specific 

issues related to decommissioning.

A brief description of the NRC staff’s review and the GEIS conclusions, as codified in Table B–1 

of Appendix B to Subpart A, 10 CFR Part 51, for each of the issues follows:

Radiation doses. Based on information in the GEIS, the NRC noted that “[d]oses to the public 

will be well below applicable regulatory standards regardless of which decommissioning method 

is used. Occupational doses would increase no more than 1 person-rem (1 person-[millisievert] 

mSv) caused by buildup of long-lived radionuclides during the license renewal term.”

Waste management. Based on information in the GEIS, the NRC noted that 

“[d]ecommissioning at the end of a 20-year license renewal period would generate no more 

solid wastes than at the end of the current license term. No increase in the quantities of 

Class C or greater than Class C wastes would be expected.”

Air quality. Based on information in the GEIS, the NRC noted that “[a]ir quality impacts of 

decommissioning are expected to be negligible either at the end of the current operating term or 

at the end of the license renewal term.”

Water quality. Based on information in the GEIS, the NRC noted that “[t]he potential for 

significant water quality impacts from erosion or spills is no greater whether decommissioning 

occurs after a 20-year license renewal period or after the original 40-year operation period, and 

measures are readily available to avoid such impacts.”

Ecological resources. Based on information in the GEIS, the NRC noted that 

“[d]ecommissioning after either the initial operating period or after a 20-year license renewal 

period is not expected to have any direct ecological impacts.”

Socioeconomic Impacts. Based on information in the GEIS, the NRC noted that 

“[d]ecommissioning would have some short-term socioeconomic impacts. The impacts would 

not be increased by delaying decommissioning until the end of a 20-year relicense period, but 

they might be decreased by population and economic growth.”

Union Electric Company, a subsidiary of Ameren Corporation and doing business as Ameren 

Missouri (Ameren), stated in its Environmental Report (ER) (Ameren 2011) that it is not aware 

of any new and significant information on the environmental impacts of Callaway’s license 

renewal with respect to decommissioning. The NRC staff has not found any new and significant 

information as it relates to decommissioning during its independent review of Ameren’s ER, the 

site visit, the scoping process, or its evaluation of other available information (including 

comments on the draft supplemental environmental impact statement). Therefore, the NRC 

staff concludes that there are no impacts related to these issues beyond those discussed in the 

GEIS. For all of these issues, the NRC staff concluded in the GEIS that the impacts are 

7-2 
Environmental Impacts of Decommissioning

SMALL, and additional plant-specific mitigation measures are not likely to be sufficiently 

beneficial to be warranted.

7.2 References

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

protection regulations for domestic licensing and related regulatory functions.”

[Ameren] Ameren Missouri. 2011. License Renewal Application, Callaway Plant Unit 1, 

Appendix E, Applicant’s Environmental Report, Operating License Renewal Stage. Fulton, MO: 

Ameren. December 15, 2011. Agencywide Documents Access and Management System 

(ADAMS) Nos. ML113540349, ML113540352, and ML113540354.

[NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG–1437. May 1996. 

ADAMS Nos. ML040690705 and ML040690738.

[NRC] U.S. Nuclear Regulatory Commission. 1999. Section 6.3–Transportation, Table 9.1, 

Summary of findings on NEPA issues for license renewal of nuclear power plants. In: Generic 

Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC: 

NRC. NUREG–1437, Volume 1, Addendum 1. August 1999. ADAMS No. ML04069720.

[NRC] U.S. Nuclear Regulatory Commission. 2002. Final Generic Environmental Impact 

Statement on Decommissioning of Nuclear Facilities Regarding the Decommissioning of 

Nuclear Power Reactors. Washington, DC: NRC. NUREG–0586, Supplement 1. 

November 2002. ADAMS Nos. ML023470304 and ML023500295.

7-3 

8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES

The National Environmental Policy Act (NEPA) requires that Federal agencies consider a range 

of reasonable alternatives to the proposed action in an environmental impact statement (EIS). 

In this case, the proposed action is whether to issue a renewed license for Callaway Plant, 

Unit 1 (Callaway), which would allow the plant to operate for 20 years beyond its current license 

expiration date. 

An operating license, however, is just one of many conditions that a licensee must meet to 

operate its nuclear plant. State regulatory agencies and the owners of the nuclear power plant 

ultimately decide whether the plant will operate, and economic and environmental 

considerations play a primary role in this decision. The U.S. Nuclear Regulatory Commission’s 

(NRC’s) responsibility is to ensure the safe operation of nuclear power facilities, not to formulate 

energy policy or encourage or discourage the development of alternative power generation (or 

replacement power alternatives). 

The license renewal process is designed to ensure safe operation of the nuclear power plant 

and protection of the environment during the license renewal term. Under the NRC’s 

environmental protection regulations in Title 10 of the Code of Federal Regulations

(10 CFR) Part 51, “Environmental protection regulations for domestic licensing and related 

regulatory functions,” which implement Section 102(2) of NEPA, renewal of a nuclear power 

plant operating license requires the preparation of an EIS.

To support the preparation of these EISs, the NRC prepared the Generic Environmental Impact 

Statement for License Renewal of Nuclear Plants (GEIS), NUREG–1437, in 1996 

(NRC 1996, 1999). The NRC prepared the license renewal GEIS to assess the environmental 

impacts of continued nuclear power plant operations during the license renewal term. The GEIS 

was intended to determine which environmental impacts would result in essentially the same 

impact at all nuclear power plants and which ones could result in different levels of impacts at 

different plants and would require a plant-specific analysis to determine the impacts. For issues 

that could not be generically addressed, the NRC develops a plant-specific supplemental EIS 

(SEIS).

NRC regulations in 10 CFR 51.71(d) implementing NEPA for license renewal indicates, in part, 

that a draft EIS will include the following: considers and weighs the environmental effects 

(impacts) of the proposed action (license renewal); the environmental impacts of alternatives to 

the proposed action; and alternatives available for reducing or avoiding adverse environmental 

effects. 

While the GEIS reached generic conclusions regarding many environmental issues associated 

with license renewal, it did not determine which alternatives are reasonable or reach 

conclusions about site-specific environmental impact levels. As such, the NRC must evaluate 

environmental impacts of alternatives on a site-specific basis. As stated in Chapter 1 of this 

SEIS, alternatives to renewing Callaway’s operating license must meet the purpose and need 

for the proposed action. They must “provide an option that allows for power generation 

capability beyond the term of a current nuclear power plant operating license to meet future 

system-generating needs, as such needs may be determined by State, utility, and, where 

authorized, Federal (other than NRC) decisionmakers.”

8-1 
Environmental Impacts of Alternatives

The NRC ultimately makes no decision about which alternative (or the proposed action) to carry 

out because that determination falls to the appropriate energy-planning decisionmakers. 

Comparing the environmental effects of these alternatives, however, will help the NRC decide if 

the adverse environmental impacts of license renewal are great enough to deny the option of 

license renewal for energy-planning decisionmakers. If the NRC acts to issue a renewed 

license, then all of the alternatives, including the proposed action, will be available to 

energy-planning decision makers. If the NRC decides 

not to renew the license (or takes no action at all), then 

energy-planning decisionmakers may no longer elect 

to continue operating Callaway and will have to resort 

to another alternative—which may or may not be 

considered in this section—to meet the energy needs 

that Callaway now satisfies.

In evaluating alternatives to license renewal, the NRC 

considered energy technologies or options currently in 

commercial operation, as well as some technologies 

not currently in commercial operation but likely to be 

commercially available by the time the current 

Callaway operating license expires. The current 

Callaway operating license will expire on 

October 18, 2024. Thus, in order to be considered as 

an alternative to license renewal, an alternative must 

be available (constructed, permitted, and connected to 

the grid) by the time the current Callaway license 

expires.

The evaluation of whether a technology can meet 

system energy needs or have costs or benefits that 

justify inclusion includes a broad review of known technology characteristics that allow direct or 

relative comparison. Most technologies have intrinsic characteristics that allow for comparison 

of the associated environmental impacts among the replacement power alternatives, such as 

scale, fuel type, and water requirements. Alternatives that cannot meet future system needs by 

providing amounts of baseload (replacement) power equivalent to Callaway’s current generating 

capacity and, in some cases, those alternatives whose costs or benefits do not justify inclusion 

in the range of reasonable alternatives, were eliminated from detailed study. The remaining 

alternatives were evaluated, and they are discussed in depth in this chapter. Each alternative 

eliminated from detailed study is briefly discussed in Section 8.5, and a basis for its removal is 

provided. In Sections 8.1–8.4, 15 discrete potential alternatives to the proposed action were 

considered and then narrowed to three discrete alternatives and one combination alternative. 

The “no action” alternative is considered in Section 8.6.

The GEIS presents an overview of some energy technologies but does not reach any 

conclusions about which alternatives are most appropriate. Since 1996, many energy 

technologies have evolved significantly in capability and cost, while regulatory structures have 

changed to either promote or impede development of particular alternatives. 

As a result, this analysis includes updated information from sources such as the Energy 

Information Administration (EIA), other organizations within the U.S. Department of Energy

(DOE), the U.S. Environmental Protection Agency (EPA), industry sources and publications, 

and information submitted by Union Electric Company, a subsidiary of Ameren Corporation and 

doing business as Ameren Missouri (Ameren) in its Environmental Report (ER) 

(Ameren 2011b). The evaluation of each alternative considers the environmental impacts 

Alternatives Evaluated in Depth:

• Gas-Fired Generation

• Coal-Fired Generation

• New Nuclear Reactor

• Combination Generation (natural 

gas combined cycle, wind, and 

energy efficiency)

Other Alternatives Considered:

• Oil-Fired Generation

• Wind 

• Solar

• Hydropower

• Small Modular Reactor

• Biomass Energy

• Fuel Cells

• Delayed Retirement

• Demand-Side Management

• Purchased Power

• No Action

8-2 
Environmental Impacts of Alternatives

across several impact categories: air quality, surface water resources, groundwater resources, 

aquatic ecology, terrestrial ecology, human health, land use, socioeconomics, transportation, 

aesthetics, historic and archaeological resources, environmental justice, and waste 

management. A three-level standard of significance—SMALL, MODERATE, or LARGE—is 

used to show the intensity of environmental effects for each alternative that is evaluated in 

depth. The order of presentation is not meant to imply increasing or decreasing level of impact, 

nor does it imply that an energy-planning decision maker would be more likely to select any 

given alternative.

Sections 8.1–8.4 describe the environmental impacts of alternatives to license renewal that are 

evaluated in depth. Table 8–1 summarizes key design characteristics of the alternative 

technologies evaluated in depth. The characteristics summarized in the table assume 

compliance with the most current Federal and State environmental regulations. These 

alternatives include fossil-fueled power generation (natural gas and coal), nuclear reactor power 

generation, and combination power generation. In Section 8.5, alternatives considered but 

eliminated from detailed study are briefly discussed. In Section 8.6, environmental effects that 

may occur if the NRC takes no action and does not issue a renewed license for Callaway are 

described. Section 8.7 summarizes the impacts of each of the alternatives considered in detail.

8-3 
Environmental Impacts of Alternatives

Table 8–1. Characteristics of Electrical Generating Technologies

Alternative

Heat Rate 

(BTU/

kWh)(a)

Fuel Type/ 

Energy 

Source

Typical Land 

Requirement 

(ac/MW)(a, b)

Typical 

Water 

Requirement 

(gpm/MW)(a,b)

Peak 

Construction 

Work Force

(workers/

1,000 MW)(a)

Peak 

Operations 

Work Force 

(workers/

1,000 MW)(a)

NGCC (c) 7,639 Natural Gas 0.18 4 1,200 50–75

SCPC 8,740 Subbituminous 

Coal 0.52 10 1,200–2,500 150–200

New Nuclear 

Power Plant 10,452 Uranium 0.49 16 2,000–5,500 225–300

Combination 

NGCC 7,639 Natural Gas <0.18 4 <1,200 <50–75 

Wind N/A Wind 1.73 0 70–100 (per 

100 MW)

6–8 (per 100 

MW)

Energy 

Efficiency N/A N/A N/A N/A N/A N/A

(a) All values reflect resource requirements per unit of electrical generating capacity in MW, except for heat rate, 

which represents the amount of heat produced per unit of electric power produced (kWh).

(b) To convert acres (ac) to hectares (ha), multiply by 0.4047. To convert gallons per minute (U.S. gpm) to cubic 

meters per minute, multiply by 0.003785.

(c) Average of recently permitted projects reflecting long-term CO2 emission rates.

Key:

ac = acre(s); BTU = British thermal units; CO2 = carbon dioxide; gpm = gallons per minute; kWh = kilowatt hour; 

MW = megawatt(s); N/A = not applicable; NGCC = natural-gas-fired combined-cycle; 

SCPC = supercritical pulverized coal-fired

Sources: EIA 2011a; INL 2010; NETL 2007; NRC 1996, 2011; NREL 2009

8.1 Gas-Fired Generation

This section evaluates the environmental impacts of a natural-gas-fired combined-cycle (NGCC) 

electrical power plant at Callaway.

Natural gas fueled 24 percent of electricity generation in the United States in 2010, accounting 

for the second largest share of electrical power generation in the country, exceeded only by coal 

(EIA 2010a). In 2010, natural gas represented 5 percent of the power generation capacity in 

Missouri (EIA 2010b). Ameren, in its ER, indicates that two 593-MW NGCC units could replace 

the 1,186-MW power that Callaway generates. The NRC staff finds this to be reasonable and 

considers an NGCC power plant a feasible, commercially available alternative for providing 

electrical generating capacity beyond Callaway’s current license expiration. 

Combined-cycle power plants derive the majority of their electrical output from a gas-turbine 

cycle and then generate additional power—without burning any additional fuel—from a 

8-4 
Environmental Impacts of Alternatives

steam-turbine cycle. The first gas-turbine stage (similar to a large jet engine) burns natural gas, 

which turns a driveshaft that powers an electric generator. The exhaust gas from the gas 

turbine is still hot enough to boil water to steam. Ducts carry the hot exhaust to a heat-recovery 

steam generator, which produces steam to drive a steam turbine and produce additional electric 

power. The combined-cycle approach is significantly more efficient than any one cycle on its 

own. Because the natural gas-fired alternative derives much of its power from a gas-turbine 

cycle, and because less heat is lost than for the existing Callaway facility, the natural-gas 

alternative requires significantly less cooling water and smaller or fewer cooling towers 

compared to coal-fired or nuclear power plants.

Ameren indicates that the new NGCC power plant would be located at the Callaway site, which 

offers potential advantages of existing infrastructure, including cooling water system, 

transmission, roads, and technical and administrative support facilities. However, new cooling 

towers would be constructed to support the new, reduced cooling needs of the NGCC plant. 

Thus, new onsite structures would include the gas turbine buildings, heat-recovery steam 

generators, cooling towers, and two exhaust stacks. In the ER, Ameren estimates that 199 ac 

(81 ha) of land would be required for the NGCC alternative at the Callaway site, including 

109 ac (44 ha) for the plant, 90 ac (36 ha) for the onsite portion of a pipeline, and 99 ac (40 ha) 

for the offsite portion of a 12-mi (19.3-km) long pipeline to connect to an existing natural gas 

pipeline. The NRC estimates that a 1,186-MW alternative could require approximately 213 ac 

(86 ha), without the additional acreage for the pipeline system. The 1,186-MW NGCC plant 

would consume an estimated 66 billion cubic feet (ft3

) (1,872 million cubic meters (m3)) of 

natural gas annually, assuming an average heat content of 1,021 British thermal units per cubic 

foot (EIA 2012a). Natural gas would be extracted from the ground through wells, then treated to 

remove impurities (such as hydrogen sulfide) and blended to meet pipeline gas standards, 

before being piped through an interstate pipeline system to the power plant site. The NRC 

estimates the NGCC alternative would withdraw water for cooling at a rate of approximately 

6.8 million gallons per day (mgd) (25,700 cubic meters per day (m3

/day)). NGCC plants do not 

generate a solid waste from the use of natural gas fuel, and most facilities are conditionally 

exempt small quantity generators for hazardous waste generated from equipment maintenance. 

A portion of the catalyst used to control nitrogen oxide emissions is removed during 

maintenance and may be regenerated, sold, or disposed of as a waste (Tate 2008), whereas 

the carbon monoxide catalyst is generally disposed of as a waste. 

Table 8–2 summarizes the key operating parameters for the 1,186-MW NGCC alternative as 

estimated by NRC staff. These values are scaled from the data presented in Table 8–1.

Table 8–2. Characteristics of 1,186-MW NGCC

Heat Rate 

(BTU/kWh)

Land 

Requirement 

(ac) (a, b)

Water 

Requirement 

(mgd) (a, b)

Peak 

Construction 

Work Force

Operations 

Work Force

7,639 213 6.8 1,423 59–89

(a) Values scaled from Table 8–1 

(b) To convert acres (ac) to hectares (ha), multiply by 0.4047. To convert million gallons per day (mgd) to cubic 

meters (m3

) per day, multiply by 3,785.

Key:

ac = acres; BTU = British thermal units; kWh = kilowatt hours; mgd = million gallons per day.

8-5 
Environmental Impacts of Alternatives

8.1.1 Air Quality

The Callaway site is located in Callaway County, which is part of the Northern Missouri 

Intrastate Air Quality Control Region (AQCR) (40 CFR 81.116). Callaway County (and the rest 

of the Northern Missouri Intrastate AQCR) is designated as unclassified or in attainment for all 

National Ambient Air Quality Standards (NAAQS) criteria pollutants (40 CFR 81.326). A 

1,186-MW NGCC alternative developed at the Callaway site would qualify as a new major 

source of criteria pollutants and require a New Source Review (NSR) and Prevention of 

Significant Deterioration of air quality (PSD) review. The NGCC alternative would need to 

comply with the standards of performance for stationary gas turbines set forth in 

40 CFR Part 60, “Standards of performance for new stationary sources (NSPS),” 

Subpart KKKK, “Standards of performance for stationary combustion turbines,” and 

incorporated by reference in Missouri Department of Natural Resources (MDNR) air regulations 

(Title 10 of the Missouri Code of State Regulations (10 CSR) 10-6.070). The standards 

establish limits for sulfur dioxide (40 CFR 60.4330) and nitrogen dioxide (40 CFR 60.4320).

Section 169A of the Clean Air Act (CAA) (42 U.S.C. 7401) establishes a national goal of 

preventing future, and remedying existing, impairment of visibility in mandatory Class I Federal 

areas when impairment results from man-made air pollution. The Regional Haze Rule, issued

by EPA in 1999 and last amended in October 2006 (71 FR 60631), requires states to 

demonstrate reasonable progress towards the national visibility goal established in 1977 to 

prevent future impairment of visibility caused by manmade pollution in Class I areas. The 

visibility protection regulatory requirements are contained in 40 CFR Part 51, “Requirements for 

preparation, adoption, and submittal of implementation plans, Subpart P, “Protection of 

visibility,” including the review of new sources that would be constructed in attainment or 

unclassified areas and may affect visibility in any Federal Class I area. If a gas-fired alternative 

were located close to a mandatory Class I area, additional air pollution control requirements 

would potentially apply. However, there are no mandatory Class I Federal areas within 50 mi 

(80 km) of the Callaway site. The closest mandatory Class I Federal area is the Mingo National 

Wildlife Refuge, which is approximately 150 mi (241 km) southeast of the Callaway site 

(40 CFR 81.434).

The State of Missouri, at the time of the initial regional haze rule was among nine states 

(Nebraska, Kansas, Oklahoma, Texas, Minnesota, Iowa, Missouri, Arkansas, and Louisiana) 

that were members of the Central Regional Air Planning Association (CENRAP). CENRAP, 

along with tribes, Federal agencies, and other interested parties worked together to identify 

regional haze and visibility issues and develop strategies to address them. As the funding for 

this group no longer exists, the individual states work with each other and the Federal land

managers as necessary on continuing issues and updates to regional haze requirements

(MDNR 2014). 

In response to the Consolidated Appropriations Act of 2008 (Public Law (PL) 110-161), EPA

issued final mandatory greenhouse gas (GHG) reporting regulations for major sources (emitting 

more than 25,000 tons per year of all GHGs), effective December 2009 (EPA 2010). The 

NGCC alternative would be subject to these reporting regulations. The NRC staff notes that 

development of new natural gas-fired plants would need to comply with GHG permitting rules 

under the NSR PSD Program with the proposed New Source Performance Standard (NSPS) of 

1,000 lb of carbon dioxide per megawatt-hour on a rolling 12-month average. 

Under the Federal Acid Rain Program, a new natural gas-fired plant would have to comply with 

Title IV of the CAA reduction requirements for sulfur dioxide and nitrogen oxides, which are the 

main precursors of acid rain and the major cause of reduced visibility. Title IV establishes 

maximum sulfur dioxide and nitrogen oxide emission rates from the existing plants and a system 

8-6 
Environmental Impacts of Alternatives

of sulfur dioxide emission allowances that can be used, sold, or saved for future use by new 

plants.

The Clean Air Interstate Rule (CAIR) was first issued by EPA in 2005, permanently capping 

sulfur dioxide and nitrogen oxide emissions from stationary sources located in 27 states 

(including Missouri) and the District of Columbia. A new fossil fuel–fired source constructed in 

Missouri would be subject to revised emission limits for sulfur dioxide and nitrogen oxides, 

issued under CAIR. However, the Federal rule was vacated by the D.C. Circuit Court on 

February 8, 2008. In December 2008, the U.S. Court of Appeals for the D.C. Circuit reinstated 

the rule, allowing it to remain in effect but also requiring EPA to revise the rule and its 

implementation plan. On July 6, 2010, EPA proposed replacing CAIR with the Cross-State Air 

Pollution Rule (CSAPR) for control of sulfur dioxide and nitrogen oxideemissions that cross 

state lines, the regulations of which would be implemented in 2011 and finalized in 2012. 

However, CSAPR was vacated by the D.C. Circuit Court on August 21, 2012. On April 29, 

2014, the U.S. Supreme Court reversed the D.C. Circuit opinion vacating CSAPR. EPA is 

reviewing the opinion and CAIR remains in effect (EPA 2014).

Using data and algorithms published by EPA and the EIA, recent air permit determinations for 

NGCC plants, and performance guarantees provided by pollution control equipment vendors, 

the NRC staff projects the following emissions for an NGCC alternative at the Callaway site:

 sulfur oxides: 115 tons (104 metric tons (MT)) per year,

 nitrogen oxides: 334 tons (303 MT) per year,

 carbon monoxide: 506 tons (459 MT) per year,

 particulate matter less than or equal to 10 μm (PM10): 223 tons (202 MT) per 

year,

 particulate matter less than or equal to 2.5 μm (PM2.5): 223 tons (202 MT) 

per year, and

 carbon dioxide: 3.71 million tons (3.37 million metric tons (MMT)) per year.

8.1.1.1 Sulfur and Nitrogen Oxides and Carbon Dioxide

The NGCC alternative would produce 115 tons (104 MT) of sulfur oxides per year and 334 tons 

(303 MT) of nitrogen oxides per year, based on the use of dry, low nitrogen oxide combustion 

technology and selective catalytic reduction (SCR) to significantly reduce nitrogen oxide 

emissions. The NGCC alternative would emit approximately 3.71 million tons (3.37 MMT) of 

carbon dioxide per year. The new plant would be subject to the continuous monitoring 

requirements for sulfur dioxide, nitrogen oxides, and carbon dioxide specified in 

40 CFR Part 75, “Continuous Emission Monitoring.”

8.1.1.2 Particulates

The NGCC alternative would produce 223 tons (202 MT) of particulates per year, all of which 

would be emitted as PM10 and PM2.5. Small amounts of particulate would be released as drift 

from the cooling tower (regardless of whether it involves a natural-draft or mechanical-draft 

tower). Particulate control would likely not be required, and this drift would not present a new 

impact on existing vegetation, which already experiences drift from the existing Callaway 

cooling tower.

8.1.1.3 Carbon Monoxide

Based on EPA emission factors (EPA 2010), the NRC staff estimates that the total carbon 

monoxide emissions would be approximately 506 tons (459 MT) per year. This emission rate 

8-7 
Environmental Impacts of Alternatives

assumes no control requirements (such as using an oxidation catalyst to reduce carbon 

monoxide emissions) would be imposed. If an oxidation catalyst were used, carbon monoxide 

emissions would be reduced by 90 percent or more.

8.1.1.4 Hazardous Air Pollutants

In December 2000, EPA issued regulatory findings on emissions of hazardous air pollutants 

(HAPs) from electric utility steam-generating units (65 FR 79825). These findings indicated that 

natural gas-fired plants emit HAPs such as arsenic, formaldehyde, and nickel and stated that 

“[t]he impacts due to hazardous air pollutants (HAP) emissions from natural gas-fired electric 

utility steam generating units were negligible based on the results of the study. The 

Administrator finds that regulation of HAP emissions from natural gas-fired electric utility steam 

generating units is not appropriate or necessary.”

8.1.1.5 Construction Impacts

Activities associated with construction of the NGCC alternative at the Callaway site would cause 

some additional air impacts as a result of emissions from construction equipment and fugitive 

dust from operation of the earth-moving and material-handling equipment. Gas fired power 

plants are constructed relatively quickly; construction lead times for NGCC plants are around 2 

to 3 years (EIA 2011b; OECD/IEA 2005). Emissions of carbon dioxide would result primarily 

from the consumption of fossil fuels by construction vehicles and equipment, workforce vehicles 

used in commuting to and from the work site, and delivery vehicles. Analogous impacts would 

occur in association with offsite pipeline construction. All such impacts would be temporary. 

Workers’ vehicles and motorized construction equipment would generate temporary criteria 

pollutant emissions. Dust control practices would reduce fugitive dust, which would be 

temporary in nature. The GHG emissions during construction would result primarily from the 

consumption of fossil fuels in the operation of construction vehicles and equipment and from the 

operation of delivery vehicles and vehicles used by the commuting workforce. Given the 

expected workforce and a relatively short construction period for both the NGCC plant and the 

pipeline, the NRC staff concludes that the impact of vehicle exhaust emissions and fugitive dust 

from operation of earth-moving and material-handling equipment would be SMALL.

8.1.1.6 Additional Operating Impacts

In addition to the air quality impacts associated with operation of the NGCC plant, air quality 

impacts would result from the use of vehicles by the commuting operating workforce. The 

NGCC workforce would be substantially smaller than the current operating workforce for 

Callaway, so commuter-related air emissions would be reduced. The impacts on air quality 

from ancillary activities during operation of an NGCC plant would be SMALL.

EPA reported that, in 2010, the total amount of carbon dioxide equivalent (CO2e) emissions 

related to electricity generation was 2,277.3 teragrams (2,277.3 MMT) (EPA 2012b). The EIA 

reports that, in 2010, electricity production in Missouri was responsible for 78,815 thousand MT 

(78.8 MMT), or 3.46 percent of the national total (EIA 2012b). The NRC staff estimates that 

uncontrolled CO2e emissions from operation of the NGCC alternative would be 3.71 million tons 

(3.37 MMT) per year. This amount represents 0.15 percent and 4.3 percent, respectively, of 

2010 U.S. and Missouri CO2e emissions. Although natural gas combustion in the combustion 

turbines would be the primary source, other miscellaneous ancillary sources (e.g., truck and rail 

deliveries of materials to the site and commuting of the workforce) would make minor 

contributions.

The National Energy Technology Laboratory (NETL) estimates that carbon capture and storage 

(CCS) technologies would capture and remove as much as 90 percent of the carbon dioxide

from the exhausts of combustion turbines. However, NETL estimates that such equipment 

8-8 
Environmental Impacts of Alternatives

imposes a significant parasitic load that would result in a decrease in power production capacity 

of approximately 14 percent, a reduction in net overall thermal efficiency of the combustion 

turbines studied from 50.8 percent to 43.7 percent, and a potential increase in the levelized cost 

of electricity produced in NGCC units so equipped by as much as 30 percent (NETL 2007).

Further, permanent sequestering of the carbon dioxide would involve removing impurities 

(including water), pressurizing it to meet pipeline specifications, and transferring it by pipeline to 

acceptable geologic formations. Even when opportunities exist to use the carbon dioxide for 

enhanced oil recovery (rather than simply disposal of the carbon dioxide in geologic formations), 

permanent disposal costs could be substantial, especially if the gas-fired units are far removed 

from acceptable geologic formations. With CCS in place, the NGCC plant would release 

0.33 MMT of carbon dioxide per year. If future regulations require the capture and 

sequestration of carbon dioxide from gas-fired facilities, the impact on climate change from this 

alternative would be further reduced.

Climate-related changes for the Midwest region that could affect an NGCC plant (primarily 

related to cooling requirements) at the Callaway site include alternating periods of drought and 

flooding, an increase in the frequency and severity of heat waves, and an increase in 

temperature of surface water bodies (rivers and lakes) (Karl et al. 2009).

Based on this information, the overall air quality impacts of the NGCC alternative at the 

Callaway site would be SMALL to MODERATE.

8.1.2 Surface Water Resources

Runoff from construction areas and water discharged from dewatering of excavations, if 

needed, would be controlled under a State-issued National Pollutant Discharge Elimination 

System (NPDES) stormwater general permit for land disturbance (MDNR 2012b). The general 

permit would require implementation of a stormwater pollution prevention plan and associated 

best management practices (BMPs) to prevent or significantly mitigate soil erosion and the 

contamination of soil, stormwater runoff, and groundwater by construction activities.

During operations, the NGCC alternative would require less cooling water than Callaway 

because it operates at a higher thermal efficiency and because it requires much less water for 

steam-cycle condenser cooling. The NRC staff estimates the NGCC alternative would withdraw 

approximately 6.8 mgd (25,700 m3

/day) of water for cooling (NETL 2007), versus 25 mgd 

(94,600 m3

/day) required for current Callaway operations. The existing closed-cycle cooling 

system would be able to support a natural gas alternative on the Callaway site without any 

increase in its current capacity.

During operations, cooling tower blowdown discharged to the Missouri River would have 

thermal profiles similar to the discharges now occurring, and chemicals similar to those 

presently used by Callaway would be used to treat the water in the closed-loop system to 

maintain cooling tower performance. Nevertheless, all effluent discharges and stormwater

discharges associated with industrial activity would be subject to a State-issued NPDES permit 

under this alternative. This would require the submission of a revised NPDES permit application 

and the granting of the modified permit by the MDNR. The NRC staff further assumes that the 

NGCC plant would be operated in accordance with appropriate management plans with 

adherence to appropriate BMP and procedures to minimize the release of fuels, chemicals, and 

other materials to soil, surface water, and groundwater. 

The NRC staff concludes that the impact on surface water quality and use from construction and 

operation of the NGCC alternative at the Callaway site would be SMALL.

8-9 
Environmental Impacts of Alternatives

8.1.3 Groundwater Resources

During construction of the NGCC units, existing wells or replacement wells completed in the 

same aquifers as for the existing Callaway power plant would likely be used to supply the 

relatively small amounts of water required for potable and sanitary uses, concrete production, 

dust suppression, and soil compaction. However, the amount of construction water consumed 

should be much less than the amount currently consumed by Callaway operations. Onsite 

water demands to support NGCC plant construction could be further reduced by the use of 

ready-mix concrete and the use of portable sanitary facilities that are serviced off site for 

construction workers. The GEIS (NRC 1996) reported that pumping rates of less than 100 gpm 

(380 litres per minute (L/min))) did not adversely affect groundwater availability.

At Callaway, groundwater currently provides approximately 48,000 gallons per day (gpd) 

(182,000 litres per day (L/day)) of potable water, or about 33 gpm (125 L/min). A well near the 

river also pumps approximately 173,000 gpd (655,000 L/day) to provide lubrication water for 

pumps at the river intake structure. The NGCC units would obtain potable water and water to 

lubricate the surface water pumps at the river intake structure from existing or replacement wells 

completed in the same aquifers as currently used to support Callaway. During operations, the 

rate of groundwater consumption, and the associated aquifer effects, should be less than that 

required for the existing Callaway facility because of the smaller number of auxiliary systems 

requiring groundwater and the much smaller workforce under the NGCC alternative.

Given these assumptions, the NRC staff concludes that the impact of construction and 

operation of a NGCC plant at the Callaway site on groundwater use and quality would be 

SMALL.

8.1.4 Aquatic Ecology

The NGCC alternative would require less cooling water to be withdrawn from the Missouri River 

than is currently withdrawn by Callaway. The volume of cooling tower blowdown would be less, 

and it would have a similar thermal profile. Therefore, the number of fish and other aquatic 

organisms affected by impingement, entrainment, and thermal impacts would be less than 

currently affected by Callaway.

Temporary impacts on surface waters may occur during construction of the NGCC alternative. 

The NRC staff relies on the State to enforce NPDES stormwater general permits to prevent or 

significantly mitigate any impacts, such as sediment loading from runoff, from active 

construction sites.

The NRC staff concludes that the impact on aquatic ecology from construction and operation of 

the NGCC alternative at the Callaway site would be SMALL. 

8.1.5 Terrestrial Ecology

In the ER, Ameren estimates that 199 ac (81 ha) of land would be required for the NGCC 

alternative at the Callaway site, including 109 ac (44 ha) for the plant, 90 ac (36 ha) for the 

onsite portion of a pipeline, and 99 ac (40 ha) for the offsite portion of a 12-mi- (19-km)-long 

pipeline to connect to an existing transmission pipeline. The NRC staff estimates that a 

1,186-MW NGCC facility could require approximately 213 ac (86 ha), without the additional 

acreage for the pipeline. 

In addition to onsite land requirements, land would be required offsite for natural-gas wells and 

collection stations. Scaling from GEIS estimates, approximately 4,270 ac (1,730 ha) would be 

required for wells, collection stations, and pipelines to bring the gas to the plant. Most of this 

8-10
Environmental Impacts of Alternatives

land requirement would occur on land where gas extraction already occurs. In addition, some 

natural gas could come from outside the United States and be delivered as liquefied gas.

The NRC staff assumes that this alternative would use existing onsite structures and previously 

disturbed areas to the extent practicable to minimize new development in undisturbed areas. 

However, it is expected that some undisturbed areas would be affected, which would directly 

impact terrestrial resources. Onsite impacts may include terrestrial habitat loss and habitat 

fragmentation. Construction noise could modify wildlife behavior; however, these effects would 

be temporary. Road improvements or construction of additional service roads to facilitate 

construction could result in the temporary or permanent loss of terrestrial habitat. Cooling tower 

operation would produce drift that could result in some deposition of dissolved solids on 

surrounding vegetation and soil from cooling-tower drift. Maintenance of the transmission lines

also would result in emissions from equipment operations, which could result in deposition on 

surrounding vegetation. Operational impacts, such as deposition of dissolved solids on 

surrounding vegetation from cooling tower drift, would be less than those experienced from 

continued operations of Callaway because of the greater thermal efficiency of the NGCC 

alternative. Operational impacts from transmission line maintenance would be similar in 

magnitude and intensity to those resulting from continued operation of the nuclear reactor. 

Depending on the location of new infrastructure in undisturbed areas, threatened and 

endangered species also may be affected. Based on the potential occurrence of threatened 

and endangered species at the Callaway site discussed in Section 2.2.8, species that could 

potentially be affected, include the gray bat (Myotis grisescens), Indiana bat (M. sodalis), 

running buffalo clover (Trifolium stoloniferum), bald eagle (Haliaeetus leucocephalus), eastern 

hellbender (Cryptobranchus alleganiensis), and northern harrier (Circus cyaneus). Consultation 

with the U.S. Fish and Wildlife Service (FWS) under the Endangered Species Act (ESA) would 

ensure that construction and operation of the NGCC alternative would not adversely affect any 

Federally listed species or adversely modify or destroy designated critical habitat. The staff 

relies on Ameren’s coordination with State natural resource agencies to further ensure that 

Ameren would take appropriate steps to avoid or mitigate impacts on State-listed species, 

habitats of conservation concern, and other protected species and habitats.

Construction of the 12-mi- (19-km)-long gas pipeline also would directly impact terrestrial 

resources. Although the pipeline would be routed along existing disturbed right-of-ways 

(ROWs) to the extent practicable, it is likely that native vegetation would be disturbed. This may 

include clearing of forest cover either adjacent to or along a new transmission corridor, resulting 

in habitat fragmentation or loss of food sources and cover for native species. 

Development outside the existing plant footprint for any new onsite structures or the gas 

pipeline would impact the Reform Conservation Area. Since the existing lease agreement 

between Ameren and the MDC restricts development within the Reform Conservation Area, any 

such development would require a revision to the existing lease agreement. If permitted under 

a revised lease agreement, impacts would include a loss of natural habitats to an extent 

commensurate with the reduction in size of the overall natural resources management area.

Based on this information, impacts on terrestrial resources would range from SMALL to 

MODERATE. 

8.1.6 Human Health

Human health issues related to construction of the NGCC alternative would be equivalent to 

those associated with the construction of any major complex industrial facility and would be 

controlled to acceptable levels through the application of BMP and Ameren’s compliance with 

applicable Federal and State worker protection regulations. 

8-11
Environmental Impacts of Alternatives

As discussed in Section 8.1.1, the overall air quality impacts associated with construction of the 

NGCC alternative at the Callaway site would be small. 

The human health effects of operation of the NGCC alternative are generally low, although in 

Table 8–2 of the GEIS (NRC 1996), the NRC identified cancer and emphysema as potential 

health risks from natural gas-fired plants. Nitrogen oxide emissions contribute to ozone 

formation, which, in turn, contributes to human health risks. Emission controls on a modern 

NGCC plant would maintain nitrogen oxide emissions well below air quality standards 

established for the purposes of protecting human health, and emissions trading or offset 

requirements mean that overall nitrogen oxide levels in the region would not increase. Health 

risks to workers also may result from handling spent catalysts that may contain heavy metals. 

However, any such risks can be managed via adherence to appropriate industrial hygiene and 

waste management practices.

Overall, human health impacts on workers and members of the public from the NGCC 

alternative at the Callaway site would be SMALL.

8.1.7 Land Use

The GEIS generically evaluates the impacts of constructing and operating various replacement 

power plant alternatives on land use, both on and off each power plant site. The analysis of 

land use impacts focuses on the amount of land area that would be affected by the construction 

and operation of a NGCC power plant at the Callaway site. Locating the new NGCC power 

plant at the Callaway site would maximize the availability of support infrastructure and reduce 

the need for additional land.

The NRC estimates that the NGCC power plant would require approximately 213 onsite ac 

(86 ha). The 213 ac (86 ha) would support the power plant and associated infrastructure, 

including the cooling water system, transmission lines, roads, and administrative support 

facilities. Additional acreage would be required for a 12-mi- (19-km)-long offsite pipeline that 

would connect to an existing transmission pipeline. Depending on the location and availability 

of existing natural gas pipelines, a 100-ft-wide ROW would be needed for the new pipeline. 

Based on this information, land use impacts from NGCC power plant and pipeline construction 

could range from SMALL to MODERATE.

In addition to onsite land requirements, land would be required off site for natural gas wells and 

collection stations. Scaling from GEIS estimates, approximately 4,270 ac (1,730 ha), would be 

required for wells, collection stations, and pipelines to bring the gas to the plant. Most of this 

land requirement would occur on land where gas extraction already occurs. In addition, some 

natural gas could come from outside the United States and be delivered as liquefied gas.

The elimination of uranium fuel for the Callaway site could partially offset some, but not all, of 

the land requirements for the NGCC. Scaling from this GEIS estimate, approximately 26 ac 

(11 ha) per year would no longer be needed for the mining and processing of uranium during 

the 20-year operating life of the plant. Operational land use impacts from a NGCC power plant 

would be SMALL.

8.1.8 Socioeconomics

Socioeconomic impacts are defined in terms of changes to the demographic and economic 

characteristics and social conditions of a region. For example, the number of jobs created by 

the construction and operation of the NGCC alternative could affect regional employment, 

income, and expenditures. Two types of jobs would be created by this alternative: 

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

8-12
Environmental Impacts of Alternatives

socioeconomic impact, and (2) power plant operations jobs, which have the greater potential for 

permanent, long-term socioeconomic impacts. Workforce requirements for the construction and 

operation of the NGCC alternative were evaluated to measure their possible effects on current 

socioeconomic conditions.

The GEIS estimates that 1,200 workers would be required to construct a 1,000-MW NGCC 

plant; therefore, the construction workforce would peak at 1,423 workers. Ameren estimates 

that a peak construction workforce of 2,038 would be required (Ameren 2011b). Assuming that 

additional workers could be needed for the construction of the pipeline, Ameren’s estimate of 

2,038 construction employees appears to be reasonable.

The relative economic impact of this many workers on the local economy and tax base would 

vary, with the greatest impacts occurring in the communities where the majority of construction 

workers would reside and spend their income. As a result, local communities could experience 

a short-term economic “boom” from increased tax revenue and income generated by 

construction expenditures and the increased demand for temporary (rental) housing and 

business services. Some construction workers could relocate to be closer to the construction 

work site. However, given the proximity of Callaway to the Columbia, Jefferson City, and 

St. Louis metropolitan areas, workers could commute to the construction site, thereby reducing 

the need for rental housing. After completing the installation of the NGCC plant, local 

communities could experience a return to pre-construction economic conditions. Based on this 

information and given the number of construction workers, socioeconomic impacts during 

construction in local communities could range from SMALL to MODERATE.

Scaling from GEIS estimates of 50 to 75 workers per 1,000 MW, the power plant operations 

workforce would be 59 to 89 workers. Ameren’s estimated operations workforce of 

approximately 100 workers appears to be reasonable. The reduction in employment at 

Callaway could affect property tax revenue and income in local communities and businesses. In 

addition, the permanent housing market also could experience increased vacancies and 

decreased prices if operations workers and their families move out of the region. However, the 

overall amount of property taxes paid to local jurisdictions under the NGCC alternative may 

increase if additional land is required offsite to support this alternative. Based on the above 

discussion, socioeconomic impacts during operations could range from SMALL to MODERATE.

8.1.9 Transportation

Commuting workers and truck deliveries of materials and equipment to the Callaway site would 

cause transportation impacts during the construction and operation of the NGCC power plant. 

During periods of peak construction activity, up to 2,038 workers could be commuting daily to 

the construction site. The increase in the volume of vehicular traffic on local roads would peak 

during shift changes, resulting in temporary level-of-service impacts and potential delays at 

intersections. Pipeline construction and modification to existing natural gas pipeline systems 

also could have short-term transportation impacts. Based on this information, traffic-related 

transportation impacts during construction could range from SMALL to MODERATE. 

Traffic-related transportation impacts would be greatly reduced after completing the installation 

of the new NGCC units. Transportation impacts would result from daily commuting by the 

operating workforce, equipment and materials deliveries, and the removal by truck of 

commercial waste material to offsite disposal or recycling facilities. As noted in Section 8.1.8, 

approximately 59 to 89 workers would be needed to operate the NGCC power plant. Since fuel 

is transported by pipeline, the transportation infrastructure would experience little to no 

increased traffic from plant operations. Overall, transportation impacts would be SMALL during 

NGCC power plant operations.

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Environmental Impacts of Alternatives

8.1.10 Aesthetics and Noise

The analysis of aesthetic impacts focuses on the degree of contrast between the NGCC 

alternative and the surrounding landscape and the visibility of the new NGCC plant at an 

existing power plant site. During construction, all of the clearing and excavation would occur on 

the existing power plant site. These activities could be visible from offsite roads. Since the 

existing power plant site already appears industrial, construction of the NGCC power plant 

would appear similar to other ongoing onsite activities. The power block of the NGCC 

alternative would look similar to the existing power plant. During construction, both continuous 

and impulse noise would be heard at offsite locations.

New onsite structures would include the gas turbine buildings, heat-recovery steam generators, 

cooling towers, and two exhaust stacks. The facility would be visible off site during daylight 

hours, and some structures may require aircraft warning lights. The new cooling towers would 

generate vapor plumes under certain meteorological conditions, as well as operational noise. 

Noise during power plant operations would be limited to industrial processes and 

communications. Pipelines delivering natural gas fuel could be audible off site near 

compressors. In general, given the industrial appearance of the existing power plant site, the 

new NGCC power plant would blend in with the surroundings. Aesthetic changes, therefore, 

would be limited to the immediate vicinity of the existing power plant site, and any impacts 

would be SMALL.

8.1.11 Historic and Archeological Resources

The potential for impacts on historic and archaeological resources from the NGCC alternative 

would vary greatly, depending on the location of the proposed construction at the Callaway site, 

because of the high potential for discovery of additional historic and archaeological resources. 

Any construction would need to avoid the previously identified 25 eligible or potentially eligible 

historic properties located at Callaway. Alternate plant locations and associated corridors of 

new construction on the Callaway site would need to be surveyed and inventoried for potential 

resources. Resources found in these surveys would need to be evaluated for eligibility on the 

National Register of Historic Places (NRHP), and mitigation of adverse effects would need to be 

addressed if eligible resources were encountered. The level of impact at these locations would 

vary, depending on the specific resources found to be present in the area of potential effect

(APE). However, given that the preference is to use previously surveyed or disturbed areas, 

and portions of the site have been previously identified as not containing significant historic or 

archaeological resources, avoiding historic and archaeological resources should be possible 

and effectively managed under current laws and regulations. Therefore, the impacts on 

historical and archaeological resources from the NGCC alternative would be SMALL.

8.1.12 Environmental Justice 

The environmental justice impact analysis evaluates the potential for disproportionately high and 

adverse human health, environmental, and socioeconomic effects on minority and low-income 

populations that could result from the construction and operation of a new power plant. 

Adverse health effects are measured in terms of the risk and rate of fatal or nonfatal adverse 

impacts on human health. Disproportionately high and adverse human health effects occur 

when the risk or rate of exposure to an environmental hazard for a minority or low-income 

population is significant and exceeds the risk or exposure rate for the general population or for 

another appropriate comparison group. Disproportionately high environmental effects refer to 

impacts or risk of impact on the natural or physical environment in a minority or low-income 

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Environmental Impacts of Alternatives

community that are significant and appreciably exceed the environmental impact on the larger 

community. Such effects may include biological, cultural, economic, or social impacts. For

example, increased demand for rental housing during replacement power plant construction 

could disproportionately affect low-income populations that rely on the previously inexpensive 

rental housing market.

Potential impacts to minority and low-income populations would mostly consist of environmental 

and socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and 

housing impacts). Noise and dust impacts from construction would be short-term and primarily 

limited to onsite activities. Minority and low-income populations residing along site access 

roads would be directly affected by increased commuter vehicle and truck traffic. However,

because of the temporary nature of construction, these effects are not likely to be high and 

adverse and would be contained to a limited time period during certain hours of the day. 

Increased demand for rental housing during construction could cause rental costs to rise, 

disproportionately affecting low-income populations living near the site who rely on inexpensive 

housing. However, given the proximity of the site to the Columbia, Jefferson City, and St. Louis

metropolitan areas, workers could commute to the construction site, thereby reducing the need 

for rental housing. The staff expects permitted air emissions to remain within regulatory 

standards.

Based on this information and the analysis of human health and environmental impacts 

presented in Section 8.1 of this SEIS, construction and operation of the NGCC power plant 

would not have disproportionately high and adverse human health and environmental effects on 

minority and low-income populations residing in the vicinity of the Callaway site.

8.1.13 Waste Management

During the construction phase of this alternative, land clearing and other construction activities 

would generate waste that could be recycled, disposed of on site, or shipped to an offsite waste 

disposal facility. Construction-related wastes would be solid, liquid, or gaseous, and some 

would require management, treatment, and disposal as hazardous wastes. Various permits 

issued by State or local authorities would control the disposition of all construction-related 

wastes. Because the alternative would be constructed on the previously disturbed Callaway site, 

the amounts of wastes produced during land clearing would be minimal.

During the operational stage, spent catalysts used to control nitrogen oxides and carbon 

monoxide emissions would make up a majority of the industrial waste generated by this 

alternative. Because the specific emission control equipment cannot be specified at this time, 

the amount of spent catalysts that would be regenerated, sold, or disposed of during each year 

of operation of the NGCC plant also cannot be calculated with precision. The NRC staff has not 

estimated the amount of spent catalysts that would be produced, but it presumes that the entire 

amount would have no recycling opportunities and would require disposal. However, 

deactivated catalyst is disposed of as a solid waste, and the amount each year would be 

modest. 

According to the GEIS, a NGCC plant would generate minimal waste; therefore, waste impacts 

would be SMALL for the NGCC alternative at the Callaway site.

8.2 Coal-Fired Generation

This section evaluates the environmental impacts of a supercritical pulverized coal-fired (SCPC) 

electrical power plant at the Callaway site.

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Environmental Impacts of Alternatives

Coal-fired generation accounts for 45 percent of the current generation of power in the United 

States, the largest share of electrical power in the country (EIA 2010a). In 2010, coal-fired 

generation represented 81 percent of the generation capacity in Missouri (EIA 2009a). 

Estimates of future increases in coal-fired generating capacity have been significantly reduced 

because of the need to meet carbon dioxide emission controls (EIA 2010a; EPRI 2011). Under 

the CAA, new major sources of carbon dioxide emissions must consider the best available 

control technology and the proposed NSPS of 1,000 lb of carbon dioxide per megawatt-hour on 

a rolling 12-month average. New coal-fired generation would need to comply with these 

mandates, which would require the use of carbon dioxide capture and sequestration. 

Ameren, in its ER, indicates that two 593-MW ultra-SCPC units could replace the 1,186 MW of 

power that Callaway generates. The NRC staff considers a coal-fired alternative to be a 

feasible, commercially available option for providing electrical generating capacity beyond 

Callaway’s current license expiration.

An SCPC power plant is similar to most existing coal-fired technologies, but it operates at higher 

pressures and temperatures (beyond the “critical point” of water). The net thermal efficiency 

would be approximately 40 percent (NETL 2007). An ultra-SCPC plant is a type of SCPC plant 

that operates at higher temperatures and pressures than most SCPC plants. 

The staff’s discussion of SCPC that follows is relevant to all SCPC plants, including the 

ultra-SCPC plants—those referred to by Ameren in its ER. For purposes of simplicity, the staff 

simply refers to these plants as SCPC plants. 

The staff notes that integrated gasification combined cycle (IGCC) technology also may be 

feasible and commercially available on a sufficient scale to replace Callaway by the time its 

current license expires. The IGCC plants use coal (or other solid or liquid feedstocks) to 

produce syngas, which burns in a combined-cycle plant similar to that used to burn natural gas. 

The IGCC plants have particular advantages that may become important if carbon dioxide 

capture and storage are technologically more feasible. However, because SCPC is a 

more-demonstrated and commercially available technology, staff considered it to be the most 

reasonable coal-fired generation alternative.

In evaluating the SCPC alternative, the NRC staff assumed that the SCPC plant would be 

located at the Callaway site, which offers the potential advantages of existing infrastructure 

(e.g., cooling water intake system, transmission, roads, and technical and administrative support 

facilities). New onsite structures would include the boiler and steam turbine building, two

exhaust stacks, and coal storage and conveyance facilities. Ameren assumed the new 

coal-fired generation alternative would use the existing natural-draft cooling towers. The NRC 

finds this acceptable; however, it is possible that if and when EPA reissues the final rule for 

cooling water intake systems at existing facilities, modifications would be necessary for a new 

generating unit.

In the ER, Ameren estimates that 164 ac (66 ha) of land would be required for the power block 

and coal storage at the Callaway site. The NRC staff estimates approximately 617 ac (250 ha) 

of land would be required in total.

SCPC plants generate solid waste from the capture of ash, products of incomplete combustion, 

and the removal of pollutants from the exhaust gas. Therefore, the NRC staff also assumes that 

onsite construction of an engineered solid waste disposal facility (landfill), totaling 200 ac 

(80 ha), would be required for disposal of solid waste for the estimated 20 years of operations.

The 1,186-MW SCPC alternative would consume 4.3 million tons (4.0 MT) of coal annually, 

assuming an average heat content of 8,800 BTU per pound as the average value for coal used 

in Missouri (EIA 2009a). For the purposes of this analysis, the NRC staff assumed that coal and 

8-16
Environmental Impacts of Alternatives

limestone (converted to calcium hydroxide for use in controlling sulfur emissions) would be 

delivered to Callaway via rail or barge. In its ER, Ameren stated that the existing Callaway rail 

spur could be reconstructed to provide the necessary rail capacity (Ameren 2011b). However, 

the former spur routing is part of the Katy Trail State Park (see Section 2.2.1), and no rails 

remain, so the spur could not be reconstructed (Ameren 2014). This would require construction 

of a new spur or short line along an alternative route to the plant site from active railroad lines to 

the north or south of Callaway or via a rail line running from a barge transfer point on the

Missouri River and north to the plant site. 

The NRC staff estimates the SCPC alternative would withdraw water for cooling at a rate of 

approximately 17 mgd (64,300 m3

/day). Assuming the system is designed to capture 

90 percent of carbon dioxide emissions, the NRC staff estimates the water withdrawal would 

increase from 17 mgd to 29 mgd (64,300 to 109,800 m3

/day). With the additional water needs 

for carbon dioxide capture, compression, and sequestration, the SCPC alternative would result 

in more water withdrawal than Callaway, which withdraws approximately 25 mgd 

(94,600 m3

/day).

Table 8–3 summarizes the key operating parameters for the 1,186-MW SCPC alternative as 

estimated by NRC staff. 

Table 8–3. Characteristics of 1,186-MW SCPC

Heat Rate 

(BTU/kWh)

Land 

Requirement 

(ac) (a) (b) 

Water Requirement 

(mgd) (a) (b) 

Peak 

Construction 

Work Force(a)

Operations 

Work Force(a)

Persons Persons 

8,740 617 17-29 1,423–2,965 177–237

(a) Values scaled from Table 8–1 

(b) To convert acres (ac) to hectares (ha), multiply by 0.4047. To convert million gallons per day (mgd) to cubic 

meters (m3

) per day, multiply by 3,785.

Key:

ac = acres; BTU = British thermal units; kWh = kilowatt hours; mgd = million gallons per day.

8.2.1 Air Quality

Air quality impacts from an SCPC plant can be substantial because significant quantities of 

sulfur oxides, nitrogen oxides, particulates, carbon monoxide, and HAPs such as mercury are 

emitted; however, many of these pollutants can be effectively controlled by various 

technologies.

Callaway is located in Callaway County, which is part of the Northern Missouri Intrastate AQCR 

(40 CFR 81.116). Callaway County (and the rest of the Northern Missouri Intrastate AQCR) is 

designated as unclassified or in attainment for all NAAQS criteria pollutants (40 CFR 81.326). A 

new 1,186-MW net electric generating SCPC plant would qualify as a new major source of 

criteria pollutants and would require a PSD review under NSR regulations (42 U.S.C. § 7401 

et seq.). The MDNR adopted the PSD regulations in 10 CSR 10-6.060. The SCPC plant would 

need to comply with the standards of performance for electric utility steam generating units set 

forth in 40 CFR Part 60, Subpart Da, “Standards of Performance for Electric Utility Steam 

Generating Units for which Construction Is Commenced after September 18, 1978,” and 

incorporated by reference in MDNR air regulations (10 CSR 10-6.070). The standards establish 

8-17
Environmental Impacts of Alternatives

limits for particulate matter (40 CFR 60.42Da), sulfur dioxide (40 CFR 60.43Da), and nitrogen 

dioxide (40 CFR 60.44Da). 

Section 169A of the CAA (42 U.S.C. 7401) establishes a national goal of preventing future, and 

remedying existing, impairment of visibility in mandatory Class I Federal areas when impairment 

results from man-made air pollution. The Regional Haze Rule, issued by EPA in 1999 and last 

amended in October 2006 (71 FR 60631), requires states to demonstrate reasonable progress 

towards the national visibility goal established in 1977 to prevent future impairment of visibility 

because of man-made pollution in Class I areas. The visibility protection regulatory 

requirements are contained in 40 CFR Part 51, Subpart P, including the review of new sources 

that would be constructed in attainment or unclassified areas and may affect visibility in any 

Federal Class I area. If an SCPC plant were located close to a mandatory Class I area, 

additional air pollution control requirements would potentially apply. However, there are no 

mandatory Federal Class I areas within 50 mi (80 km) of the Callaway site. The closest 

mandatory Federal Class I area is the Mingo National Wildlife Refuge, which is approximately 

150 mi (241 km) southeast of the Callaway site (40 CFR 81.434). 

The State of Missouri, at the time of the initial regional haze rule, was among nine states 

(Nebraska, Kansas, Oklahoma, Texas, Minnesota, Iowa, Missouri, Arkansas, and Louisiana) 

that were members of the Central Regional Air Planning Association (CENRAP). CENRAP, 

along with tribes, Federal agencies, and other interested parties, worked together to identify 

regional haze and visibility issues and develop strategies to address them. As the funding for 

this group no longer exists, the individual states work with each other and the Federal land 

managers as necessary on continuing issues and updates to regional haze requirements 

(MDNR 2014).

In response to the Consolidated Appropriations Act of 2008 (PL 110-161), EPA issued final 

mandatory GHG reporting regulations for major sources effective in December 2009 (EPA 2010, 

2011). Major sources are defined as those emitting more than 25,000 tons per year of all 

GHGs. An SCPC alternative would be subject to these reporting regulations. The NRC staff 

notes that development of a new SCPC plant would need to comply with GHG permitting rules 

under the NSR PSD Program, with the proposed NSPS of 1,000 lb of carbon dioxide per 

megawatt-hour (rolling 12-month average) for new coal-fired plants that install CCS 

immediately.

EPA is proposing an alternative compliance method based on a 30-year averaging period that 

requires meeting an average of 1,800 lb of carbon dioxide per megawatt-hour (a rolling 

12-month average), which is attainable by an SCPC plant without CCS for the first 10 years. 

Beginning in the 11th year, the SCPC plant would need to meet an average of 600 lb of carbon 

dioxide per megawatt-hour (a rolling 12-month average) for the remaining 20 years of the 

30-year averaging period to meet the 1,000 lb of carbon dioxide per megawatt-hour limit over a 

30-year period. A new SCPC plant with CCS installed immediately would need to achieve a 

minimum 50 percent reduction in carbon dioxide emissions to meet the NSPS of 1,000 lb of 

carbon dioxide per megawatt-hour. If a new SCPC plant chose the 30-year average period 

option, CCS with a higher carbon dioxide removal efficiency would need to be installed and be 

operational by the beginning of the 11th year (77 FR 22392).

Under the Federal Acid Rain Program, the SCPC alternative would have to comply with Title IV 

of the CAA reduction requirements for sulfur dioxide and nitrogen oxides, which are the main 

precursors of acid rain and the major causes of reduced visibility. Title IV establishes maximum 

sulfur dioxide and nitrogen oxide emission rates from the existing plants and a system of sulfur 

dioxide emission allowances that can be used, sold, or saved for future use by new plants.

8-18
Environmental Impacts of Alternatives

The CAIR was first issued by EPA in 2005, permanently capping sulfur dioxide and nitrogen 

oxide emissions from stationary sources located in 27 states (including Missouri) and the District 

of Columbia. A new SCPC plant constructed in Missouri would be subject to revised emission 

limits for sulfur dioxide and nitrogen oxides issued under CAIR. However, CAIR was vacated by 

the D.C. Circuit Court on February 8, 2008. In December 2008, the U.S. Court of Appeals for 

the D.C. Circuit reinstated CAIR but required EPA to revise the rule and its implementation plan. 

On July 6, 2010, EPA proposed replacing CAIR with the CSAPR for control of sulfur dioxide and 

nitrogen oxide emissions that cross state lines. The CSAPR was to be implemented in 2011 

and finalized in 2012. However, CSAPR was vacated by the D.C. Circuit Court on 

August 21, 2012. On April 29, 2014, the U.S. Supreme Court reversed the D.C. Circuit opinion 

vacating CSAPR. EPA is reviewing the opinion and CAIR remains in effect (EPA 2014).

An SCPC alternative also would be subject to the Mercury and Air Toxics Standards (MATS) 

final rule, finalized by EPA on December 16, 2011 (EPA 2012b). MATS sets standards for 

emissions of heavy metals (mercury, arsenic, chromium, and nickel) and acid gases 

(hydrochloric acid and hydrofluoric acid). Numerical emission limits are set for mercury and 

particulate matter (as a surrogate for nonmercury metals) and hydrochloric acid (as a surrogate 

for all toxic acid gases).

Using data published by EPA and the EIA, recent air permit applications for coal-fired plants, 

and likely emission controls, NRC staff projects the following emissions for an SCPC alternative 

at the Callaway site:

 sulfur oxides: 666 tons (60 MT) per year,

 nitrogen oxides: 3,618 tons (3,280 MT) per year,

 carbon monoxide: 1,096 tons (994 MT) per year,

 PM10: 228 tons (208 MT) per year,

 PM2.5: 114 tons (104 MT) per year,

 carbon dioxide: 8.1 million tons (7.3 MMT) per year, and

 mercury: 0.18 tons (0.17 MT) per year.

8.2.1.1 Sulfur and Nitrogen Oxides and Carbon Dioxide

The SCPC alternative would produce 666 tons (604 MT) of sulfur oxides per year and 

3,618 tons (3,280 MT) of nitrogen oxides per year. These estimates are based on the use of 

sulfur dioxide wet limestone-based scrubbers with 98 percent efficiency, the use of SCR with a 

nitrogen oxides removal efficiency of 8 percent, and combustion modifications such as low 

nitrogen oxide burners, flue gas recirculation, and overfire air. The SCPC plant would emit 

approximately 8.1 million tons (7.3 MMT) of carbon dioxide per year. The new plant would be 

subject to the continuous monitoring requirements for sulfur dioxide, nitrogen oxides, and 

carbon dioxide specified in 40 CFR Part 75. 

8.2.1.2 Particulates

The SCPC alternative would produce 228 tons (208 MT) of particulates per year, emitted as 

PM10. Typical control technology used on coal-fired plants includes fabric filters installed in 

baghouses. Control efficiency is in excess of 99 percent and was applied to the emission 

estimate. Staff estimates emissions of PM2.5 would be approximately 50 percent of the PM10

emission rate. Small amounts of particulate would be released as drift from the cooling tower 

(regardless of whether it involves a natural-draft or mechanical-draft tower). Particulate control 

on the cooling tower would likely consist of a drift/mist eliminator system, typical for new fossil 

fuel-fired power plants. 

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Environmental Impacts of Alternatives

8.2.1.3 Carbon Monoxide

Based on EPA emission factors (EPA 2010), the NRC staff estimates that the total carbon 

monoxide emissions would be approximately 1,096 tons (994 MT) per year. This emission rate 

assumes no control requirements (e.g., use of an oxidation catalyst to reduce carbon monoxide 

emissions) would be imposed.

8.2.1.4 Hazardous Air Pollutants

Coal combustion generates various HAPs. Mercury is the most prominent HAP emitted and is 

subject to regulation by the MATS rule. The particulate and sulfur dioxide emission controls 

required for coal combustion under other applicable regulations would also limit emissions of 

nonmercury metals and acid gases under the MATS rule. NRC staff estimates that an SCPC 

alternative replacing the electrical output of the Callaway plant would generate 0.18 tons 

(0.17 MT) of mercury per year.

8.2.1.5 Construction Impacts

Activities associated with construction of the SCPC alternative at the Callaway site would cause 

some additional air quality impacts. Workers’ vehicles, material delivery vehicles, and 

motorized construction equipment would generate temporary criteria pollutant and GHG 

emissions because of consumption of fossil fuels and fugitive dust from operation of the 

earth-moving and material-handling equipment. Analogous emissions would occur in 

association with new offsite railroad line and possible barge slip construction (for delivery of coal 

and other materials to the site). All such impacts would be temporary. Dust control practices 

would reduce fugitive dust, which would be temporary in nature. Given the expected workforce 

and a relatively short construction period for the SCPC alternative, the NRC staff concludes that 

the impact of construction equipment and vehicle exhaust emissions and fugitive dust from 

operation of earth-moving and material-handling equipment would be SMALL.

8.2.1.6 Additional Operating Impacts

In addition to the air quality impacts associated with operation of the SCPC plant, additional air 

quality impacts would result from vehicles used by the commuting operating workforce. 

However, the workforce at an SCPC plant would be substantially smaller than the current 

operating workforce for Callaway, so a change to an SCPC plant would result in substantial 

reductions in commuting-related air emissions. The impacts on air quality from ancillary 

activities during operation of an SCPC plant would be SMALL.

EPA reported that, in 2010, the total amount of CO2e emissions related to electricity generation 

was 2,277.3 teragrams (2,277.3 MMT) (EPA 2012a). The EIA reported that, in 2010, electricity 

production in Missouri was responsible for 78.8 MMT of CO2e emissions, or 3.46 percent of the 

national total (EIA 2012b). The NRC staff estimates that uncontrolled CO2e emissions from 

operation of the SCPC alternative would amount to 8.1 million tons (7.3 MMT). This amount 

represents 0.32 percent and 9.3 percent, respectively, of 2010 U.S. and Missouri CO2e 

emissions. Although coal combustion would be the primary source, other miscellaneous 

ancillary sources (e.g., truck and rail deliveries of fuel and materials to the site and commuting 

of the workforce) would make minor contributions.

NETL estimates that CCS technologies could capture and remove as much as 90 percent of the 

carbon dioxide produced by the plant. However, NETL estimates that such equipment imposes 

a significant parasitic load that would result in a power production capacity decrease and a 

potential increase in the levelized cost of electricity produced (NETL 2007). Further, permanent 

sequestering of the carbon dioxide would involve removing impurities (including water), 

pressurizing it to meet pipeline specifications, and transferring it by pipeline to acceptable 

8-20
Environmental Impacts of Alternatives

geologic formations. Even when opportunities exist to use the carbon dioxide for enhanced oil 

recovery (rather than simply disposing of the carbon dioxide in geologic formations), permanent 

disposal costs could be substantial, especially if the SCPC plant is far removed from acceptable 

geologic formations. With CCS in place, the SCPC plant would release 0.8 million tons 

(0.73 MMT) of carbon dioxide per year. If future regulations require the capture and 

sequestration of carbon dioxide from coal-fired facilities, the impact on climate change from this 

alternative would be further reduced.

Climate-related changes for the Midwest region that could affect an SCPC plant (primarily 

related to cooling requirements) at the Callaway site include alternating periods of drought and 

flooding, an increase in the frequency and severity of heat waves, and an increase in the 

temperature of surface water bodies (rivers and lakes) (Karl et al. 2009).

Based on this information, the overall air quality impacts of the SCPC alternative at the 

Callaway site would be MODERATE. 

8.2.2 Surface Water Resources

Surface water resources impacts from construction activities associated with the SCPC 

alternative would be expected to be similar to, but somewhat greater than, those under the 

NGCC alternative. This is attributable to the additional land required for construction of the 

power block and for excavation and construction of an onsite disposal facility. At the Callaway 

site, some temporary impacts on surface water quality may result from increased sediment 

loading and from any pollutants in stormwater runoff from disturbed areas. In addition, the 

construction of a new rail line and possible barge slip to transport coal to the site location could 

result in impacts on water quality. Nevertheless, as described in Section 8.1.2, water quality 

impacts would be minimized by the application of BMPs and compliance with State-issued 

NPDES permits. Additional offsite impacts, including hydrologic changes in affected streams 

and contaminant runoff, would result from coal mining (see Section 8.2.7).

During operations, surface water flowing through a closed-cycle system would be used to cool 

the SCPC plant. The total volume of surface water required by the SCPC plant, including that 

needed for cooling and carbon capture, would be approximately 4 mgd (15,100 m3

/day) greater 

than that currently used by the Callaway Unit 1 plant (see Section 8.2). Consequently, the 

cooling tower blowdown volume would be correspondingly greater; otherwise, the blowdown 

discharge would be chemically and thermally similar to Callaway Unit 1’s existing discharge to 

the Missouri River. In general, surface water resources impact assessment presented in 

Section 4.3.2 of this SEIS generally applies to the SCPC alternative, although impacts could be 

greater due the additional water demand associated with carbon sequestration. All effluent 

discharges and stormwater discharges associated with industrial activity would be subject to a 

State-issued NPDES permit under this alternative. This would require submitting a revised 

NPDES permit application (MDNR 2012b), and granting of the modified permit by the MDNR. 

Coal, fly ash, and clinker storage could cause surface water contamination, but with proper 

design, the impacts could be mitigated. The NRC further assumes that the SCPC plant and 

waste disposal facility would be operated in accordance with appropriate permits and 

management plans, with adherence to appropriate BMP and procedures to minimize the release 

of fuels, chemicals, and other materials to soil, surface water, and groundwater. As a result, the 

NRC staff concludes that the impact on surface water quality and use from construction and 

operation of the SCPC plant at the Callaway site would be SMALL.

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Environmental Impacts of Alternatives

8.2.3 Groundwater Resources

Construction activities associated with the SCPC alternative could include the need to conduct 

groundwater dewatering. This is because of the more extensive excavation that would be 

required for the SCPC power block and the onsite disposal facility as compared to the NGCC 

alternative. Nevertheless, engineering measures, such as the use of cofferdams, sumps, wells, 

or other methods to address high water-table conditions, can be used to minimize impacts on 

facility construction. Facility construction would increase the amount of impervious surface at 

the site location and alter the subsurface strata because of excavation work and the placement 

of backfill following facility completion. While this could cause a localized lowering of 

water-table elevation in surficial aquifers, if present, any such changes off site would likely be 

minor. Below-grade portions of a new SCPC plant also could alter the direction of groundwater 

flow, although such effects would likely be very localized. Finally, the application of BMP in 

accordance with a State-issued NPDES stormwater general permit (MDNR 2012b) would 

prevent or minimize any groundwater quality impacts during construction. 

Existing wells or replacement wells completed in the same aquifers currently used to support 

Callaway would likely be used to supply the relatively small amounts of water required for 

potable and sanitary uses, concrete production, dust suppression, and soil compaction. 

However, the amount of construction water consumed should be much less than the amount 

currently consumed by Callaway operations. Onsite water demands could be further reduced 

by the use of ready-mix concrete and the use of portable sanitary facilities that are serviced 

offsite for construction workers. The 1996 GEIS (NRC 1996) has found that pumping rates of 

less than 100 gpm (380 L/min) have not been shown to adversely affect groundwater

availability.

The new power plant would obtain potable water and water to lubricate the surface water pumps 

at the river intake structure from existing or replacement wells completed in the same aquifers 

currently used to supply water for Callaway. During operations, the rate of groundwater

consumption should be about the same as for the existing Callaway facility. Consequently, the 

groundwater resources impact assessment presented in Section 4.4.2 of this SEIS generally 

applies to the SCPC alternative. Also during operations, coal, fly ash, and clinker storage could 

cause groundwater contamination, but with proper design, the impacts could be mitigated. The 

onsite disposal of coal ash and air pollution control scrubber wastes has the potential to impact 

groundwater quality. The leaching of contaminants from the fly ash and scrubber sludge and its 

potential impacts on groundwater can be minimized in modern facilities with protective barriers, 

disposal cell liners, and leachate collection and treatment systems, along with groundwater 

monitoring systems. The facility would also need a State-issued landfill permit (MDNR 2012b).

Therefore, based on the above assessment, the impacts on groundwater use and quality would 

be SMALL.

8.2.4 Aquatic Ecology

The SCPC plant would require less cooling water than Callaway, but total water requirements 

could be greater if surface water is also used to supply the total makeup demand for carbon 

capture (see Sections 8.1 and 8.2.2). Therefore, potential impacts on aquatic organisms 

caused by impingement, entrainment, and thermal plumes could be similar to but somewhat 

greater than those described in Section 4.5 of this SEIS. 

The additional surface water withdrawal associated with the carbon capture could result in 

additional adverse impacts on the Federally endangered pallid sturgeon, primarily through 

impingement and entrainment. Based on the potential occurrence of the sturgeon and other 

8-22
Environmental Impacts of Alternatives

threatened and endangered species at the Callaway site discussed in Section 2.2.7, 

consultation with the FWS under the ESA would be required for any alternative project. This 

consultation would ensure that construction and operation of the SCPC alternative would not 

adversely affect any Federally listed species or adversely modify or destroy designated critical 

habitat. The staff relies on Ameren’s coordination with State natural resource agencies would 

further ensure that Ameren would take appropriate steps to avoid or mitigate impacts on 

State-listed species, habitats of conservation concern, and other protected species and habitats. 

In addition, also relies on the State to enforce the NPDES stormwater general permit to require 

the use of the best available technology in minimizing impacts associated with impingement and 

entrainment of aquatic organisms from the Missouri River.

Temporary impacts on surface waters may also occur during construction of the SCPC 

alternative, although State-enforced NPDES stormwater general permits should prevent or 

significantly mitigate any impacts such as sediment loading from runoff from active construction 

sites. 

Based on the above information, impacts on aquatic resources from the SCPC alternative 

should be SMALL.

8.2.5 Terrestrial Ecology

The NRC staff estimated that constructing a new SCPC plant would require approximately 

617 ac (250 ha) of land, an update from the estimate provided in the GEIS. Ameren estimates 

that 164 ac (66 ha) of land would be required for construction (comprising the power block and 

coal storage area). An additional 95 ac (38 ha) of land would be required for the disposal of ash 

and scrubber sludge over a 40-year plant life (Ameren 2011b). The NRC staff assumes that this 

alternative would use existing onsite structures and previously disturbed areas to the extent 

practicable to minimize new development in undisturbed areas. 

However, considering that the existing industrial area on the plant site covers 512 ac (207 ha), 

a significant amount of new undisturbed area would be required to construct new facilities. 

Onsite impacts on terrestrial resources would likely include terrestrial habitat loss and habitat 

fragmentation. Given the amount of undeveloped land that would be required, habitats such as 

herbaceous and forested wetlands, upland forest, and grasslands would likely be lost or 

otherwise adversely affected. 

Habitats for threatened and endangered species may also be affected. Based on the potential 

occurrence of threatened and endangered species at the Callaway site discussed in 

Section 2.2.8, species that could potentially be affected include the gray bat, Indiana bat,

running buffalo clover, bald eagle, eastern hellbender, and northern harrier. Consultation with 

the FWS under the ESA would occur during development of the SCPC plant to ensure that 

construction and operation of this alternative would not adversely affect any Federally listed 

species or adversely modify or destroy designated critical habitat. The staff would rely on 

Ameren’s coordination with State natural resource agencies to further ensure that Ameren takes 

the appropriate steps necessary to avoid or mitigate impacts on State-listed species, habitats of 

conservation concern, and other protected species and habitats.

Development outside the existing plant footprint for new onsite structures would impact the 

Reform Conservation Area. Since the existing lease agreement between Ameren and the MDC

restricts development within the Reform Conservation Area, any such development would 

require a revision to the existing lease agreement. If permitted under a revised lease 

agreement, impacts would include a loss of natural habitats to an extent commensurate with the 

reduction in size of the overall natural resources management area. Considering the land 

8-23
Environmental Impacts of Alternatives

requirements associated with the SCPC, the loss of undisturbed natural land area within the 

Reform Conservation Area could be significant. 

Offsite impacts also would occur as a result of coal mining. Based on scaled GEIS estimates, 

the SCPC alternative could require up to about 26,100 ac (10,600 ha) of land for coal mining 

and waste disposal during power plant operations, which could have a significant impact on 

terrestrial resources. However, much of the land in existing coal mining areas has already

experienced some level of disturbance. 

The elimination of the use of uranium fuel at the Callaway site would partially offset some of the 

land requirements for the SCPC. According to the GEIS, approximately 100 ac (41 ha) of land 

per year are temporarily committed for the fuel cycle for a 1,000-MW plant, of which 

approximately 22 ac (9 ha) are disturbed. Scaling from GEIS estimates, approximately 26 ac 

(11 ha) per year would no longer be needed for the mining and processing of uranium during 

the 20-year operating life of the plant (assumes a 1,186-MW plant would disturb 26 ac (11 ha) of 

land per year if a 1,000-MW plant disturbs 22 ac (9 ha) per year, as stated in the GEIS). 

Cooling tower drift would not present a new impact on existing vegetation, which already 

experiences drift from the existing Callaway cooling tower.

Based on the above information, impacts on terrestrial resources from the SCPC alternative 

would be MODERATE to LARGE.

8.2.6 Human Health

Human health issues related to construction of the SCPC alternative would be equivalent to 

those associated with the construction of any major complex industrial facility and would be 

controlled to acceptable levels through the application of BMP and Ameren’s compliance with 

applicable Federal and State worker protection regulations. 

Operation of the SCPC alternative introduces worker risks from coal and limestone mining, coal 

and limestone transportation, disposal of ash and scrubber wastes, and transportation of 

reusable byproducts. In addition, there are public risks from inhalation of stack emissions. 

Emission impacts can be widespread, and health risks can be difficult to quantify. 

Human health risks of coal-fired power plants are described, in general, in Table 8–2 of the 

GEIS (NRC 1996). Cancer and emphysema as a result of the inhalation of toxins and 

particulates are identified as potential health risks to occupational workers and members of the 

public (NRC 1996). The human health risks associated with coal-fired power plants, both for 

occupational workers and members of the public, are greater than those of the current Callaway 

plant because of exposures to chemicals such as mercury, sulfur oxides, nitrogen oxides, 

radioactive elements such as uranium and thorium contained in coal and coal ash, and 

polycyclic aromatic hydrocarbon compounds, including benzo(a)pyrene. 

Regulatory agencies, including EPA and state agencies, set air emission standards and 

requirements based on human health impacts. These agencies also impose site-specific 

emission limits as needed to protect human health. Many of the byproducts of coal combustion 

responsible for health effects are largely controlled, captured, or converted in modern power 

plants, although some level of health effects may remain. EPA has concluded that certain 

segments of the U.S. population (e.g., the developing fetus and subsistence fish-eating 

populations) are believed to be at potential risk of adverse health effects because of mercury 

exposures from sources such as coal-fired power plants, though these emissions are likely to be

smaller from modern SCPC plants than from conventional coal-fired plants (65 FR 79825). 

8-24
Environmental Impacts of Alternatives

Aside from emissions impacts, coal-fired power generation introduces the risk of coal pile fires, 

and for those plants that manage coal combustion residue liquids and sludge in waste 

impoundments, the release of the waste may result because of a failure of the impoundment. 

Good housekeeping practices to control coal dust greatly reduce the potential for coal dust 

explosions or coal pile fires. Although there have been several instances in recent years, 

sludge impoundment failures are still rare. Free water and leachate also could be recovered 

from such waste streams and recycled and the solid or semisolid portions removed to permitted 

offsite disposal facilities.

Overall, given extensive health-based regulation and controls likely to be imposed as permit 

conditions, the NRC staff expects that human health impacts on workers and members of the 

public from the SCPC alternative would be SMALL.

8.2.7 Land Use

The GEIS generically evaluates the impact of constructing and operating various replacement 

power plant alternatives on land use, both on and off each power plant site. The analysis of 

land use impacts focuses on the amount of land area that would be affected by the construction 

and operation of an SCPC power plant at an existing power plant site. Locating the new SCPC 

power plant at the Callaway site would maximize the availability of support infrastructure and 

reduce the need for additional land.

Based on scaled GEIS estimates, approximately 617 ac (250 ha) of land would be required for 

the power block and coal storage at the site. A 200-ac (81-ha) engineered solid waste disposal 

facility (landfill) would be constructed to dispose of solid waste for the estimated 20 years of 

operation. Based on this information, land use impacts from SCPC power plant and landfill 

construction could range from SMALL to MODERATE. Depending on existing power plant 

infrastructure, additional land may be needed for frequent coal and limestone deliveries.

Offsite impacts also would occur as a result of coal mining. Based on scaled GEIS estimates, 

the SCPC alternative could require up to about 26,100 ac (10,600 ha) of land for coal mining 

and waste disposal during power plant operations. However, much of the land in existing coal 

mining areas has already experienced some level of disturbance. 

The elimination of uranium fuel for Callaway could partially offset some, but not all, of the land 

requirements for the SCPC alternative. Scaling from GEIS estimates, approximately 26 ac 

(11 ha) per year would no longer be needed for the mining and processing of uranium during 

the 20-year operating life of the plant. Since a substantial amount of land could be converted 

for coal and limestone delivery and waste disposal, land use impacts could range from SMALL 

to MODERATE.

8.2.8 Socioeconomics

As previously explained in Section 8.1.8, two types of jobs would be created by this alternative: 

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

socioeconomic impact, and (2) power plant operations jobs, which have the greater potential for 

permanent, long-term socioeconomic impacts. Workforce requirements for the construction and 

operation of the SCPC alternative were evaluated to measure their possible effects on current 

socioeconomic conditions.

Scaling from GEIS estimates, the construction workforce would peak at 1,423 to 2,965 workers. 

Ameren’s estimate of 1,839 workers during the peak construction period (Ameren 2011b) falls 

within this range and appears to be reasonable.

8-25
Environmental Impacts of Alternatives

The relative economic impact of this many workers on the local economy and tax base would 

vary, with the greatest impacts occurring in the communities where a majority of construction 

workers would reside and spend their income. As a result, local communities could experience 

a short-term “boom” from increased tax revenue and income generated by construction 

expenditures and the increased demand for temporary (rental) housing and business services. 

Some construction workers could relocate to be closer to the construction work site. However, 

since Callaway is located near the Columbia, Jefferson City, and St. Louis metropolitan areas, 

workers could commute to the construction site instead, thereby reducing the need for rental 

housing. After completing the installation of the SCPC power plant, local communities could 

experience a return to preconstruction economic conditions. Based on this information and 

given the number of construction workers, socioeconomic impacts during construction in local 

communities could range from SMALL to MODERATE.

Scaling from GEIS estimates, the power plant operations workforce would range from 177 to 

237 workers. Ameren’s estimated operations workforce of approximately 160 workers 

(Ameren 2011b) appears to be reasonable. This alternative would result in a loss of 

approximately 860 relatively high-paying jobs at Callaway, with a corresponding reduction in 

purchasing activity and tax contributions to the regional economy. In addition, the permanent 

housing market could also experience increased vacancies and decreased prices if operations 

workers and their families move out of the region. However, a larger amount of property taxes

may be paid to local jurisdictions under the SCPC alternative as more land may be required for 

coal-fired power plant operations than Callaway. Therefore, socioeconomic impacts during 

operations could range from SMALL to MODERATE.

8.2.9 Transportation 

Commuting workers and truck deliveries of materials and equipment to the Callaway site would 

cause transportation impacts during the construction and operation of the SCPC power plant. 

During periods of peak construction activity, up to 1,423 to 2,965 construction workers could be 

commuting daily to the construction site (see Section 8.2.8). Workers commuting to the 

construction site would arrive by site access roads, and the volume of traffic on nearby roads 

could increase substantially during shift changes. In addition to commuting workers, trucks 

would be transporting construction materials and equipment to the work site, thus increasing the 

amount of traffic on local roads. The increase in vehicular traffic would peak during shift 

changes, resulting in temporary level-of-service impacts and delays at intersections. 

The existing rail spur at Callaway cannot be reconstructed to provide the necessary rail capacity 

for the delivery of coal and limestone to the site (Ameren 2014). It may be possible to construct 

a new rail spur along an alternative route to the plant site from active railroad lines to the north 

and south of the plant, or via a rail line run from a barge transfer point on the Missouri River to 

the plant site. Thus, some power plant components and materials could also be delivered by 

train. Train deliveries could cause additional traffic delays at railroad crossings. Based on this 

information, traffic-related transportation impacts during construction would range from 

MODERATE to LARGE.

Traffic-related transportation impacts on local roads would be greatly reduced after the 

completion of the power plant. Transportation impacts would result from daily commuting by the 

operating workforce, equipment and materials deliveries, and the removal by truck of 

commercial waste material to offsite disposal or recycling facilities. As noted in Section 8.2.8, 

approximately 177 to 237 workers would be needed to operate the SCPC power plant. The 

increase in traffic on roadways would peak during shift changes, resulting in temporary 

level-of-service impacts and delays at intersections. Frequent deliveries of coal and limestone 

and removal of ash by rail or barge would add to the overall transportation impact. Onsite coal 

8-26
Environmental Impacts of Alternatives

storage would make it possible to receive several trains per day. Assuming a unit train has 

125 cars and each car holds 100 tons (91 MT), approximately 386 unit trains per year (about 

7 trains per week) would be needed to deliver an estimated 4.7 million tons (4.3 MMT) of coal to 

the SCPC plant. Smaller unit trains would result in more frequent deliveries of coal and 

limestone causing further levels of service impacts on local roads affected by the delays at 

railroad crossings. Overall, transportation impacts would range from SMALL to MODERATE 

during power plant operations. 

8.2.10 Aesthetics and Noise 

The analysis of aesthetic impacts focuses on the degree of contrast between the SCPC 

alternative and the surrounding landscape and the visibility of the new SCPC plant at the 

Callaway power plant site. During construction, all of the clearing and excavation would occur 

on site. These activities could be visible from offsite roads. Since Callaway already appears 

industrial, construction of the SCPC power plant would appear similar to other ongoing onsite 

activities.

The boilers required for the SCPC alternative could be up to 200 ft (60 m) in height, and each of 

the additional stacks would be approximately 600 ft (180 m) in height. The existing rail spur at 

Callaway cannot be reconstructed to provide the necessary rail capacity for the delivery of coal 

and limestone to the site. As noted in Section 8.2, a new rail line could be constructed to the 

plant site from main railroad lines located to the north and south or via a spur run from a barge 

transfer point on the Missouri River. The visual impacts of these additional features would add 

to the overall visual impact of the Callaway site. The SCPC power plant would be noticeable at 

night because of 24-hour operation of coal-handling equipment. The visibility of the SCPC 

power plant would be similar to that of the existing nuclear power plant, given the high cooling 

tower, standing 553 ft (169 m), at Callaway. Coal-fired power generation would also introduce 

mechanical noise that would be audible off site. Sources of noise produced by SCPC power 

plant operations would be continuous and intermittent. Continuous sources include the 

mechanical equipment associated with normal power plant operations. Intermittent sources 

would include the coal-handling equipment, solid waste disposal systems, outside 

loudspeakers, and vehicular traffic. Noise impacts associated with coal and limestone delivery 

to the site by rail would be greatest along the existing railroad, possible new barge slip, and new

rail line leading to the plant. Although passing trains significantly raise noise levels, their 

relatively short duration tends to mitigate impacts over time. 

Thus, given the industrial appearance of the Callaway site, aesthetic changes and the elevated 

noise levels experienced by residents living in the vicinity of the SCPC power plant at the 

Callaway site and increased rail traffic would range from SMALL to MODERATE.

8.2.11 Historic and Archeological Resources

The potential for impacts on historic and archaeological resources from the SCPC alternative 

would vary greatly, depending on the location of the proposed facility on the Callaway site 

because of the high potential for discovery of additional historic and archaeological resources. 

Any construction would need to avoid the previously identified 25 eligible or potentially eligible 

historic properties located at Callaway. Alternate SCPC plant locations and associated 

corridors of new construction on the Callaway site would need to be surveyed and inventoried 

for potential resources. Any additional offsite land area needed to support construction of the 

SCPC plant would also need to be surveyed for potential resources. Resources found in these 

surveys would need to be evaluated for eligibility on the NRHP, and mitigation of adverse 

effects would need to be addressed if eligible resources were encountered. The level of impact 

8-27
Environmental Impacts of Alternatives

at these locations would vary, depending on the specific resources found to be present in the 

APE. However, given that the preference is to use previously surveyed and/or disturbed areas, 

and portions of the site have been previously identified as not containing significant resources, 

avoidance of historic and archaeological resources should be possible and effectively managed 

under current laws and regulations. Therefore, the impacts on historic and archaeological 

resources from the SCPC alternative would be SMALL 

8.2.12 Environmental Justice 

This analysis evaluates the potential for disproportionately high and adverse human health, 

environmental, and socioeconomic effects on minority and low-income populations that could 

result from construction and operation of a new SCPC power plant. As previously discussed in 

Section 8.1.12, such effects may include human health, biological, cultural, economic, or social 

impacts. 

Potential impacts to minority and low-income populations would mostly consist of environmental 

and socioeconomic effects during construction (e.g., noise, dust, traffic, and housing impacts). 

Noise and dust impacts during construction would be short term and primarily limited to onsite 

activities. Minority and low-income populations residing along site access roads also would be 

directly affected by increased commuter vehicle and truck traffic. However, because of the 

temporary nature of construction, these effects are not likely to be high and adverse and would 

be contained to a limited time period during certain hours of the day. Increased demand for 

rental housing during construction could cause rental costs to rise disproportionately affecting 

low-income populations who rely on inexpensive housing. However, given the proximity of the 

site to the Columbia, Jefferson City, and St. Louis, metropolitan areas, workers could commute 

to the construction site, thereby reducing the need for rental housing. The noise and visual 

intrusion associated with the rail transport of coal and limestone could affect minority and 

low-income populations. However, impacts are not likely to be disproportionate, because 

everyone living along the railroad tracks would experience the same potential effects. The staff 

expects permitted air emissions to remain within regulatory standards.

Based on this information and the analysis of human health and environmental impacts 

presented in Section 8.2 of this SEIS, construction and operation of an SCPC alternative would 

not have disproportionately high and adverse human health and environmental effects on 

minority and low-income populations residing in the vicinity of the Callaway site.

8.2.13 Waste Management 

During the construction phase of this alternative, land clearing and other construction activities 

would generate wastes that could be recycled, disposed of on site, or shipped to an offsite 

waste disposal facility. Construction-related wastes would be solid, liquid, or gaseous, and 

some would require management, treatment, and disposal as hazardous wastes. Various 

permits, issued by State or local authorities, would control the disposition of all 

construction-related wastes. Because the alternative would be constructed on the previously 

disturbed Callaway site, the amounts of wastes produced during land clearing would be minimal.

Coal combustion generates several waste streams, including ash (a dry solid) and sludge 

(a semisolid byproduct of emission control system operation). The 1,186-MW power plant 

would annually generate approximately 306,980 tons (278,490 MT) of ash, and 87,430 tons 

(79,320 MT) of scrubber waste. Approximately 85 percent of the ash would be recycled; 

therefore, approximately 133,480 tons (121,090 MT) of ash and scrubber waste would remain 

annually for disposal. Disposal of the remaining waste in an onsite facility could affect land use 

and groundwater quality, but would require proper siting, design, construction, and operation in 

8-28
Environmental Impacts of Alternatives

accordance with applicable regulations, as well as implementation of monitoring and 

management practices to minimize impacts. After closure of the waste site and revegetation, 

the land could be available for other uses.

In May 2000, EPA issued a “Notice of Regulatory Determination on Wastes from the 

Combustion of Fossil Fuels” (65 FR 32214) stating that it would issue regulations for the 

disposal of coal combustion waste under Subtitle D of the Resource Conservation and 

Recovery Act. The EPA has not yet issued these regulations.

During the operational stage, the SCPC alternative would also generate spent SCR catalyst 

used to control nitrogen oxide emissions. Because the specific emission control equipment 

cannot be specified at this time, the amount of spent catalyst regenerated, sold, or disposed of 

during each year of operation cannot be calculated with precision. The NRC staff has not made 

an estimate of the amount of spent catalysts that would be produced and presumes that the 

entire amount would have no recycling opportunities and would require disposal. Depending on 

the catalysts used, special handling may also be required to address the potential hazardous 

character of these spent catalysts.

The amount of the construction waste would be small compared to the amount of waste 

generated during the operational stage, and much of it could be recycled. Overall, the impacts 

from waste generated during the construction stage would be minor. The staff concludes that 

the overall impacts of waste generation and disposal from construction and operation of this 

alternative would be MODERATE.

8.3 New Nuclear Reactor

This section presents the environmental impacts of new nuclear power generation at the 

Callaway site.

Ameren had previously proposed to build a Callaway Unit 2 near the existing reactor and 

submitted a combined license application (COLA) to the NRC in 2008. While in 2009, Ameren 

suspended its efforts to build the new unit, in 2010 Ameren informed the NRC that it intended to 

pursue an early site permit for the unit (Ameren 2011b). In lieu of renewing the Callaway 

license, a new nuclear reactor could be constructed to replace the existing Callaway Unit 1 at 

the Callaway site.

In its COLA ER (Ameren 2009), Ameren evaluated the construction and operation of AREVA’s 

U.S. Evolutionary Power Reactor (EPR) at the Callaway site. In evaluating the new nuclear 

reactor alternative in this section, the NRC staff assumes that the replacement reactor would be 

an advanced light-water reactor such as the Advanced Passive 1000 (AP1000) model 

pressurized-water reactor, a reactor design for which the NRC has already issued a certification. 

With a gross electrical output of 1,200 MW, the AP1000 approximates Callaway’s currently 

installed capacity of 1,186 MW better than the U.S. EPR.

To estimate the impacts of this replacement reactor, the NRC reviewed its assessment of 

construction and operating impacts for one of two AP1000 units at the Virgil C. Summer Nuclear 

Station (VCSNS) in Fairfield County, South Carolina. The NRC issued the final EIS for these 

units in 2011 (NRC 2011). The NRC amended some parameters applied to the VCSNS site to 

reflect conditions at the Callaway site. With these differences taken into consideration, the 

impacts of constructing and operating one AP1000 unit at the Callaway site should bound the 

impacts of replacing Callaway Unit 1’s currently installed capacity. 

For the new nuclear reactor alternative, the NRC staff assumes that the new AP1000 reactor 

would be constructed at the Callaway site within the footprint of either the current Unit 1 plant or, 

8-29
Environmental Impacts of Alternatives

more likely, the previously proposed Unit 2 plant. This would take advantage of existing 

infrastructure (e.g., cooling water intake system, transmission, roads, and technical and 

administrative support facilities). In addition to the cooling towers, other onsite visible structures 

would include the boiler and turbine buildings and exhaust stacks. Based on GEIS estimates, 

approximately 500 to 1,000 ac (202 to 404 ha) of land would be required, and Ameren 

estimated 647 ac (262 ha). For this analysis, the NRC estimates 588 ac (238 ha) of land would 

be required, which would be within the available land area.

The new 1,200-MW nuclear reactor would consume similar amounts of fuel as the existing 

Callaway facility. Accordingly, the new nuclear reactor alternative would result in the generation 

of similar amounts of radioactive waste as Callaway. The new nuclear reactor alternative would 

withdraw approximately 28 mgd (106,000 m3

/day) of water for cooling, compared to the 

estimated 25 mgd (94,600 m3

/day) of water withdrawn by Callaway (Ameren 2011b). For the 

purposes of this alternatives analysis, the NRC assumes that the new nuclear reactor would 

generate the same types and quantities of airborne radiological and nonradiological emissions.

Table 8–4 summarizes the key operating parameters for the 1,200-MW new nuclear alternative 

as estimated by NRC. These values are calculated from the data presented in Table 8–1 using 

expected gross capacity.

Table 8–4. Characteristics of 1,200-MW Nuclear Alternative

Heat Rate 

(Btu/kWh)

Land 

Requirement 

(ac) (a)(b)

Water 

Requirement 

(mgd)(a)(b)

Peak 

Construction 

Work Force(a)

Operations Work 

Force(a)

10,452 588 28 2,400-6,600 270-360

(a) Values scaled from Table 8–1 

(b) To convert acres (ac) to hectares (ha), multiply by 0.4047. To convert million gallons per day (mgd) to cubic 

meters (m3

) per day, multiply by 3,785.

Key:

ac = acres; BTU = British thermal units; kWh = kilowatt hours; mgd = million gallons per day.

8.3.1 Air Quality

Callaway is located in Callaway County, which is part of the Northern Missouri Intrastate AQCR 

(40 CFR 81.116). Callaway County (and the rest of the Northern Missouri Intrastate AQCR) is 

designated as unclassified or in attainment for all NAAQS criteria pollutants (40 CFR 81.326). 

Ameren reported the following air emissions from Callaway in 2011 (Ameren 2012b). Similar air 

emissions from a new nuclear power plant are expected, because these emissions are primarily 

from backup diesel generators that would also be used at a new nuclear plant:

 sulfur dioxide: 5.0 tons (4.6 MT) per year,

 nitrogen oxides: 21 tons (19.1 MT) per year,

 carbon monoxide: 4.1 tons (3.7 MT) per year,

 PM10: 0.6 tons (0.5 MT) per year,

 PM2.5: 0.6 tons (0.5 MT) per year, and

 carbon dioxide: 4,611 tons (4,196 MT) per year.

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Environmental Impacts of Alternatives

8.3.1.1 Construction Impacts

During construction, air quality would be affected by the release of criteria pollutants from 

construction vehicles and equipment, workforce commuting vehicles, and material delivery 

vehicles. Releases of volatile organic compounds (VOCs) would be expected from onsite 

vehicle and equipment fueling activities and from the use of cleaning agents and corrosion 

control coatings. The new reactor most likely would be located on previously disturbed areas 

for the proposed Callaway Unit 2. Ground disturbance—such as from ground-clearing and

cut-and-fill activities, movement of construction vehicles on unpaved and disturbed land 

surfaces, and delivery and stockpiling of materials used in construction (e.g., sand and gravel)—

would all still occur and would increase fugitive dust releases. Ameren would be expected to 

apply BMP to reduce such air quality impacts to acceptable levels. GHG emissions during 

construction would result primarily from the consumption of fossil fuels in the operation of 

construction vehicles and equipment and from the operation of delivery vehicles and vehicles 

used by the commuting workforce. These impacts would be short-lived and are expected 

to be SMALL.

8.3.1.2 Additional Operating Impacts

During operation, air quality impacts would include releases of criteria pollutants from vehicles 

used by the commuting workforce and vehicles (primarily trucks) used to deliver supplies and 

equipment to the site. The expected operation of diesel-fueled emergency generators for 

preventative maintenance purposes or during refueling operations and operation of an auxiliary 

fossil fuel boiler would represent additional sources of criteria pollutants during operation. 

Finally, operation of the cooling tower would result in the release of particulates in the form of 

drift. Overall, impacts on air quality during operation would be SMALL.

Operation of a new nuclear reactor would have essentially identical effects on climate change 

as operation of the current Callaway facility. Operation of the reactor itself does not result in the 

release of GHGs that could impact climate. However, GHG emissions result from some 

ancillary support activities, such as the periodic preventative maintenance operation of 

diesel-fueled emergency generators, operation of an auxiliary boiler, the onsite travel of 

vehicles, and commuting of the operating workforce. Because operating parameters of an 

alternative reactor would be essentially the same as the existing reactor, and the operating 

workforce would be of the same approximate size as the current workforce, impacts on climate 

from an alternative reactor at Callaway can be expected to be SMALL. Climate-related changes 

for the Midwest region that could affect an alternative reactor (primarily related to cooling 

requirements) at the Callaway site include alternating periods of drought and flooding, an 

increase in the frequency and severity of heat waves, and an increase in temperature of surface 

water bodies (rivers and lakes) (Karl et al. 2009).

The overall air quality impacts of a new nuclear power plant located at the Callaway site would 

be SMALL.

8.3.2 Surface Water Resources

Surface water would not be used to construct the nuclear power plant. During operations, 

surface water flowing through a closed-cycle system would be used to cool the new power 

plant. The volume of water required for cooling would be similar to the volume used by the 

existing Callaway Unit 1.

The new nuclear reactor alternative would withdraw approximately 28 mgd (106,000 m3

/day) of 

water for cooling, compared to the estimated 25 mgd (94,600 m3

/day) that is withdrawn by 

Callaway (Ameren 2011b). 

8-31
Environmental Impacts of Alternatives

During construction, runoff from construction areas and water discharged from the dewatering of 

excavations, if needed, would be controlled under a State-issued NPDES stormwater general 

permit for land disturbance (MDNR 2012b). The permit would require implementation of a 

stormwater pollution prevention plan and associated BMP to prevent or significantly mitigate soil 

erosion and contamination of soil, stormwater runoff, and groundwater by construction activities.

During operations, cooling water volume and discharge temperature and all surface water

quality impacts would be approximately the same as for the current Callaway facility. All effluent 

discharges and stormwater discharges associated with industrial activity would be subject to a 

state-issued NPDES permit under this alternative. The NRC further assumes that a new 

nuclear power plant would be operated in accordance with appropriate management plans with 

adherence to appropriate BMP and procedures to minimize the release of fuels, chemicals, and 

other materials to soil, surface water, and groundwater. 

Given the above, the NRC staff concludes that the impact on surface water quality and use from 

the construction and operation of the new nuclear power plant at the Callaway site would be 

SMALL.

8.3.3 Groundwater Resources

Construction activities associated with a new nuclear power plant would be expected to include 

the need to conduct groundwater dewatering. This is because of the extensive excavation that 

would be required for the nuclear island. Nevertheless, engineering measures, such as the use 

of cofferdams, sumps, wells, or other methods to address high water-table conditions, can be 

used to minimize impacts to facilitate construction. Facility construction would increase the 

amount of impervious surface at the site location and alter the subsurface strata because of 

excavation work and the placement of backfill following facility completion. While this could 

cause a localized decline in water-table elevation in surficial aquifers, if present, any such 

changes would likely be minor off site. Below-grade portions of the facility, particularly the 

containment structure, could alter the direction of groundwater flow, although such effects would 

likely be confined to the plant site. Finally, the application of BMP in accordance with a 

State-issued NPDES stormwater general permit (MDNR 2012b) would prevent or minimize any 

groundwater quality impacts during construction. 

Existing wells or replacement wells completed in the same aquifers currently used to support 

Callaway Unit 1 would likely be used to supply the relatively small amounts of water required for 

potable and sanitary uses, concrete production, dust suppression, and soil compaction. 

However, the amount of construction water consumed should be much less than the amount 

currently consumed by Callaway Unit 1 operations. Onsite water demands could be further 

reduced by the use of ready-mix concrete and the use of portable sanitary facilities that are 

serviced off site for construction workers. The GEIS (NRC 1996) has found that pumping rates 

of less than 100 gpm (380 L/min) have not been shown to adversely affect groundwater

availability. The new nuclear power plant would obtain potable water and water to lubricate the 

surface water pumps at the river intake structure from existing or replacement wells completed 

in the same aquifers currently used for water supply for Callaway. During operations, the rate of 

groundwater consumption should be about the same as for the existing Callaway facility. 

Consequently, the groundwater resources impact assessment presented in Section 4.4.2 of this 

SEIS applies to this alternative.

The NRC staff concludes that the impact of construction and operation of the new nuclear 

reactor at the Callaway site on groundwater use and quality would be SMALL.

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Environmental Impacts of Alternatives

8.3.4 Aquatic Ecology

The total water requirements for the new nuclear reactor would be greater than the surface 

water requirements for the current Callaway site. Therefore, potential impacts on aquatic 

organisms caused by impingement, entrainment, and thermal plumes could be greater than 

those described in Section 4.5 for Callaway Unit 1. 

The additional surface water withdrawal associated with the new nuclear reactor would result in 

additional adverse impacts on the Federally endangered pallid sturgeon associated with 

impingement and entrainment. A new nuclear reactor may have a larger thermal plume based 

on the additional water withdrawals. Based on the potential occurrence of the sturgeon and 

other threatened and endangered species at the Callaway site discussed in Section 2.2.7, 

consultation with the FWS under the ESA would be required for any alternative project. This 

consultation would ensure that construction and operation of the new nuclear reactor alternative 

would not adversely affect any Federally listed species or adversely modify or destroy 

designated critical habitat. Additionally, the staff relies on Ameren’s coordination with State 

natural resource agencies to ensure that Ameren would take appropriate steps to avoid or 

mitigate impacts on State-listed species, habitats of conservation concern, and other protected 

species and habitats. In addition, the staff relies on the State’s enforcement of the NPDES

stormwater general permit, which would require the use of the best available technology to 

minimize impacts associated with impingement and entrainment of aquatic organisms from the 

Missouri River, as well as require regular monitoring and mitigation measures, as necessary, to 

minimize any adverse thermal affects associated with a thermal plume.

Temporary impacts on surface waters may also occur during construction of the new nuclear 

reactor. However, the NRC concludes that the State’s enforcement of NPDES stormwater

general permits would prevent or significantly mitigate any impacts such as sediment loading 

from runoff from active construction sites.

Based on the above information, impacts on aquatic resources from the new nuclear reactor

alternative would be SMALL.

8.3.5 Terrestrial Ecology

Constructing the new nuclear reactor alternative would require approximately 588 ac (238 ha) of 

land. The NRC staff assumes that this alternative would use existing onsite structures and 

previously disturbed areas to the extent practicable to minimize new development in 

undisturbed areas. However, it is expected that some undisturbed areas would be affected, 

which would directly impact terrestrial resources. Onsite impacts may include habitat 

fragmentation and loss of food resources. Operation of the existing cooling towers would 

produce drift, which would result in some deposition of dissolved solids on surrounding 

vegetation and soil from cooling-tower drift; these impacts would be similar to or slightly more 

than the current operating impacts due to the higher water consumption of the new nuclear 

reactor alterative. Depending on the location of new infrastructure in undisturbed areas, 

threatened and endangered species may also be affected. Based on the potential occurrence 

of threatened and endangered species at the Callaway site discussed in Section 2.2.8, species 

that could potentially be affected include the gray bat, Indiana bat, running buffalo clover, bald 

eagle, eastern hellbender, and northern harrier. Consultation with the FWS under the ESA

would be required during the development of a new nuclear reactor to ensure that construction 

and operation of this alternative would not adversely affect any Federally listed species or 

adversely modify or destroy designated critical habitat. The staff relies on Ameren’s 

coordination with State natural resource agencies to ensure that Ameren would take appropriate 

8-33
Environmental Impacts of Alternatives

steps to avoid or mitigate impacts on State-listed species, habitats of conservation concern, and 

other protected species and habitats.

Development outside the existing plant footprint for any new onsite structures would impact the 

Reform Conservation Area. Since the existing lease agreement between Ameren and the MDC

restricts development within the Reform Conservation Area, any such development would 

require a revision to the existing lease agreement. If permitted under a revised lease 

agreement, impacts would include a loss of natural habitats to an extent commensurate with the 

reduction in size of the overall natural resources management area.

Based on this information, impacts on terrestrial resources would range from SMALL to 

MODERATE.

8.3.6 Human Health

Human health effects of a new nuclear reactor would be similar to those of the existing Callaway 

facility. Human health issues related to construction would be equivalent to those associated 

with the construction of any major complex industrial facility and would be controlled to 

acceptable levels through the application of BMP and Ameren’s compliance with applicable 

Federal and State worker protection regulations. 

Human health impacts from operation of the nuclear reactor alternative would be equivalent to 

those associated with continued operation of the existing reactor under license renewal. In 

summary, and as discussed in Section 4.8 of this SEIS:

 There was no measurable radiation dose contribution caused by current plant 

operations outside the Callaway controlled area or inside the controlled area 

in locations accessible to members of the public.

 The results of Callaway’s environmental monitoring program have not 

indicated any measurable impacts to the air, surface water, groundwater, 

milk, soil, sediment, fish, vegetable crop, and vegetation pathways at 

indicator monitoring stations.

 The radiological doses to members of the public from radioactive effluents for 

the years 2006 through 2011 complied with Federal radiation protection 

standards.

 There have been no known occurrences of thermophilic microorganisms 

associated with the potential discharge of heated effluent to the Missouri 

River.

 All of the Callaway transmission lines conform to the NESC’s electrical shock 

standard of inducing no more than 5 milliamps.

 The GEIS’s finding of UNCERTAIN regarding the potential effects of chronic 

exposure to electromagnetic fields from power lines remains appropriate until 

further studies indicate otherwise.

Based on this information, the staff concludes that the human health impacts from construction 

and operation of a new nuclear plant would be SMALL.

8.3.7 Land Use 

As discussed in Section 8.1.7, the GEIS generically evaluates the impacts of constructing and 

operating various replacement power plant alternatives on land use, both on and off each power 

plant site. The analysis of land use impacts focuses on the amount of land area that would be 

8-34
Environmental Impacts of Alternatives

affected by the construction and operation of a nuclear power plant at the Callaway site. 

Locating the new nuclear power plant at the Callaway site would maximize the availability of 

support infrastructure and reduce the need for additional land.

Approximately 588 ac (238 ha) of land would be required to construct and operate a new 

nuclear power plant. Locating the new nuclear power plant adjacent to an existing nuclear 

power plant would mean that the majority of the affected land area would already be zoned for 

industrial use. Siting the new reactor on the existing Callaway site would also take advantage of 

existing infrastructure, as there is sufficient buildable land available on the site. Locating the 

new reactor at or near an existing nuclear power plant site also means that local residents are 

already accustomed to living near a nuclear power plant. Land use impacts from constructing a 

new reactor at the Callaway plant site would be SMALL.

The amount of land required to mine uranium and fabricate nuclear fuel during rector operations 

would be similar to the amount of land required to support Callaway, although an additional 

amount of land for mining would be required during the license renewal term. Impacts 

associated with uranium mining and fuel fabrication to support the new nuclear alternative would 

generally be no different than those currently occurring in support of the existing Callaway 

Unit 1. Overall land use impacts from nuclear power plant operations at the Callaway plant site 

could range from SMALL to MODERATE.

8.3.8 Socioeconomics

As previously explained in Section 8.1.8 for the NGCC alternative, the number of jobs created 

by construction and operation of a replacement power plant could affect regional employment, 

income, and expenditures. Two types of jobs would be created by this alternative: 

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

socioeconomic impact, and (2) power plant operations jobs, which have a greater potential for 

permanent, long-term socioeconomic impacts.

Scaling from GEIS estimates, the construction workforce would peak at 2,400 to 6,600 workers. 

Ameren’s estimate of 3,950 workers during the peak construction period (Ameren 2011b) falls 

within this range and appears to be reasonable.

The relative economic impact of this many construction workers on the local economy and tax 

base would vary, with the greatest impacts occurring in the communities where a majority of 

construction workers would reside and spend their income. As a result, local communities could 

experience a short-term “boom” from increased tax revenue and income generated by 

construction expenditures and the increased demand for temporary (rental) housing and 

business services. Some construction workers could relocate to be closer to the construction 

work site. However, since Callaway is located near the Columbia, Jefferson, and St. Louis 

metropolitan areas, workers could commute to the construction site, thereby reducing the need 

for rental housing. After completing the installation of the new nuclear power plant, local 

communities could experience a return to preconstruction economic conditions. Based on this 

information and given the number of workers, socioeconomic impacts during construction in 

local communities could range from SMALL to LARGE.

Scaling from GEIS estimates, the power plant operations workforce would be 270 to 

360 workers. Ameren’s estimated operations workforce of 363 workers (Ameren 2011b) 

appears to be reasonable. The operations workforce for the new nuclear power plant would be 

smaller than the current operating workforce at Callaway. A number of reactor operations 

workers would likely include some of the 860 workers from Callaway. The amount of property 

taxes paid under the new nuclear alternative may increase if additional land is required to 

support this alternative. However, a reduction in total employment at Callaway could affect 

8-35
Environmental Impacts of Alternatives

property tax revenue and income in local communities and businesses. In addition, the 

permanent housing market could also experience increased vacancies and decreased prices if 

Callaway operations workers and their families move out of the region. Therefore, 

socioeconomic impacts during new reactor operations could range from SMALL to MODERATE 

as the Callaway site transitions to the new reactor.

8.3.9 Transportation

Commuting workers and truck deliveries of materials and equipment to the Callaway site would 

cause transportation impacts during the construction and operation of a new nuclear power 

plant. During periods of peak construction activity, approximately 2,400 to 6,600 workers could 

be commuting daily to the site. Workers commuting to the construction site would arrive by site 

access roads, and the volume of traffic on nearby roads could increase substantially during shift 

changes. In addition to commuting workers, trucks would transport construction materials and 

equipment to the work site, increasing the amount of traffic on local roads. The increase in 

vehicular traffic would peak during shift changes, resulting in temporary levels of service 

impacts and delays at intersections. Some plant components and materials could also be 

delivered by train using a new rail line or spur to the Callaway site, as described in Section 8.2. 

Train deliveries could cause additional traffic delays at railroad crossings. Traffic-related 

transportation impacts during construction could range from MODERATE to LARGE.

Traffic-related transportation impacts on local roads would be greatly reduced after completion 

of the power plant. Transportation impacts would include daily commuting by the operating 

workforce, equipment and materials deliveries, and the removal by truck of commercial waste 

material to offsite disposal or recycling facilities. As noted in Section 8.3.8, an estimated 270 to 

360 workers would be needed to operate the new nuclear plant, less than the current operating 

workforce at Callaway. Overall, transportation impacts would be SMALL during new nuclear 

power plant operations.

8.3.10 Aesthetics and Noise

The analysis of aesthetic impacts focuses on the degree of contrast between the new nuclear 

power plant and the surrounding landscape and the visibility of the new units at the existing 

Callaway Plant site. Visual impacts would be consistent with the industrial nature of the power 

plant site. The new nuclear power plant would look very similar to the existing nuclear power 

plant. During construction, all of the clearing and excavation would occur on site. These 

activities may be visible from offsite roads. Since the existing power plant site already appears 

industrial, construction of the new nuclear power plant would appear similar to other ongoing 

onsite activities. In addition to the cooling towers, other onsite visible structures would include 

the boiler and turbine buildings and exhaust stacks.

Since much of the existing infrastructure would remain in use, the Callaway Plant site, even with 

the addition of a new nuclear reactor would appear unchanged. However, the Callaway Plant 

site would appear larger due to the expanded size of the facility footprint. Aesthetic impacts 

would range from SMALL to MODERATE during plant construction and would be SMALL during 

plant operations.

Noise generated during power plant operations would mostly be limited to routine industrial 

processes and communications. The natural draft cooling tower would also generate noise. 

Noise impacts from the new nuclear power plant would be similar to the noise produced by the 

existing Callaway Plant Unit 1 and SMALL.

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Environmental Impacts of Alternatives

8.3.11 Historic and Archeological Resources

The potential for impacts on historic and archaeological resources from the new nuclear 

alternative would vary greatly, depending on the location of the proposed reactor at Callaway, 

because of the high potential for discovery of additional historic and archaeological resources. 

Any construction on the Callaway site would need to avoid the previously identified 25 eligible or 

potentially eligible historic properties. Alternative reactor locations and associated corridors of 

new construction at Callaway would need to be surveyed and inventoried for potential 

resources. Resources found by these surveys would need to be evaluated for eligibility on the 

NRHP, and mitigation of adverse effects would need to be addressed if eligible resources were 

encountered. The level of impact at these locations would vary, depending on the specific 

resources found to be present in the APE. However, given that the preference is to use 

previously surveyed and/or disturbed areas and portions of the site have been previously 

identified as not containing significant resources, avoidance of historic and archaeological 

resources should be possible and effectively managed under current laws and regulations. 

Therefore, the impacts on historic and archaeological resources from the new nuclear 

alternative would be SMALL.

8.3.12 Environmental Justice 

This analysis evaluates the potential for disproportionately high and adverse human health, 

environmental, and socioeconomic effects on minority and low-income populations that could 

result from construction and operation of a new nuclear reactor. As previously discussed in 

Section 8.1.12, such effects may include human health, biological, cultural, economic, or social 

impacts.

Potential impacts to minority and low-income populations would mostly consist of environmental 

and socioeconomic effects during construction (e.g., noise, dust, traffic, and housing impacts). 

Noise and dust impacts during construction would be short term and primarily limited to onsite 

activities. Minority and low-income populations residing along site access roads would be 

directly affected by increased commuter vehicle and truck traffic. However, because of the 

temporary nature of construction, these effects are not likely to be high and adverse and would 

be contained to a limited time period during certain hours of the day. Increased demand for 

rental housing during construction could cause rental costs to rise, disproportionately affecting 

low-income populations living near Callaway who rely on inexpensive housing. However, given 

the proximity of the site to the Columbia, Jefferson City, and St. Louis metropolitan areas, 

workers could commute to the construction site, thereby reducing the need for rental housing.

Potential human health and environmental effects from nuclear power plant operations would be 

similar to those of the existing Callaway Plant Unit 1. Radiation doses from the new nuclear 

power plant are expected to be well below regulatory limits. The staff expects permitted air 

emissions to remain within regulatory standards. Accordingly no adverse impacts with respect 

to radiation dose or air emissions are expected. Given the distribution and concentration of 

minority and low-income populations in the vicinity of the site, no disproportionate impacts are 

expected.

Based on this information and the analysis of human health and environmental impacts 

presented in Section 8.3 of this EIS, the construction and operation of a new nuclear power 

plant would not have disproportionately high and adverse human health and environmental 

effects on minority and low-income populations residing in the vicinity of the Callaway site.

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Environmental Impacts of Alternatives

8.3.13 Waste Management

During the construction phase of this alternative, land clearing and other construction activities 

would generate waste that could be recycled, disposed of on site, or shipped to an offsite waste 

disposal facility. Construction-related wastes would be solid, liquid, or gaseous, and some 

would require management, treatment, and disposal as hazardous wastes. Various permits, 

issued by State or local authorities, would control the disposition of all construction-related 

wastes. Because this alternative would be constructed on the previously disturbed Callaway 

site, the amounts of wastes produced during land clearing would be minimal.

During the operational stage, normal plant operations, routine plant maintenance, and cleaning 

activities would generate nonradioactive and radioactive waste comparable to those at the 

existing Callaway Unit 1.

According to the GEIS (NRC 1996), the generation and management of solid nonradioactive 

and radioactive waste during the terms of an extended license are not expected to result in 

significant environmental impacts. A new nuclear plant would generate waste streams similar to 

those at a nuclear plant that has undergone license renewal. The workforce would be smaller 

than the current operating workforce for Callaway, so a new nuclear reactor alternative would 

result in a reduction in domestic and sanitary wastes. Based on this information, the waste 

impacts of a new reactor at Callaway would be SMALL.

8.4 Combination Generation

This section evaluates the environmental impacts of a combination alternative. The MDNR wind 

evaluations predict that Callaway County would have very little or no area with an average 

annual wind speed of 13.6 miles per hour (mph) (6.0 meters per second (m/s)) or greater as is 

typical for development of wind projects (MDNR 2012a). Consequently, this combination 

includes a portion of the replacement power baseload supplied by the NGCC capacity identified 

in Section 8.1, a wind power component, and an energy efficiency component. The NGCC and 

energy efficiency combination would be supplemented by wind, when available.

The wind component of the combination alternative would be located in one or more areas of 

Missouri with the appropriate wind profile, but not on the existing site. Wind capacity in Missouri 

increased from 0 to 459 MW from 2006 to 2011 (DOE 2012a). NRC staff estimates an 

additional 300 MW of wind capacity would be reasonably available by 2024. The wind portion of 

the combination alternative would also require interconnection to the transmission grid and a 

transmission line. The location of the grid interconnection would depend on the location of the 

wind facility(s) and available transmission capacity. 

The NRC staff estimates that construction of 188 1.6-MW turbines would temporarily disturb 

519 ac (210 ha) of land, of which approximately 222 ac (90 ha) would be permanently occupied 

by the turbine foundations, access roads, and electrical collection and transmission system. 

Ameren’s Integrated Resource Plan (Ameren 2011a) evaluated several scenarios of energy 

efficiency potential through 2030. For the 2025 time frame, Ameren’s evaluation identified 

331 MW of energy efficiency capacity in the business-as-usual case, and 846 MW in the 

realistically achievable case. The difference between these two scenarios is 515 MW. NRC 

estimates that 25 percent of this energy efficiency potential, or about 130 MW, would 

reasonably offset baseload demand in 2024.

The NRC staff estimated the capacity of the NGCC component of the combination alternative by 

assuming 130 MW of energy efficiency and 300 MW of wind with a 35 percent capacity factor 

(or 105 MW). Therefore, the NGCC component would represent the remaining 951 MW of the 

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Environmental Impacts of Alternatives

combination alternative’s net capacity of 1,186 MW. The size, impacts, and appearance of a 

natural gas-fired facility would be similar to the full-scale NGCC alternative considered in 

Section 8.1. All construction and operation effects would scale accordingly.

Table 8–5 summarizes the key operating parameters for the 1,186-MW combination alternative 

as estimated by the NRC staff.

Table 8–5. Characteristics of 1,186-MW Combination Alternative

Energy 

Source

Heat Rate 

(Btu/

kWh)

Land 

Requirement (ac) (a) (b)

Water 

Requirement 

(mgd) (a) (b)

Peak 

Construction 

Work Force(a)

Operations 

Work 

Force(a)

NGCC 7,639 171 5.5 1,141 48–71

Wind N/A 519 (temporary)

222 (permanent) Negligible 210–300 18–24

Energy 

Efficiency N/A N/A N/A N/A N/A

(a) Values scaled from Table 8–1 

(b) To convert acres (ac) to hectares (ha), multiply by 0.4047. To convert million gallons per day (mgd) to cubic 

meters (m3

) per day, multiply by 3,785.

Key:

ac = acres; BTU = British thermal units; kWh = kilowatt hours; mgd = million gallons per day

8.4.1 Air Quality

Section 8.1.1 discusses the various State and Federal regulations that would control the 

construction and operation of an NGCC plant. Although the NGCC facility of this alternative has 

approximately 80 percent of the rated capacity of the discrete NGCC alternative discussed in 

Section 8.1 (951 MW compared to 1,186 MW), the same regulatory controls would apply to air 

emissions.

Using data and algorithms published by EPA and the EIA and performance guarantees provided 

by pollution control equipment vendors, the NRC staff projects the following emissions for a 

951-MW NGCC facility to partially replace the capacity of Callaway:

 sulfur oxides: 92 tons (83 MT) per year,

 nitrogen oxides: 268 tons (242 MT) per year,

 carbon monoxide: 405 tons (368 MT) per year,

 PM10: 179 tons (162 MT) per year,

 PM2.5: 179 tons (162 MT) per year, and

 carbon dioxide: 2.98 million tons (2.70 MMT) per year.

Sulfur oxides, nitrogen oxides, carbon monoxide, and particulate matter emissions during 

operation would be noticeable. Air quality impacts resulting from operation of the NGCC portion 

would be SMALL to MODERATE.

8.4.1.1 Construction Impacts

Air quality impacts, including GHG emissions, from construction of the NGCC portion of this 

combination alternative would be similar to those described in Section 8.1.1.5. The slightly 

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Environmental Impacts of Alternatives

smaller facility required for this alternative would not have a significantly smaller footprint and 

would thus impact approximately the same amount of land area and require only slightly less 

time to construct. Gas fired power plants are constructed relatively quickly, construction lead 

times for NGCC plants are around 2 to 3 years (EIA 2011b; OECD/IEA 2005).

For the wind farm portion of this alternative, construction activities that could impact air quality 

include vehicle traffic from workers and equipment; construction of access roads; removal of 

vegetative cover; construction of laydown areas, staging areas, and pads; and concrete pouring 

for buildings and tower foundations. Construction activities also would generate fugitive dust 

from vehicle travel; the movement, transport, and stockpiling of soils; concrete batching; drilling; 

and pile driving. The use of worker and delivery vehicles, operation of ancillary construction 

equipment, construction of onsite buildings and electrical substations, and installation of 

electrical interconnections among turbines would also produce emissions. These activities 

would be temporary and would cease once construction is complete. The construction of wind 

farms can take about 1 year (NREL 2006). GHGs would be produced during construction of the 

wind farm portion of this alternative. Without a detailed construction plan, however, it is not 

possible to meaningfully estimate total emissions. The emissions would come mainly from the 

exhausts of construction equipment, vehicles used by the commuting workforce, and from 

trucks used to deliver construction materials and components. The overall air quality impacts 

associated with construction of the wind portion of the combination alternative would be SMALL.

8.4.1.2 Additional Operating Impacts

EPA reported that, in 2010, the total amount of CO2e emissions related to electricity generation 

was 2,277.3 teragrams (2,277.3 MMT) (EPA 2012a). The EIA reports that, in 2010, electricity 

production in Missouri was responsible for 78,815 thousand MT (78.8 MMT), or 3.46 percent of 

the national total (EIA 2012b). The NRC staff estimates that uncontrolled CO2e emissions from 

operation of the NGCC portion of this combination alternative would amount to 2.98 million tons 

(2.70 MMT) per year. This amount represents 0.12 percent and 3.4 percent, respectively, of 

2010 U.S. and Missouri CO2e emissions. Assuming that CCS controls were required in the 

future and 90 percent of the carbon dioxide in the exhaust could be removed (NETL 2007), the 

NGCC facility would release 0.27 MMT of CO2e emissions per year.

Although natural gas combustion in the combustion turbines would be the primary source of 

GHGs during operation, other miscellaneous ancillary sources—such as truck and rail deliveries 

of materials to the site and commuting of the workforce—would make minor contributions. The 

impacts from ancillary activities during operation of the NGCC portion would be SMALL.

Impacts on air quality from the operation of the wind turbines themselves would be insignificant. 

There could be minor VOC emissions during routine changes of lubricating fluids and greases. 

Fugitive dust from road travel, vehicular exhaust, and brush clearing, in addition to the tailpipe 

emissions associated with vehicle travel, would occur during operations. However, all these 

activities would have limited scope and should have no significant impact on air quality. Overall, 

air quality impacts associated with operation of the wind farm portion of the combined 

alternative would be SMALL. No GHG emissions are released during operation of a wind 

turbine; however, negligible amounts would be released from the vehicles used to transport 

maintenance personnel throughout the operating lives of either facility. Therefore, negligible 

impacts on climate are expected.

The overall air quality impacts of a combination alternative at the Callaway site would be SMALL 

to MODERATE.

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Environmental Impacts of Alternatives

8.4.2 Surface Water Resources

Impacts on surface water resources from constructing and operating a new NGCC plant as part 

of a combination alternative would be similar to, but generally less than, those described in 

Section 8.1.2 because the NGCC component has been scaled back to 951 MW. Impacts would 

be SMALL. 

The energy efficiency component of the alternative would not impact surface water use or 

quality. Impacts on surface water use and quality would be SMALL.

For wind farm installation, construction impacts on surface water quality could include increased 

sediment in stormwater flowing across or from active construction areas and the incidental 

release of various fuels and chemicals. Runoff from construction areas and water discharged 

from dewatering of excavations, if needed, would be controlled under a State-issued NPDES

stormwater general permit for land disturbance (MDNR 2012b). The permit would require 

implementation of a stormwater pollution prevention plan and associated BMP to prevent or 

significantly mitigate soil erosion and contamination of soil, stormwater runoff, and groundwater

by construction activities.

Small amounts of water would be required during the construction phase for each of the wind 

turbines. Water would be used for dust suppression and compaction during site clearing and for 

concrete production for pad and piling construction, as appropriate. Although surface water

from nearby water bodies, or from groundwater, may be used for pad site construction at some 

locations, it is likely that water would be procured from offsite sources and trucked to the point of 

use on an as-needed basis. The use of ready-mix concrete would also reduce the need for 

onsite use of nearby water sources.

The installation of land-based wind turbines would also require installation of access roads and 

possibly transmission lines, especially for turbine sites not proximate to transmission line 

corridors. Access road construction would also require some water for dust suppression and 

roadbed compaction and would have the potential to result in soil erosion and stormwater runoff

from cleared areas. Water would likely be trucked to the point of use from offsite locations 

along with road construction materials. Construction activities would be conducted in 

accordance with State-issued NPDES general stormwater permits for stormwater discharges 

associated with construction activity, which would require the implementation of appropriate 

BMP to prevent or mitigate water quality impacts.

The combination alternative would withdraw approximately 5.5 mgd (20,812 m3

/day) of water for 

NGCC power plant cooling, compared to the 25 mgd (94,600 m3

/day) that is withdrawn by 

Callaway (Ameren 2011b). It is expected that use of the existing intake and discharge

infrastructure on the Missouri River would be sufficient to support the NGCC plant. Surface 

water withdrawals would be subject to, and would remain well within, Callaway’s existing 

permits. Effluent discharges and stormwater discharges associated with industrial activity would 

be subject to a new or revised State-issued NPDES permit under this alternative. To support 

operations of individual wind turbine installations, very small amounts of water would be used to 

periodically clean turbine blades and motors as part of routine servicing. It would be expected 

that water would be procured from nearby sources and trucked to the point of use. Adherence 

to appropriate waste management and minimization plans, spill prevention practices, and 

pollution prevention plans during servicing of wind turbine installations would minimize the risks 

to soils and surface water resources from spills of petroleum, oil, and lubricant products and 

runoff. 

As a result, impacts on surface water use and quality from construction and operation of the 

components of the combination alternative would be SMALL.

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Environmental Impacts of Alternatives

8.4.3 Groundwater Resources

Impacts on groundwater resources from constructing and operating a new NGCC plant as part 

of a combination alternative would be similar to but generally less than those described in 

Section 8.1.3. Impacts would be SMALL. 

The energy efficiency component of the alternative would not impact groundwater use or quality. 

Impacts on groundwater use or quality would be SMALL.

For the wind farm portion, construction activities are expected to have minimal, or no, impact on 

groundwater quantity and quality. For all construction activities, appropriate BMP, including spill 

prevention practices, would be used during wind turbine construction to prevent or minimize 

impacts on groundwater quality. Very little water would be used during operation, as no water is 

required for cooling purposes. No impacts on groundwater are expected during wind farm 

operation. 

Overall, impacts on groundwater quantity and quality under the combination alternative would 

be SMALL.

8.4.4 Aquatic Ecology

The combination alternative would require less cooling water to be withdrawn from the Missouri 

River than is currently withdrawn by the existing Callaway facility; the thermal discharge also 

would be smaller. Therefore, the number of fish and other aquatic organisms affected by 

impingement, entrainment, and thermal impacts would be less than those associated with the 

license renewal. Temporary impacts on surface waters would result from construction of the 

NGCC portion and from construction of the new wind farms and related infrastructure. These 

impacts should be minimized through Ameren’s compliance with applicable water quality 

permits, such as the NPDES stormwater general permits.

Based on this information, the NRC expects that any adverse impacts on aquatic ecology 

associated with the combination alternative would be SMALL.

8.4.5 Terrestrial Ecology

A combination alternative consisting of an NGCC facility, a wind energy component, and an 

energy conservation and efficiency component would make use of existing disturbed land at the 

Callaway site for the natural gas-fired units but would require additional land off site to 

accommodate the wind turbines and related infrastructure. Since the size of the NGCC facility 

would be similar to that of the full NGCC plant alternative considered in Section 8.1, 

construction and operation impacts on terrestrial resources would be SMALL, as described in 

Section 8.1.5.

The NRC estimates that construction of 188 wind turbines would temporarily disturb 

approximately 519 ac (210 ha) of land, of which approximately 222 ac (90 ha) would be 

permanently occupied by the turbine foundations, access roads, and electrical collection and 

transmission system. This does not include the land required for the transmission line to 

connect the wind farm to the transmission grid, which would vary based on the location of the 

turbines and proximity to existing transmission line infrastructure. Impacts from construction of 

the wind farm portion of the combination alternative would include loss of terrestrial habitat and 

habitat fragmentation. It is expected that the wind turbines would be sited in open habitats 

(e.g., cropland, grassland, etc.) to reduce terrestrial impacts to the extent practicable. 

Construction of transmission lines may require clearing of forested land. Proper siting of the 

wind farm would reduce direct impacts on birds because of bird strikes. However, given the 

8-42
Environmental Impacts of Alternatives

number of turbines associated with the wind farm, some bird mortality would likely occur. There 

would also be potential disruption of migratory bird routes during seasonal migration periods. 

Consultation with the FWS under the ESA would ensure that construction and operation of the 

combination alternative would not adversely affect any Federally listed species or adversely 

modify or destroy designated critical habitat. Ameren’s coordination with State natural resource 

agencies would help ensure that Ameren would take appropriate steps to avoid or mitigate 

impacts on State-listed species, habitats of conservation concern, and other protected species 

and habitats. Because impacts from the wind farm portion of this alternative could vary widely 

based on location, impacts on terrestrial resources from construction and operation of the wind 

farm would be SMALL to MODERATE.

The conservation and efficiency component of the combination alternative would have no 

impacts on terrestrial ecology.

Overall, the impacts to terrestrial resources from the combination alternative would be SMALL to 

MODERATE.

8.4.6 Human Health

Human health impacts of the slightly smaller NGCC power plant under this alternative would be 

proportionally the same as those for the NGCC plant discussed in Section 8.1.6 and would be 

SMALL.

Human health issues related to construction would be equivalent to those associated with the 

construction of any major complex industrial facility and would be controlled to acceptable levels 

through the application of BMP and Ameren’s compliance with applicable Federal and State 

worker protection regulations.

There are concerns that operation of wind turbines could affect the health of individuals living 

near a wind development project. Potential impacts include low-frequency noise, turbine blade 

shadowing, and blade flicker. The extent of these impacts on human health has not been 

verified by clinical studies; however, since most wind farms would be expected to be located in 

remote areas, and since all such impacts would be expected to significantly decline with 

distance, very few members of the general population, if any, would be impacted. Turbines also 

could cause safety hazards to nearby airports and may interfere with radar operations. Overall, 

health risks to workers and members of the public from construction and operation of the wind 

farm components under this alternative would be SMALL.

8.4.7 Land Use

As discussed in Section 8.1.7, the GEIS (NRC 1996) generically discusses the impact of 

constructing and operating various replacement power plant alternatives on land use, both on 

and off each power plant site. The analysis of land use impacts here focuses on the amount of 

land area that would be affected by the construction and operation of a combination of NGCC 

power plant at Callaway, wind farms, and energy efficiency.

The footprint of the NGCC portion of the combination alternative would be smaller than the 

footprint of the NGCC facility discussed in Section 8.1.7. A new 951-MW NGCC plant would 

require approximately 171 ac (69 ha) of land and could be constructed largely within the existing 

developed industrial footprint of the Callaway site. This amount of land use would include other 

plant structures and associated infrastructure. Similar to the NGCC replacement alternative 

considered in Section 8.1.7, additional land would be needed for a new 12-mi (19-km) natural

gas supply pipeline. In addition to onsite land requirements, land would be required off site for 

natural gas wells and collection stations. Scaling from GEIS estimates, approximately 3,400 ac 

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Environmental Impacts of Alternatives

(1,400 ha) (based on 3,600 ac per 1,000 megawatts electric (MWe) and 951 MWe for NGCC) 

(NRC 1996) would be required for wells, collection stations, and pipelines to bring the gas to the 

plant. Most of this land requirement would occur on land where gas extraction already occurs. 

Therefore, land use impacts from the construction and operation of the NGCC portion of this 

combination alternative at the Callaway site could range from SMALL to MODERATE.

As a part of this alternative, approximately 188 1.6-MW wind turbines would be constructed on 

519 ac (210 ha) of land. During operation, an estimated 222 ac (90 ha) of this land would be 

permanently occupied by turbine foundations, access roads, the electrical collection system, 

and the transmission line. Most of the wind turbines would likely be located on open cropland, 

which would remain largely unaffected by the presence of the wind turbines. Since wind 

turbines require ample spacing between one another to avoid air turbulence, the size of the 

wind farm can be quite large. However, during operations, only 5 to 10 percent of the total 

acreage within a wind farm is actually occupied by turbines, access roads, support buildings, 

and associated infrastructure, while the remaining land area can be returned to its original 

condition or some other compatible use, such as farming or grazing.

Delivery of heavy and oversized wind turbine components would also require the construction of 

temporary site access roads, some of which may require a circuitous route to their destination. 

However, once construction is completed, many temporary access roads can be reclaimed and 

replaced with more direct access to the wind turbines for maintenance purposes. Likewise, land 

used for equipment and material laydown areas, turbine assembly, and installation could be 

returned to its original state. Overall, land use impacts from construction and operation of the 

new wind farms would range from SMALL to MODERATE.

The elimination of uranium fuel for Callaway could partially offset offsite land requirements for 

other energy projects. Scaling from GEIS estimates, approximately 2,400 ac (960 ha) would no 

longer be needed for the mining and processing of uranium.

The land use impacts of the Energy Efficiency and Conservation Program would be minimal. 

The rapid replacement and disposal of older inefficient appliances and other equipment would 

generate waste material and could increase the size and need to construct new landfills; 

however, given the time for program development and implementation, the cost of 

replacements, and the average life of equipment, the replacement process would probably be 

gradual. More efficient appliances and equipment would replace older equipment (especially in 

the case of frequently replaced items, such as light bulbs). In addition, many items (such as 

home appliances and industrial equipment) have recycling value and would not be disposed of 

in landfills. Therefore, land use impacts from the combination alternative could range from 

SMALL to MODERATE.

8.4.8 Socioeconomics

As previously explained in Section 8.1.8, two types of jobs would be created by this alternative: 

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

socioeconomic impact, and (2) operations jobs, which have the greater potential for permanent, 

long-term socioeconomic impacts. Workforce requirements for the construction and operation 

of the combination alternative were evaluated to measure their possible effects on current 

socioeconomic conditions.

Socioeconomic impacts associated with construction and operation of the smaller NGCC power 

plant under this combination alternative would be less than those described for the NGCC 

alternative in Section 8.1 due to the smaller power plant. Based on GEIS estimates, the NGCC 

power plant would require a construction workforce of approximately 1,400 workers 

(NRC 1996). The relative economic impact of this many workers on the local economy and tax 

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Environmental Impacts of Alternatives

base would vary, with the greatest impacts occurring in the communities where the majority of 

construction workers would reside and spend their income. As a result, local communities could 

experience a short-term economic “boom” from increased tax revenue and income generated by 

construction expenditures and the increased demand for temporary (rental) housing and 

business services. Some construction workers could relocate in order to be closer to the 

construction work site. However, given the proximity of Callaway to the Columbia, 

Jefferson City, and St. Louis metropolitan areas, workers could commute to the construction 

site, thereby reducing the need for rental housing. Based on this information and given the 

number of construction workers, socioeconomic impacts during construction in local 

communities could range from SMALL to MODERATE.

Neither Ameren nor the GEIS (NRC 1996) provide estimates of the construction workforce for 

the wind portion of the combination alternative. However, according to the National Renewable 

Energy Laboratory (NREL), between 70 and 100 construction jobs are created per 100 MW of 

installed wind (NREL 2012). Scaling from these estimates, between 210 and 300 construction 

workers would be required for installation of a 300-MW wind portion of the combination 

alternative. Similar to the NGCC portion of this alternative, the relative economic impact of wind 

farm construction workers on the local economy and tax base would vary, with the greatest 

impacts occurring in the communities where the majority of construction workers would reside 

and spend their income. Some wind farm construction workers could relocate to be near the 

construction work site. However, given the proximity of the site to Akron and Cleveland, 

workers could commute to the construction site, thereby reducing the need for rental housing. 

Because the workforce for wind energy development projects is generally small, it is expected 

that associated socioeconomic impacts would be minor. After construction, local communities 

may be temporarily affected by the loss of construction jobs and associated loss in demand for 

business services. However, these effects would likely be spread over a larger area, as the 

wind farms may be constructed in more than one location. Based on this information, the 

combined overall socioeconomic impacts of construction under the combination alternative 

could range from SMALL to MODERATE, due to overlapping effects should more than one 

construction activity occur within the same area.

Based on GEIS estimates, the NGCC power plant would require an operations workforce of 

approximately 140 workers (NRC 1996). For a 100-MW wind farm, between six and eight 

operational jobs are created (NREL 2012); therefore, for the 300-MW wind portion of the 

combination alternative, between 18 and 24 operational jobs would be created. The relative 

economic impact of this many workers on local communities and the tax base would be SMALL.

The net reduction in employment at Callaway could affect property tax revenue and income in 

local communities and businesses. Implementing this alternative would also result in the net 

loss of approximately 700 relatively high-paying jobs at Callaway, with a corresponding 

reduction in purchasing activity and tax contributions to the regional economy. In addition, the 

permanent housing market could also experience increased vacancies and decreased prices if 

operations workers and their families move out of the region. However, the amount of property 

taxes paid under the combination alternative may offset some of the lost tax revenues in the 

socioeconomic region around Callaway. Also, as noted in the GEIS, an Energy Conservation 

and Efficiency Program would create jobs (NRC 1996). Overall, socioeconomic impacts under 

the combination alternative would range from SMALL to MODERATE because of the small 

number of operations workers required to operate each component of this combination 

alternative and because of the reduction in employment at Callaway and the potential overall 

net reduction of tax revenue from this combination alternative.

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Environmental Impacts of Alternatives

8.4.9 Transportation

Transportation impacts during the construction and operation of the NGCC component of this 

combination alternative would be less than the impacts for the NGCC alternative discussed in 

Section 8.1.9. This is because the construction workforce and the volume of material and 

equipment needing to be transported to the construction site would be less than the standalone 

alternative. In addition, the transportation impacts of this combination alternative would be 

spread out over a wider area.

Nevertheless, construction and operation of an NGCC power plant at Callaway and wind farms 

would increase the number of vehicles on the roads near these facilities. During construction, 

cars and trucks would deliver workers, materials, and equipment to the work sites. The 

increase in vehicular traffic would peak during shift changes, resulting in temporary 

level-of-service impacts and delays at intersections. Transportation of heavy and oversized 

wind turbine components could have a noticeable impact on traffic and transportation, but such 

impacts are likely to be spread over a large area. Some components and materials could also 

be delivered by train or barge, depending on location. Train deliveries could cause additional 

traffic delays at railroad crossings. Pipeline construction and modification of existing natural gas 

pipeline systems could also have impacts on traffic or transportation. Based on this information, 

traffic-related transportation impacts during construction could range from SMALL to 

MODERATE, depending on the location of the wind farm sites, current road capacities, and 

average daily traffic volumes.

During operation of the NGCC plant and wind farm components, transportation impacts would 

be less noticeable. In addition, wind energy project operation workers would be spread across 

the service region, and any traffic related transportation effects from the energy efficiency 

alternative would also be widely distributed. Therefore, given the relatively small number of 

operations workers at these facilities, the level-of-service traffic impacts on local roads during 

operations would be SMALL.

8.4.10 Aesthetics and Noise

The analysis of aesthetic impacts focuses on the degree of contrast between the NGCC and 

wind components of the combination alternative and surrounding landscapes and the visibility of 

the new NGCC plant at Callaway and wind turbines. In general, aesthetic impacts would be 

limited to the immediate vicinity of the NGCC site and wind farms. However, wind turbines 

would have the greatest visual impact.

Aesthetic impacts from the NGCC portion of the combination alternative would be essentially 

the same as those described for the NGCC alternative in Section 8.1.10. Power plant 

infrastructure would be generally smaller and less noticeable than the Callaway Unit 1 

containment and turbine buildings. Cooling towers would continue to generate condensate 

plumes and operational noise. Noise during power plant operations would be limited to 

industrial processes and communications. In addition to the power plant structures, 

construction of natural gas pipelines would have temporary visual and noise impacts. Noise 

from the pipelines may be audible off site near gas compressor stations. In general, aesthetic

and noise impacts in the vicinity of the NGCC power plant at the Callaway site would be 

SMALL.

Installation of wind turbines represents a significant aesthetic change over the existing 

viewshed. With a projected 188 turbines over 400 ft (120 m) tall spread across multiple sites, 

wind turbines would dominate the view and would likely become the major focus of attention. 

Because wind farms are generally located in rural or remote areas, the introduction of wind 

8-46
Environmental Impacts of Alternatives

turbines will be in sharp contrast to the visual appearance of the surrounding environment. 

Placing turbines along ridgelines would maximize their visibility and noise. During operation of 

the wind farm portion of the combination alternative, noise sources would be mechanical and 

aerodynamic noise from wind turbines; transformer and switchgear noise from substations; 

corona noise from transmission lines; and vehicular traffic noise. Based on this information, 

aesthetic impacts from wind farm construction and operation would range from MODERATE to 

LARGE depending on location and surroundings.

Aesthetic impacts of the Energy Efficiency and Conservation Program would be minimal. The 

rapid replacement and disposal of older inefficient appliances and other equipment would 

generate waste material and could increase the size and need to construct new of landfills, 

which could have a SMALL to MODERATE visual impact. Operational impacts from the Energy 

Conservation and Efficiency Program would be SMALL, because it would not require any visible 

changes to existing infrastructure. Based on this information, overall aesthetic and noise 

impacts from the combination alternative would range from MODERATE to LARGE.

8.4.11 Historic and Archeological Resources

Impacts on historic and archaeological resources from the NGCC component of this alternative 

would be similar to those discussed for the NGCC alternative in Section 8.1.11. Energy 

efficiency would have no effect on historic and archaeological resources. Surveys would be 

needed to identify and evaluate cultural resources and address mitigation of potential impacts 

before construction of any new wind farm. Studies would be needed for all areas of potential 

disturbance (e.g., roads, transmission corridors, other ROWs). Areas with the greatest 

sensitivity should be avoided. 

Construction of wind farms and their support infrastructure would have the greatest potential to 

impact cultural resources because of earthmoving activities (e.g., grading and digging) and 

pedestrian and vehicular traffic. Visual impacts on significant cultural resources—such as 

viewsheds from other types of historic properties—may also occur. Depending on the resource 

richness of the site chosen for the wind farms and associated infrastructure, the impacts could 

range from SMALL to LARGE. Therefore, the overall impacts on historic and archaeological 

resources from the combination alternative could range from SMALL to LARGE.

8.4.12 Environmental Justice 

This analysis evaluates the potential for disproportionately high and adverse human health, 

environmental, and socioeconomic effects on minority and low-income populations that could 

result from construction and operation of a new NGCC power plant at the Callaway site, wind 

energy projects, and the Energy Efficiency and Conservation Program. As previously discussed 

in Section 8.1.12, such effects may include human health, biological, cultural, economic, or 

social impacts.

Potential impacts to minority and low-income populations would mostly consist of environmental 

and socioeconomic effects during construction (e.g., noise, dust, traffic, employment, and 

housing impacts). Noise and dust impacts during construction would be short-term and 

primarily restricted to onsite activities. Minority and low-income populations residing along site 

access roads also would be affected by increased commuter vehicle and truck traffic. However, 

because of the temporary nature of construction, these effects are not likely to be high and 

adverse and would be contained to a limited time period during certain hours of the day. 

Increased demand for rental housing during construction could affect low-income populations 

living near the construction site. However, given the small number of workers required to 

8-47
Environmental Impacts of Alternatives

construct the NGCC power plant and wind farm and the possibility that workers could commute 

to the construction site, the need for rental housing would not be significant.

Whether or not there would be disproportionate impacts to minority and low-income populations 

resulting from construction and operation of wind farms would depend upon the site chosen and 

the nearby population distribution. Operational impacts from the wind turbines would mostly be 

limited to noise and aesthetic effects. In addition, whether or not there would be 

disproportionate impacts to minority and low-income populations resulting from the construction 

and operation of the NGCC component would depend upon facility design and its location at the 

Callaway site. Low income populations could benefit from weatherization and insulation in an 

Energy Conservation and Efficiency Program. This could have a greater beneficial effect on 

low-income populations than the general population, because low-income households generally 

experience greater home energy burdens than the average household.

Based on this information and the analysis of human health and environmental impacts 

presented in Section 8.4 of this SEIS, the combination alternative would not have 

disproportionately high and adverse human health and environmental effects on minority and 

low-income populations.

8.4.13 Waste Management

During the construction phases of the NGCC and wind farm portions of this alternative, land 

clearing and other construction activities would generate waste that could be recycled, disposed 

of on site, or shipped to an offsite waste disposal facility. Construction-related wastes would be 

solid, liquid, or gaseous, and some would require management, treatment, and disposal as 

hazardous waste. Various permits, issued by state or local authorities, would control the 

disposal of all construction-related wastes. 

The wastes from construction of the NGCC facility under this alternative would be less than the 

construction wastes for the NGCC alternative discussed in Section 8.1. Operational wastes 

would also be less. Waste impacts from construction and operation of the NGCC facility in this 

alternative would be SMALL.

In general, wind farm waste-related impacts could occur from the improper management or 

inadvertent release of hazardous materials (e.g., fuels, lubricants, pesticides, and dielectric 

fluids in substation electrical equipment) and from routine maintenance activities that would 

generate spent lubricating and hydraulic fluids and water-based coolants. During operation, 

generation of waste would be minimal and would fall under the control of various State and 

Federal regulations, depending on the nature of the waste. Waste impacts from the wind farm 

components of this alternative would be SMALL.

8.5 Alternatives Considered But Dismissed

8.5.1 Oil-Fired Generation

Oil-fired generation currently accounts for approximately 1 percent of power generation capacity 

in the United States, declining from 3 percent in 1999 (EIA 2010a). The variable costs, or fuel 

costs, of oil-fired generation are generally greater than for other fossil fuels or nuclear 

generation. In 2009, the average delivered cost of coal was 222 cents per million British 

thermal units (MMBTU), compared to 737 cents for petroleum liquids, and 550 cents for natural 

gas (EIA 2009b). The ratio of low-sulfur light crude oil prices to natural gas prices on an 

energy-equivalent basis is historically volatile and is expected to remain high relative to the 

historical average throughout 2035. The ratio is maintained by growing worldwide demand for 

8-48
Environmental Impacts of Alternatives

petroleum transportation fuels and robust North 

American natural gas supply relative to demand 

(EIA 2012a). As a result, the NRC does not consider 

new oil-fired generation to be a reasonable 

alternative to Callaway license renewal.

8.5.2 Wind

The feasibility of wind power relies on the availability of the wind resource within the region of 

interest and access to transmission infrastructure. Wind power has increased in scale 

significantly, and the largest operating plant in the United States is a 1,020-MW facility located 

in Tehachapi Pass in Kern County, California. The advantages of wind power are the use of a 

renewable natural resource and no direct airborne emissions. Disadvantages are a large total 

land commitment (although much of the land surrounding individual wind turbines could be used 

for other purposes such as agriculture), a relatively low capacity factor, aesthetic intrusion, and 

bird and bat casualties.

The energy potential in wind is expressed by wind generation classes, which range from 1 (least 

energetic) to 7 (most energetic). Wind resources with wind speeds of at least 15.7 mph 

(7.0 m/s), that is, Class 3 or better (as measured 50 m above the ground), are most desirable 

for utility-scale amounts of electricity. However, advances in wind energy technology 

development, specifically blade diameter, make areas previously considered “low” wind 

resources, such as areas with wind speeds of 13.4 mph (6 m/s), suitable for development 

(NREL 2012).

The majority of Missouri is classified as a Class 1 region, with the northwest and western portion 

of the State classified between Class 2 and Class 3 (NREL 2009). Approximately 459 MW of 

wind capacity is operating in Missouri as of 2011 (DOE 2012a). Based on the amount of 

available windy land area, the NREL estimates 274,255 MW of potential installed wind capacity 

for Missouri, with a gross capacity factor of 30 percent at 80 m heights above ground 

(NREL 2011). Although this does not address current cost and turbine design limitations, as 

stated previously, turbine technology improvements are leading to industry expectations to 

serve sites with lower wind speeds (NREL 2012).

The national average capacity factor for wind power was reported to be 31.6 percent in 2011 

(DOE 2011). Therefore, a wind project with a nameplate capacity of 1,186 MW would produce 

1,186 MW of peak generation, and an average annual generation of 375 MW. For a wind farm 

to produce 1,186 MW on an average annual basis, a nameplate capacity of 3,753 MW, 

comprised of over 2,300 1.6-MW turbines, would be required. Single wind-power facilities of 

that size are not currently technologically feasible. Interconnected wind farm arrays have been 

proposed to provide the equivalent of large baseload facilities, such as the 1,186-MW required 

to replace Callaway. However, the Ameren ER cites several credible studies that conclude that 

interconnected wind farm arrays do not have the capacity and reliability to provide baseload 

power (Ameren 2011b). 

Because of its intermittent nature, wind power is not suitable for baseload generation. The 

potential for energy storage could address the variable aspect of wind power, which is now one

of the primary drivers behind renewed interest in energy storage. Storage provides one solution 

to provide firm capacity and energy, allowing intermittent generation to effectively replace 

baseload generation. As of 2009, only four energy storage technologies (sodium-sulfur 

batteries, pumped hydro, compressed air energy storage, and thermal storage) have a total 

worldwide installed capacity that exceeds 100 MW (NREL 2010). Storage technology is not 

Capacity factor is the ratio of the 

actual amount of electricity generated 

in a given time period to the amount 

that could theoretically be generated if 

the power source could run full time at 

full power.

8-49
Environmental Impacts of Alternatives

sufficiently advanced to allow wind power to be considered suitable as a baseload generating 

source. 

As a result, the NRC does not consider new wind generation to be a reasonable standalone 

alternative to Callaway license renewal. However, when combined with other technologies with 

inherently higher capacity factors, wind energy can contribute to a viable alternative. The NRC 

evaluated such a possible combination in Section 8.4.

8.5.3 Solar

Solar technologies use the sun’s energy to produce electricity. Solar power technologies 

include photovoltaic (PV) and concentrating solar power (CSP). In PV systems, sunlight 

incident on special PV materials produces direct current electricity. An advantage of PV is that 

it is suitable for locations with low direct-sun irradiation. The average capacity factor of PV is 

approximately 18 percent (NREL 2010). The two types of CSP technology with the greatest 

development are the parabolic trough and the power tower. Both CSP technologies involve 

capturing the sun’s heat, or solar thermal energy, and converting it to steam, which powers a 

conventional steam turbine generator. Unlike PV, solar thermal energy can be stored. The 

average capacity factor of CSP without storage is approximately 20 to 28 percent; with 6 to 

7.5 hours of storage, the capacity factor is 40 to 50 percent (NREL 2010). 

The advantages of solar power are the use of a renewable natural resource and no direct 

airborne emissions. Disadvantages are a large total land commitment and a relatively low 

capacity factor.

Solar resources across the United States are good to excellent, with solar insolation levels 

ranging from about 2.7 to 6.8 kilowatt hours per square meter per year (NREL 2010). Missouri 

receives approximately 4.5 to 5 kilowatt hours per square meter per day (kWh/m2

/day) of global 

radiation, compared to roughly 6 to 8 kWh/m2

/day in areas of the Southwest and West, such as 

California (NREL 2008). Midwest Independent System Operator (MISO) does not project any 

additions of solar capacity in the region by 2021; however, it projects a potential for 9 MW by 

2021 (NERC 2011).

Because of its intermittent nature, solar PV is not suitable for baseload generation. As 

discussed above for wind generation, the potential for energy storage could address the 

variable aspect of solar PV; however, this option is not currently commercially available. As a 

result, the NRC does not consider new solar PV generation to be a reasonable alternative to 

Callaway license renewal.

Solar thermal development is currently focused in areas with high solar irradiation. The 

United States has a cumulative CSP installed capacity of approximately 500 MW, the majority of 

which is located in the Southwest (NREL 2010). A 250-MW CSP plant is under construction 

near Gila Bend, Arizona, that will cover 1,900 ac (770 ha) and use 900,000 mirrors to direct 

sunlight to heat a working fluid inside its tubes (NREL 2012). Based on current capacity factors 

of CSP with storage, a nameplate capacity of 1,186 MW would produce 1,186 MW of peak 

generation, and an average annual generation of 534 MW. For a CSP with storage to produce 

1,186 MW on an average annual basis, a nameplate capacity of 2,636 MW would be required. 

The NRC estimates that a nameplate 1,186-MW solar CSP alternative would occupy 

approximately 3,558 ac (1,440 ha) of land. Because of its intermittent nature, solar thermal 

power is not considered suitable for baseload generation, but is suitable in combination with 

other baseload generation such as NGCC. Given the poor direct irradiation in Missouri, the land 

area required, and the uncertainty in the total capacity factor even with storage, the NRC does 

not consider solar thermal energy to be a reasonable alternative to Callaway license renewal.

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Environmental Impacts of Alternatives

8.5.4 Hydropower

Hydroelectric power (hydropower) uses the energy of falling water to turn turbines and generate 

electricity. Hydropower generation currently accounts for approximately 6 percent of power 

generation capacity in the United States, which is a decline from 9 percent in 1999 (EIA 2010a). 

There are three basic sources of hydropower generation in inland waters: (1) impoundments or 

reservoirs, (2) diversions (or run-of-the-river facilities), and (3) pumped storage from a lower 

reservoir or reach of a river to an upper reservoir. The water is then released to the river or 

pumped back to the impoundment or upper reservoir (pumped storage). Hydropower offers 

advantages in that it can generate more electricity during peak-demand periods or less 

electricity during low-demand periods and, if using a reservoir, energy can be stored.

Dam-and-release facilities affect large amounts of land behind the dam to create reservoirs but 

can provide substantial amounts of power at capacity factors greater than 90 percent. Because 

dams change flowing water ecosystems into lake or reservoir ecosystems and can submerge 

extensive areas of land, the effects to terrestrial, aquatic, and protected species are often 

severe. Power-generating capacities of run-of-the-river dams fluctuate with the flow of water in 

the river, and the operation of such dams is typically constrained (and stopped entirely during 

certain periods) to reduce undue stress on the aquatic ecosystems. Pumped storage facilities 

use grid power to pump water to higher elevations during off-peak load periods and release the 

water during peak load periods through turbines. Pumped storage facilities are not considered 

baseload and are not considered further.

Ameren currently owns and operates the Osage Energy Center, a 240-MW hydroelectric 

generating facility in Lakeside, Missouri. Since 2002, Ameren has implemented upgrades and 

efficiency improvements, increasing plant capacity from 175 MW to 242 MW (NHP 2012). 

Based on the GEIS, the staff estimates land use of 1,600 square miles (4,100 square 

kilometers) per 1,000 MW for hydroelectric power. Based on this estimate, replacement of 

Callaway’s generating capacity would require flooding approximately 1.2 million ac 

(0.5 million ha), resulting in a large impact on land use. In addition, operation of a hydroelectric 

facility would alter aquatic habitats above and below the dam, which severely affects existing 

aquatic communities and often affects terrestrial communities. 

Finally, DOE’s Idaho National Engineering and Environmental Laboratory (now Idaho National 

Laboratory (INL)) assessed hydropower resources in Missouri in 1993 and identified a potential 

for approximately 323 MW of potential hydropower capacity on 10 river basins (INEEL 1993). 

Because of the potential for adverse aquatic impacts, the large land use impacts, and the lack of 

adequate hydropower capacity in Missouri, the NRC does not consider hydroelectric power to 

be a reasonable alternative to Callaway license renewal.

8.5.5 Small Modular Reactor

NRC defines small modular reactors (SMRs) as have generating capacities generally less than 

300 MW (IAEA 2009). Many SMRs employ technologies similar to those of large-scale nuclear 

plants. SMRs have several advantages over traditional nuclear power plants, including 

modularity, limited onsite preparation, smaller direct land footprint, and a corresponding 

reduction in construction costs and duration. Some SMRs are designed to operate for decades 

without refueling.

On April 12, 2012, Ameren announced that it had entered into an agreement with Westinghouse 

Electric Company to exclusively support Westinghouse’s application for DOE’s SMR investment 

funds. The investment funding, announced by DOE on March 22, 2012, will support 

first-of-its-kind engineering design certifications and operating licenses for up to two SMR 

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Environmental Impacts of Alternatives

designs over 5 years (Ameren 2012a). If Westinghouse receives DOE investment funds, 

Ameren could be the first utility in the country to seek a COL for construction and operation of a 

Westinghouse SMR.

Because none of the current design concepts are commercially available, the NRC does not 

consider SMRs to be a reasonable alternative to Callaway license renewal.

8.5.6 Biomass Energy

Biomass energy refers to a process by which an organic material and/or waste is directly used 

to generate energy. 

In the 1996, GEIS, NRC staff found that none of the available biomass technologies were 

available on a sufficiently large scale or reliable enough to replace a baseload plant such as 

Callaway. Plants that generate electricity from other biomass energy resources such as food 

crops, grassy and woody plants, residues from agriculture, oil-rich algae, and manure typically 

have capacities less than 20 MW (EIA 2010a). A typical waste-to-energy (WTE) plant 

generates from about 10 to 40 MW of electricity, depending on the specifications for the plant. 

Therefore, a typical WTE plant could not replace the energy produced by Callaway. Ameren 

announced in 2009 an agreement to purchase methane from Fred Weber, Inc.’s Maryland 

Heights, Missouri, solid waste landfill. In 2011, Ameren started installing combustion turbines 

capable of generating about 15 MW of electricity by burning methane gas at the landfill. This 

type of energy production is called “landfill gas to energy.” The project was completed in July 

2012 (Ameren 2012c). 

The MDNR Division of Energy evaluated and reported on the availability of biomass feedstock 

in Missouri in 2005. This biomass feedstock included crop residues, production of short rotation 

woody crops, timber harvesting residues and standing timber removed by thinning, primary 

wood processing wastes, landfill methane potential, animal manures, and municipal solid waste

resources. Crop residues and processing feedstocks represent a total of 79 million MMBTU, 

and other biomass options represent a total of 462 million MMBTU of energy (MDNR 2006). 

A 1,186-MW biomass-fired alternative would require 104 million MMBTU of biomass energy 

annually, assuming a capacity factor and heat rate similar to coal-fired generation. This 

represents over 20 percent of the entire biomass energy potential for Missouri. The cost of 

transporting biomass, generally using trucks, increases with the distance it is transported. 

A distance of 50 to 60 mi (80 to 96 km) is considered an upper limit in evaluations of the 

economics of biomass energy because of these increasing costs (Gan and Mayfield 2007; 

Purdue University 2008).

Because of the cost of transporting biomass, the existing scale of biomass generation 

technologies, and the significant resource consumption, the NRC does not consider 

biomass-derived fuels to be a reasonable alternative to Callaway license renewal.

8.5.7 Fuel Cells

Fuel cells produce power electrochemically by passing a hydrogen-rich fuel over an anode and 

air over a cathode and separating the two by an electrolyte. The primary byproducts are heat, 

water, and carbon dioxide. 

Fuel cells are currently not economically or technologically competitive with other alternatives

for electricity generation. The EIA projects the addition of 390-420 MW of fuel cell capacity in 

the United States by 2035 (EIA 2012a). Given the early stage of commercial development and 

a national projected fuel cell capacity of less than half of the energy required for a replacement 

8-52
Environmental Impacts of Alternatives

alternative, the NRC does not consider fuel cells to be a reasonable alternative to Callaway 

license renewal.

8.5.8 Delayed Retirement

Delayed retirement of existing non-nuclear generating plants is a potential alternative to license 

renewal. In its current Integrated Resource Plan (Ameren 2011a), Ameren’s preferred plan 

assumed that the Meramec coal-fired steam generating plant would continue to operate through 

the planning horizon with no addition of significant environmental controls. However, Ameren 

states that it may retire Meramec in 2015 (Ameren 2011b). If the Meramec plant were retired, it 

would result in the loss of baseload generating capacity of about 900 MW, which is less than the 

capacity of Callaway.

In addition, economic and environmental factors may trigger contractions in available capacity. 

MISO identified 2,919 MW to 12,652 MW of coal fleet capacity at risk for retirement 

(MISO 2011). Pending contractions in capacity make it less likely that delayed retirement could 

be an alternative to Callaway license renewal. Therefore, the NRC does not consider delayed 

retirement of non-nuclear plants to be a reasonable alternative.

8.5.9 Demand-Side Management

Demand-side management (DSM) programs include conservation, energy efficiency, and 

demand-response programs that reduce peak demand for electricity. The DSM measures help 

minimize environmental impacts by avoiding the construction of new electric generation 

facilities. MISO currently administers a substantial DSM portfolio; however, its programs 

primarily reduce peak loads rather than offset baseload generation such as Callaway 

(NERC 2011). Some types of DSM, such as energy efficiency and energy conservation, can 

offset baseload generation. Ameren’s Integrated Resource Plan evaluation for all of its 

electricity generation, including Callaway, identified 331 MW of energy efficiency capacity in 

2025 as a result of existing programs, and an additional 515 MW as a result of realistically 

achievable programs (Ameren 2011a). These projections are based on peak demand savings 

from energy efficiency. Because this 515 MW is less than the capacity provided by Callaway, 

the NRC does not consider DSM to be a reasonable standalone alternative to Callaway license 

renewal. 

8.5.10 Purchased Power

Purchased power would include power purchased from the MISO system or a new generating 

capacity using technologies that are evaluated in the GEIS. MISO currently projects its planning 

reserve margin requirement as 17.4 percent for the 2011 planning year. Through 2021, the 

forecasted reserve margin for MISO exceeds the target requirement. The excess capacity 

represents approximately 17,911 MW of the existing certain capacity and forecast capacity 

(NERC 2011). 

Purchased power would reflect the impacts of an existing operating coal-fired plant, given that 

81 percent of the generating capacity in Missouri is coal-fired. These impacts would include air 

emissions, water use, and ash generation as summarized in Section 8.2. In addition, the need 

to comply with future environmental regulations may lead to a decision to retire some plants, 

particularly those based on coal-fired generation. If new generation provides the purchased 

power, it would mostly likely be from NGCC power plants. This alternative is evaluated in 

Section 8.1. The impacts of purchased power from an NGCC plant would be similar to those of 

the NGCC alternative evaluated in Section 8.1, except that the purchased power may be 

derived from an existing facility at a location other than Callaway. Because the purchased 

8-53
Environmental Impacts of Alternatives

power options would be similar to the coal-fired generation and gas-fired generation 

(i.e., NGCC) alternatives, the NRC did not evaluate purchased power further.

8.5.11 Non-Powered Dams

A study published by DOE in 2012 assessed the energy potential at non-powered dams (NPDs) 

throughout the United States (DOE 2012b). In this context, NPDs are dams that do not include 

hydroelectric turbine (hydropower) equipment. Such dams were constructed for one or more 

non-energy human benefits, including flood control, water supply, navigation, or recreation. The 

energy generation potential is based on the hypothesis that many of the costs and 

environmental impacts of dam construction have already been incurred at NPDs and may not 

be significantly increased by the incorporation of new energy-production facilities. A list of the 

top 100 NPDs with hydropower potential includes a number of dams in Missouri with estimated 

potential capacities in the range of 92 to 300 MW (DOE 2012b). Because of its limited potential 

capacity, this alternative is not a viable standalone option as a replacement for Callaway.

8.6 No-Action Alternative

This section examines the environmental effects that would occur if the NRC took no action. 

No action in this case means that the NRC denies a renewed operating license for Callaway 

and the license expires at the end of the current license term, in October 2024. If the NRC 

takes no action, the plant will shut down at or before the end of the current license. After 

shutdown, plant operators would initiate decommissioning in accordance with 10 CFR 50.82.

No action does not satisfy the purpose and need for this SEIS, as it neither provides 

power-generation capacity nor meets the needs currently met by Callaway or the alternatives

evaluated in Sections 8.1 through 8.4. Assuming that a need currently exists for the power 

generated by Callaway, the no-action alternative would require the appropriate energy-planning 

decisionmakers (not the NRC) to rely on an alternative (or combination of them) to replace the 

capacity of Callaway or reduce the need for power. 

This section addresses only those impacts that arise directly as a result of plant shutdown. The 

environmental impacts from decommissioning and related activities have already been 

addressed in several other documents, including Supplement 1 of NUREG–0586, Final Generic 

Environmental Impact Statement on Decommissioning of Nuclear Facilities Regarding the 

Decommissioning of Nuclear Power Reactors (NRC 2002); Chapter 7 of the license renewal 

GEIS (NRC 1996); and Chapter 7 of this SEIS. These analyses either directly address or bound 

the environmental impacts of decommissioning whenever Ameren ceases operating Callaway.

Even with a renewed operating license, Callaway will eventually be shut down, and the 

environmental effects addressed in this Section will occur at that time. Since these effects have 

not otherwise been addressed in this SEIS, the impacts will be addressed in this section. As 

with decommissioning effects, shutdown effects are expected to be similar whether they occur 

at the end of the current license or at the end of a renewed license.

8.6.1 Air Quality

When the plant stops operating, there will be a reduction in emissions from activities related to 

plant operation, such as use of diesel generators and employee vehicles. The NRC staff has 

determined that emissions during the renewal term would have a SMALL impact on air quality; 

therefore, if emissions decrease, the impact on air quality would also decrease, resulting in a 

SMALL impact.

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Environmental Impacts of Alternatives

8.6.2 Surface Water Resources

Chapter 4 discusses the impacts on surface water from plant operation. Operational impacts 

include withdrawals from the Missouri River in association with operation of the cooling system

and discharges of wastewater. Impacts also include stormwater runoff from industrial areas of 

the plant, which are controlled through NPDES permit provisions. 

As Callaway is shutdown, impacts associated with surface water withdrawals, including 

consumptive use, and effluent discharges would decrease. The reactor cooling system would 

continue to function in the short term to remove the heat of decay in the reactor, and other 

auxiliary cooling systems would continue to operate as long as necessary. Stormwater 

discharges from industrialized portions of the site would continue largely unchanged until the 

start of decommissioning activities. The current NPDES permits would continue in effect after 

reactor shutdown and would be replaced by an amended permit or new permits with the start of 

decommissioning activities. The NRC concludes that impacts on surface water use and quality 

from the no-action alternative would be SMALL.

8.6.3 Groundwater Resources

With plant shutdown, there would be a reduction in groundwater use over that of normal plant 

operation as the plant workforce is drawn down and plant auxiliary operations requiring 

groundwater are curtailed or ceased. 

Tritium contamination is known to exist in groundwater beneath the Callaway site, and 

remediation and mitigation activities are ongoing. Once operation of the reactor ceases, the 

potential for additional releases of tritium to the groundwater is expected to diminish. 

Remediation activities are expected to continue after reactor operation ceases. The NRC 

concludes that impacts on groundwater use and quality from the no-action alternative would be 

SMALL.

8.6.4 Aquatic Ecology

As a result of plant shut down, impacts on aquatic ecology would decrease because the plant 

would withdraw and discharge less water than it does during operations. Therefore, fewer 

organisms would be subject to impingement, entrainment, and thermal shock. Shutdown would 

reduce the already SMALL level of impacts on aquatic resources.

8.6.5 Terrestrial Ecology

Terrestrial ecology impacts would remain SMALL. No additional land disturbances on or offsite 

would occur as a result of the shutdown of Callaway. Any shutdown activities would be 

expected to be confined to the industrialized and previously disturbed portions of the plant site. 

Impacts on terrestrial species and habitats would be SMALL. No identifiable impacts on 

protected species and habitats would result because of the no-action alternative. 

8.6.6 Human Health

After cessation of plant operations, the amounts of radioactive material released to the 

environment in gaseous and liquid forms, all of which are currently within respective regulatory 

limits, would be reduced or eliminated. The potential for a variety of accidents (radiological or 

industrial) would also be reduced to only those associated specifically with shutdown activities 

and fuel handling and storage. In Chapter 4 of this SEIS, the NRC staff concluded that the 

8-55
Environmental Impacts of Alternatives

impacts of continued plant operation on human health are SMALL. In Chapter 5 of this SEIS, 

the NRC staff concluded that impacts of accidents during operation are SMALL. Therefore, as 

radioactive emissions to the environment decrease, and as the likelihood and variety of 

accidents decrease after shutdown, the NRC staff concludes that impacts on human health from 

the no-action alternative would be SMALL.

8.6.7 Land Use

Plant shutdown would not affect onsite land use. Plant structures and other facilities would 

remain in place until decommissioning. Most transmission lines connected to Callaway would 

remain in service after the plant stops operating. Maintenance of most existing transmission 

lines would continue as before. Impacts on land use from plant shutdown would be SMALL.

8.6.8 Socioeconomics 

Plant shutdown would have a noticeable impact on socioeconomic conditions in the 

communities located near Callaway. After cessation of plant operations, there would be 

immediate socioeconomic impacts from the loss of jobs (some, though not all, of the 

860 employees would begin to leave), and tax payments may be reduced. As a majority of 

Callaway employees reside in Boone, Callaway, and Cole Counties, socioeconomic impacts 

from plant shutdown would be concentrated in these counties, with a corresponding reduction in 

purchasing activity and tax contributions to the regional economy. Revenue losses from 

Callaway operations would directly affect Callaway County and other local taxing districts and 

communities closest to, and most reliant on, the plant’s tax revenue. The impact of the job loss, 

however, may not be as noticeable given the amount of time required to decontaminate and 

decommission existing facilities and the proximity of Callaway to the Columbia, Jefferson City, 

and St. Louis metropolitan areas. The socioeconomics impacts of plant shutdown (which may 

not entirely cease until after decommissioning) could, depending on the jurisdiction, range from 

SMALL to MODERATE. 

8.6.9 Transportation

Traffic volumes on the roads in the vicinity of Callaway would be reduced after plant shutdown. 

Most of the reduction in traffic volume would be associated with the loss of jobs at the nuclear 

power plant. The number of deliveries to the power plant would be reduced until 

decommissioning. Transportation impacts resulting from plant shutdown would be SMALL.

8.6.10 Aesthetics and Noise 

Many sources of operational noise would cease. Therefore, aesthetic impacts of plant 

shutdown would be SMALL.

8.6.11 Historic and Archaeological Resources

Impacts from the no-action alternative on historic and archaeological resources would be 

SMALL, because no additional land disturbances would occur on or off the Callaway site.

8.6.12 Environmental Justice

Impacts on minority and low-income populations would depend on the number of jobs and the 

amount of tax revenues lost by communities in the immediate vicinity of the plant after Callaway 

ceases operations. Closure of Callaway would reduce the overall number of jobs (860 people 

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Environmental Impacts of Alternatives

are currently employed at the facility) and tax revenue for social services attributed to nuclear 

plant operations. Minority and low-income populations in the vicinity of Callaway could 

experience some socioeconomic effects from plant shutdown, but these effects would not likely 

be high and adverse. See Appendix J of NUREG-0586, Supplement 1, Final Generic 

Environmental Impact Statement on Decommissioning of Nuclear Facilities Regarding the 

Decommissioning of Nuclear Power Reactors (NRC 2002) for additional discussion of these 

impacts.

8.6.13 Waste Management

Once Callaway is shutdown, the generation of high-level waste would cease and the generation 

of low-level and mixed wastes would be diminished, limited only to those wastes associated with 

reactor shutdown and fuel-handling activities. Therefore, the NRC staff concludes that the 

impacts of waste generation under the no-action alternative would be SMALL.

8.7 Alternatives Summary

In this chapter, the following alternatives to Callaway license renewal were considered and 

analyzed in detail: NGCC generation, SCPC generation, a new nuclear reactor, and 

combination power generation. The no-action alternative and its effects were also considered. 

Table 8–6 summarizes the impacts for all alternatives to the Callaway license renewal.

Based on the above evaluations, the NRC staff concludes that the environmental impacts of 

renewal of the operating license for Callaway would be smaller than those of feasible and 

commercially viable alternatives studied in this SEIS that satisfy the purpose and need of 

license renewal (provision of 1,186 MW of baseload power to the grid). Impacts on air quality 

are less from continued operation of Callaway than from any of the alternatives involving fossil 

fuels. Finally, the staff concluded that under the no-action alternative, the act of shutting down 

Callaway on or before its license expiration would have mostly SMALL impacts, although 

socioeconomic impacts would be SMALL to MODERATE. Depending on how the power lost to 

the region from reactor shutdown was replaced (decisions outside of the NRC’s authority and 

made instead by Ameren, other power producers, MISO operators, and State or non-NRC 

Federal authorities), the net environmental impact of the no-action alternative could be greater 

than continued reactor operation, especially if fossil energy power plants are used to provide 

replacement power generation capacity.

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Environmental Impacts of Alternatives

Table 8–6. Summary of Environmental Impacts of Proposed Action and Alternatives

Alternative

Impact Area

Callaway 

License 

Renewal 

(proposed 

action)

NaturalGas-Fired 

CombinedCycle 

(NGCC)

Supercritical 

Pulverized 

Coal 

(SCPC)

New 

Nuclear

Combination 

Generation

No-action 

Alternative

Air Quality Small Small to 

Moderate Moderate Small Small to 

Moderate Small

Surface Water Small Small Small Small Small Small

Groundwater Small Small Small Small Small Small

Aquatic Ecology Small Small Small Small Small Small

Terrestrial 

Ecology Small Small to 

Moderate

Moderate to 

Large

Small to 

Moderate

Small to 

Moderate Small

Human Health Small Small Small Small Small Small

Land Use Small Small to 

Moderate

Small to 

Moderate

Small to 

Moderate

Small to 

Moderate Small

Socioeconomics Small Small to 

Moderate

Small to 

Moderate

Small to 

Large

Small to 

Moderate

Small to 

Moderate

Transportation Small Small to 

Moderate

Small to 

Moderate

Small to 

Large Small Small

Aesthetics and 

Noise Small Small Small to Moderate

Small to

Moderate

Moderate 

to Large Small

Historic and 

Archaeological 

Resources

Small Small Small Small Small to 

Large Small

Waste 

Management Small Small Moderate Small Small Small

8.8 References

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40 CFR Part 60. Code of Federal Regulations, Title 40, Protection of the Environment, Part 60, 

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Feedstock Availability in Missouri. Prepared by Fink RJ and Fink RL. Jefferson City, MO: 

Missouri DNR Energy Center. Final Report. February 2006. Available at 

http://www.dnr.mo.gov/energydocs/biomass-inventory2005-07.pdf (accessed 3 August 2012).

[MDNR] Missouri Department of Natural Resources. 2012a. “Division of Energy, Wind Energy 

Resources.” Available at <http://www.dnr.mo.gov/energy/renewables/wind-energy.htm> 

(accessed 3 August 2012).

[MDNR] Missouri Department of Natural Resources. 2012b. “Forms, Application and Permits.” 

Available at <http://www.dnr.mo.gov/forms/index.html> (accessed 3 August 2012).

[MDNR] Missouri Department of Natural Resources. 2014. Letter from R. Stout, Chief of Policy, 

to C. Bladey, Chief, Rules, Announcements, and Directives Branch 15 (RADB), U.S. Nuclear 

Regulatory Commission. Subject: Generic Environmental Impact Statement for License 

Renewal of Nuclear Plants, Supplement 51, regarding Callaway Plant Unit 1, NUREG–1437. 

ADAMS No. ML14107A066.

8-61
Environmental Impacts of Alternatives

[MISO] Midwest Independent System Operator. 2011. EPA Impact Analysis: Impacts from the 

EPA Regulations on MISO October 2011. Available at 

<http://www.midwestiso.org/Library/Repository/Study/

MISO%20E PA%20Impact%20Analysis.pdf> (accessed 3 September 2012).

[NERC] North American Electric Reliability Corporation. 2011. 2011 Long-Term Reliability 

Assessment. November 2011. 559 p. Available at 

<http://www.nerc.com/files/2011LTRA_Final.pdf> (accessed 15 August 2012).

[NETL] National Energy Technology Laboratory. 2007. Cost and Performance Baseline for 

Fossil Energy Plants. DOE/NETL-2007/1281. Volume 1: Bituminous Coal and Natural Gas to 

Electricity, Final Report. Revision 1. August 2007. Available at 

<http://www.netl.doe.gov/energy-analyses/pubs/BitBase_FinRep_2007.pdf> (accessed 

3 August 2012).

[NHP] National Hydropower Association. 2012. “Outstanding Stewards of America’s Waters 

Award, 2011 Winners, Ameren Missouri.” Available at 

<http://hydro.org/about-nha/awards/osaw/2011-winners/ameren-missouri/> (accessed 

16 August 2012).

[NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG-1437, Volumes 1 

and 2. May 1996. ADAMS Nos. ML040690705 and ML040690738.

[NRC] U.S. Nuclear Regulatory Commission. 1999. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG-1437, Volume 1, 

Addendum 1. August 1999. ADAMS No. ML040690720.

[NRC] U.S. Nuclear Regulatory Commission. 2002. Generic Environmental Impact Statement

on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of 

Nuclear Power Reactors. Washington, DC: NRC. NUREG-0586, Supplement 1. 

November 2002. ADAMS Nos. ML023500310, ML023500322, ML023500295, and 

ML023500395.

[NRC] U.S. Nuclear Regulatory Commission. 2011. Final Environmental Impact Statement for 

Combined Licenses for Virgil C. Summer Nuclear Station Units 2 and 3. Washington, DC: NRC. 

NUREG-1939. Final Report. April 2011. ADAMS No. ML11098A044.

[NREL] National Renewable Energy Laboratory. 2006. Comparing Statewide Economic Impacts 

of New Generation from Wind, Coal, and Natural Gas in Arizona, Colorado, and Michigan. 

Available at: 

<http://www.windpoweringamerica.gov/pdfs/38154_econdev_compare_statewide.pdf> 

(accessed 4 April 2013)

[NREL] National Renewable Energy Laboratory. 2008. Solar Resource Assessment. Technical 

Report NREL/TP-581-42301. February 2008. 54 p. Available at 

<http://www.nrel.gov/docs/fy08osti/42301.pdf> (accessed 16 August 2012).

[NREL] National Renewable Energy Laboratory. 2009. “United States - Wind Resource Map.” 

1 p. Available at <http://www.nrel.gov/gis/pdfs/windsmodel4pub1-1-9base200904enh.pdf> 

(accessed 16 August 2012).

[NREL] National Renewable Energy Laboratory. 2010. The Role of Energy Storage with 

Renewable Electricity Generation. NREL/TP-6A2-47187. Golden, CO: NREL. January 2010. 

61 p. Available at <http://www.nrel.gov/docs/fy10osti/47187.pdf> (accessed 30 July 2012).

8-62
Environmental Impacts of Alternatives

[NREL] National Renewable Energy Laboratory. 2011. “Estimates of Windy Land Area and 

Wind Energy Potential, by State, for areas >=30% Capacity Factor at 80m.” April 13 2011. 

Available at <http://www.windpoweringamerica.gov/docs/wind_potential_80m_30percent.xls> 

(accessed 30 July 2012).

[NREL] National Renewable Energy Laboratory. 2012. “Recent Developments in the Levelized 

Cost of Energy from U.S. Wind Power Projects.” February 2012. PowerPoint presentation. 

Available at <http://eetd.lbl.gov/ea/ems/reports/wind-energy-costs-2-2012.pdf> (accessed 

3 August 2012).

[OECD/IEA] Organization for Economic Co-Operation and Development/International Energy 

Agency. 2005. Available at (accessed 4 April 2013).

Purdue University. 2008. “Bioenergy Publications.” Fact Sheet ID-404: The Economics of 

Renewable Energy: Corn Stover and Switchgrass, Brechbill S and Tyner WE, Department of 

Agricultural Economics. June 2008. Available at <http://www.ces.purdue.edu/bioenergy> 

(accessed 3 October 2012).

Tate A, Skipper J, Wenz F. 2008. Environmentally Sound Handling of Deactivated SCR 

Catalyst. Coal Power Magazine July 31, 2008. Available at <http://www.coalpowermag.com/> 

(accessed 3 August 2012).

8-63

9.0 CONCLUSION

This supplemental environmental impact statement (SEIS) contains the environmental review of 

the application submitted by Union Electric Company, a subsidiary of Ameren Corporation and 

doing business as Ameren Missouri (Ameren), for a renewed operating license for Callaway 

Plant, Unit 1 (Callaway), as required by Part 51 of Title 10 of the Code of Federal Regulations

(10 CFR Part 51), the U.S. Nuclear Regulatory Commission’s (NRC’s) regulations that 

implement the National Environmental Policy Act. This chapter presents conclusions and 

recommendations from the site-specific environmental review of Callaway and summarizes 

site-specific environmental issues of license renewal that the NRC staff noted during the review. 

Section 9.1 summarizes the environmental impacts of license renewal; Section 9.2 presents a 

comparison of the environmental impacts of license renewal and energy alternatives; 

Section 9.3 discusses unavoidable impacts of license renewal, energy alternatives, and 

resource commitments; and Section 9.4 presents conclusions and staff recommendations.

9.1 Environmental Impacts of License Renewal

The NRC staff’s review of site-specific environmental issues in this SEIS leads to the conclusion 

that issuing a renewed license at Callaway would have SMALL impacts in all of the Category 2 

issues and the two uncategorized issues (environmental justice and chronic effects of 

electromagnetic fields) applicable to license renewal at Callaway. The NRC staff considered 

mitigation measures for each Category 2 issue, as applicable. However, in all cases the NRC 

staff determined that site-specific mitigation measures were not likely to be sufficiently beneficial 

to warrant implementation. 

The NRC staff also conducted a severe accident mitigation alternatives (SAMA) review and 

concluded that none of the potentially cost-beneficial SAMA relate to adequately managing the 

effects of aging during the period of extended operation. Therefore, they need not be 

implemented as part of the license renewal, in accordance with 10 CFR Part 54, “Requirements 

for renewal of operating licenses for nuclear power plants.”

The staff also considered cumulative impacts of past, present, and reasonably foreseeable 

future actions, regardless of what agency (Federal or non-Federal) or person undertakes them. 

The staff concluded in Section 4.12 that cumulative impacts of Callaway’s license renewal 

would be SMALL for all areas, except aquatic and terrestrial resources. For aquatic resources, 

the staff concluded that the cumulative impact would be LARGE. For terrestrial resources, the 

cumulative impacts would be SMALL to MODERATE.

9.2 Comparison of Environmental Impacts of License Renewal and Alternatives

The NRC staff also considered cumulative impacts of past, present, and reasonably foreseeable 

future actions, regardless of what agency (Federal or non-Federal) or person undertakes them. 

The NRC staff concluded in Section 4.11 that cumulative impacts of Callaway’s license renewal 

would be SMALL for all resources areas, with the exception of aquatic resources. The NRC 

staff determined that, although the incremental impacts from Callaway on the Missouri River are 

minimal because of the use of a closed-cycle cooling system, the cumulative stress from all the 

alterations to the aquatic habitat spread across the geographic area of interest have 

destabilized this resource. Therefore, the NRC staff concludes that the cumulative impacts from 

the proposed license renewal and other past, present, and reasonably foreseeable projects on 

the aquatic resources would be LARGE. However, the incremental impacts from the proposed 

9-1 
Conclusion

license renewal would be SMALL since license renewal would have minimal impacts on aquatic 

resources.

In Chapter 8, the NRC staff considered the following alternatives to Callaway license renewal:

 natural-gas-fired combined-cycle (NGCC), 

 supercritical pulverized coal-fired, 

 new nuclear reactor, and

 combination alternative (NGCC, wind power, and energy efficiency). 

In Chapter 8, the NRC staff determined that impacts from license renewal would generally be 

equal to or less than the impacts of alternatives to license renewal. In comparing likely 

environmental impacts from the alternatives and the environmental impacts of license renewal, 

it was found that there is no clear environmentally preferred alternative to license renewal. All 

alternatives capable of meeting the needs currently served by Callaway entail impacts greater 

than or equal to the proposed action of Callaway license renewal. Additionally, because the 

no-action alternative necessitates the implementation of one or a combination of alternatives, 

the no-action alternative would have environmental impacts greater than or equal to the 

proposed license renewal action. Based on the analysis of alternatives to license renewal, the 

NRC staff has determined that the impacts of license renewal are reasonable when taken in the 

context of alternatives to the renewal of the Callaway license.

9.3 Resource Commitments

9.3.1 Unavoidable Adverse Environmental Impacts

Unavoidable adverse environmental impacts are impacts that would occur after implementation 

of all workable mitigation measures. Carrying out any of the energy alternatives considered in 

this SEIS, including the proposed action, would result in some unavoidable adverse 

environmental impacts.

Minor unavoidable adverse impacts on air quality would occur due to emission and release of 

various chemical and radiological constituents from power plant operations. Nonradiological 

emissions resulting from power plant operations are expected to comply with 

U.S. Environmental Protection Agency emissions standards, although the alternative of 

operating a fossil-fueled power plant in some areas may worsen existing attainment issues. 

Chemical and radiological emissions would not exceed the National Emission Standards for 

Hazardous Air Pollutants.

During nuclear power plant operations, workers and members of the public would face 

unavoidable exposure to radiation and hazardous and toxic chemicals. Workers would be 

exposed to radiation and chemicals associated with routine plant operations and the handling of 

nuclear fuel and waste material. Workers would have higher levels of exposure than members 

of the public, but doses would be administratively controlled and would not exceed standards or 

administrative control limits. In comparison, the alternatives involving the construction and 

operation of a non-nuclear power generating facility would also result in unavoidable exposure 

to hazardous and toxic chemicals to workers and the public.

The generation of spent nuclear fuel (SNF) and waste material, including low-level radioactive 

waste, hazardous waste, and nonhazardous waste, would also be unavoidable. In comparison, 

hazardous and nonhazardous wastes would also be generated at non-nuclear power generating 

facilities. Wastes generated during plant operations would be collected, stored, and shipped for 

suitable treatment, recycling, or disposal in accordance with applicable Federal and state 

9-2 
Conclusion

regulations. Because of the costs of handling these materials, power plant operators would be 

expected to carry out all activities and optimize all operations in a way that generates the 

smallest amount of waste possible.

9.3.2 Short-Term Versus Long-Term Productivity

The operation of power generating facilities would result in short-term uses of the environment, 

as described in Chapters 4, 5, 6, 7, and 8. “Short-term” is the period of time that continued 

power generating activities take place.

Power plant operations require short-term use of the environment and commitment of 

resources, as well as commit certain resources (e.g., land and energy) indefinitely or 

permanently. Certain short-term resource commitments are substantially greater under most 

energy alternatives, including license renewal, than under the no-action alternative because of 

the continued generation of electrical power and the continued use of generating sites and 

associated infrastructure. During operations, all energy alternatives require similar relationships 

between local short-term uses of the environment and the maintenance and enhancement of 

long-term productivity.

Air emissions from power plant operations introduce small amounts of radiological and 

nonradiological constituents to the region around the plant site. Over time, these emissions 

would result in increased concentrations and exposure, but they are not expected to impact air 

quality or radiation exposure to the extent that public health and long-term productivity of the 

environment would be impaired.

Continued employment, expenditures, and tax revenues generated during power plant 

operations directly benefit local, regional, and State economies over the short term. Local 

governments investing project-generated tax revenues into infrastructure and other required 

services could enhance economic productivity over the long term.

The management and disposal of SNF, low-level radioactive waste, hazardous waste, and 

nonhazardous waste requires an increase in energy and consumes space at treatment, storage, 

or disposal facilities. Regardless of the location, the use of land to meet waste disposal needs 

would reduce the long-term productivity of the land.

Power plant facilities are committed to electricity production over the short term. After 

decommissioning these facilities and restoring the area, the land could be available for other 

future productive uses.

9.3.3 Irreversible and Irretrievable Commitments of Resources

This section describes the irreversible and irretrievable commitment of resources that have 

been noted in this SEIS. Resources are irreversible when primary or secondary impacts limit 

the future options for a resource. An irretrievable commitment refers to the use or consumption 

of resources that are neither renewable nor recoverable for future use. Irreversible and 

irretrievable commitment of resources for electrical power generation include the commitment of 

land, water, energy, raw materials, and other natural and man-made resources required for 

power plant operations. In general, the commitment of capital, energy, labor, and material 

resources are also irreversible.

The implementation of any of the energy alternatives considered in this SEIS would entail the 

irreversible and irretrievable commitment of energy, water, chemicals, and in some cases, fossil 

fuels. These resources would be committed during the license renewal term and over the entire 

life cycle of the power plant, and they would be unrecoverable.

9-3 
Conclusion

Energy expended would be in the form of fuel for equipment, vehicles, and power plant 

operations and electricity for equipment and facility operations. Electricity and fuel would be 

purchased from offsite commercial sources. Water would be obtained from existing water 

supply systems. These resources are readily available, and the amounts required are not 

expected to deplete available supplies or exceed available system capacities.

9.4 Recommendations

The NRC’s recommendation is that the adverse environmental impacts of license renewal for 

Callaway are not great enough to deny the option of license renewal for energy-planning 

decisionmakers. This recommendation is based on the following:

 the analysis and findings in NUREG–1437, Generic Environmental Impact 

Statement for License Renewal of Nuclear Plants;

 the Environmental Report submitted by Ameren; 

 consultation with Federal, state, and local agencies; 

 the NRC’s environmental review; and

 consideration of public comments received during the reviewing process. 

9-4 
10.0 LIST OF PREPARERS

Members of the U.S. Nuclear Regulatory Commission (NRC)’s Office of Nuclear Reactor 

Regulation (NRR) prepared this supplemental environmental impact statement (SEIS) with 

assistance from other NRC organizations and contractor support from Ecology and 

Environment, Inc. (E & E), and SC&A, Inc. (SC&A). Pacific Northwest National Laboratory 

(PNNL) provided contractor support for the severe accident mitigation alternatives (SAMA) 

analysis. Table 10–1 identifies each contributor’s name, affiliation, and function or expertise.

10-1 
List of Preparers

Table 10–1. List of Preparers

Name Affiliation Function or Expertise

NRC

Brian Wittick NRR Branch Chief

David Wrona NRR Branch Chief

Melanie Wong NRR Branch Chief

Tam Tran NRR Project Manager

Carmen Fells NRR Project Manager

Kevin Folk NRR Technical Monitor; Geology and Soils

Nancy Martinez NRR Alternatives; Air Quality and Meteorology

Emily Larson NRR Historical and Archaeological Resources

Dennis Logan NRR Aquatic Ecology, Special Status Species and Habitats

Briana Grange NRR Terrestrial Ecology, Special Status Species and 

Habitats

William Ford NRR Water Resources

Jeffrey Rikhoff NRR Land Use; Socioeconomics and Environmental Justice

Stephen Klementowicz NRR Nuclear Fuel Cycle, Waste Storage/Management; 

Human Health

John Parillo NRR SAMA

Rodneshia Green NRR Administrative Assistant

Contractor(a)

Jacquelyn Gillings E & E Program Manager

Jone Guerin E & E Project Manager; Socioeconomics and Environmental 

Justice

Daniel Kennedy E & E Geology and Soils

Donna Kassel E & E Alternatives; Cumulative Impacts; Waste Management

Janine Whitken E & E Alternatives

Bruce Wattle E & E Air Quality and Meteorology

Natasha Snyder E & E Historical and Archaeological Resources

Sean Meegan E & E Aquatic Ecology

Gregory Netti E & E Aquatic and Terrestrial Ecology

Katie Dixon E & E Water Resources 

Deepali McCloe E & E Land Use; Socioeconomics and Environmental Justice

Donald Kolb E & E Land Use

Aris Papadopoulos SC&A Alternatives

Karene Riley SC&A Cumulative Impacts

Gregory Hofer SC&A Nuclear Fuel Cycle, Waste Storage/Management

Frank Ray Vollert SC&A Geology and Soils

John Mauro SC&A Human Health 

Rose Gogliotti SC&A Human Health 

David Back SC&A Water Resources 

Merle Chambers BLH Technical Editing

10-2 
List of Preparers

Name Affiliation Function or Expertise

SAMA Contractor(b)

Garill Coles PNNL SAMA

(a) The E & E team included E & E as the prime contractor and SC&A as a subcontractor to E & E 

(b) PNNL is operated by Batelle for the U.S. Department of Energy 

10-3 

11.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS 

TO WHOM COPIES OF THIS SEIS ARE SENT

Name and Title Company and Address

EIS Filing Section U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, NW

Washington, DC 20004

Reid Nelson

Office of Federal Programs

Advisory Council on Historic Preservation

Old Post Office Building, Suite 803

1100 Pennsylvania Avenue, NW 

Washington, DC 20004

Ms. Amy Salveter

Field Supervisor, U.S. Fish and Wildlife Service

U.S. Fish and Wildlife Service

Columbia, MO Field Office

101 Park DeVille Drive

Suite A

Columbia, MO 65203

Ms. Janet Sternberg

Policy Coordination Unit, Missouri Department of 

Conservation

Missouri Department of Conservation

2901 West Truman Blvd.

Jefferson City, MO 65109

Emily Clancy Missouri Department of Conservation

ATTN: Resource Science Division

P.O. Box 180

Jefferson City, MO 65102-0180

Tom Melius

Midwest Regional Director 

U.S. Fish and Wildlife Service

5600 American Blvd West

Suite 990

Bloomington, MN 55437-1458

Mark Miles

Director and Deputy, State Historic Preservation 

Office

Missouri Department of Natural Resources

State Historic Preservation Office

P.O. Box 176

Jefferson City, MO 65102

Judith Deel Missouri Department of Natural Resources

State Historic Preservation Office

P.O. Box 176

Jefferson City, MO 65102

Dru Buntin

Director’s Office, Missouri Department of Natural 

Resources

Missouri Department of Natural Resources

P.O. Box 176

Jefferson City, MO 65102

Robert Stout

Chief of Policy

Missouri Department of Natural Resources 

P.O. Box 176 

Jefferson City, MO 65102

Mark Roberts U.S. Fish and Wildlife Service

Pennsylvania Field Office

315 South Allen Street, Suite 322

State College, PA 16801

11-1 
List of Agencies, Organizations, and Persons

to Whom Copies of This SEIS Are Sent

Name and Title Company and Address

Rick L. Hansen U.S. Fish and Wildlife Service

Ecological Services

101 Park DeVille Drive, Suite A

Columbia, MO 65203

Wyatt J. Doyle Assistant Project Leader

Columbia Fish and Wildlife Conservation Office

Jeff Demand

Wildlife Management Biologist

Missouri Department of Conservation

Prairie Fork Conservation Area

4502 State Highway D

P.O. Box 43

Williamsburg, MO 63388

Jennifer Campbell-Allison

Policy Coordinator

Missouri Department of Conservation

2901 W. Truman Blvd.

Jefferson City, MO 65109

Jane Beetem

Director's Office

Missouri Department of Natural Resources

P.O. Box 176

Jefferson City, MO 65102

George Blanchard

Governor

Absentee-Shawnee Tribe of Indians of Oklahoma

2025 South Gordon Cooper Drive

Shawnee, OK 74801

Brenda Shemayne Edwards 

Chairwoman

Caddo Nation

P.O. Box 487

Binger, OK 73009

Bill John Baker 

Principal Chief

Cherokee Nation

P.O. Box 948

Tahlequah, OK 74465

Janice Prairie Chief-Boswell 

Governor

Cheyenne & Arapaho Tribes of Oklahoma

P.O. Box 38

Concho, OK 73022

Bill Anoatubby

Governor

Chickasaw Nation of Oklahoma

P.O. Box 1548

Ada, OK 74821-1548

Gregory E. Pyle

Chief

Choctaw Nation of Oklahoma

P.O. Drawer 1210

16th & Locust Street

Durant, OK 74702

John A. Barrett, Jr.

Chairman

Citizen Potawatomi Nation

1601 S. Gordon Cooper Drive

Shawnee, OK 74801

Kerry Holton

Nation President

Delaware Nation

P.O. Box 825

Andarko, OK 73005

Glenna J. Wallace 

Chief 

Eastern Shawnee Tribe of Oklahoma

P.O. Box 350

Seneca, MO 64865

Tom Rhodd 

Chairman 

Iowa Tribe of Kansas and Nebraska

3345B Thrasher Road

White Cloud, KS 66094

11-2 
List of Agencies, Organizations, and Persons

to Whom Copies of This SEIS Are Sent

Name and Title Company and Address

Janice Rowe-Kurak 

Chair

Iowa Tribe of Oklahoma

R.R. 1, Box 721

Perkins, OK 74059-9599

Thomas E. Gamble 

Chief

Miami Tribe of Oklahoma

P.O. Box 1326

Miami, OK 74355

George Tiger 

Principal Chief

Muscogee (Creek) Nation of Oklahoma

P.O. Box 580

Okmulgee, OK 74447

Amen Sheridan 

Chairman

Omaha Tribe of Nebraska & Iowa

P.O. Box 368

Macy, NE 68039

John D. Red Eagle

Principal Chief

Osage Nation

627 Grandview

P.O. Box 779

Pawhuska, OK 74056

John R. Shotton

Chairman

Otoe-Missouria Tribe of Oklahoma

8151 Highway 177

Red Rock, OK 74651

Marshall Gover

President, Pawnee Nation Business Council

Pawnee Nation of Oklahoma

881 Little Dee Drive

Pawnee, OK 74058

John P. Froman 

Chief

Peoria Tribe of Oklahoma

P.O. Box 1527

Miami, OK 74355

Douglas G. Rhodd

Chairman

Ponca Tribe of Indians of Oklahoma

20 White Eagle Drive

Ponca City, OK 74601

Rebecca White

Chairwoman

Ponca Tribe of Nebraska

P.O. Box 288 

Niobrara, NE 68760

Steve Ortiz

Tribal Chairman

Prairie Band of Potawatomi Indians

16281 Q Road

Mayetta, KS 66509

John Berrey

Chairman

Quapaw Tribe of Oklahoma

P.O. Box 765

Quapaw, OK 74363

Michael Dougherty

Chairperson

Sac and Fox of the Missouri in Kansas and 

Nebraska

305 North Main

Reserve, KS 66434

George Thurman 

Principal Chief

Sac and Fox Nation of Oklahoma

Route 2, Box 246

Stroud, OK 74079

Frank Blackcloud 

Chairman

Sac and Fox Tribe of the Mississippi in Iowa

349 Meskwaki Road

Tama, IA 52339

11-3 
List of Agencies, Organizations, and Persons

to Whom Copies of This SEIS Are Sent

Name and Title Company and Address

Ron Sparkman

Chairman

Shawnee Tribe

P.O. Box 189

Miami, OK 74355

George Wickliffe

Chief 

United Keetoowah Band of Cherokee Indians of 

Oklahoma

P.O. Box 746

Tahlequah, OK 74457

John Blackhawk

Chairman

Winnebago Tribe of Nebraska

P.O. Box 687

Winnebago, NE 68071

Billy Friend

Chief

Wyandotte Nation

64700 East Highway 60

Wyandotte, OK 74370

LeRoy Benton City of Fulton, MO

Kay Drey Beyond Nuclear

Doc Fritzer Callaway County, MO

Bill Johnson City of Fulton, MO

Courtney Johnson Resident

Pamela Murray City of Holts Summit, MO

Ruth Shaefer Resident

Ed Smith Missouri Coalition for the Environment

3115 S. Grand Blvd, Ste 650

St. Louis, MO 63118

Frank Wise Resident

Fadi Diya

Senior Vice President and Chief Nuclear Officer

Ameren Missouri Callaway Energy Center

P.O. Box 620

Fulton, MO 65251

Sarah Kovaleski Ameren Missouri Callaway Energy Center 

PO Box 620

Fulton, MO 65251-0620

Regional Administrator U.S. Nuclear Regulatory Commission

Region IV

1600 E Lamar Blvd

Arlington, TX 76011

Regional State Liaison Officer U.S. NRC

Region IV

Public Affairs Officer U.S. Nuclear Regulatory Commission

Region IV

Senior Resident Inspector US NRC 

Resident Inspector's Office

Union Electric Company, Callaway Plant

8201 NRC Rd.

Steedman, MO 65077-1302

EIS Review Coordinator U.S. Environmental Protection Agency

Region 7

11201 Renner Blvd.

Lenexa, KS 66219 

11-4 
List of Agencies, Organizations, and Persons

to Whom Copies of This SEIS Are Sent

Name and Title Company and Address

Rebecca Wright

Member

Missouri Coalition for the Environment

3115 S. Grand Blvd., Ste. 650

St. Louis, MO 63118 

Harry Robertson

Attorney

Great Rivers Environmental Law Center

319 No. Fourth St., Suite 800A

St. Louis, MO 63102

Kay Drey

Member

Beyond Nuclear

515 West Point Ave., St. Louis, MO 63130

tritium3@sbcglobal.net

Arlene Sandler

Member

Missouri Coalition for the Environment

3115 S. Grand Blvd., Suite 650

St. Louis, MO 63118 

Edward Smith

Safe Energy Director

Missouri Coalition for the Environment

3115 S. Grand Blvd., Ste. 650

St. Louis, MO 63118 

esmith@moenviron.org

Pamela Todorovich St. Louis Resident

8 Fair Oaks, St. Louis, MO 63124

Steve Dinolfo Jefferson City Resident

1302 Roseview Drive, Jefferson City, MO 65101

stevedinolfo@aol.com

Robert Stewart

Regional Environmental Officer

U.S. Department of the Interior

Office of the Secretary, Denver Federal Center, 

Building 67, Room 118, PO Box 25007 (D-108), 

Denver, CO 80225-0007

R. Stout

Chief of Policy

State of Missouri, Department of Natural 

Resources

P.O. Box 176, Jefferson City, MO 65102

Jeffery Robichaud

Deputy Director

U.S. Environmental Protection Agency, Region 7

11201 Renner Boulevard

Lenexa, Kansas 66219

Mary Mosley Fulton Resident

1010 Vine St.

Fulton, MO 65251

mmosley@tranquility.net

Mark Kelly Dillsboro Resident

mark.kelly2011zr@gmail.com

Kevin Kamps

Member

Beyond Nuclear

6930 Carroll Avenue, Suite 400

Takoma Park, Maryland 20912

kevin@beyondnuclear.org

11-5 

12.0 INDEX

A 

accidents.. xxvi, xxvii, 2-7, 5-1, 5-3, 5-4, A-5, 

A-35, A-39, A-41, A-42, A-43, A-45, A-53, A-54, 

A-55, A-56, F-2, F-4, F-7, F-8, F-10, F-11, F-15, 

F-28, F-42, F-43

Advisory Council on Historic Preservation 

(ACHP)...xxiii, 1-8, 4-28, 4-29, 4-54, 4-59, 11-1, 

D-3, D-4, E-3 

aesthetic... 4-31, 8-14, 8-27, 8-36, 8-46, 8-47, 

8-48, 8-49, 8-56

alternatives . iii, xx, xxi, 1-6, 2-21, 5-2, 5-3, 6-3, 

6-4, 6-5, 6-6, 8-1, 8-2, 8-3, 8-12, 8-25, 8-30, 

8-34, 8-43, 8-52, 8-54, 8-57, 9-1, 9-2, 9-3, A-1, 

A-3, A-4, A-31, A-32, A-33, A-35, A-37, A-43, 

A-54, B-10, F-18, F-19, F-47

archaeological resources...xx, 1-8, 2-71, 2-72, 

2-74, 2-75, 2-76, 2-77, 2-78, 4-26, 4-29, 4-30, 

4-50, 4-53, 8-3, 8-14, 8-27, 8-37, 8-47, 8-56, 

B-10, D-1, G-6 

B 

biological assessment... 4-12, 4-15, A-65, 

A-78, H-1 

biota.... 2-39, 2-41, 4-8, 4-44, B-3 

boiling water reactor... B-8 

burnup... 2-7, A-57, A-58, B-14

C 

chronic effects... 1-4, 4-19, 4-25, 9-1, B-1, B-8 

Clean Air Act (CAA) .. xxiv, 4-41, 8-6, 8-16, 

8-18, 8-59, A-60, C-2 

closed-cycle cooling... 2-17, 2-19, 4-7, 4-45, 

8-9, 8-21, 8-31, 9-1, B-6 

consumptive use.. 4-5, 8-55, A-64 

cooling system .. xix, xx, 1-4, 1-5, 1-7, 4-7, 4-9, 

4-10, 4-45, 5-8, 7-1, 8-9, 8-55, 9-1, A-33, B-1, 

B-3, B-4, B-5, G-3, H-1 

core damage frequency (CDF)... xxiv, 5-4, 5-5, 

5-6, A-61, A-63, F-1, F-2, F-3, F-5, F-6, F-7, F-8, 

F-9, F-10, F-11, F-14, F-15, F-17, F-18, F-19, 

F-21, F-23, F-40, F-42, F-43, F-44, F-45

Council on Environmental Quality (CEQ)........ 

xxiv, 1-5, 4-30, 4-31, 4-55, A-37, A-74, A-75 

critical habitat.... 2-15, 2-45, 2-46, 2-53, 2-54, 

2-79, 4-11, 4-17, 4-18, 8-11, 8-23, 8-33, 8-43, 

A-67, C-3, H-1 

cultural resources.... 2-18, 2-71, 2-74, 4-29, 

4-30, 4-50, 8-47, A-71, C-1 

D 

decommissioning .. 8-56

demography ... 2-57

design-basis accident ... xxiv, 4-35, 5-1, B-10

discharges ... 1-10, 2-7, 2-8, 2-11, 2-17, 2-19, 

2-28, 2-32, 2-33, 2-34, 2-37, 2-41, 2-42, 2-48, 

4-4, 4-6, 4-7, 4-8, 4-9, 4-11, 4-12, 4-15, 4-23, 

4-24, 4-42, 4-43, 4-52, 8-21, 8-32, 8-34, 8-41, 

8-42, 8-55, A-60, A-61, A-64, A-66, A-68, A-70, 

A-74, B-2, B-3, B-4, B-8, F-32, G-3, G-5, G-6, 

H-6, H-7 

dose....xxviii, xxix, xxx, 2-7, 2-8, 2-9, 4-21, 4-22, 

4-23, 4-47, 5-5, 6-2, 8-34, 8-37, A-45, A-47, 

A-73, B-8, B-11, B-12, F-3, F-12, F-13, F-15, 

F-19, F-41, F-42, F-45

dredging... 1-10, 2-38, A-66 

E 

education... 2-57, 4-26, B-9, H-8 

electromagnetic fields... xxv, 1-4, 4-9, 4-25, 

4-48, 8-34, 9-1, B-1, B-7, B-8 

endangered and threatened species .. xx, 1-8, 

2-16, 2-46, 2-49, 2-50, 2-84, 4-11, 4-59, 8-11, 

8-23, 8-33, A-67, A-78, B-7, C-1, D-1, G-8, H-1, 

H-6, H-8 

Endangered Species Act (ESA)... xx, xxv, 1-8, 

2-46, 2-47, 2-48, 2-52, 2-53, 2-55, 2-79, 2-80, 

4-11, 4-12, 4-15, 4-16, 4-44, 4-56, 4-60, 8-11, 

8-23, 8-33, 8-43, C-3, D-1, E-6, G-5, H-1 

entrainment .. 2-48, 4-7, 4-12, 4-44, 8-10, 8-22, 

8-33, 8-42, 8-55, A-61, A-65, A-78, B-3, B-4, 

H-9, H-10, H-11, H-12, H-13

environmental justice (EJ)... xix, xx, 1-4, 1-7, 

2-85, 4-26, 4-30, 4-31, 4-35, 4-49, 4-52, 4-53, 

4-56, 8-3, 8-14, 9-1, B-1, B-15

essential fish habitat (EFH)... 2-46, C-3, D-1 

F 

Fish and Wildlife Coordination Act (FWCA).... 

C-3 

12-1 
Index

G 

Generic Environmental Impact Statement 

(GEIS) .. iii, xvii, xviii, xix, xx, xxii, xxvi, 1-4, 1-5, 

1-6, 1-7, 1-12, 2-13, 2-63, 2-89, 2-90, 4-1, 4-2, 

4-4, 4-5, 4-7, 4-8, 4-9, 4-11, 4-19, 4-20, 4-24, 

4-25, 4-26, 4-36, 4-37, 4-52, 4-58, 4-59, 5-1, 

5-2, 5-10, 6-1, 6-2, 6-3, 6-11, 7-1, 7-2, 7-3, 8-1, 

8-2, 8-10, 8-12, 8-13, 8-15, 8-22, 8-23, 8-24, 

8-25, 8-26, 8-30, 8-32, 8-34, 8-35, 8-38, 8-43, 

8-44, 8-45, 8-51, 8-52, 8-53, 8-54, 8-57, 8-61, 

8-62, 9-4, A-1, A-2, A-6, A-10, A-29, A-30, A-33, 

A-34, A-35, A-36, A-38, A-43, A-47, A-48, A-49, 

A-51, A-54, A-58, A-59, B-1, B-10, E-4, E-5, E-6 

greenhouse gases... xxvi, 4-40, 6-3, 6-10, 6-12, 

8-6, A-74 

groundwater ... xix, xx, xxvi, 1-4, 1-7, 2-18, 

2-19, 2-20, 2-21, 2-34, 2-35, 2-36, 2-37, 2-39, 

2-59, 4-5, 4-6, 4-7, 4-20, 4-21, 4-35, 4-36, 4-37, 

4-42, 4-43, 4-44, 4-52, 4-54, 8-3, 8-9, 8-10, 

8-21, 8-22, 8-28, 8-32, 8-34, 8-41, 8-42, 8-55, 

A-41, A-45, A-67, A-68, A-69, A-70, A-75, A-76, 

B-1, B-5, B-6, B-10, C-1 

H 

hazardous waste .. xxvi, 1-10, 2-10, 2-11, 8-5, 

8-15, 8-28, 8-38, 8-48, 9-2, 9-3, C-3 

heat shock... 4-7, 4-44, B-4 

high-level drum storage area... xxvi, 2-9 

high-level waste ... xix, 1-5, 6-1, 6-2, 7-1, 8-57, 

A-50, A-58, B-10, B-11, B-12, B-13, B-14

I 

impingement... 2-48, 4-7, 4-12, 4-44, 8-10, 

8-22, 8-33, 8-42, 8-55, A-61, A-65, A-78, B-3, 

B-4, B-5, H-9, H-10, H-11, H-12, H-13

independent spent fuel storage installation 

(ISFSI)....xxvi, 2-8, 4-38, 4-46, 4-47, 4-48, 4-49, 

4-50, A-5, A-48, A-58, A-60, A-62, A-77, G-2 

Indian tribes.... 2-73, 2-78, 4-29, 4-31, 4-35, 

A-52

invasive species... 2-40, 2-54, 4-46

L 

long-term dose .. A-51

low-level waste .. 6-1, B-13

M 

Magnuson-Stevens Fishery Conservation 

and Management Act (MSA) ... xxviii, C-3 

Marine Mammal Protection Act (MMPA).......... 

xxviii, C-3 

maximum occupational doses .. 4-20, B-8 

Missouri Department of Conservation... xxvii, 

2-1, 2-16, 2-21, 2-43, 2-44, 2-46, 2-47, 2-49, 

2-50, 2-51, 2-52, 2-53, 2-54, 2-55, 2-56, 2-63, 

2-74, 2-86, 2-87, 4-11, 4-15, 4-16, 4-17, 4-19, 

4-30, 4-38, 4-44, 4-45, 4-57, 4-59, 8-11, 8-23, 

8-34, G-5, G-7, G-8, G-9, H-3, H-7, H-8, H-12, 

H-14

Missouri Department of Natural Resources.... 

xxvii, 1-8, 1-10, 1-11, 2-10, 2-11, 2-17, 2-18, 

2-21, 2-23, 2-24, 2-32, 2-34, 2-36, 2-43, 2-49, 

2-57, 2-58, 2-59, 2-74, 2-80, 2-87, 2-88, 4-4, 

4-40, 4-41, 4-43, 4-57, 4-58, 8-6, 8-9, 8-17, 

8-18, 8-21, 8-22, 8-32, 8-38, 8-41, 8-52, 8-61, 

A-60, A-62, A-78, G-3, G-9, H-6 

mitigation... xix, xxxi, 1-5, 1-6, 2-37, 4-2, 7-1, 

7-3, 8-14, 8-27, 8-33, 8-37, 8-47, 8-55, 9-1, 9-2, 

A-33, A-35, A-43, A-55, A-66, A-78, G-5 

mixed waste.... xxvii, 2-11, 2-12, 8-57, B-14

N 

National Environmental Policy Act (NEPA)..... 

xvii, xviii, xxix, 1-1, 1-4, 1-7, 1-11, 1-12, 2-78, 

4-1, 4-3, 4-6, 4-10, 4-11, 4-20, 4-24, 4-30, 4-55, 

4-56, 4-59, 6-2, 6-3, 6-11, 7-3, 8-1, 9-1, A-3, 

A-5, A-31, A-32, A-33, A-34, A-35, A-36, A-37, 

A-38, A-48, A-51, A-58, A-59, A-77, A-78, 

A-171, B-1, B-2, B-11, B-13, D-1 

National Marine Fisheries Service (NMFS)...... 

xxix, 2-46, C-3 

National Pollutant Discharge Elimination 

System (NPDES) ...xxix, 1-10, 1-11, 2-11, 2-19, 

2-32, 2-81, 2-82, 4-12, 4-53, 4-60, 8-9, 8-10, 

8-21, 8-22, 8-23, 8-32, 8-33, 8-41, 8-42, 8-55, 

A-46, A-47, A-60, A-61, A-62, A-64, A-66, A-67, 

B-2, C-1, C-2, H-6, H-15

Native American tribes.. 2-73, 2-78, 4-29, 

4-35, A-52

no-action alternative... iii, xxi, 2-21, 4-10, 8-54, 

8-55, 8-56, 8-57, 9-2, 9-3, A-4 

nonattainment ... 4-2, 4-40, B-7 

12-2 
Index

O 

ODCM .. 2-7 

once-through cooling .... A-62, B-3, B-4, G-3 

P 

peak dose... B-12

postulated accidents .. 4-35, 5-1 

R 

radon .. 4-21, B-10, B-11

Ranney wells .. B-5, B-6 

reactor... xvii, xviii, xxi, xxx, xxxi, 1-4, 1-7, 2-1, 

2-7, 2-8, 2-11, 2-12, 2-13, 2-17, 2-19, 2-21, 

2-36, 2-37, 2-46, 3-1, 4-6, 4-7, 4-21, 4-23, 4-27, 

4-38, 4-47, 4-48, 4-49, 4-50, 4-53, 5-2, 5-3, 5-6, 

5-8, 6-2, 6-3, 6-5, 6-10, 7-1, 8-3, 8-11, 8-29,

8-30, 8-31, 8-32, 8-33, 8-34, 8-35, 8-36, 8-37, 

8-38, 8-55, 8-57, 8-59, 9-2, A-3, A-4, A-5, A-7, 

A-35, A-36, A-38, A-39, A-40, A-42, A-45, A-49, 

A-51, A-52, A-53, A-54, A-55, A-56, A-57, A-58, 

A-59, A-60, A-70, A-76, A-77, B-1, B-6, B-11, 

F-1, F-5, F-7, F-10, F-11, F-12, F-17, F-24, F-25, 

F-43, F-49, G-2, G-4, H-3 

Reform Conservation Area...2-1, 2-6, 2-15, 

2-21, 2-43, 2-44, 2-45, 2-47, 2-49, 2-63, 2-74, 

2-80, 2-83, 2-86, 4-15, 4-16, 4-29, 4-46, 4-47, 

4-52, 4-55, 8-11, 8-23, 8-34, G-4, G-7, G-9, H-3 

refurbishment.. xx, 2-24, 3-1, 4-2, 4-3, 4-10, 

4-27, 4-29, 4-42, A-75, A-77, B-2, B-3, B-5, B-7, 

B-8, B-9, B-10, F-43

replacement power . iii, xxx, 5-7, 8-1, 8-2, 8-12, 

8-15, 8-25, 8-34, 8-35, 8-38, 8-43, 8-57, A-32, 

F-40, F-41, F-43

S 

salinity gradients.. B-2 

scoping.... xvii, xviii, xix, 1-2, 1-6, 1-7, 1-11, 4-2, 

4-3, 4-4, 4-5, 4-7, 4-8, 4-9, 4-10, 4-19, 4-20, 

4-26, 4-38, 5-2, 6-2, 7-2, A-1, A-2, A-3, A-5, A-6, 

A-11, A-30, A-47, A-51, A-52, A-54, A-59, G-1 

seismic .. 2-24, 5-4, A-4, A-5, F-7, F-8, F-10, 

F-17, F-19, F-44

severe accident mitigation alternative 

(SAMA).. xx, xxi, xxxi, 5-2, 5-3, 5-4, 5-5, 5-6, 

5-7, 5-8, 5-9, 5-10, 9-1, 10-1, 10-2, 10-3, A-31, 

A-43, A-44, A-65, F-1, F-2, F-3, F-4, F-5, F-6, 

F-7, F-8, F-9, F-10, F-11, F-12, F-13, F-14, F-15, 

F-16, F-17, F-18, F-19, F-20, F-21, F-22, F-23, 

F-39, F-40, F-41, F-43, F-44, F-45, F-46, F-47, 

F-48, F-49, F-50, F-52

severe accidents...xx, xxxi, 4-35, 5-1, 5-2, 5-3, 

9-1, 10-1, A-34, A-35, A-54, B-10, F-1, F-4, F-7, 

F-39, F-42, F-43, F-52

solid waste... 2-9, 2-10, 6-1, 6-2, 7-2, 8-5, 8-15, 

8-16, 8-25, 8-27, 8-52, B-15, C-1, C-3 

spent fuel ... xix, xxvi, 1-5, 2-8, 4-47, 4-48, 6-1, 

6-2, 6-10, 7-1, A-34, A-35, A-36, A-38, A-40, 

A-41, A-48, A-49, A-50, A-51, A-52, A-53, A-54, 

A-55, A-56, A-57, A-58, A-59, A-77, B-10, B-11, 

B-12, B-13, B-14, G-2 

State Historic Preservation Office (SHPO)...... 

xxxi, 1-8, 2-71, 2-74, 2-78, 4-29, 4-30, 4-59, 

11-1, B-10, C-3, D-3, D-5, E-3, E-4, E-5 

State Pollutant Discharge Elimination 

System (SPDES)....C-1 

stormwater... 2-33, 2-37, 2-44, 8-9, 8-10, 8-21, 

8-22, 8-23, 8-32, 8-33, 8-41, 8-42, 8-55, A-68, 

A-70

surface runoff... 2-33, 2-34, 2-44, 4-43, 4-44, 

8-9, 8-10, 8-21, 8-23, 8-32, 8-33, 8-41, 8-55, 

A-68 

surface water.. xxxi, 2-21, 2-32, 2-59, 4-3, 4-4, 

4-6, 4-14, 4-21, 4-35, 4-36, 4-42, 4-43, 4-44, 

4-52, 8-3, 8-9, 8-10, 8-21, 8-22, 8-23, 8-31, 

8-32, 8-33, 8-34, 8-41, 8-42, 8-55, A-5, A-60, 

A-67, A-68, A-70, B-2, B-5, C-1, C-2, H-6 

T 

taxes... 2-67, 2-69, 2-70, 4-28, 8-13, 8-26, 8-35, 

8-45

transmission line corridors .. 2-16, 2-44, 2-45, 

2-47, 2-52, 2-53, 2-54, 2-55, 2-56, 4-12, 4-13, 

4-14, 4-15, 4-16, 4-17, 4-18, 4-38, 8-41, G-2 

transmission lines ...xxx, 2-12, 2-13, 2-15, 

2-16, 2-22, 2-45, 2-46, 2-47, 2-48, 2-49, 2-50, 

2-51, 2-52, 4-1, 4-2, 4-3, 4-9, 4-10, 4-12, 4-13, 

4-14, 4-18, 4-24, 4-25, 4-26, 4-28, 4-46, 4-47, 

4-48, 4-52, 8-11, 8-12, 8-34, 8-41, 8-42, 8-47, 

8-56, B-7, B-10, H-1 

tritium.... 2-37, 4-7, 4-20, 4-23, 4-37, 8-55, 

A-41, A-45, A-69, A-70

12-3 
Index

U 

U.S. Department of Energy (DOE) ....xxiv, xxv, 

4-25, 4-38, 4-55, 8-2, 8-38, 8-49, 8-51, 8-54, 

8-59, 8-60, 8-61, 8-62, 10-3, A-49, A-58, B-12

U.S. Environmental Protection Agency (EPA) ..

xxv, 1-1, 1-9, 1-10, 2-10, 2-11, 2-16, 2-23, 2-24, 

2-37, 2-63, 2-79, 2-84, 4-7, 4-19, 4-22, 4-40, 

4-42, 4-47, 4-53, 4-56, 6-2, 8-1, 8-2, 8-6, 8-7, 

8-8, 8-16, 8-18, 8-19, 8-20, 8-24, 8-29, 8-39, 

8-40, 8-59, 8-60, 8-61, 8-62, 9-2, 11-1, 11-4, 

11-5, A-8, A-29, A-30, A-36, A-37, A-45, A-47, 

A-48, A-49, A-50, A-60, A-66, A-69, A-73, A-74, 

A-78, B-13, C-1, E-5, G-2, G-3 

U.S. Fish and Wildlife Service (FWS) ..xxv, 

1-9, 2-16, 2-38, 2-40, 2-41, 2-46, 2-47, 2-48, 

2-49, 2-50, 2-52, 2-53, 2-54, 2-55, 2-78, 2-79, 

2-80, 2-84, 2-85, 2-89, 4-7, 4-11, 4-12, 4-13, 

4-14, 4-15, 4-16, 4-17, 4-18, 4-44, 4-53, 4-55, 

4-56, 4-59, 4-60, 4-61, 8-11, 8-23, 8-33, 8-43, 

11-1, 11-2, A-65, A-78, C-3, D-3, E-3, E-4, E-5, 

E-6, G-6, G-8, H-1, H-6, H-8, H-10, H-11, H-12, 

H-13, H-14, H-15

universal waste ... 2-11

uranium...xxviii, xxxi, 2-7, 2-8, 4-47, 6-1, 6-2, 

6-3, 6-4, 6-5, 6-6, 6-7, 6-8, 6-9, 8-12, 8-24, 8-25, 

8-35, 8-44, A-7, A-52, A-56, A-57, A-58, B-10, 

B-13, B-14

W 

wastewater... 1-10, 2-11, 2-17, 2-19, 2-37, 4-4, 

4-42, 4-43, 8-55, B-2, G-2 

Y 

Yucca Mountain ....A-49, A-50, B-12, B-13, 

B-14

12-4 
Appendix A 

COMMENTS RECEIVED ON THE CALLAWAY 

ENVIRONMENTAL REVIEW

A.COMMENTS RECEIVED ON THE CALLAWAY ENVIRONMENTAL 

REVIEW 

A.1 Comments Received During the Scoping Period

Union Electric Company, a subsidiary of Ameren Corporation and doing business as Ameren 

Missouri (Ameren or the applicant), submitted an application for a renewed operating license for 

Callaway Plant Unit 1 (Callaway), which included an Environmental Report (ER) 

(Ameren 2011a). The U.S. Nuclear Regulatory Commission’s (NRC’s) scoping process in 

response to this application began on February 24, 2012, with the publication in the Federal 

Register of the NRC’s Notice of Intent to conduct scoping (77 FR 11171). The scoping process 

included two public meetings both held at the Fulton City Hall Council Chambers in Fulton, 

Missouri, on March 14, 2012. Approximately 50 members of the public attended the meetings. 

After the NRC’s prepared statements about the license renewal process, the meetings were 

opened to members of the public for their comments. Attendees provided oral statements that 

were recorded and transcribed by a certified court reporter (NRC 2012a, 2012b). No written 

statements were submitted during the public meeting. Transcripts of the entire meeting were 

provided as an attachment to the Scoping Meeting Summary dated April 11, 2012 (NRC 2012c). 

In addition to the comments received during the public meetings, comments were also received 

through www.Regulations.gov. 

Each commenter was given a unique identifier, so every comment could be traced back to its 

author. Table A–1 identifies the individuals who provided comments applicable to the 

environmental review and the Commenter ID associated with each person’s set of comments. 

The individuals are listed in the order in which they spoke at the public meetings. Comments 

received through www.Regulations.gov are listed in the order in which they were received. To 

maintain consistency with the Scoping Meeting Summary (NRC 2012c), the unique identifier 

used in that report for each set of comments is retained in this appendix.

Specific comments were categorized and consolidated by topic. Comments with similar specific 

objectives were combined to capture the common essential issues raised by participants. 

Comments fall into one of the following general groups:

 Specific comments that address environmental issues within the purview of 

the NRC environmental regulations related to license renewal. These 

comments address the Category 1 (generic) or Category 2 (site-specific) 

issues identified in NUREG–1437, Generic Environmental Impact Statement

(GEIS) for License Renewal of Nuclear Plants (NRC 1996), or issues not 

addressed in the GEIS. The comments also address alternatives to license 

renewal and related Federal actions. There are comments that do not 

identify new information for the NRC to analyze as part of its environmental 

review.

 There are comments that address issues that do not fall within or are 

specifically excluded from the purview of NRC environmental regulations 

related to license renewal. These comments typically address issues such as 

the need for power, emergency preparedness, security, current operational 

safety issues, and safety issues related to operation during the renewal 

period. 

A-1 
Appendix A

Table A–1. Individuals Providing Comments During the Scoping Comment Period

Each commenter is identified below, along with his or her

affiliation and how the comments were submitted.

Commenter Affiliation (if stated) ID Comment Source

ADAMS 

Accession 

Number

Ed Smith

State Energy Director, 

Missouri Coalition for 

the Environment

1 Afternoon scoping

meeting

ML12095A400

Pamela Murray Alderman, 

City of Holts Summit 2 Afternoon scopingmeeting ML12095A400

Kay Drey

Member of Board 

of Directors, 

Beyond Nuclear

3

Afternoon scoping

meeting

Articles submitted

ML12095A400

ML12101A419

ML12101A423

Ruth Shaefer Resident 4 Afternoon scoping

meeting ML12095A400

Bill Johnson City Administrator, 

Fulton, MO 5 Afternoon scopingmeeting ML12095A400

Frank Wise Resident 6 Evening scoping

meeting ML12096A386

LeRoy Benton Mayor, 

City of Fulton, MO 7 Evening scopingmeeting ML12096A386

Doc Fritzer County Commissioner, 

Callaway County, MO 8 Evening scopingmeeting ML12096A386

Courtney Johnson Resident 9 Evening scoping

meeting ML12096A386

Anonymous Missouri 10 www.Regulations.gov ML12062A071

Kurt Wadzinski Bureau of Land Management 11 www.Regulations.gov ML12076A124

To evaluate the comments, the NRC staff gave each comment a unique identification code that 

categorizes the comment by technical issue and allows each comment or set of comments to be 

traced back to the commenter and original source (i.e., transcript or www.Regulations.gov) from 

which the comments were submitted.

Comments were placed into one of the technical issue categories, which are based on the 

topics that will be contained within the staff’s supplemental environmental impact statement 

(SEIS) for Callaway, as outlined by the GEIS. These technical issue categories, and their 

abbreviation codes, are presented in Table A-2.

A-2 
Appendix A

Table A–2. Technical Issue Categories

Comments were divided into 1 of the 8 categories below, 

each of which has a unique abbreviation code.

Code Technical Issue Page

AL Alternatives A-3

GE Geology A-4

LR License Renewal and NEPA Process A-5

OL Opposition to License Renewal A-6

OS Outside of Scope(a) not included

PA Postulated Accidents A-7

RW Radiological Waste A-6

SR Support of License Renewal A-6

(a) Outside of scope are those comments that pertain to issues that are not evaluated during the environmental 

review of license renewal and include, but are not limited to, issues such as the need for power, emergency 

preparedness, safety, security, and terrorism.

Comments received during the NRC’s scoping process applicable to the Callaway 

environmental review are presented in this section, along with the NRC response. The 

comments are presented in the order shown in Table A-2. The comments that are outside the 

scope of the environmental review for Callaway are not included here but can be found in the 

NRC’s scoping summary report, which can be accessed through the Agencywide Documents 

Access and Management System (ADAMS) at Accession No. ML13182A614.

A.1.1 Alternatives (AL)

Comment 10-5-AL: Ameren Missouri needs to focus on making Missouri more energy efficient 

(the last I heard we were ranked 42/50 states in efficiency) and invest in clean, renewable 

energy sources. Ameren’s own report in 2011 said there was no need for new generation and 

an old coal plant could be closed if they just invested in efficiency. Instead of doing this, they 

sought to charge ratepayers to build a new reactor, and have cut all but about $1 million from 

their renewable energy programs.

Response: In evaluating alternatives to license renewal, the NRC staff first selects energy 

technologies or options currently in commercial operation, as well as some technologies not 

currently in commercial operation but likely to be commercially available by the time the current 

Callaway operating license expires in 2024. Second, the NRC staff screens the alternatives to 

remove those that cannot meet future system needs. The remaining options are screened to 

remove those that have costs or benefits that cannot justify inclusion in the range of reasonable 

alternatives.

The NRC staff will then evaluate all reasonable alternatives to the proposed action that remain 

in Chapter 8 of the SEIS. In that chapter, the NRC staff examines the potential environmental 

impacts of alternatives to license renewal for Callaway, as well as alternatives that may reduce 

or avoid adverse environmental impacts from license renewal, when and where these 

alternatives are applicable.

In addition to evaluating alternatives to the proposed action, the NRC staff also, when 

appropriate, examines alternatives that may reduce or avoid environmental impacts of the 

A-3 
Appendix A

proposed action. The NRC staff does so to illustrate how such alternatives may mitigate 

potential impacts of license renewal.

The NRC staff considered 15 alternatives to the proposed action and then narrowed the list to 

the 4 alternatives considered. In addition to the alternatives evaluated in depth, the staff 

considered the no-action alternative (i.e., not renewing the operating license).

The alternatives evaluated in depth included the following:

 natural-gas-fired combined-cycle (NGCC), 

 supercritical pulverized coal-fired,

 new nuclear reactor, and

 combination generation (NGCC, wind power, and energy efficiency). 

Other alternatives considered, but dismissed, are listed below:

 oil-fired generation, 

 wind, 

 solar, 

 hydropower, 

 small modular reactor, 

 biomass energy, 

 fuel cells, 

 delayed retirement, 

 demand-side management, 

 purchased power, and

 no action. 

A.1.2 Geology (GE)

Comment 10-3-GE: The Callaway reactor is located in a flood plain, Tornado Alley, and near 

the New Madrid fault line, making this nuclear reactor susceptible to a variety of natural 

disasters, which is what ultimately did in Fukushima. We know that as buildings age they 

weaken, and nuclear reactors are no different. (This comment is also categorized under the 

Postulated Accidents section as comment 10-4-PA)

Response: Physical and environmental conditions related to site hydrology, meteorology, and 

geology were considered in the original site selection and design of all nuclear power plants, 

including Callaway, and are part of the licensing bases for operating plants. Such physical and 

environmental conditions are not affected by continued plant operations and are not expected to 

change appreciably during the license renewal term. Hazards from flooding, severe weather 

such as tornadoes, seismic events, and related natural phenomena are assessed in the 

site-specific safety review, where appropriate, that is performed for license renewals, rather than 

in the environmental review.

As part of the license renewal safety review, the NRC staff examines Ameren’s aging 

management programs to ensure that the effects of aging on structures and components will be 

adequately managed during the period of extended operation. This review, which is separate 

A-4 
Appendix A

from the environmental review, ensures adequate protection of the public’s health and safety 

during the 20-year license renewal period. The NRC staff documents its safety review in the 

Safety Evaluation Report related to the Callaway license renewal.

Furthermore, the NRC requires all licensees to take natural phenomena into account to maintain 

safe operating conditions at all nuclear power plants. When new information becomes 

available, the NRC evaluates the new information to determine if any changes are needed at 

existing plants. This ongoing reactor oversight process remains separate from license renewal. 

Thus, the topics of flooding, tornadoes, and earthquakes are outside the scope of the 

environmental review for Callaway. Nevertheless, the topics of flooding, tornadoes, and 

earthquakes are discussed in this SEIS as part of characterizing the environmental baseline 

(affected environment) and associated resource conditions of the Callaway site and vicinity, 

although no impacts or hazard analysis has been performed. Specifically, Section 2.2.2 of this 

SEIS includes a discussion of meteorological extremes and severe weather relative to the 

Callaway site. Section 2.2.3 describes the geologic environment of the Callaway site and 

vicinity, including its seismic setting encompassing the New Madrid fault zone. Section 2.2.4 

describes the surface water resources of the site and vicinity, including surface water flow. 

As noted in Section 2.2.4, the Callaway plant is situated on a plateau approximately 5 miles 

from the Missouri River and outside the river floodplain.

Unrelated to license renewal, the NRC completed the Generic Issues Program Safety/Risk 

Assessment Stage for Generic Issue 199 (GI-199) in August 2010, “Implications of Updated 

Probabilistic Seismic Hazard Estimates in Central and Eastern United States on Existing 

Plants,” which evaluated recent updates to estimates of the seismic hazard in the central and 

eastern United States. The results of the GI-199 Safety/Risk Assessment (NRC 2010a) stated 

that the currently operating nuclear power plants have an adequate safety margin for seismic 

issues. The NRC’s assessment stated that overall seismic risk estimates remain small, and 

adequate protection is maintained. NRC Information Notice 2010-18 (NRC 2010b) was then 

issued to nuclear power plants and independent spent fuel storage installations (ISFSIs). It 

provided notice of the NRC’s intent to follow the appropriate regulatory process to request that 

operating plants and ISFSIs provide specific information relating to their facilities to enable the 

NRC staff to complete the regulatory assessment during which candidate backfits would be 

identified and evaluated. The NRC then developed a draft generic letter to request needed data 

from power reactor licensees. Following the accident at the Fukushima Dai-ichi nuclear power 

plant in Japan resulting from the March 11, 2011, Great Tohoku Earthquake and subsequent 

tsunami, the NRC established the Near-Term Task Force (NTTF) as directed by the 

Commission. The NTTF’s assessment resulted in the issuance of letters on March 12, 2012, in 

accordance with Title 10 of the Code of Federal Regulations, Part 50, “Domestic licensing of 

production and utilization facilities,” Section 54, “Conditions of licenses,” paragraph (f) 

(10 CFR 50.54(f)), which addressed GI-199 in its entirety in recommendations 2.1 and 2.3 

regarding seismic and flooding reevaluations, respectively (NRC 2012). The NRC’s Japan 

Lessons Learned Project Directorate has now assumed the work of GI-199, including the 

evaluation of information received from and actions taken by power reactor licensees in 

response to the 10 CFR 50.54(f) letters.

A.1.3 License Renewal and NEPA Process (LR)

Comment 1-1-LR: As a preliminary matter, we request that the NRC extend the deadline for 

submitting written scoping comments until 30 days after the deadline for submitting hearing 

requests and contentions. That date is April 24th. 

A-5 
Appendix A

So while we believe it is appropriate for the NRC to hold public meetings now in order to explain 

a license renewal process to the public, it is unreasonable and unfair to require the public to 

comment on the scope of the Supplemental GEIS at this stage of the proceeding. When the 

Missouri Coalition for the Environment and other members of the public are reviewing the 

license renewal application that’s four hundred and—excuse me—the 1,200 page highly 

technical license renewal application and the 400 page highly technical Environmental Report.

With respect to the scope of the Supplemental Generic Environmental Impact Statement, the 

Missouri Coalition for the Environment has two overarching concerns. First, we believe it is 

unacceptable for the NRC to rely on the 1996 GEIS for the renewal of the Callaway license 

because it’s severely out of date. The NRC should postpone preparation of the Supplemental 

GEIS for the Callaway Unit until it [has] finalized and revised [the] GEIS that it issued for 

comment in July of 2009. In the alternative it should prepare an EIS, Environmental Impact 

Statement, for Callaway that addresses all environmental issues and does not rely at all on a 

16-year-old document.

Given that the draft version of the revised GEIS was issued fully two and a half years ago, 

continued reliance on this old document is utterly unjustified.

Response: The comment expresses concerns related to the amount of time allowed to provide 

comments and requests an extension to the scoping comment period. The NRC established 

the time period for comments on the scope of the environmental review for license renewal to 

balance the Commission’s goal of ensuring openness in the regulatory processes with its goal 

of ensuring that the NRC’s actions are effective, efficient, realistic, and timely. Interested parties 

were invited to provide comments during a 60-day period following the publication date of the 

Notice of Intent to Prepare an Environmental Impact Statement in the Federal Register 

(77 FR 11171). This is the standard amount of time allowed for comments on the license 

renewal scoping process.

The comment also suggests that the renewal process be postponed until the GEIS update is 

finalized. In June of this year, the NRC published a revised GEIS (NRC 2013). Consequently, 

information was added to this SEIS to reflect changes in the new GEIS. These updates may be 

found in Chapters 1, 2, 4, and 6.

Comment 4-1-LR: I’d like to defer my comments. I think the gentleman from the Coalition has 

said it.

Comment 11-1-LR: The Bureau of Land Management appreciates the opportunity to review 

and provide comments regarding Docket No. 50-483, NRC-2012-0001 (Callaway Plant 

Operating License Renewal). However, the BLM has no jurisdiction or authority with respect to 

this project, the agency does not have expertise or information relevant to this project, nor does 

the agency intend to submit comments regarding this project.

Response: These comments provide no new and significant information and will not be 

evaluated further in the development of the SEIS.

A.1.4 Opposition to License Renewal (OR)

Comment 3-1-OR: And all I’m here today is just to submit for the record of today’s scoping

meeting three documents. One is a brand new copy of the Economist. And its cover is called, 

“Nuclear Energy, the Dream That Failed.” And I really like the cover. And there are some long 

reports in here. So I think this is something that may be of interest to some of you. 

And then two pamphlets that I helped write. One is called, “Dirty, Dangerous, and Expensive: 

The Verdict Is In on Nuclear Power.” These are not in favor of nuclear power. And the other 

A-6 
Appendix A

one is called “The Lethal Legacy of the Atomic Age: 1942 to the Year 2012,” which is now to 

infinity. And it says, “A mountain of waste 70 years high, it’s time to stop making it.”

Response: The comment and its associated documents provide no new and significant 

information and will not be evaluated further in the development of the SEIS.

A.1.5 Postulated Accidents (PA)

Comment 10-4-PA: The Callaway reactor is located in a flood plain, Tornado Alley, and near 

the New Madrid fault line, making this nuclear reactor susceptible to a variety of natural 

disasters, which is what ultimately did in Fukushima. We know that as buildings age they 

weaken, and nuclear reactors are no different. (This comment is also categorized under the 

Geology section as comment 10-3-GE).

Response: Please see the response to this same comment at comment 10-3-GE, above.

A.1.6 Radiological Waste (RW)

Comment 6-1-RW: I’m just curious if the waste storage situation will have any effect on the 

license renewal. I hear that the Federal government has not yet achieved a permanent waste 

storage. How will that affect the renewal?

Comment 10-2-RW: Not only is there no permanent solution to the storage of the dangerous 

waste which results from energy generation, but it is also a very unsafe form of energy 

production.

Response: Radioactive and nonradioactive waste management is discussed in Section 2.1.2 

of this SEIS. The NRC’s evaluation of impacts of the uranium fuel cycle and waste 

management are addressed in Chapter 6 of this SEIS.

A.1.7 Support for License Renewal (SR)

Comment 2-1-SR: I am a local elected official. I’m not an environmentalist. But I do have 

some experience being a Callaway County resident. And that is that Ameren Missouri has had 

a history of being very responsive whenever an issue has been raised. And I’m sure that when 

the final regulations are implemented that that will continue. I certainly hope it will. And 

certainly I feel that past behavior and this case responsiveness is a good predictor of future 

behavior. So I do not have any specific concerns regarding that.

Being active in my community, I have been involved with Ameren Missouri and found them to be 

a good corporate citizen. I’d like to speak briefly about two projects Ameren Missouri has been 

involved with. One of those is a tree planting in Holts Summit. And they were a financial 

contributor. They also provided a great deal of labor when it came time to plant hundreds of 

trees and shrubs in Holts Summit. They provided expertise for our environmental project. They 

also throughout the State of Missouri are involved in the Missouri Relief Program. They are a 

major benefactor for this program, which provides free trees to cities and non-profit 

corporations. And I just think that that demonstration for the respect for the environment should 

also be taken into consideration. And I’d like to thank the NRC and the City of Fulton for 

providing this facility.

Comment 5-1-SR: The citizens of Fulton like the Ameren plant where it is. We like the 

operation. We like the staffing. We like the safety levels. We are incredibly involved in the 

safety review of the facilities out there. If anyone is concerned about the safety record, our 

records are available online if you want to take the time to look. The inspections are online. 

A-7 
Appendix A

You can even ask for the NRC to mail you—e-mail you, put you on a list and get an e-mail to 

you if you’d like. 

We’ve had a great positive relationship with the nuclear plant for the 27 years it’s been in 

operation and for the 10 years or so before that when it was under construction. We hope to be 

able to maintain that strong relationship for a long time. 

What’s good for Fulton, what’s good for Callaway County, what’s good for the State of Missouri, 

is good for the Callaway Plant and vice versa. What is good for us is good for them. It’s a great 

working relationship.

As I kind of said, having been here for 17 years, I have been involved in dozens and dozens of 

drills associated with the safety performance of the plant. The city is actively involved when it 

comes to the drills. The City Administrator, myself, is there. The Mayor is there, the Police 

Chief, Fire Chief, planning officials, city engineers, city utilities. We, through our actions, 

support and endorse the Ameren plant. 

And many times throughout the year, Ameren comes to us and says, “Is there anything we can 

do for you?” Sometimes we take them up on it; sometimes we don’t. But they are an incredible 

corporate citizen to the community of Fulton. 

And like I said, we would like to encourage the NRC to agree with this extension. 

Comment 7-1-SR: Ameren’s safety record has been an excellent one. And I know that safety 

is of the highest priority at the plant just through my dealings and associations with the Ameren 

personnel throughout the community. I endorse their request for license renewal of the current 

facility and encourage a positive response to their request. 

Ameren’s energy campus is a vital part of Callaway County’s and the State of Missouri’s 

economy. As the Environmental Protection Agency (EPA) regulations to continue to make

coal-fired plants cost-prohibitive to operate, nuclear plants such as the one here at Callaway will 

be of vital importance to the availability and reliability of electricity to the Midwest, of the State of 

Missouri. And, of course, without adequate economical supply of electric energy, our national 

and regional economies will be extremely negatively impacted. 

Again, thank you for your time. And again I endorse the Ameren’s request for a license 

renewal.

Comment 8-1-SR: Ameren has been a very good partner in the community, as LeRoy 

identified as a resident of Callaway County since a few years ago. Back in the ’50s, I moved 

here was to—and ever since they started buying up the property to build the original plant with a 

lot of speculation on what’s going to happen. But the fact that it’s been in operation for over 

25 years, we haven’t turned green yet. I think everybody has finally accepted the fact we do 

have a good base load facility here.

What's impressed me the most with the operation down there is that they set high standards for 

themselves for safety and operations. And it’s not just standards for this facility, but they want 

to be the industry standard. And that’s always impressed me with the management down there.

And as we go through our emergency planning drills, we meet on a regular basis. Every other 

year we have a greater drill with the NRC. In the off year, we still have the drill. And from those 

exercises we have a chance to improve upon what we’ve learned from the previous exercise, 

anything that’s changed during the course of the year that’s involved in the rollover in the 

personnel down there, so to keep everybody informed on what’s going on and keep in touch on 

it. But I think those have been very beneficial.

A-8 
Appendix A

One of the best benefits I think we’ve seen from Callaway County is that—an Emergency 

Preparedness that has made this county so much further ahead of other counties for natural 

disasters. And the advantage we’ve seen is that although most of our drills for probably 

20 years were all focused on what would happen if there was an emergency at the Ameren 

plant, we’ve got the same partners and players with the ambulance, with the law enforcement, 

with the Sheriff’s Department, with the ambulances. And it’s given us an opportunity to be ready 

for tornados, other storms, any type of natural disaster.

And over the last couple of years, other counties have started trying to prepare for disasters. 

Joplin is a perfect example. Even at Branson in the past year. We are so much further ahead 

in this county than some of the other counties because of Ameren being located in Callaway 

County. So we’re proud of that fact.

That's a big factor that we have, that Fulton and Callaway County have over a lot of other 

counties. So for that, I think that’s another plus for Ameren being here.

I think I’ve pretty well covered all the facts. I’ve been sitting there trying to scribble a few notes. 

But we would be very supportive of the extension of this facility. A few years ago when they 

replaced the turbines in there, we knew they were going to be asking for an extension of 

another 20 years. So we’re very supportive of that and hope that takes place.

Comment 9-1-SR: My generation sees the nuclear plant as jobs and opportunity as well as a 

provider of cost-effective, safe base load energy for our community. Many of my friends’ 

parents work for the plant. And through the years I’ve heard a lot of very positive comments 

about it from them.

Based on growing up here and seeing the professional career opportunities that Ameren 

provides, I decided many years ago that I would pursue a college degree that would make 

myself marketable to Ameren. I’m a student at Iowa State University studying chemical 

engineering and considering a minor in nuclear engineering. I can think of no better career than 

to be a chemical or nuclear engineer at the Callaway Nuclear Plant.

The extension being proposed at this hearing would provide me and those that came before me 

and those that will come after me job opportunities and clean, safe, reliable energy for many 

years to come. And I’d like to encourage the NRC to approve this license extension.

Response: These comments express support for nuclear power, the license renewal of 

Callaway, or both. The comments provide no new and significant information and will not be 

evaluated further in the development of the SEIS.

A.2 References

10 CFR 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic licensing of 

production and utilization facilities.”

77 FR 11171. U.S. Nuclear Regulatory Commission. “License Renewal Application for Callaway 

Plant, Unit 1, Union Electric Company.” Federal Register 77(37):11171–11173. 

February 24, 2012.

[Ameren] Ameren Missouri. 2011a. Callaway Plant Unit 1 --- License Renewal Application, 

Applicant’s Environmental Report; Operating License Renewal Stage. Fulton, MO. 

December 15, 2011. Agencywide Documents Access and Management System (ADAMS) 

Nos. ML113530372 and ML113540354.

A-9 
Appendix A

[NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG–1437, Volumes 1 and 

2. May 1996. ADAMS Nos. ML040690705 and ML040690738.

[NRC] U.S. Nuclear Regulatory Commission. 2012a. Official Transcript of Proceeding, 

“Callaway Plant License Renewal Public Meeting, Afternoon Session.” March 14, 2012. ADAMS 

No. ML12095A400.

[NRC] U.S. Nuclear Regulatory Commission. 2012b. Official Transcript of Proceeding, 

“Callaway Plant License Renewal Public Meeting, Evening Session.” March 14, 2012. ADAMS 

No. ML12096A386.

[NRC] U.S. Nuclear Regulatory Commission. 2012c. Summary of Public Scoping Meetings 

Conducted Related to the Review of the Callaway Plant, Unit 1, License Renewal Application. 

April 11, 2012. ADAMS No. ML12089A099.

[NRC] U.S. Nuclear Regulatory Commission. 2013. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. Washington, DC: NRC. NUREG–1437, Revision 1, 

Volumes 1, 2, and 3. ADAMS Nos. ML13106A241, ML13106A242, and ML13106A244.

A-10
Appendix A

A.3 Comment Letters and Meeting Transcripts

The following pages contain the comments, identified by commenter designation and comment 

number, from letters and public scoping meeting transcripts.

A-11
Appendix A

A-12

29 

to thank the Nuclear Regulatory Commission for having 

2 this public meeting today. 

3 So the Missouri Coalition -- I should have 

4 started reading my document first . The Missouri 

Coalition for the Environment appreciates the 

opportunity to submit comments to the Nuclear 

Regulatory Commission regarding the scope of the 

Supplement to the Generic Environmental Impact 

Statement of the license renewal for the Callaway 

1 The Missouri Coalition for the Environment 

12 is a 42 - year old independent statewide environmental 

13 non-profit. It includes members living near the 

14 Cal laway Nuclear Reactor. The Coalition has a long 

1 history of legal intervention with the Callaway 

Reactor that goes back four decades. Our long1 standing concern has been one of public safety and 

1 protection of our environment. 

1 The Coalition plans to intervene in the 

2 upcoming license proceedings regarding the Union 

2 Electric Company's license for renewal application. 

22 As a prel~m~nary matter, we request that the NRC 

23 extend the deadline for submitting written seeping 

24 

2 

comments until 30 days after the deadline for 

submitting hearing requests and contentions . That 

NEAL R. GROSS 

(202) 234-4433 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

1-1-LR I 
Appendix A 

A-13

30 

~ate is April 24th. 

2 So while we believe it is appropriate for 

3 the NRC to hold public meetings now in order to 

4 explain a license renewal process to the public, it is 

~reasonable and unfair to require the public to 

comment on the scope of the Supplemental GEIS at this 

stage of the proceedi ng . When the Missouri Coal ition 1-1-LR 

Continued 

for the Environment and other members of the public 

~re reviewing the license renewal application that's 

1 four hundred and -- excuse me -- the 1,200 page highly 

1 technical license renewal application and the 400 page 

12 ~ighly technical environment al report . 

13 With respect to the scope of the 

14 Supplemental Generic Environmental Impact Statement, 

1 the Missouri Coalition for the Environment has two 

pverarching concerns. First, we believe it is 

1 ~acceptable for the NRC to rel y on the 1996 GEIS for 

1 the renewal of the Callaway license because it's 

1 severely out of date . The NRC should postpone 

2 rreparation of the Supplemental GEIS for the Callaway 

2 pnit until it is finalized and revised GEIS that it 

22 issued for comment in July of 2009. In the 

23 ~lternative it should prepare an EI S, Environmental 

24 Impact Statement, for Callaway that addresses all 

2 environmental issues and does not rely at all on a 16-

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005·3701 www.nealrgross.com 
Appendix A

A-14

~1 

year-old document. 

2 Given that the draft version of the 1-1-LR 

Continued 

3 revised GEIS was issued fully two and a half years 

4 ago, continued reliance on this old document is 

utterly unjustified . 

Second the Coalition demands that the 

Supplemental GEIS address the environmental 

applications of the Fukushima Daiichi Nuclear Reactor 

accident, including the environmental risks posed by 

1 the NRC's apparent decision to postpone implementation 

1 of a number of the Fukushima Task Force 

12 recommendations for safety and environmental 

13 protection upgrades until some undetermined future 

14 time . 

1 The Supplemental GEIS should -- excuse me 

- - the Supplemental GEIS should recommendations - -

1 excuse me -- I'll just start over. 

1 The Supplemental GEIS should address all 

1 the Fukushima - - should address all the Fukushima Task 

2 Force recommendations that are relevant to Callaway . 

2 By (A) identifying which recommendations 

22 have been implemented and explaining how they have 

23 been impl emented . 

24 And (B) identifying all recommendations 

2 whose implementation has been postponed or explaining 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

1-2-0S I 
Appendix A 

A-15

32 

how that postponement will affect the safety and 

2 environmental risks posed by the reactor. 

3 Thank you for your time. 

4 MS. SALTER: Thank you, Mr. Smith. 

I would now invite Pamela Murray to come 

up to the podium. Ms. Murray is an Alderman with the 

city of Holts Summit. 

MS. MURRAY: Thank you for this 

opportunity to address everyone. I am a local elected 

1 official. I'm not an environmentalist . But I do have 

1 some experience being a Callaway County resident. And 

12 that is that Ameren Missouri has had a history of 

13 being very responsive whenever an issue has been 

14 raised. And I'm sure that when the final regulations 

are implemented that that will continue. I certainly 

hope it will. And certainly I feel that past behavior 

and this case responsiveness i s a good predictor of 

future behavior. So I do not have any specific 

concerns regarding that . 

Being active in my community, I have been 

involved with Ameren Missouri and found them to be a 

22 good corporate citizen. I'd like to speak briefly 

23 about two projects Ameren Missouri has been involved 

24 

2 

with . One of those is a tree planting in Holts 

Summit . And they were a financial contributor. They 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

I 

1-2-0S I 

Continued I 

2-1-SR I 
Appendix A

A-16

33 

also provided a great deal of labor when it came time ~~~--~ 

2-1-SR 

2 to plant hundreds of trees and shrubs in Holts Summit. Continued 

3 They provided expertise for our environmental project . 

4 They also throughout the state of Missouri are 

involved in the Missouri Relief Program. They are a 

major benefactor for this program which provides free 

trees to cities and non-profit corporations . And I 

just think that that demonstration for the respect for 

the environment should also be taken into 

1 consideration . And I'd like to thank the NRC and the 

1 City of Fulton for providing this facility . 

12 Thank you . 

13 MS. SALTER : Thank you, Ms . Murray . 

14 I ' d like to invite Kay Drey up to the 

1 podium . Ms. Drey is with Beyond Nuclear. 

MS . DREY: Hi, thank you for this, having 

1 this meeting today. My name is Kay Drey. I live in 

1 St . Louis. And I ' ve been a member of the Missouri 

1 Coalition for the Environment since its creation . And 

2 I'm also a member of the Board of Directors at Beyond 

2 Nuclear, an organization located in Tacoma Park, 

22 Maryland . 

23 And all I 'm here today is j ust to submit 

13-1-0RI 

24 for the record of today ' s scoping meeting three 

2 documents . One is a brand new copy of the Economist . 

(202) 234-4433 

Nt:AL K. ut<._.i~~ 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
Appendix A 

A-17

34 

And its cover is called, "Nuclear Energy, the Dream 

2 That Failed." And I really like the cover. And there 

3 are some long reports in here . 3-1-0R 

so I think this is Continued 

4 something that may be of interest to some of you . 

And then two pamphlets that I helped 

write . One is called, "Dirty, Dangerous, and 

Expensive : The Verdict I s in on Nuclear Power." 

These are not in favor of nuclear power. And the 

other one is called "The Lethal Legacy of the Atomic 

1 Age : 1942 to the Year 2012," which is now to 

1 infinity. And it says, "A mountain of waste 70 years 

12 high, it's time to stop making it . " 

13 And I have more copies i f anyone would 

14 like a copy . 

And so again, I do thank you for the 

opportunity to have this meeting here. 

MS . SALTER: With that, I'd like to invite 

Ruth Schaefer. 

MS . SCHAEFER: I'd like to defer my 

comments. I think the gentleman from the Coalition 

has said it. 

22 MS . SALTER: Okay, you are our last 

23 speaker . 

24 

2 

Oh, we have another card . 

invite Bill Johnson to the podium. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005·3701 

Al l right . I 

Pl ease introduce 

www.nealrgross.com 

4-1-LRI 
Appendix A

A-18

35 

yourself and, if you're affiliated with an 

2 organization, you can mention that too. 

3 MR. JOHNSON: Good afternoon . My name is 

4 Bil l Johnson . I'm the City Administrator of Fulton, 

Missouri, and I have been for the past 16 and a half, 

17 years . I'm here actually speaking as a citizen 

because the City Council has not of yet taken an 

official position on this. But I am 100 percent 

confident the City Council would be behind every word 

1 that I am about to say. 

1 The citizens of Fulton like the Ameren 

12 plant where it is. We like the operation . We like 5-1-SR 1 

13 the staffing. We like the safety levels. We are 

14 incredibly involved in the safety review of the 

facilities out there. If anyone is concerned about 

the safety record, our records are available online if 

you want to take the time to look. The inspections 

are online. You can even ask for the NRC to mail you 

-- email you, put you on a list and get an email to 

you if you'd like. 

We've had a great positive relationship 

22 with the nuclear plant for the 27 years it's been in 

23 operation and for the 10 years or so before that when 

24 it was under construction . We hope to be able to 

2 maintain that strong relationship for a long time. 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
Appendix A 

A-19

36 

What's good for Fulton, what's good for 

2 Callaway County, what's good for the State of 5-1-SR 

3 Missouri, is good for the Callaway Plant and vice Continued 

4 versa . What is good for us is good for them. It's a 

great working relationship. 

As I kind of said, having been here for 17 

years, I have been involved in dozens and dozens of 

drills associated with the safety performance of the 

plant. The city is actively involved when it comes to 

1 the drills. The City Administrator, myself, is there . 

1 The Nayor is there, the Police Chief, Fire Chief, 

12 planning officials, city engineers, city utilities. 

13 We through our actions support and endorse the Ameren 

14 plant. 

1 And many times throughout the year, Ameren 

comes to us and says, "Is there anything we can do for 

1 you?" Sometimes we take them up on it; sometimes we 

1 don't. But they are an incredible corporate citizen 

1 to the community of Fulton. 

2 And like I said, we would like to 

2 encourage the NRC to agree with this extension. 

22 Thank you. 

23 MS. SALTER: Thank you, very much . I do 

24 believe unless there's another yellow card back there 

2 that we don't have anyone else signed up to make a 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005·3701 www.nealrgross.com 
Appendix A

A-20

24 

1 So if you have a question, you can raise 

2 your hand and I'll bring the microphone to you. 

3 All right, a gentleman in the back . 

4 Please start by introducing yourself . 

MR. WISE: My name is Frank Wise of the 

6 city of Jefferson . I'm just curious if the waste 

storage situati on will have any effect on the license 

renewal . I hear that the federal government has not 

s yet achieved a permanent waste storage . How will that 

1C affect the renewal? 

11 MS. SALTER: Brian, you going to talk 

12 about that? 

13 MR. HARRIS : The waste storage, that's a 

14 separate regulatory process in another office within 

the NRC . So we focus specifically on the license 

16 renewal process. We are aware that's managed another 

1~ office within the agency. 

MS. SALTER: Is that something you will 

1S take into consideration in the license renewal or 

2C there's another process? 

21 MR. HARRIS: That's another process in 

22 which they'll handle your question. 

23 

24 

2c; 

MS. SALTER: Dennis. 

MR. MOREY: I just want to clarify on 

that, the waste storage issue. That what we're doing 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

16-1-RWI 
Appendix A 

A-21

29 

I'm sure that the endorsement will happen in the very 

2 near future. 

3 

4 

Ameren's safety record has been an 

excellent one. And I know that safety is of the 

highest priority at the plant just through my dealingsi

7_1_SR I 

and associations with the Ameren personnel throughout 

the community. I endorse their request for license 

renewal of the current facility and encourage a 

positive response to their request. 

1 Ameren's energy campus is a vital part of 

1 Callaway County's and the state of Missouri's economy. 

12 As the Environmental Protection Agency regulations to 

13 continue to make coal fired plants cost prohibitive to 

14 operate, nuclear plants such as the one here at 

Callaway will be of vital importance to the 

availability and reliability of electricity to the 

Midwest of the state of Missouri. And of course 

without adequate economical supply of electric energy, 

our national and regional economies will be extremely 

negatively impacted . 

Again, thank you for your time. And again 

22 I endorse the Ameren's request for a license renewal. 

23 Thank you. 

24 

2 

(202) 234-4433 

MS. SALTER: Thank you, Mr. Benton. 

We now invite Doc Kritzer to come up . 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
Appendix A

A-22

30 

He's a County Commissioner for Callaway County. 

2 MR. FRITZER: Good evening. It's Fritzer, 

3 but I've been called a lot worse . I hadn't really 

4 intended or planned to address the group tonight . 

I've been out of town today and our Presiding 

Commissioner came over this afternoon's meeting . And 

I made a few notes when I found out he had already 

addressed it. I understand you all had good 

attendance, so that was good. 

1 On behalf of the County Commission, our 

1 structure in Missouri I don't know if some of 

12 different states are all different on it. But we have 

13 three County Commissioners in each one of our 

14 counties. And Missouri has 114 counties. I also 

happen to be the President of the County 

Commissioner's Association for the state of Missouri. 

I was in South Missouri earlier today for 

a meeting down there with a regional group of the 

commissioners. And one of the questions they asked 

about was the status of the current Ameren plant and 

what's going to happen with Unit 2. And I know this 

22 isn't a discussion for Unit 2. But everyone is very 

23 supportive of that, too, for the record. 

24 

2 community 

(202) 234-4433 

Ameren has been a very good partner in the ~~~~ 

18-1-SR I 

as LeRoy identified as a resident of !Continued! 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
Appendix A 

A-23

2 

31 

Callaway County since a few years ago. Back in the 

'50s, I moved here was to and ever since they 8-1-SR 

Continued 

3 started buying up the property to build the original 

4 plant with a lot of speculation on what's going to 

happen . But the fact that it's been in operation for 

over 25 years, we haven't turned green yet . I think 

everybody has finally accepted the fact we do have a 

good base load facility here . 

What's impressed me the most with the 

1 operation down there is that they set high standards 

1 for themselves for safety and operations. And it ' s 

12 not just standards for this facility, but they want to 

13 be the industry standard . And t hat 's always impressed 

14 me with the management down there . 

1 And as we go through our emergency 

planning drills, we meet on a regular basis. Every 

1 other year we have a greater drill with the NRC. In 

1 the off year, 111e still have the drill . And from those 

1 exercises we have a chance to improve upon what we've 

2 learned from the previous exercise. Anything that's 

2 changed during the course of the year t hat's involved 

22 in the rollover in the personnel down there. So to 

23 keep everybody informed on what's going on and keep in 

24 touch on it . 

2 beneficial . 

(202) 234-4433 

But I think those have been very 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
Appendix A

A-24

32 

One of the best benefits I think we've 

2 seen from Callaway County is that an Emergency 

3 

4 

1 

Preparedness that has made this county so much further 18-1 -SR 1 

!Continued! 

ahead of other counties for natural disasters . And 

the advantage we've seen is that although most of our 

drills for probably 20 years were all focused on what 

would happen if there was an emergency at the Ameren 

plant, we've got the same partners and players with 

the ambulance, with the law enforcement, with the 

Sheriff's Department, with the ambulances. And it IS 

1 given us an opportunity to be ready for tornados, 

12 other storms, any type of natural disaster. 

13 And over the last couple of years, other 

14 counties have started trying to prepare for disasters . 

1 Joplin is a perfect example. Even at Branson in the 

past year. We are so much further ahead in this 

1 county than some of the other counties because of 

1 Ameren being located in Callaway County. So we're 

1 proud of that fact. 

2 That's a big factor that •11e have, that 

2 Fulton and Callaway County have over a lot of other 

22 counties. So for that, I think that's another plus 

23 for Ameren being here. 

24 I think I've pretty well covered all the 

2 facts . 

(202) 234-4433 

I've been sitting there trying to scribble a 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
Appendix A 

A-25

33 

few notes. But we would be very supportive of the 

2 extension of this facility. A few years ago when they 

3 replaced the turbines in there, we knew they were 

4 going to be asking for an extension of another 20 

years. So we're very supportive of that and hope that 

takes place. 

Thank you. 

MS. SALTER: Thank you. 

I have one final person that's signed up 

1 to speak. So if you're on the fence, now would be the 

1 time to give Dawn your card. 

12 And with that, I'd like to invite our 

13 final commenter at least as of right now . Courtney 

14 Johnson. 

1 MS . JOHNSON: Hi, good evening. My name 

is Courtney Johnson. And I'm 19 years old. I have 

1 lived in Fulton my entire life. So, you know, I grew 

1 up with a nuclear plant. It's always been right 

1 outside of town and that's just how it's always been 

2 since the time I grew up. 

2 My generation sees the nuclear plant as 

22 jobs and opportunity as well as a provider of cost23 effective, safe base load energy for our community. 

24 Many of my friends' parents work for the plant . And 

2 through the years I've heard a lot of very positive 

(202) 234-4433 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005·3701 www.nealrgross.com 

8-1-SR 

Continued 

9-1-SR I 
Appendix A

A-26

34 

comments about it from them. 

2 Based on growing up here and seeing the 

3 professional career opportunities that Ameren 

4 provides, I decided many years ago that I would pursue 

a college degree that would make myself marketable to 

Ameren . I'm a student at Iowa State University - 1--: =---, 

studying chemical engineering and considering a minor Continued 

in nuclear engineering . I can think of no better 

career than to be a chemical or nuclear engineer at 

1 the Callaway Nuclear Plant . 

1 The extension being proposed at this 

12 hearing would provide me and those that came before me 

13 and those that will come after me job opportunities 

14 and clean, safe, reliable energy for many years to 

1 come. And I'd like to encourage the NRC to approve 

this license extension. 

1 MS. SALTER: Thank you. 

1 So with that, that was the last person 

1 that signed up . And I don't see Dawn with any other 

2 yellow cards. I'll give you one final chance before 

2 we move to close the meeting. 

22 Okay, well, with that I'd like to thank 

23 everyone for coming and before I turn it over to 

24 Dennis for some final comments, a couple of quick 

2 things. 

(202) 234-4433 

We do have the evaluation forms in the back . 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
Appendix A 

A-27

PUBLIC SUBMISSION 

Docket: NRC-2012-0001 

Receipt and Availability of Application for License Renewal 

Comment On: NRC-2012-0001-0003 

Page 1 of 1 

As of: February 29, 20 12 

Received: February 29, 2012 

Status: Pending_Post 

Tracking No. 80fc899f 

(::omments Due: April 24, 2012 

Submission Type: Web 

&L/;p..-7' / o2? / .:2_) 

Y/ ~/C ///71 

License Renewal Application for Callaway Plant, Unit 1, Union Electric Company; Intent to 

Prepare Environmental Impact Statement 0 

Document: NRC-2012-0001-DRAFT-0001 ~D Comment on FR Doc # 2012-04315 · !···1 . ' .. ' 

_) 

.-) 

Submitter Information 

Address: Missouri 

General Comment 

:.0 

c 

r-

., .. 

(./) 

10-3-GE, 

10-4-PA 

Ameren Missouri needs to focus on making Missouri more energy efficient (the last I heard we 

were ranked 42/50 states in efficiency) and invest in clean, renewable energy sources. Ameren's 11 O-S-ALI 

own report in 20 II said there was no need for new generation and an old coal plant could be 

closed if they just invested in efficiency. Instead of doing this, they sought to charge ratepayers to 

build a new reactor, and have cut all but about $1 million from their renewable energy programs. 

By the time the current license expires in 2024, the market for these alternative energy sources 

will be established, making the continued operation of a nuclear reactor inordinately expensive in,...__-=-"'"'"' 

comparison. No, there is no guarantee the price of solar and wind generated power will go down 11 0-6-0S I 

in the next twelve years, but history and economics tell us that as technology advances and supply 

and demand increase, prices go down. 

. P-R~S -= ;!71Y-f-i>3 

~ ~C! r~@rr.J) 

https://fdms.erulemaking.net/fdms-web-agency/component/contentstreamer?objectld=09... 02/29/2012 
Appendix A

A-28

PUBLIC SUBMISSION 

Docket: NRC-2012-0001 

Page 1 of 1 

As of: March 14, 2012 

Received: March 14, 2012 

Status: Pending_Post 

Trackjng No. 80fd6fa6 

Comments Due: April 24,2012 

Submission Type: Web 

Receipt and Availability of Application for License Renewal 

Comment On: NRC-2012-0001-0003 

License Renewal Application for Callaway Plant, Unit 1, Union Electric Company; Intent to 

Prepare Environmental Impact Statement 

Document: NRC-20 12-000 I-DRAFT -0002 

Conunent on FR Doc # 2012-04 315 

c12p,I;L ;~ /2) 

7;7~/G /11/1 

Submitter Information 

Name: Kurt Wadzinski 

Address: 

626 E. Wisconsin Ave. 

Suite 200 

Milwaukee, WI, 53202 

Organization: Northeastern States Field Office 

Government Agency Type: Federal 

Government Agency: BLM 

. ·· _u 

·- • t 

! i 

--, 

:. i 

--....... .-,-1 

~ ! 

0 

General Comment 

The Bureau of Land Management appreciates the opportunity to review and provide comments 111 _

1

_LR I 

regarding Docket No. 50-483, NRC-2012-0001 (Callaway Plant Operating License Renewal). 

However, the BLM has no jurisdiction or authority with respect to this project, the agency does 

not have expertise or information relevant to this project, nor does the agency intend to submit 

comments regarding this project. 

~-;i(._P:JJ ;: /fj)u--iJ3 

~ ~ r~Cevo ) 

https://fdms.erulemaking.net/fdms-web-agency /component/contentstreamer?objectld=09... 03114/20 12 
Appendix A

A.4 Comments Received on the Draft SEIS

On February 12, 2014, the NRC issued the Generic Environmental Impact Statement for 

License Renewal of Nuclear Plants Regarding Callaway, Draft Report for Comment (NUREG–

1437, Supplement 51, referred to as the draft SEIS) to Federal, tribal, state, and local 

government agencies and interested members of the public. The EPA issued its Notice of 

Availability on February 21, 2014 (79 FR 9898), that included the draft SEIS. The public 

comment period ended on April 7, 2014. As part of the process to solicit public comments on 

the draft SEIS, the NRC did the following:

• placed a copy of the draft SEIS at the Callaway County Public Library in 

Fulton, Missouri; 

• made the draft SEIS available in the NRC’s Public Document Room in 

Rockville, Maryland; 

• placed a copy of the draft SEIS on the NRC Web site, on February 12, 2014, 

at http://www.nrc.gov/reading-rm/

doc-collections/nuregs/staff/sr1437/supplement51/; 

• provided a copy of the draft SEIS to any member of the public that requested 

one; 

• sent copies of the draft SEIS to certain Federal, tribal, state, and local 

government agencies; 

• published a notice of availability of the draft SEIS in the Federal Register on 

March 3, 2014 (79 FR 11834); 

• filed the draft SEIS with the EPA; and 

• announced and held two public meetings at the Fulton City Hall in Fulton, 

Missouri, on March 19, 2014, to describe the preliminary results of the 

environmental review, answer any related questions, and take public 

comments.

Approximately 35 people attended the meetings, and 6 attendees provided oral comments. A 

certified court reporter recorded the oral comments and prepared written transcripts of the 

meeting. A meeting summary is available in ADAMS (ADAMS No. ML14112A276). In addition 

to the comments received at the public meetings, the NRC received 13 comment submittals 

(i.e., e-mail, entry at Regulations.Gov, or letters with comments). Excerpts from the public 

meeting transcripts and all letters and e-mails are included in Section A.5 with labels marking 

individual comments.

To identify each individual comment, the NRC reviewed the transcript of the public meetings 

and each e-mail and letter received on the draft SEIS. The NRC identified statements related to 

the proposed action and recorded the statements as comments.

Each commenter was given a unique identifier, so every comment could be traced back to its 

author. Table A-3 identifies the individuals who provided comments applicable to the 

environmental review and the Commenter ID associated with each person’s set of comments. 

The individuals are listed in the order in which they spoke at the public meeting and in numerical 

order for the comments received in the transcript or by e-mails or letters.

A-29
Appendix A

Table A–3. Individuals Providing Comments During the Scoping Comment Period

Each commenter is identified below, along with his or her

affiliation and how the comments were submitted.

Commenter Affiliation (if stated) ID Comment Source

ADAMS 

Accession 

Number

R. Wright Missouri Coalition for the 

Environment 1 Afternoon scopingmeeting ML14112A380

H. Robertson Great Rivers Environmental Law 

Center

2 Afternoon scoping

meeting ML14112A380

K. Drey Beyond Nuclear 3 Afternoon scoping

meeting ML14112A380

A. Sandler Missouri Coalition for the 

Environment 4 Afternoon scopingmeeting ML14112A380

E. Smith Missouri Coalition for the 

Environment 5 Afternoon scopingmeeting ML14112A380

P. Todorovich St. Louis Resident 6 Afternoon scoping

meeting ML14112A380

S. Dinolfo Jefferson City Resident 7 Regulations.gov ML14084A319

R. Stewart U.S. Department of the Interior 8 Regulations.gov ML14090A401

A. Sandler University City Resident 9 Regulations.gov ML14092A183

R. Stout State of Missouri Department of 

Natural Resources 10 Regulations.gov ML14107A066

E. Smith Missouri Coalition for the 

Environment 11 Regulations.gov ML14107A067

J. Robichaud U.S. Environmental Protection 

Agency 12 Regulations.gov ML14107A108

NA NA 13 Regulations.gov ML14107A112

NA NA 14 Regulations.gov ML14107A130

M. Mosley Fulton Resident 15 Regulations.gov ML14107A131

M. Kelly Dillsboro Resident 16 Regulations.gov ML14107A068

K. Drey Beyond Nuclear 17 Regulations.gov ML14107A006

K. Kamps Beyond Nuclear 18 Regulations.gov ML14107A007

S. Kovaleski Ameren 19 Regulations.gov ML14113A372

Each comment has a comment ID consisting of two numbers separated by a hyphen. The part 

of the comment ID before the hyphen is the Commenter ID. The part of the comment ID after 

the hyphen is the comment number, which refers to the sequential comment given by the 

commenter. For example, comment xx-yy is the yy comment from the Commenter xx.

In response to the comments, the staff did not identify any new and significant information 

provided on Category 1 issues or information that required further evaluation of Category 2 

issues. Therefore, the conclusions in the GEIS and draft SEIS remained valid and bounding, 

and no further evaluation was performed.

The following sections present the comments, or summaries of the comments, along with the 

NRC responses to them. In response to the issues raised, consistent with 10 CFR 51.91, the 

staff provides explanations of why the comments do not warrant further response, citing 

A-30
Appendix A

sources, authorities, or reasons that support the explanation, as appropriate. When comments 

have resulted in modification or supplementation of information presented in the draft SEIS, 

those changes are noted within the NRC response. Changes made to the draft document are 

marked with a change bar (vertical lines) on the side margin of the page.

Comments are grouped in the categories presented in Table A-4.

Table A–4. Comment Categories

Comments were divided into the 14 categories below, 

each of which has a unique abbreviation code.

Code Category

AL Alternatives

LR License Renewal and NEPA Process (e.g., Rule Making)

GN Support or Opposition to License Renewal

OS Outside of Scope (a)

PA Postulated Accidents (e.g., SAMA)

RW Radioactive Waste and Monitoring (e.g., Waste Confidence, monitoring)

CL Text Clarification

WR Water Resource

AQ Air Quality

EC Ecology

HH Human Health

CC Climate Change

RE Refurbishment

CO Agency or Tribal Information

(a) Outside of scope are those comments that pertain to issues that are not evaluated during the environmental 

review of license renewal and include, but are not limited to, issues such as emergency preparedness, safety

(e.g., natural phenomena hazard and plant aging management), and nuclear power economy. 

Comments received during the comment period for the draft SEIS are presented in this section, 

in the order shown in Table A-4. 

A.4.1 Alternatives (AL)

The original sources for the comments in this category (alternatives) can be found in 

Section A.5 and are labeled with the following identifiers: 2-2, 12-6. These comments are 

extracted from the original sources.

Comment 2-2: And I would like to make some comments on the way the [DSEIS] dismisses 

certain energy generation alternatives. My peer phrased this as a question earlier, but why 

does the [DSEIS] only consider wind energy that is located in Missouri? While there is wind 

energy in Missouri the investor owned utilities, like Ameren Missouri don’t take any of that wind. 

They get their wind energy from Kansas and Iowa. And that is important because a graphically 

dispersed wind is the more reliable wind. However the [DSEIS] does not show that the State of 

Iowa presently gets almost 25 percent total electricity from wind. And so I don’t think it can be 

said that it is not a practical alternative.

I see no indication in the [DSEIS] that the NRC is aware of a project like Clean Line Energy 

Partners, which is currently before the Missouri Public Service Commission to build a direct 

A-31
Appendix A

current transmission line to carry wind energy from Kansas, across Missouri, to Illinois and 

Indiana. With a possibility, and not a certainty by any means, but a possibility of dropping 

500 megawatts of wind energy off in the Ameren Missouri service territory which would greatly 

increase Ameren’s wind energy capacity. The alternatives of the [DSEIS] consider a strictly 

baseload generation from coal, nuclear and natural gas. Well baseload, some of you were 

talking about the missing baseload. What exactly is baseload? The true source of reliability is 

not individual power plants like Callaway 1, or any other; it’s the availability of energy on the 

coal transmission grid. And certainly you are aware that nuclear plants frequently have both 

planned and unplanned outages. There are refueling outages every eighteen months at 

Callaway 1. And in its lifetime Callaway has had at least thirty-nine forced outages lasting from 

a few hours to about a month and a half. In 2011 and 2012 there were sixty-seven reactors 

worldwide, including of course, Fukushima Dai-ichi, and 18 percent of all the commercial light 

and power reactors in the world had extended unplanned outages. And at times like these it’s 

electricity that is available on the grid that picks up the slack. And you cannot say that an 

individual power plant is crucial to reliability.

Another alternative that is slighted by the [DSEIS] is demand side management, which means 

utility energy efficiency programs. Ameren Missouri is running some of these plans right now, 

but they minimize the effectiveness of demand side management in substituting for generating 

capacity. Missouri has a law called the Missouri Energy Efficiency Investment Act that obligates 

and regulates utilities like Ameren to achieve all cost effective demand side savings. And 

according to the Public Service Commission’s rules if they meet these goals then by the year 

2020 they will be saving 9.9 percent of the total annual energy replaced by efficiency. And that 

will continue to grow by 1.9 percent per year after that, Ameren, well, at least by Ameren’s 

figures from the Integrated Resource Plan for how much capacity it thinks can be replaced by 

demand side management. And yet, in the proceedings that I am aware of from the Missouri 

Public Service Commission [PSC], Ameren has been severely criticized by most of the parties, 

including PSC staff and the Office of Public Council, the consumer watchdog, that they have 

severely understated the potential for saving energy in Missouri by demand side management 

compared to studies that have been done in other states, and the results that have actually 

been achieved in other states, and in potential studies with other Missouri utilities. So I think 

that wind energy and demand side management deserve consideration as an alternative to 

baseload generation for coal.

Response:

This comment expresses concern about adequate discussion regarding the use of wind energy 

and energy efficiency as alternatives to Callaway license renewal. Consistent with 

10 CFR 51.91(a)(1) and 51.91(b), in Chapter 8 of the SEIS, the NRC evaluates potential 

replacement power alternatives to license renewal, including a discreet alternative that 

considers energy production generated from a combination of wind farms, natural gas-fired 

power plants, and from energy efficiency programs. However, it is the staff’s opinion that an 

alternative capable of producing as much baseload power as Callaway and which relied more 

significantly or exclusively on wind energy or energy efficiency is not deemed to be a 

reasonable option at this time.

This comment provides no “significant new information relevant to the proposed action” for this 

SEIS and, therefore, the staff made no changes to the SEIS as a result of the comment. 

Comment 12-6: Though a summary of impacts for each alternative is presented in Table 8-6, 

there does not appear to be a rigorous evaluation of the alternatives carried forward in the 

DSEIS for detailed review. In our view, the power of the evaluation required by NEPA, 

particularly an evaluation of a reasonable range of alternatives to a proposed action, is in a 

A-32
Appendix A

detailed and well-documented determination of whether it is good public policy to proceed with 

an action as opposed to another alternative. The discussion of this evaluation of a range of 

reasonable alternatives within Chapter 8 Environmental Impacts of Alternatives is not 

compelling and separation points critical to an informed decision to select the preferred 

alternative over a different alternative are not readily apparent.

As presently described in the DSEIS, the impacts of the alternatives considered are 

characterized according to rather broad categories, primarily in isolation from each other and 

the proposed action. It does not appear that the alternatives are evaluated in direct comparison 

to the license renewal/extended operation proposed alternative. In effect, the license renewal 

stands separately from all other alternatives and is evaluated on its merit alone. As mentioned 

previously in our comments, this intent is reflected in the project purpose and need statement. 

Additionally, some significant impacts associated with continued operation of any facility are not 

addressed within the DSEIS, but are addressed generically in the GElS or other NEPA

documentation, making a complete comparison of several large scale impacts of continued 

operation to the other alternatives impossible. Though we understand that many of the issues 

being discussed are addressed in the GElS, there are certainly some sections that would seem 

to warrant reproduction or reiteration within the individual supplemental EISs. It would appear 

that this would be an issue that would certainly bear inclusion in the SEIS. The FSEIS should 

incorporate the evaluation of all of the impacts of license renewal, addressed in other NEPA 

documentation, into the assessment of the preferred action and utilize this information to 

‘rigorously explore and objectively evaluate all reasonable alternatives’ as is required in 

40 CFR 1502.14(a).

Response: 

NRC’s license renewal process classifies environmental and human health issues as either 

Category 1 (generic to all nuclear power plants) or 2 (requires a site-specific evaluation).

Category 1 issues are termed ‘generic’ issues because the conclusions related to their 

environmental impacts were found to be common to all plants (or, in some cases, to plants 

having specific characteristics such as a particular type of cooling system). For Category 1

issues, a single level of significance was common to all plants, mitigation was considered, and 

the NRC determined that it was not likely to be beneficial. Issues that were resolved generically 

are not reevaluated in the site-specific supplement to the generic environmental impact 

statement on license renewal (SEIS) because the conclusions reached would be the same as in 

the GEIS, unless new and significant information is identified that would lead the NRC staff to 

reevaluate the GEIS’s conclusions. During the environmental review of license renewal of 

Callaway, the NRC staff makes a concerted effort to determine whether any new and significant 

information exists that would change the generic conclusions for Category 1 issues.

Category 2 issues are those that require a site-specific review. For each of the Category 2 

issues applicable to Callaway, the staff evaluated site-specific data provided by Ameren, other 

Federal agencies, State agencies, tribal and local governments, as well as information from the 

open literature and members of the public. From this data, the staff has conducted a sitespecific evaluation of the particular issues and presents its analyses and conclusions in the 

SEIS.

In the SEIS, the NRC staff considered all alternatives in detail, based on the technical review

of the potential environmental impacts found in Chapters 4, 5, 6, 7, and 8. The NRC staff

rigorously explored and devoted sufficient treatment to each considered alternative to

determine which alternatives were environmentally preferable. Each of the alternatives 

considered were evaluated in terms of potential environmental impacts by NRC technical

staff in the same resource areas evaluated for the proposed action in Chapter 4 of the 

A-33
Appendix A

SEIS. Potential environmental impacts in each resource area were determined to be

SMALL, MODERATE, or LARGE based on these technical evaluations in order to provide a 

clear basis for choice among the alternatives. These findings are presented in Chapter 8, 

Table 8-6 alongside the impacts of the proposed action—Callaway license renewal—in

order to present a clear and direct comparison of the overall impact levels. From this 

comparison, the NRC staff determined that these alternatives resulted in larger potentially 

adverse environmental impacts than the proposed action.

As allowed by NEPA and consistent with the staff’s standard review plan, the staff “incorporated 

by reference” the analysis and conclusion from the GEIS as appropriate in this SEIS 

(Chapters 4, 5, 6, 7, and 8).

The comment provides no “significant new information relevant to the proposed action” for this 

SEIS and, therefore, the staff made no changes to the SEIS as a result of the comment. 

A.4.2 License Renewal and NEPA Process (LR) 

The original sources for the comments in this category (rulemaking) can be found in Section A.5 

and are labeled with the following identifiers: 5-1, 5-4, 11-2, 12-1, 12-3, 12-11. These 

comments are extracted from the original sources.

Comment 5-1: Ed Smith, Missouri Coalition for the Environment. This is again, from 

Section 5.3 Severe Accidents and Drafts. It says, ‘Severe accidents initiated by external 

phenomenons such as tornadoes, floods, earthquakes, fires and sabotages have not 

traditionally been discussed in quantitative terms in FES(s) and were not specifically considered 

for the Callaway site in the GEIS,’ again, referencing the 1996 NRC document. ‘However the 

GEIS did evaluate existing impact assessment performed by the NRC and by the nuclear 

industry at forty-four nuclear plants in the United States and concluded that the risk from beyond 

design-basis earthquakes at existing nuclear plants is SMALL,’ small as in all capital letters. 

‘The GEIS for a license renewal performed a discretionary analysis of terrorist acts in 

connection with license renewals and concluded that the risks from such acts would be no 

worse than an endogen release expected from internally initiated events. In the GEIS the 

Commission concludes that the risk from sabotage and beyond design-basis earthquakes in 

existing nuclear power plants is SMALL. And additionally, that the risks from other external 

events are adequately addressed by the generic consideration of internally initiated severe 

accidents,’ again citing the 1996 GEIS, which I haven’t revisited that document recently, but I 

would imagine the threat of cybersecurity and cyberterrorism has escalated a bit [since] 1996.

‘Based on the information in the GEIS,’—I read a little bit of that earlier so I’ll skip that. ‘The 

staff identified no new significant information related to severe accidents during review of the 

Applicant’s Environmental Report, the Site Audit Scoping Process or the evaluation of other 

available information. Therefore, there are no impacts related to these issues beyond those 

discussed in the GEIS.’ 

That is what the NRC had to say and here is what the Coalition of the Environment wrote and 

will be submitting later. ‘The Missouri Coalition of the Environment believes that spent fuel

storage risks are one of the most serious unaddressed safety environmental issues facing the 

NRC today. The consequences of a pool fire are potentially catastrophic, affecting millions of 

people and costing millions of dollars. There is no excuse [to impose] this potential colossal risk 

on the public,’ and that’s because we have the Price-Anderson Act which caps utility liability at 

21 billion dollars, which is paid for by the nuclear utility customers to begin with. Taxpayers pay 

for the rest as most of you already know. Good luck getting that money from Congress these 

days.

A-34
Appendix A

Comment 5-4: MCE [Missouri Coalition for the Environment] participated in a 

Rulemaking Petition submitted February 18, 2014, and resubmitted it again today to the NRC 

Commission for context, seeking the reopening of the license renewal GEIS to consider new 

and significant information generated by the NRC’s proceeding on an expedited transfer of 

spent fuel. 

In that expedited spent pool transfer proceeding, the NRC staff found that if even a small 

fraction of the inventory of the Peach Bottom reactor pool was released to the environment in a 

severe spent fuel pool accident, an average area of 9400 square miles will be rendered 

uninhabitable and 4.1 million people would be displaced over the long term. This information is

new, because no EIS for reactor licensing, GEIS for reactor relicensing, or environmental 

assessment for standardization design certification has specified the size of the area that could 

be contaminated or the number of people who could be displaced for an extended period of time 

by a high-density spent fuel pool fire. And high density is exactly what we have at the Callaway 

reactor.

The information is significant because it underlines the NRC’s conclusion in environmental 

studies, such as the one being discussed today for reactor licensing and relicensing, that the 

impacts of spent fuel storage during reactor operation are insignificant. Such widespread 

contamination and long-term displacement of people can have enormous socioeconomic 

impacts, as witnessed by the effects of Fukushima, an accident where land contamination has 

disrupted the lives of a large number of Japanese citizens. It is estimated that over 

100,000 Japanese people are still displaced from their homes and communities. The 

Japan Times recently cited a report from local Fukushima prefecture authorities that found more 

people have died from stress-related illnesses and other health-related problems near the 

nuclear reactor than who died from the disaster-related injuries. This is just from the Fukushima 

prefecture and the areas around it. It is not from the entirety of this tsunami disaster. We saw 

some of these same things, I would add to that, after the [BP] oil disaster in the Gulf of Mexico.

Real world nuclear disasters—surely the impact on communities surrounding a nuclear reactor

are significant and therefore must be considered by the NRC in a meaningful way. The 

Peach Bottom review the NRC acknowledged—in the Peach Bottom review the NRC 

acknowledged for the first time the potential consequences of a pool fire severe enough to 

warrant mitigation regardless of how low the probability estimated by the NRC for such an 

accident. No EIS for reactor licensing, GEIS for reactor relicensing—I’ve said that already. 

Maybe I didn’t? Yes, I did. Sorry.

To ensure compliance with NEPA, The National Environmental Policy Act, in the consideration 

of this new and significant information the Missouri Coalition for the Environment and other 

Petitioners request that the NRC take the following actions:

Suspend the effectiveness of Table B-1 of 10 CFR, Part 51, Subpart A of Appendix B, A1B 1

[sic], which codifies the NRC’s generic finding that spent fuel storage in high-density reactor

pools during the license renewal term of operating reactors poses no significant environmental 

impacts and therefore need not be considered in individual reactor licensing decisions.

Suspend the effectiveness, in any new reactor licensing proceeding for reactors that employ 

high-density pool storage of spent fuel, of all regulations approving the standardized designs for 

those new reactors, and all environmental assessments approving severe accident mitigation

design alternatives. I wanted to make sure we pointed that out, because Ameren Missouri has, 

for the last [5] or so years, been interested in new nuclear power in Missouri.

Third, republish for public comment the following documents with respect to new and significant 

information regarding the environmental impacts of high-density spent fuel storage in reactor

A-35
Appendix A

pools and the costs and benefits of measures for avoiding or mitigating those impacts, including 

the license renewal Generic Environmental Impact Statement, [NUREG]–1437, Revision 1, 

June 2013, and the 2013 Revised License Renewal GEIS. Second, the EIS(s) from new 

reactors, third, the EA(s) for all new certifications for standardized reactor designs; again, 

because Ameren is interested in building new nuclear reactors in Missouri; duly modified NRC 

regulations that make or rely on the findings regarding the environmental impact for spent fuel 

storage during reactor operation, including Table B-1, and all regulations approving 

standardized reactor designs. 

And lastly, suspend all the reactor licensing decisions and license renewal decisions pending 

completion of the proceeding. I had a few more questions and if there is time at the end maybe 

we can talk some more, but thanks.

Comment 11-2: To ensure compliance with National Environmental Policy Act (NEPA) in the 

consideration of this new and significant information, MCE [Missouri Coalition for the 

Environment] and other petitioners requested the NRC to take the following actions:

 Suspend the effectiveness of Table B-1 of 10 CFR Part 51, Subpart A, 

Appendix B [‘Table B-1’], which codifies the NRC’s generic finding that spent 

fuel storage in high­density reactor pools during the license renewal term of 

operating reactors poses no significant environmental impacts and therefore 

need not be considered in individual reactor licensing decisions.

 Withhold Ameren Missouri’s license extension until a comprehensive risk 

assessment is undertaken by the NRC on the environmental impact of a 

high-, medium-, and low-density spent fuel pool fire at the Callaway 1 nuclear 

reactor. The risk assessment must be available for public comment once 

completed.

 Suspend the effectiveness, in any new reactor licensing proceeding for 

reactors that employ high-density pool storage of spent fuel, of all regulations 

approving the standardized designs for those new reactors and all 

Environmental Assessments approving Severe Accident Mitigation Design 

Alternatives. 

 Republish for public comment the following documents with respect to new 

and significant information regarding the environmental impacts of highdensity spent fuel storage in reactor pools and the costs and benefits of 

measures for avoiding or mitigating those impacts:

– the License Renewal Generic Environmental Impact Statement 

(NUREG–1437, Rev. 1, June 2013) (‘2013 Revised License Renewal 

GElS’);

– the EISs for all new reactors;

– the EAs for all new certifications for standardized reactor designs (MCE 

includes this in our comments given Ameren Missouri’s longstanding 

interest in expanded nuclear reactor development in Missouri),

 Duly modify NRC regulations that make or rely on findings regarding the 

environmental impacts of spent fuel storage during reactor operation, 

including Table B-1 and all regulations approving standardized reactor 

designs; and

 Suspend all new reactor licensing decisions and license renewal decisions 

pending completion of this proceeding.

A-36
Appendix A

Comment 12-1: The ‘Purpose and Need’ statement, as written, seems to warrant further 

explanation in the FSEIS, as the document appears to confuse project ‘purpose and need’ with 

the proposed action itself. The intent of 40 CFR 1502.14 is difficult to achieve when project 

purpose and need are so directly linked to the reissuance of an operating license. Clarification 

whether the purpose of the project is to meet the projected future energy demands of the region 

currently met by Callaway operation, or rather if it specifically pertains to a license renewal 

decision, would be beneficial. Without such clarification of purpose and need, the EPA

[Environmental Protection Agency] has concerns about whether a rigorous evaluation of the 

alternatives carried forward can truly be completed, as required by 40 CFR 1502.14.

Comment 12-3: We acknowledge that the DSEIS relies upon the GElS for its purpose and need 

statement and that this statement is generic to all NRC license renewal decisions. However, we 

believe it is important to comment on this feature of the DSEIS as it appears to influence the 

thoroughness of the document’s evaluation of alternatives. Both the GElS and the draft SEIS 

appear to confuse project ‘purpose and need’ with the proposed action itself. This 

misinterpretation could impede the complete and effective consideration of all reasonable 

alternatives in this DSEIS.

In a NEPA context the project purpose and need is to ‘provide an option that allows for power 

generation capability beyond the term of a current nuclear power plant operating license to meet 

future system generating needs, which may be determined by State, utility, and, where 

authorized, Federal decisionmakers’ (Section 1.2, Purpose and Need for the Proposed Federal 

Action).

However, the expiration of Callaway’s current operating license and the need to meet existing 

energy needs in the region are what the NRC is responding to ‘in proposing the alternatives

including the proposed action’ (40 [CFR] 1502.13), only one of which is the renewal of the 

existing license. For the purpose of meeting the existing and projected energy needs in the 

region, per 40 CFR 1502.14 (a), (b), (c), and (d), various alternatives to the relicensing of the 

Callaway plant should be fully considered and evaluated. This approach to purpose and need 

fully implements CEQ [Council on Environmental Quality] requirements regarding NRC’s 

responsibility to ‘rigorously explore and objectively evaluate all reasonable alternatives,’ ‘devote 

substantial treatment to each alternative considered in detail,’ ‘include reasonable alternatives 

not within the jurisdiction of the lead agency,’ and ‘include the alternative of no action.’ 

The intent of 40 CFR 1502.14 is difficult to achieve when project purpose and need are so 

directly linked to the reissuance of an operating license. An alternative which does not meet the 

project purpose and need, as stated, does not appear to be a reasonable or viable alternative. 

The FSEIS should clarify whether the purpose of the project is to meet the projected future 

energy demands of the region currently met by Callaway operation, or rather if it specifically 

pertains to a license renewal decision.

Comment 12-11: The EPA has some concern about the timing of this DSEIS and licensing 

action being conducted so far in advance [of the expiration date] of the existing license. The 

existing license expires in 2024. Therefore, this DSEIS in support of relicensing is being 

prepared more than 10 years before the existing license expires. While it is indeed logical to 

start this process well in advance of the expiration date to allow for the time needed to conduct 

an appropriate analysis and allow for public involvement in the process, 10 years may be 

excessive. Such a large span of lead time poses potential problems, such as the increased 

chance that conditions could change in material ways that would necessitate further 

supplemental environmental review and revisiting of the licensing decision. There is always a 

risk of changed circumstances, but that risk is much greater when a review is being done so far 

in advance of the action in question taking effect.

A-37
Appendix A

Response:

These comments express concern about the adequacy of the license renewal rule. These 

comments, except for 12-11, refer to the GEIS which is codified in 10 CFR 51, Subpart A, 

Appendix B; the “purpose and need” statement for this SEIS is specified in the GEIS. 

Comment 12-11 refers to the timeliness of the submittal of the Callaway license renewal 

application and the associated development of the SEIS, which is codified in 10 CFR 54.17(c). 

These comments are beyond the scope of the NRC’s environmental review. Comment 

petitioning to issue, amend, or rescind the license renewal rule is governed by 10 CFR 2.802, 

“Petition for Rulemaking,” and is beyond the scope of this environmental review for Callaway 

license renewal.

The staff noted that, in response to the Ameren’s application for license renewal, the staff has 

prepared this SEIS taking into consideration the best available information with respect to the 

requested licensing action, as allowed by NEPA. Relative to revisiting a licensing decision, the 

staff further noted, in accordance with the Atomic Energy Act, the Commission has the authority 

to suspend, modify, revoke, etc. (as warranted) an issued license regardless if it is a current 

license or a renewed license.

The comments provide no “significant new information relevant to the proposed action” for this 

SEIS and, therefore, the staff made no changes to the SEIS as a result of the comments.

A.4.3 Support or Opposition to License Renewal (GN) 

The original sources for the comments in this category (general) can be found in Section A.5 

and are labeled with the following identifiers: 7-1, 13-1. These comments are extracted from 

the original sources.

Comment 7-1: I strongly support the renewal of the Ameren Callaway Nuclear Plant license. 

This facility produces safe, reliable, and affordable electricity and has since its inception. I live 

approximately 20 miles from the facility and have no fear about the safety of this plant, or its 

ability to handle its spent fuel rods. This plant also supplies this electricity using a very small 

footprint. Additionally, I would recommend that the NRC provide a waiver for any 

precertification licensing studies to build an additional reactor on this [site]. There is ample 

room to build another facility, and large-scale reactors such as this plant produce electricity at 

cheaper rates than SMRs [small modular reactors].

Comment 13-1: I oppose renewing the license of Callaway Plant, Unit 1, because it was built to 

last only 30 years. It has lasted 30 years and there’s no guarantee that it is safe enough to 

remain in use longer than that. Let’s close this plant and support renewable energy without 

radioactive waste materials to manage.

Response:

The comments express general support of or opposition to Ameren, nuclear power, or license 

renewal of Callaway. 

The comments provide no “significant new information relevant to the proposed action” for this 

SEIS and, therefore, the staff made no changes to the SEIS as a result of the comments.

A.4.4 Outside of Scope (OS)

The original sources for the comments in this category (emergency; safety including natural 

phenomena hazard, plant aging, and Fukushima; or nuclear economy) can be found in 

A-38
Appendix A

Section A.5 and are labeled with the following identifiers: 1-1, 1-2, 1-3, 3-2, 3-3, 4-2, 5-3, 6-1, 

6-2, 6-3. These comments are extracted from the original sources.

Emergency Preparedness

Comment 6-2: St. Louis is only 60 air miles away. If there would be an accident radioactive 

iodine would shallow [sic] on the wind, a 30-mile-an-hour wind, and get to St. Louis in two hours. 

Could we be alerted? Would we have time to take those pills to protect our thyroid?

Response:

This comment expresses concerns regarding emergency preparedness in the unlikely event of 

a reactor accident at Callaway. Comments concerning emergency preparedness are beyond 

the scope of license renewal environmental review. This subject is under the NRC’s oversight

as a part of the current licensing basis. The NRC addresses the area of performance as part of 

ongoing regulatory oversight, including during the Callaway period of extended operation if the 

licenses are renewed.

Over the years, the combined efforts of the NRC, Federal Emergency Management Agency

(FEMA), Ameren, Missouri State and local officials, as well as thousands of volunteers and local

first responders (such as police, firefighters, and medical response personnel), have produced

comprehensive emergency preparedness programs that assure the adequate protection of the

public in the event of a radiological emergency at Callaway. Emergency preparedness planning

incorporates the means to rapidly identify, evaluate, and react to a wide spectrum of emergency

conditions. Emergency plans are dynamic and are routinely reviewed and updated to reflect an

ever-changing environment during the operation of Callaway, including during the period of 

extended operation if the Callaway licenses are renewed.

The Commission considered the need for a review of emergency planning issues during its

license renewal rulemaking proceedings on 10 CFR Part 54, which included public notice and

comment. As discussed in the Statement of Consideration for this rulemaking (56 FR 64966),

the programs for emergency preparedness apply to all nuclear power facilities. Requirements

for emergency planning are in the regulations at 10 CFR 50.47 and Appendix E to 10 CFR 

Part 50. Through its standards and required exercises, the Commission reviews existing 

emergency preparedness plans throughout the life of Callaway, keeping up with changing 

demographics and other site-related factors. Therefore, the Commission determination at the 

time of the rule change was that emergency planning was adequately considered on an ongoing 

basis and did not need to be part of license renewal.

The most recent emergency exercise for Callaway occurred on November 7, 2012. The results 

of the Callaway exercise are published in a FEMA report and are viewable at the following Web 

site:

http://www.nrc.gov/about-nrc/emerg-preparedness/related-information/fema-after-actionreports.html

The comment provides no “significant new information relevant to the proposed action” for this 

SEIS and, therefore, the staff made no changes to the SEIS as a result of the comment.

Safety Including Natural Phenomena Hazard and Plant Aging Management 

Comment 1-1: My name is Rebecca Wright and I live in St. Louis, Missouri. I have family 

members living in the Fulton area, and some in the Columbia area, and I used to live in this 

area, so I have concerns. 

And two of my concerns are about the relicensing of the Callaway Plant. I have questions about 

potential large catastrophes that are considered so unlikely that they are not planned for or not 

A-39
Appendix A

even asked about. And actually one of them, there’s no—you know we have seen it happen, 

but not to the extent that it would be called a [catastrophe]. And that’s loss of cooling water from 

the water intake structure of the Missouri River. And I’m not aware that we have—the 

Callaway Plant has a functioning onsite pond that is able to sustain the cooling of the reactor

and the spent fuel pool.

But in 2011 we all watched the waters rise in the flood, and six of the dams on the 

Missouri River, from the Fort Peck Dam in Montana, to the Gavins Point Dam in South Dakota; 

each hold[s] massive amounts of water in their reservoirs, but the dams are old and the 

reservoirs are really old. And stress could cause them to liquefy or the water on top of the 

dams, and the way the snow is when it opened, they could have failed and eroded, just totally 

eroded in the containment. And the failure of the Fort Peck Dam in Montana could have set off 

a domino effect creating like a tsunami down the Missouri River, moving out and flooding 

everything in its path. And the water intake, or the cooling water intake at the Callaway Plant 

could have been stripped away or at least over top, cutting off the electricity and functioning of 

the pumps and causing the loss of cooling water in the reactor core and could result in a 

meltdown and also cutting off the cooling water to the spent fuel pool. And the water is likely to 

sit there and remain there for a long period of time, kind of creating an embarrassment of fixes 

for them. So I think that’s a really major concern and I’m not sure that it is addressed. And 

also, in case of a drought the water level could be very low and the water could be too warm to 

effectively cool the reactor. 

And then another concern of mine is the failure of the electric power grid. And it could be from 

any reason, and it could be, you know, massive or regional. But one concern that has been 

raised is that scientists have warned about the possible failure of the [hydropower] grid due to 

massive solar flares. And there have been solar flares historically. And one was on September 

[first] in 1859, before there was much of an electric grid, and it was called the Carrington Event. 

And it set telegraph stations on fire and the networks experienced major outages. A similar 

event today could have catastrophic consequences, which is probably going to take—scientists 

have said the recovery could take an estimated [4 to 10] years. And that’s according to a report 

from the National Research Council. And I don’t think there has ever been any kind of—I’ve 

seen the question in the literature—but I don’t think that any EIS has ever addressed this for the 

Callaway Plant or anything of this kind. For as long as it would take to restore the entire power 

if the entire power grid failed, such loss of power and cooling water may result not only in the 

amount of the reactor coolant and loss of the cooling water in the spent fuel pools, it could lead 

to propagate a zirconium primer fire and result in the use of large amounts of radioactive 

materials. So, I guess I would like to know if there is any remedy other than not having nuclear 

power, which is a good plan?

Comment 3-3: I am still concerned about problems during construction of the Callaway Plant. 

There were defective embedded steel plates with studs that just fell off. They are supposed to 

be able to stay on to the embedded plates even falling from an airplane, and yet they fell off of 

the truss and so forth. And although the NRC discounted the significance of these embedded 

plates and the defective stud welding, I think this is still a huge concern. They have even 

eroded so far that one of the floors [has] collapsed. And I’m also still concerned about the 

honeycomb they found in the basemat. Due to mistakes in the construction of the basemat, 

there were huge holes in the basemat of the reactor containment building.

Comment 6-1: I just have a few comments. My name is Pamela Todorovich. I live at 8 Fair 

Oaks, St. Louis, Missouri. Concerns about the United States’ aging infrastructure [have] been in 

the news a lot lately, about bridges and highways, and rails, and gas lines. But an equally 

pressing issue is the aging nuclear plants. There are many people in Callaway County and in 

the St. Louis area that are very concerned about this.

A-40
Appendix A

Comment 6-3: Extending the license of the Ameren Nuclear Plant would be akin to, in my 

opinion, akin to driving a [40]-year-old car. You know something is going to happen. Pipes 

corrode. The crude that Kay mentioned builds up. Nuclear radiation leaks out. The gamma 

rays and [cobalt]-60 are very dangerous, making especially dangerous work for people who 

work in the plant. I was reading about another old plant. In 2007 the Vermont Yankee Nuclear 

Plant had a partial collapse of its cooling tower. And then again in 2010 the operators of that 

plant discovered that nearby groundwater had been contaminated by radioactive tritium, which 

apparently had leaked out from underground pipes. And yet, despite these transgressions the 

NRC extended Vermont Yankee’s license for operation the very next year. We continue to see 

many examples of these old plants releasing deadly nuclear isotopes into the environment and 

ultimately into our bodies. I was going to also mention, it occurred to me when I read that the 

spent fuel pools only have about [6] years left as far as the capacity. I would like to know what 

the plan is then? So as a mother, and a grandmother, and a concerned citizen, I am urging the 

NRC to reject the extension of this license and operation for the safety and health of all 

Missourians.

Response:

The comments are beyond the scope of the license renewal environmental review. The NRC 

addresses plant performance, including operational safety, as part of the ongoing regulatory 

oversight provided for all currently operating power reactors. Therefore, the NRC does not 

reevaluate current operation as part of the license renewal review. This is consistent with 

10 CFR 54.30, “[Matters] not subject to a renewal review.”

The NRC staff safety review addresses the aging management of structures and components 

within the scope of the license renewal separately from the environmental review. The staff 

examines Ameren’s programs and processes designed to manage the effects of structure and 

component aging and to ensure adequate protection of the public’s health and safety during the 

20-year license renewal period. This may result in additional aging management measures as 

necessary. The staff documents its safety review in the Safety Evaluation Report related to the 

Callaway license renewal. The staff has forwarded these comments to the safety review team 

for consideration as appropriate.

The comments provide no “significant new information relevant to the proposed action” for this 

SEIS and, therefore, the staff made no changes to the SEIS as a result of the comments.

Events at Fukushima Japan

Comment 1-3: ...and the fear of nuclear power in the Fukushima province. There is also a 

chance that another accident at a nuclear plant could make nuclear power reviled more than it 

already is to some people. The older this generation of nuclear power plants become[s], the 

more likely they will run into failure,... 

Comment 3-2: I believe that there is inadequate attention to the potential for a very huge 

accident, the [kind] that our world has seen in Fukushima and elsewhere.

Comment 4-2: We have been very lucky so far in the United States, but catastrophic accidents 

at Chernobyl and Fukushima have forced people from their homes, caused deaths, disease and 

birth defects, and produced contamination over a broad area. Radioactive water is still leaking 

into the Pacific Ocean [from] Fukushima. And one article I read reported that it would take [100] 

years to clean up the site of the disaster, and there have been quite a few near misses. Pick up 

a copy of We Almost Lost Detroit at the library; Arlene is a retired [librarian]. 

Comment 5-3: The Fukushima accident supposedly inspired the NRC to take a closer look at 

the problem in the expedited spent fuel transfer proceeding. But the Consequence Study the 

A-41
Appendix A

NRC staff turned out in 2013 was extremely inadequate and a complete disappointment. In 

spite of its inadequacies, however, the Consequence Study and the [cost-benefit] analysis that 

accompanied it, yielded new and significant information about the risks of pool fires and the 

benefits of reducing the density of fuel in the pools.

Response:

This comment expresses concerns about the safety issues and aging management of Callaway

plant systems in comparison to the accident at Fukushima, Japan. The aging management of 

Callaway structures and components within the scope of the license renewal safety review is 

addressed in the staff’s safety evaluation report (SER) for Callaway. This is separate from the 

environmental review, which focuses on the environmental impacts of license renewal. The 

comments have been provided to the license renewal safety review team for consideration in 

the development of the SER as appropriate. The SER for Callaway license renewal is available 

on the web for public inspection:

http://www.nrc.gov/reactors/operating/licensing/renewal/applications/south-texas-project.html

Fukushima lessons learned. On March 11, 2011, a massive earthquake off the east coast of

Honshu, Japan, produced a devastating tsunami that struck Fukushima. The six-unit

Fukushima Dai-ichi nuclear power plant was directly impacted by these events. The resulting

damage caused the failure of several of the units’ safety systems needed to maintain cooling

water flow to the reactors. As a result of the loss of cooling, the fuel overheated, and there was

a partial meltdown of the fuel contained in several of the reactors. Damage to the systems and

structures containing reactor fuel resulted in the release of radioactive material to the

surrounding environment.

In 2011, the Commission directed the staff to convene an agency task force of senior leaders

and experts to conduct a methodical and systematic review of the relevant NRC regulatory

requirements, programs, and processes, including their implementation, and to recommend

whether the agency should make near-term improvements to its regulatory system. As part of

the short-term review, the task force concluded that, while improvements are expected to be

made as a result of the lessons learned from the Fukushima events, the continued operation of

nuclear power plants and licensing activities for new plants do not pose an imminent risk to

public health and safety. 

The NRC will continue to evaluate the need to make improvement to existing regulatory

requirements based on NRC assessments of the Fukushima events as more information is

learned. To the extent that any revisions are made to NRC regulatory requirements, they would

be made applicable to Callaway regardless of whether or not Callaway has renewed licenses. 

The information available about the event, NRC assessment of the event, NRC actions in 

response to the event, and other information on the ongoing lessons learned are available for 

public inspection at the NRC web site:

http://www.nrc.gov/reactors/operating/ops-experience/japan-info.html

Nuclear Economy

Comment 1-2: And then I have concerns about finances that have already manifested in 

various regions of the United States and other countries with their nuclear power plants. 

Several financial predictors indicate that nuclear power plants are becoming too expensive to 

operate because of costly repairs. And some companies operating nuclear plants decided to try 

to recover their costs from customers or are begging for other subsidies. I’ve seen huge ads in 

the Wall Street Journal, and I’ve seen, even I guess the Callaway Plant, they are trying to do 

what for a new plant would be the cost of construction work in progress just to kind of put in 

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Appendix A

repair work, attaching it to the repairs bills. So other plants are on the verge of shutting down. 

Other financial challenges arise from a cheaper form and supply of electricity from renewable or 

fossil fuels, such as gas. We think that like within the next [20] years renewable energy will 

dominate as much as it has in Germany or Portugal. At least Germany is shutting down some 

of its plants and replacing that with renewables, because of global warming.

Response:

This comment raised concerns about the nuclear operational economy (i.e., operational 

efficiency, viability, or profitability) of Callaway. The NRC has no role in the operational 

economy of Callaway, except for the Callaway capability to comply with NRC requirements for 

protecting the public safety, security, and the environment. Furthermore, the NRC has long 

considered that determination of the economic viability of continuing the operation of a nuclear 

power plant is an issue that should be left to appropriate energy-planning decisionmakers (State 

regulatory and utility officials).

The comment provides no “significant new information relevant to the proposed action” for this 

SEIS and, therefore, the staff made no changes to the SEIS as a result of the comment.

A.4.5 Postulated Accidents (PA) 

The original sources for the comments in this category (accident) can be found in Section A.5 

and are labeled with the following identifiers: 4-5, 9-3. These comments are extracted from the 

original sources.

Comment 4-5: In Appendix F as in Frank, of this GEIS draft, page F-2, Ameren reports that 

‘Sixteen potentially cost-beneficial SAMA, Severe Accident Mitigation Alternatives, will be 

entered in Callaway’s long-range plan development process for further consideration.’ Arlene 

asks why isn’t the plan for these mitigation alternatives a part of the relicensing requirements 

right now? Are there accident mitigation alternatives that are most costly and therefore not 

being considered at all?

In its Executive Summary of the Draft the NRC ‘concluded that none of the potentially 

cost-beneficial Severe Accident Mitigation Alternatives related to adequately managing the 

effects of aging during the period of extended operation.’ I don’t think she’s talking about that. 

‘Therefore they may not be implemented as part of the license renewal.’ What does this mean? 

Which Severe Accident Mitigation Alternatives would be able to manage the effects of plant 

aging? How many additional sediment retention monitors will be needed as part of the waste 

water treatment system if the Callaway license were extended? What kind of monitoring would 

you have?

Comment 9-3: It’s all about the money. In Appendix F of this GElS draft, p. F-2, Ameren 

reports that ‘16 potentially cost-beneficial SAMA (Severe Accident Mitigation Alternatives) will 

be entered into Callaway’s long-range plan development process for further [implementation]

consideration.’ Why isn’t the plan for these mitigation alternatives part of the relicensing 

requirements right now? Are there accident mitigation alternatives that are more costly and, 

therefore, not being considered at all? In its Executive Summary in the draft, the NRC 

‘concluded that none of the potentially cost-beneficial SAMA relate to adequately managing the 

effects of aging during the period of extended operation. Therefore they need not be 

implemented as part of the license renewal.’ What does this mean? Which Severe Accident 

Mitigation Alternatives would be able to manage the effects of plant aging?

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Appendix A

Response:

The NRC staff reviewed the evaluation in the applicant’s ER of potential SAMA and participated 

in a SAMA site audit. Based on its review, the NRC staff concluded that none of the potentially 

cost-beneficial SAMA relate to adequately managing the effects of aging during the period of 

extended operation. Therefore, they need not be implemented as part of the license renewal, in 

accordance with 10 CFR 54.29 “Standard for issuance of a renewed license” and 10 CFR 54.30 

“Matters not subject to a renewal review.” 

Aging management of plant structures and components are specified in 10 CFR 54.21 

“Contents of application – technical information.” The review of cost-beneficial SAMA considers 

whether structures and components (SCs) associated with these SAMA: (1) perform their 

intended function without moving parts or without a change in configuration or properties and 

(2) that these SSCs are not subject to replacement based on qualified life or specified time 

period.

In addition, the NRC staff safety review addresses the aging management of structures and 

components within the scope of the license renewal separately from the environmental review. 

The staff examines Ameren’s programs and processes designed to manage the effects of 

structure and component aging and to ensure adequate protection of the public’s health and 

safety during the 20-year license renewal period. This may result in additional aging 

management measures as necessary. The staff documented its review in the Safety Evaluation 

Report.

The comments provide no “significant new information relevant to the proposed action” for this 

SEIS and, therefore, the staff made no changes to the SEIS as a result of the comments.

A.4.6 Radioactive Waste and Monitoring (RW)

The original sources for the comments in this category (waste) can be found in Section A.5 and 

are labeled with the following identifiers: 1-4, 2-1, 3-1, 3-5, 3-6, 4-1, 4-6, 5-2, 9-1, 9-2, 9-4, 11-1, 

12-2, 12-4, 12-7, 12-8, 14-1, 15-1, 16-1, 16-2, 17-1, 17-2, 17-4, 18-1. These comments are 

extracted from the original sources.

Radioactive Waste Effluent and Monitoring 

Comment 3-1: I have had to delay my effort to review the NRC’s 450-page Generic 

Environmental Statement on Callaway because I, and many other St. Louisans have been 

working hard instead to give the U.S. Army Corps of Engineers the responsibility for the 

radioactive waste that was illegally dumped in the West Lake Landfill in St. Louis County.

Comment 3-6: And I guess my number one concern about nuclear power plants is the routine 

releases of radioactive gases into the air and radioactive materials into the water, that in our 

case here in Missouri is dumped into the Missouri River, and also in streams in St. Louis and so 

forth. And I think that the fact that Union Electric or Missouri Ameren is seeking to operate the 

plant beyond the initial [40] years, for another [20] years, means more gaseous releases and 

routine liquid releases will happen. And I think that is really simply unacceptable.

Comment 4-1: She said my name is Arlene Sandler (phonetic). I live at 6947 Kirby Avenue in 

University City, Missouri and I am unable to attend this hearing today, although I am a complete 

cynic about the value of citizen testimony in a process that has historically been rubberstamped 

by the Nuclear Regulatory Commission with its industry-friendly regulations. I felt that I had to 

make a few comments about a technology that I have proposed for decades.

During my involvement with the Missouri Coalition for the Environment's efforts to compel 

Union Electric to provide increased monitoring for radioactive sludge from the Callaway Plant 

A-44
Appendix A

back in the 1980(s) I, Arlene Sandler, spent a lot of time, -- excuse me, reading Incident Reports 

which were required, -- That would be good if you don't mind, as long as she's bringing water. 

That's great. Thank you.

I might add that Arlene Sandler, who has written this statement, is a member of the Board, and 

has been for many years, of the Missouri Coalition for the Environment. But to continue her 

statement, during my involvement with the Missouri Coalition for the Environment's efforts to 

compel Union Electric to provide increased monitoring of radioactive sludge from the Callaway 

Plant back in the 1980(s), I, Arlene Sandler, spent a lot of time reading Incident Reports which 

were required published announcements of unexpected events at nuclear power plants. And as 

I read through many, many pages of examples of human error and equipment malfunctions at 

nuclear power plants all over the country I realized then that nuclear power was a very risky way 

to generate electricity, and I am even more convinced of that today.

Comment 4-3: Some concerns and questions about extending the Callaway license until 2044. 

(1) The potential risk of contaminating water. Lake Thunderbird, Lake Lochaweeno, and 

Canyon Lake are within a 6-mile radius of the plant. The longest river in North America, in 

Missouri, is 5 miles away. I am concerned about contamination not only from an accident, but 

from routine releases during the daily operation of the plant for an additional [20] years.

Comment 9-1: The potential risk of contaminating water. Lake Thunderbird, Lake Lochaweeno,

and Canyon Lake are within a 6-mile radius of the plant. The longest river in North America, the 

Missouri, is 5 miles away. I’m concerned about contamination not only from an accident, but 

from routine releases during the daily operation of the plant for an additional 20 years.

Comment 17-4: Extending Callaway’s operating license would burden living creatures and the 

environment with [20] additional years of emissions of certain radioactive liquid, solid, and 

gaseous materials generated at the plant for which no adequate filtering technologies exist. 

And no accurate monitoring equipment. That includes radioactive hydrogen (tritium), and 

dissolved and entrained noble gases (krypton that becomes rubidium and then strontium, and 

xenon that becomes cesium) that would be released to the air and then land, and to the 

Missouri River and the groundwater, during the routine operation of the plant. It doesn’t take an 

accident. 

Response:

The NRC’s regulatory limits for radiological protection are set to protect workers and the public 

from the harmful health effects (i.e., cancer and other biological impacts) of radiation on 

humans. Radiation standards reflect extensive scientific study by national and international 

organizations. The NRC actively participates and monitors the work of these organizations to 

keep current on the latest trends in radiation protection.

Callaway was licensed by the NRC with the expectation that it would generate, store, and 

release radioactive material to both the air and water during normal operation. The amount of 

radioactive material released from nuclear power facilities is controlled, measured, monitored, 

and known to be small. The radiation dose received by members of the public from the 

operation of Callaway is low and within NRC and EPA dose limits.

To ensure Callaway is operated safely, the NRC (a) licenses Callaway to operate, (b) licenses

Callaway operators, and (c) establishes license conditions for the safe operation of Callaway

including the adequate management of radioactive waste effluent and monitoring. The NRC 

staff provides continuous oversight of Callaway under the NRC’s inspection and enforcement 

programs. The NRC’s reactor oversight process integrates the NRC’s inspection, assessment, 

and enforcement programs. The operating reactor assessment program evaluates the overall 

operational performance of Callaway and communicates those results to Ameren, members of 

A-45
Appendix A

the public, and other government agencies. The assessment program collects information from 

inspections and performance indicators in order to enable the NRC to arrive at objective

conclusions about Callaway performance. Based on this assessment information, the NRC 

determines the appropriate level of agency response. The NRC conducts followup actions, as 

applicable, to ensure that corrective actions designed to address performance weaknesses 

were effective. While the NRC maintains regulatory oversight of Callaway, it is the responsibility 

of Callaway’s management to ensure that plant operation complies with NRC requirements at all 

times.

Chapter 4 of this SEIS discusses the Radiological Environmental Monitoring Program (REMP) 

that Callaway uses for environmental monitoring. The purpose of the REMP is to evaluate the 

radiological impact that operation may have on the environment. The program is designed to 

highlight and look at specific consumption pathways for the local population. The Callaway 

REMP is made up of three categories based on the exposure pathways to the public. They are 

as follows: atmospheric, aquatic, and ambient gamma radiation. The atmospheric samples 

taken around Callaway are airborne particulate, airborne iodine, milk (relative to atmospheric 

pathway), and vegetation. The NRC staff routinely inspects Callaway’s radioactive effluent 

monitoring and environmental monitoring programs for compliance with NRC regulations. In 

Chapter 4 of this final SEIS, the NRC staff reviewed Callaway’s data on radioactive effluents 

and environmental monitoring to determine the potential impacts of renewing the Callaway 

operating license.

The staff’s review of Callaway’s radioactive effluent control and environmental monitoring 

programs showed that radiation doses to members of the public were controlled within Federal 

radiation protection standards contained in Appendix I to 10 CFR Part 50, 10 CFR Part 20, and 

40 CFR Part 190 and concluded that the impacts would be SMALL during the license renewal 

term.

The comments provide no “significant new information relevant to the proposed action” for this 

SEIS and, therefore, the staff made no changes to the SEIS as a result of the comments.

Specific Comments on Radiological Environmental Monitoring Program

Comment 12-2b: The DSEIS effectively identifies the purpose and utilization of the Radiological 

Environmental Monitoring Program [REMP], a supplement to the Radioactive Effluent 

Monitoring Program, in relation to the Callaway plant operations and monitoring. The NRC’s 

assertion that ‘the impacts from radioactive effluents would be SMALL’ would further benefit 

from the adequate and thorough characterization of the data produced by these monitoring 

programs, as well as an identification of the monitoring sites used to collect data, the type of 

[medium] sampled at each location and a representation of monitoring trends relative to 

baseline data. A more complete discussion in the FSEIS of more detailed requirements and 

regulatory limitations set forth in the National Pollutant Discharge Elimination System permit 

would be valuable to the integrity of the assertions outlined in the Environmental Impacts of 

Operation section.

Comment 12-7: Section 4.9.2.2 addresses Callaway’s current Radiological Environmental 

Monitoring Program [REMP] and the Radioactive Effluent Monitoring Program, which provide a 

formal mechanism for determining the levels of radioactivity in the local environment and in 

facility effluents/releases. ‘The REMP supplements the Radioactive Effluent Monitoring 

Program by verifying that any measurable concentrations of radioactive materials and levels of 

radiation in the environment are not higher than those calculated using the radioactive effluent 

release measurements and transport models.’ Ameren issues an annual radiological 

environmental operating report that discusses the results of the REMP and files an annual 

report with the NRC that lists the types and quantities of radioactive effluent releases. The NRC 

A-46
Appendix A

reviewed [5] years of annual REMP data and effluent release reports in preparation of the

DSEIS. It is stated in this section that ‘Routine plant operational and maintenance activities 

currently performed will continue during the license renewal term. Based on the past 

performance of the radioactive waste management system in maintaining the dose from 

radioactive effluents at ALARA levels, similar performance is expected during the license 

renewal term...Continued compliance with regulatory requirements is expected during the 

license renewal term; therefore, the impacts from radioactive effluents would be SMALL.’ 

While the EPA recognizes that the approach to monitoring environmental and effluent 

radioactivity by Ameren under both programs appears to be very comprehensive, we suggest 

that the FSEIS should include a more detailed presentation of data than is provided in the 

DSEIS. Subsections within Section 4.9.2, Radiological Impacts of Normal Operations include a 

description of how the REMP is designed and a statement that the NRC’s evaluation of data 

resulted in ‘no indication of an adverse trend in radioactivity levels in the environment.’ There is 

no detail about monitoring locations or a document vehicle summarizing the actual data 

reviewed by the NRC. The subsection summarizing the effluent release data does provide 

some degree of quantified presentation, but, given the importance of the issue of radiological 

release, it is not prominent and combines both gaseous and liquid releases. We suggest that 

the FSEIS contain a map showing the locations of monitoring stations within the REMP, a table

listing those stations, the media sampled at each location, and a representation of monitoring 

trends relative to baseline data. Effluent release data should be characterized in the FSEIS 

specific to gaseous or liquid releases and sources of release within the facility.

A more complete discussion in the FSEIS of more detailed requirements and regulatory 

limitations set forth in the National Pollutant Discharge Elimination System permit would be 

beneficial to both Chapters 2 and 4. The NPDES permit for the Callaway Plant is possibly the 

most significant regulatory document available for public review. The permit regulates 11 

discharges to the Missouri River, and these discharges, arguably, constitute the largest 

opportunity for facility-generated contaminants to leave the facility site. The FSEIS should 

include a copy of the complete permit, including special conditions, and a section summarizing 

what parameters are monitored and which are limited and how the NPDES permit requirements 

dovetail with the Radioactive Effluent Monitoring Program.

Response:

The staff considered the best available information for its independent analysis in the SEIS. For 

consideration of non-radiological contaminants to leave the site, the NRC staff discussed

NPDES permit and impacts to water resources in Chapter 2 and 4 of the SEIS.

For radiological contaminants consideration, the NRC staff discussed Callaway’s REMP in 

Section 4.9.2.2 of the SEIS. REMPs at nuclear power plants were generically evaluated in the 

License Renewal GEIS (GEIS) as part of the Human Health issue listed in Table B-1 of 10 CFR 

Part 51 and classified as a Category 1 issue generic to all nuclear power plants. The GEIS 

contains a thorough discussion of the purpose, function, and description of the types of samples 

taken, the radiological analysis performed on those samples, and the results of the monitoring. 

The detailed analyses from the GEIS are incorporated by reference into the SEIS. As a 

Category 1 issue, the REMP discussion in the Callaway SEIS tiers off (is based on) the 

information in the GEIS so as not to repeat information that has already been evaluated in the 

LR GEIS, and the environmental impacts were determined to be SMALL for all nuclear power 

plants.

As part of the Callaway review, the NRC reviewed 5 years of REMP data to support its 

conclusion that there were no significant impacts or an adverse trend of radioactivity building up 

in the environment. Based on the NRC staff’s review of Ameren’s ER, the scoping comments, 

A-47
Appendix A

the site audit, and Callaway’s REMP data, the NRC staff found no new and significant 

information that would contradict conclusions in the GEIS. 

Information on the Callaway REMP, including types and numbers of samples, maps showing 

the locations of sampling stations, and radionuclide analysis are contained in Callaway’s Annual 

Radiological Environmental Operating Reports. The reference list at the end of Chapter 4 

contains a listing of the REMP reports reviewed by the NRC staff. These annual reports are 

available on the NRC’s public Web site. Therefore, there are no impacts beyond those 

identified and evaluated in the GEIS. 

The comments provide no “significant new information relevant to the proposed action” for this 

SEIS and, therefore, the staff made no changes to the SEIS as a result of the comments.

Specific Comments on Waste Confidence (Continued Storage of Spent Nuclear Fuel)

Comment 12-2a: The FSEIS should include updated information regarding the decisionmaking 

process for the revised Waste Confidence Rule in regards to Callaway. Additionally, the DSEIS 

indicates that there is a future necessity for the implementation of an independent spent fuel 

storage installation for the plant because the spent fuel pool does not have adequate storage 

capacity to take the plant to the end of its current operating license. By approximately 2020, the 

spent fuel pool will not have enough capacity to offload an entire core. The DSEIS states that, 

because this project is sufficiently far in the future, no specific plans have been developed. EPA

asserts that the FSEIS cannot sufficiently address the issue of the storage of spent nuclear fuel 

prior to completion of the Waste Confidence GEIS and completion and approval of a plan for the 

facility to properly manage spent fuel on- or off-site within the next 6 years. 

Comment 12-4: Storage, transportation, and disposition of spent nuclear fuel is of particular 

concern for all nuclear power plants. The U.S. Environmental Protection Agency recently 

commented on NRC’s Waste Confidence [continued storage] Draft Generic Environmental 

Impact Statement regarding the pending update to the Waste Confidence Rule. The EPA’s 

comment letter was submitted to NRC on January 15, 2014. The EPA appreciates the 

opportunity to comment on this important issue.

The FSEIS should include updated information regarding the decisionmaking process for the 

revised Waste Confidence Rule in regards to Callaway. It should address how radioactive 

waste handling, storage, and disposition will be conducted at Callaway in light of the updated 

rule, and the changes to current procedures that will be made as a result of the updated rule. 

The FSEIS should clarify the potential changes in direct, indirect, and cumulative impacts that 

may occur as a result of the updated rule.

The [Continued Storage Draft Generic Environmental Impact Statement] states that, if the 

results of the Waste Confidence Rule and supporting [generic] EIS identify information requiring 

a supplement to the SEIS, that an appropriate additional NEPA review will be performed for 

those issues prior to the NRC making a final licensing decision. Section 2.1.2 Radioactive 

Waste Management of the DSEIS states that “an independent spent fuel storage installation is 

proposed for the plant because the pool does not have adequate storage capacity to take the 

plant to the end of its current operating license. By approximately 2020, the spent fuel pool will 

not have enough capacity to offload an entire core.’ This section goes on to state that ‘Ameren 

intends to construct an independent spent fuel storage installation, but this project is sufficiently 

far enough in the future that no specific plans have been prepared at this time.’ Being that the 

spent fuel pool will reach its maximum capacity prior to the start of the proposed license renewal 

and that this renewal would extend the licensing period 30 years into the future, the EPA

contends that the timely preparation of a plan for construction of an ISFSI is indeed 

exceptionally relevant and pertinent to making a fully informed and effective license renewal 

A-48
Appendix A

decision. The unique circumstances of spent fuel management at the Callaway Plant make this, 

in our opinion, an issue for which significant information has been identified warranting a sitespecific analysis. This issue has not been adequately addressed in the DSEIS.

As the FSEIS cannot sufficiently address the issue of the storage of spent nuclear fuel prior to

completion of the Waste Confidence GEIS and completion and approval of a plan for the facility 

to properly manage spent fuel on- or off-site within the next 6 years, we request that the 

issuance of the FSEIS be delayed until those two issues are fully and finally addressed. As 

directed by the Commission, the NRC will not issue a renewed license before the resolution of 

waste confidence-related issues. We strongly echo this standpoint, but also recommend that no 

decision on the reissuance of Callaway’s license be made until and unless the Waste 

Confidence [Continued Storage Draft Generic Environmental Impact Statement] has been 

finalized and the facility-specific plan for spent fuel storage past 2020 has been finalized and 

approved by the NRC.

Comment 18-1: It is our opinion that circumstances in past [2] months in New Mexico have 

seriously undermined the assumptions that have given rise to the generic conclusion that atomic 

reactors like Callaway can be allowed to continue in operation, generate incredibly lethal highlevel radioactive waste products from fissioning, and that there will be adequate measures in 

place to keep those deadly genies bottled up for the necessary million years into the future.

(The U.S. EPA, under D.C. Circuit Court of Appeals orders issued in 2004 to rewrite its Yucca

Mountain dumpsite regulations, without an arbitrarily short 10,000-year cutoff period, in 2008 

admitted that commercial irradiated nuclear fuel is hazardous for a million years. However, 

even this unimaginably long timeframe is too short, for certain radioactive poisons contained in 

irradiated nuclear fuel are hazardous for far longer than a million years. Iodine-129, for 

example, has a 15.7-million-year half-life and, thus, a hazardous persistence of 157 to 314 

million years. In this sense, 40 or 60 years of electricity from the Callaway atomic reactor is but 

the fleeting byproduct. The actual product is forever deadly high-level radioactive waste, for 

which we have no solution in sight. In fact, we don’t even know what to do with the first cupful 

of high-level radioactive waste generated by Enrico Fermi at his Chicago Pile-I during the 

Manhattan Project on December 2, 1942. Nor do we know what to do with the first cupful of 

commercial high-level radioactive waste, first generated in 1957 at Admiral Hyman Rickover’s 

Shippingport, Pennsylvania, prototype reactor.)

On February 4, 2014, assumptions of very low probability crumbled at the Energy Department’s 

Waste Isolation Pilot Plant (WIPP) near Carlsbad, New Mexico, when a fire in a large salt truck 

raged for hours, deep underground. Ten days later, an even more unlikely mishap nonetheless 

happened: radioactive wastes containing plutonium and other transuranic poisons blew through 

the WIPP ventilation system, traveling 2,150 feet up to the surface, contaminating at most 

recent count 21 workers at the surface, and spreading radioactive material, including americium 

and plutonium, into the environment, which has fallen out some distance downwind.

Nearly [2] months after the fire, WIPP remains closed, and what happened underground 

remains unclear. It is not known whether the leak and the truck fire are connected; the collapse 

of a ceiling of one of the facility’s storage chambers, and/or a waste-drum breach could be to 

blame for the radioactivity release. As DOE contractors have sent robot probes to explore 

WIPP’s subsurface shafts, tunnels, and chambers, and the first DOE scout teams clad in triplelayered protection suits and Self-Contained Breathing Apparatus (SCUBA) are taking their 

tentative first steps underground to try to determine the root cause of the radioactivity release, 

the extent of subterranean contamination, and the risks associated with decontamination and 

potential ‘restart’ of WIPP, the future of the world’s only operating high-hazard radioactive waste 

repository is uncertain.

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Appendix A

The truck fire is believed to have started when diesel fuel or hydraulic fluid leaked inside a 

truck’s engine compartment. The fire consumed the driver’s compartment and the truck’s large 

front tires, which produced copious amounts of thick black smoke, prompting 86 workers to be 

evacuated. Six workers were treated at the Carlsbad hospital for smoke inhalation, and another 

seven were treated at the site. Workers have not been allowed back in the mine since.

The Feb. 14th radioactivity release compounded this prohibition on workers entering the 

underground all the more, apart from the small teams of scouts in thick protective suits 

mentioned above, at least until the extent of underground contamination is determined, as well 

as what will be required in the way of decontamination for worker protection during facility 

operations.

The Energy Department investigation report of March 14 concluded the truck fire could have 

been prevented had the contractor and Energy Department site managers bothered, after being 

repeatedly warned, to remove a buildup of flammable material in the mine, to regularly maintain 

trucks and equipment, and to correct emergency response deficiencies. Moreover, the 

automatic fire suppression system had been turned off before the fire.

Then there was also the radioactivity leak, which may or may not be connected to the truck fire. 

Among the various possible causes of the radioactivity leak is a waste drum breach, now under 

consideration. Waste drums containing trans-uranics [sic] generate hydrogen, methane, and 

other volatile gases, which, if unvented, can build up and breach their burial container. If 

exposed to an ignition source, such gases could also explode.

Concerns have also been raised about the possibility of a storage room ceiling or wall collapse. 

Eventually, when WIPP closes, sometime after 2030, the salt formation is expected to slowly 

‘flow’ and ‘grow,’ and eventually seal off the drums of radioactive waste. But this was not 

expected to happen until long after the repository is filled and closed. If a collapse has already 

occurred, just 15 years after the facility opened, it will raise additional questions about WIPP’s 

ability to ensure engineered barriers and institutional controls will work for a 10,000-year period, 

as required by law and regulation. (As mentioned above, EPA’s court-ordered, current Yucca 

Mountain regulations, for commercial irradiated nuclear fuel and nuclear weapons complex 

high-level radioactive waste disposal, require a million years of hazard being taken into account 

under [Federal] regulations.)

Environmental groups including Beyond Nuclear, Missouri Coalition for the Environment, and 

three dozen others, engaged as a coalition in the NRC’s pending ‘Nuclear Waste Confidence’ 

Environmental Impact Statement proceeding, have warned, authoritatively, of the dangers of 

storing commercial irradiated nuclear fuel in bedded salt formations.

On behalf of this environmental coalition, Dr. Arjun Makhijani, President of Institute for Energy 

and Environmental Research, filed a formal declaration with the NRC on December 20, 2013 

(http://www.cleanenergy.org/wp-content/uploads/MakhiianiDeclaration.pdf), in which he stated: 

(p. 6/70)

Disposal impacts are relevant because they are part of the waste confidence finding that a 

mined geologic repository is feasible. By definition of such feasibility, such a repository must 

meet reasonable health and safety standards. Moreover, we note that Table S-3 at 

10 CFR 51.51 is invalid for estimating high-level waste disposal impacts. Among other things, 

its underlying assumption of disposal in a bedded salt repository for spent fuel disposal was 

repudiated by the NRC itself in 2008. (citation: U.S. Nuclear Regulatory Commission. 

10 CFR Part 51: [Docket ID-2008-0482]: ‘Waste Confidence Decision Update,’ 

Federal Register, v. 73, no. 197 (October 9, 2008): pp.59555. On the Web at 

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Appendix A

http://www.gpo.gov/fdsys/pkg/FR-2008-l0-09/pdf/E8-23381.pdf. ‘FR DOC # E8-23381’ 

‘Proposed Rules’)

(p. 9/70)

Proposed Table B-1 is inconsistent with another regulation that also makes a finding on the 

same subject: Table S-3 in 10 CFR 51.51.[footnote 1] Table S-3 summarizes the NRC’s 

conclusion that the impacts of spent fuel disposal will be zero, based on the assumption that 

spent fuel will be disposed of in a bedded salt repository. Proposed Table B-1 contradicts 

Table S-3 by concluding that long-term doses could be as high as 100 millirem per year. But 

the NRC does not attempt to reconcile proposed Table B-1 and Table S-3; nor does it address 

the fact that in the 2008 Draft Waste Confidence Update, it repudiated bedded salt as a geologic 

medium for a repository.[footnote 2] Nothing in the NRC’s response to public comments on this 

point negated this repudiation of the unsuitability of bedded salt for spent fuel 

disposal.[footnote 3]

Dr. Makhijani’s conclusion is that ‘[t]he NRC’s understanding today is that radiation doses to the 

public could be well above the zero exposure assumed in Table S-3.’ (Statement p. 41/70).

I understand that there is an ongoing rulemaking proceeding over waste confidence, but the 

point to be made here, in the context of the Callaway atomic reactor proposed 20-year license 

extension case EIS, is that there is serious recent new information that calls into question the 

Table S-3 assumptions that allowed Callaway to be licensed in the first place, much less 

granted a 20-year extension and allowed to generate hundreds of additional metric tons of 

forever deadly, highly radioactive irradiated nuclear fuel. The NEPA document for the 20-year 

license extension application cannot be considered thorough and fully disclosing without 

scientific reconsideration of the assumption that the dangerous garbage from nuclear fissioning 

will not pose horrific hazards to less-informed and more-vulnerable populations in the poorer 

(which are likely to be found in the overpopulated) world of the future.

The NRC itself has repudiated the science of WIPP, at least in regards to the disposal of 

commercial irradiated nuclear fuel, containing concentrated thermal heat loads which can 

deform and ‘fail’ (collapse) engineered bedded salt chambers. Yet, NRC still, nonetheless, 

relies on that now-discredited and obsolete science for one of the fundamental driving rationales 

for commercial nuclear power. The time of reckoning commenced February 4. Even more 

significant nails were driven into the coffin lid of NRC’s false Table S-3 assumptions on 

February 14. NRC must heed these lessons and reject Callaway’s 20-year license extension. 

In fact, NRC [should] force Callaway’s immediate shutdown, for lack of a foreseeable solution to 

the forever deadly high-level radioactive wastes it generates, its curse on all future generations.

Response:

The License Renewal GEIS (GEIS), NUREG-1437, addresses the onsite storage of SNF during 

the 20-year license renewal period. The GEIS concluded that the impact of onsite storage of 

SNF during the 20-year license renewal term would be SMALL and that the issue was generic 

to all nuclear power plants. The Callaway SEIS discussion in Chapter 6 tiers off the GEIS’s 

discussion and conclusion. The NRC identified no new and significant information related to the 

storage of SNF during the 20-year license renewal period, during its independent review of 

Ameren’s ER, the scoping process, or the site audit. Therefore, the NRC staff concluded that 

there would be no impact during the license renewal term beyond those discussed in the GEIS.

For the period beyond the licensed life for reactor operations, on August 26, 2014, the 

Commission approved a revised rule at 10 CFR 51.23 and associated Generic Environmental 

Impact Statement for Continued Storage of Spent Nuclear Fuel (NUREG-2157, ADAMS 

Accession No. ML14188B749). Subsequently, on September 19, 2014, the NRC published the 

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Appendix A

revised rule (79 FR 56238) in the Federal Register along with NUREG-2157 (79 FR 56263). 

The revised rule adopts the generic impact determinations made in NUREG-2157 and codifies 

the NRC’s generic determinations regarding the environmental impacts of continued storage of 

spent nuclear fuel beyond a reactor’s operating license (i.e., those impacts that could occur as a 

result of the storage of spent nuclear fuel at at-reactor or away-from-reactor sites after a 

reactor’s licensed life for operation and until a permanent repository becomes available). By 

rule, those impacts are deemed incorporated into this SEIS.

NUREG-2157 supports the revised rule and includes, among other things, the staff’s analyses 

related to the particular deficiencies identified by the D.C. Circuit in the vacated Waste 

Confidence decision and rule. The NRC staff’s consideration of the issues identified by the 

D.C. Circuit was aided considerably by the public’s extensive participation in the process, 

including comments received during scoping, on the draft NUREG- 2157 and revised rule, and 

participation in nationwide public meetings, among other things.

The revised Continued Storage Rule does not require any changes to the management (i.e., 

handling, storage, and disposition) of SNF at a reactor site. As previously stated, the revised 10 

CFR 51.23 documents the environmental impacts of continued storage of SNF. Therefore, 

there are no potential changes in direct, indirect, and cumulative impacts that result from the 

revised rule.

The NRC staff intends to address any impacts from the Continued Storage Rule subsequently in 

a Record of Decision or as a supplement to this SEIS, as appropriate.

Spent Fuel Storage

Comment 1-4: ...or the continued radioactive waste problems and the cost of storing them 

forever will culminate and we’ll simply just stop making and denigrating these nuclear power 

plants. 

Comment 2-1: My name is Harry Robertson. I am an attorney with the Great Rivers 

Environmental Law Center in St. Louis.

I want to echo concerns about the spent fuel storage problem. And we’re told that Ameren will 

run out of storage capacity by 2020, but they are expected to build an interim storage facility, yet 

they have no current license to do that. It would seem important to know what exactly this will 

be. I would assume—and I’m being told—that it includes dry-cast storage, but when will it be 

done? 2020 is not far off. What will it cost? All those questions are not addressed in the 

[DSEIS]. 

Comment 3-5: I think, also, the fact that Callaway and other reactors in this country—but also 

specifically Callaway—is using higher burn-up fuel. And the fuel is being kept in a spent fuel

pool at Callaway. And the pool is just being crowded with more and more and more irradiated 

fuel products. And there is still no permanent disposal site in the United States for the fuel, so it 

is going to have to stay at Callaway as far as we are concerned. Or maybe they will send it, as 

they keep trying to, to the Native American tribal lands. But the spent fuel pool is vastly 

overcrowded and they are using fuel that has a higher concentration of uranium-235. This 

higher burn-up fuel will lead to greater degradation of the [plating], the tubing that holds the fuel 

pellets. And because of the higher degradation and the [plating] that they have discovered 

there were higher releases of radioactive isotopes into the liquid effluent of gaseous releases. 

Comment 4-4: Her second comment. Risks from an indepted [sic] storage of high-level 

radioactive waste storage on site. There is no current repository for spent fuel rods, so all of the 

rods that have ever been removed from the Callaway reactor are in a pool which will be filled to 

capacity by 2020. Ameren states in the Callaway Environmental Facts-2011, ‘Spent nuclear 

A-52
Appendix A

fuel consists of bundles of fuel rods called fuel assemblies that have been removed from a 

nuclear reactor when it can no longer sustain a nuclear reaction.’ But, crowded together over 

time in a pool filled to capacity with barriers prone to corrosion, those assemblies can start a 

nuclear chain reaction.

Just how dangerous are these rods? And this is quoting from Bob Alvarez Institute for Policy 

Studies, and this is called Spent Nuclear Fuel Pools in the U.S.: Reducing the Deadly Risks of 

Storage. ‘Spent fuel rods give off about 1 million rem ([10,000] sieverts) of radiation per hour at 

a distance of 1 foot has enough radiation to kill people in a matter of seconds.’ And I should say 

that I also have something that Bob Alvarez wrote that I want to submit as a part of my 

statement, if that’s okay? I meant to say that.

To continue, Arlene has written, does a specific plan exist right now for the design and the 

construction of a new spent fuel pool at Callaway? It’s all about the money.

Comment 4-6: Common sense. If there is no location for the radioactive waste that has been 

accumulating at nuclear power plants since they began generating electricity, why would any 

rational person want to continue to create more?

Nuclear power has some unique characteristics that Amory Lovins, [chief scientist] of the Rocky 

Mountain Institute describes as follows: ‘Nuclear power is the only energy source where mishap 

or malice can kill so many people so far away; the only one whose ingredients can help make 

and hide nuclear bombs; the only climate solution that substitutes proliferation, accident, and 

high level of radioactive waste dangers.’ 

Comment 5-2: The only reason the risks exist is that the Government and reactor licensees 

have not done a good job of managing the waste generated by reactors. The volumes of waste 

piling up in fuel pools at Callaway and other reactors were never contemplated when these 

reactors were issued their original licenses. The Callaway nuclear reactor for example, has 

2,363 fuel assemblies in its fuel pool. I believe it was originally licensed for right around 400. 

And we also know now that Ameren's going to be moving those out of its fuel pool. 

We think the NRC has swept the issue of pool fires under the rug for far too long, and many 

other things, including waste storage. The NRC has never made a comprehensive analysis of 

pool fire risks as it did for reactor accidents with the Severe Accident Study in NuReg 1150. 

The imposition of such great risks on a public without careful study is inexcusable.

Comment 9-2: There is no permanent repository for spent fuel rods, so all the rods that have 

ever been removed from the Callaway reactor are in a pool which will be filled to capacity by

2020. Ameren states in its Callaway Plant Environmental Facts-2011, ‘Spent nuclear fuel

consists of bundles of fuel rods called “fuel assemblies” that have been removed from the

nuclear reactor when they can no longer sustain a nuclear reaction.’ But crowded together, 

over time, in a pool filled to capacity, with barriers prone to corrosion, those assemblies can 

start a nuclear chain reaction.

Just how dangerous are these rods? ‘Spent fuel rods give off about 1 million rems (10,000 Sv) 

of radiation per hour at a distance of 1 foot—enough radiation to kill people in a matter of 

seconds.’ (Bob Alvarez, Institute for Policy Studies. ‘Spent Nuclear Fuel Pools in the U.S.: 

Reducing the Deadly Risks of Storage.’) 

Does a specific plan exist right now for the design and construction for a new spent fuel pool at 

Callaway?

Comment 9-4: If there is no location for the radioactive waste that has been accumulating at 

nuclear power plants since they began generating electricity, why would any rational person 

want to continue to create more?

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Appendix A

Comment 11-1: NRC: Severe accidents initiated by external phenomena such as tornadoes, 

floods, earthquakes, fires, and sabotage have not traditionally been discussed in quantitative 

terms in FES's and were not specifically considered for the Callaway site in the GElS 

(NRC 1996). However, the Generic Environmental Impact Statement (GEIS) did evaluate 

existing impact assessment performed by the NRC and by the nuclear industry at 44 nuclear 

plants in the United States and concluded that the risk from beyond design-basis earthquakes at 

existing nuclear power plants is SMALL. The GElS for license renewal performed a 

discretionary analysis of terrorist acts in connection with license renewals and concluded that 

the risk from such acts would be no worse than the damage and release expected from 

internally initiated events. In the GEIS, the Commission concludes that the risk from sabotage 

and beyond design-basis earthquakes at existing nuclear power plants is small and, 

additionally, that the risks from other external events are adequately addressed by a generic 

consideration of internally initiated severe accidents (NRC 1996).

Based on the information in the GEIS, the staff found the following to be true:

The probability weighted consequences of atmospheric releases, fallout onto 

open bodies of water, releases to ground water, and societal and economic 

impacts from severe accidents are small for all plants. However, alternatives to 

mitigate severe accidents must be considered for all plants that have not 

considered such alternatives.

The staff identified no new significant information related to severe accidents during review of 

the applicant's ER (Ameren 2011a), the site audit, the scoping process, or the evaluation of 

other available information. Therefore, there are no impacts related to these issues beyond 

those discusses in the GEIS. 

MCE Petition: The Missouri Coalition for the Environment (MCE) believes that spent fuel

storage risks are one of the most serious unaddressed safety and environmental issues facing 

the NRC today. The consequences of a pool fire are potentially catastrophic, affecting millions 

of people and costing billions of dollars. There is no excuse for imposing this potentially 

colossal risk on the public. The only reason the risk exists is that the government and reactor

licensees have not done a good job of managing the waste generated by reactors. The 

volumes of waste piling up in the fuel pool at Callaway was never contemplated when its original 

license was issued in 1984.

We think the Nuclear Regulatory Commission (NRC) has swept the issue of pool fires under the 

rug for far too long. The NRC has never conducted a comprehensive analysis of pool fire risks, 

as it did for reactor accidents with the Severe Accident Study (NUREG-1150). The imposition of 

such great risks on the public without careful study is inexcusable. The Fukushima accident

supposedly inspired NRC to take a closer look at the problem in the Expedited Spent Fuel 

Transfer proceeding - but the Consequence Study the NRC Staff turned out in 2013 was 

extremely inadequate.

In spite of its inadequacies, however, the Consequence Study and the cost-benefit analysis that 

accompanied it yielded new and significant information about the risks of pool fires and the 

benefits of reducing the density of fuel in pools. MCE participated in a rulemaking petition, 

submitted Feb. 18, 2014, seeking re-opening of the License Renewal GElS to consider new and 

significant information generated by the NRC's proceeding on expedited transfer of spent fuel. 

It is unreasonable to issue a license extension without fully examining the risk of the spent fuel 

pool fire at the Callaway 1 nuclear reactor as a part of the Environmental Report. The NRC 

response to this concern at the March 19, 2014 public meeting in Fulton was that spent fuel 

considerations were outside the scope of the Environmental Report, which is simply bad public 

policy.

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Appendix A

In the Expedited Spent Fuel Transfer Proceeding, the NRC Staff found that if even a small 

fraction of the inventory of a Peach Bottom reactor pool were released to the environment in a 

severe spent fuel pool accident, an average area of 9,400 square miles (24,300 square 

kilometers) would be rendered uninhabitable, and that 4.1 million people would be displaced 

over the long-term. This information is "new" because no EIS for reactor licensing, GElS for 

reactor re-licensing, or Environmental Assessment for standardization design certification has 

specified the size of the area that could be contaminated or the number of people who could be 

displaced for an extended period of time by a high-density spent fuel pool fire. The information 

is "significant" because it undermines the NRC's conclusion in environmental studies, such as 

the one for Callaway, for reactor licensing and re-licensing that the impacts of spent fuel storage 

during reactor operation are insignificant. Such widespread contamination and long-term 

displacement of people could have enormous socioeconomic impacts, as witnessed by the 

effects of the Fukushima accident, where "land contamination has disrupted the lives of a large 

number of Japanese Citizens."

It is estimated that over 100,000 Japanese people are still displaced from their homes and 

communities. The Japan Times recently cited a report from local Fukushima prefecture 

authorities that found more people have died from stress-related illnesses and other health 

related problems near the nuclear reactor than who died from disaster-related injuries. Real 

world nuclear disasters show the impact on communities surrounding a nuclear reactor are 

significant and therefore must be considered by the Nuclear Regulatory Commission in a 

meaningful way.

In the Peach Bottom review, the NRC acknowledged for the first time that the potential 

consequences of a pool fire are severe enough to warrant mitigation, regardless of the low 

probability estimated by the NRC for such an accident. No Environmental Impact Statement 

(EIS) for reactor licensing, GElS for reactor re-licensing, or Environmental Assessment for 

reactor design certification has acknowledged that mitigation of pool fires is warranted or 

weighed the costs and environmental benefits of such mitigation measures.

Comment 14-1: Please do not renew Callaway Nuclear plant license. Plants get more 

dangerous as they age. Nuclear power is too expensive. The Callaway plant has not moved 

it's spent fuel rods into hard cask storage, and the wasted fuel rods are getting more crowded 

and more dangerous in the pool. No renewal should even be considered without proper on site 

storage of nuclear waste. It is time to spend our energy money on what is safer and more

economical, and is quick to build--solar and wind.

Comment 15-1: My biggest concern is storage of the spent fuel rods. No one has come up with 

a safe way to store them, and, until someone does, no nuclear power plant license should be 

renewed. I am also concerned that there is not an adequate plan for evacuation in case of a 

serious accident. I live within 10 miles of the plant and I am concerned for my safety and the 

safety of my neighbors. The disaster at the Fukushima plant in Japan should have been a 

wake-up call for safety.

Comment 16-1: The Callaway operating license should not be renewed. The NRC and nuclear 

industry history of generation and tolerance of inaccurate technical information and records 

have undermined their abilities to accurately assess the long-term safety and economic 

consequences of extending Callaway’s operating license.

A few examples of the NRC’s information problems are described using excerpts from NRC,

industry, and court records in the ‘Supporting Information’ section and references cited below.

The NRC’s own projections described in the ‘Callaway Safety Evaluation Report’ are that, by

2020, the spent fuel pool at Callaway will be insufficient to offload a core if current practices 

A-55
Appendix A

continue is of particular concern. (Ref. 1) This situation alone should be sufficient reason to 

deny license renewal. Promises of ISFS in dry casks do not amount to safe storage. (Although 

some justifications for the license renewal are made by economic arguments, the actual costs of 

ISFS are uncertain.)

The history of nuclear power is filled with empty promises and faulty projections. ‘Safe

permanent storage or disposal of spent nuclear waste’ remains as mythical as ‘energy too 

cheap to meter’ promised over [50] years ago.

Unites States General Accounting Office (GAO) report described the nature of spent nuclear

waste in their report cover letter addressed to Senate Committee on Environment and Public 

Works: ‘Spent nuclear fuel—the used fuel periodically removed from reactors in nuclear power 

plants—is one of the most hazardous materials made by man. Without protective shielding, the 

fuel’s intense radiation can kill a person within minutes if directly exposed to it or cause cancer 

in those exposed to smaller doses.’ (Ref. 2)

Comment 16-2: One serious accident could render large parts of the US uninhabitable. NRC 

and industry records indicate that their information problems are systemic. All projections and 

decisions are made based on information. Therefore, NRC and industry information, projections 

and promises should be critically reviewed. NRC and industry projections cited in the ‘Callaway 

Safety Evaluation Report’ rely heavily on industry information (see Appendix D References in 

that report). 

The ‘Callaway Safety Evaluation Report’ describes fuel rods used in the plant. It states, ‘Each 

fuel rod is constructed of zirconium alloy tubing containing uranium oxide fuel pellets.’ This 

‘zirconium alloy tubing’ component is also called ‘zirconium nuclear fuel rod cladding’ or just 

‘cladding’ (not to be confused with stainless steel reactor cladding and other cladding referred to 

numerous times in the ‘Callaway Safety Evaluation Report’). The Callaway ‘zirconium alloy 

tubing’ is the same component whose history of testing problems described in the ‘Supporting 

Information’ section below. It is likely that the same zirconium alloys are used in Callaway fuel 

rods from the same suppliers (Westinghouse, GE Nuclear, and Global Nuclear Fuels) whose 

problems are described below and in the cited references. NRC statements indicating that they 

would take no action to review or correct the inaccurate information and records are particular 

concerns.

Zirconium alloy tubing of the type used in Callaway nuclear reactors. This component is also 

referred to as ‘zirconium fuel rod cladding’ or just cladding (not to be confused with reactor

vessel cladding referred to in the ‘Callaway Safety Evaluation Report’).

Spent nuclear fuel [SNF] has been stored in spent fuel pools for decades. During this period, 

fuel rod cladding is the only component keeping radioisotopes from leaking into coolant water.

After cooling, spent fuel rods are placed in dry storage casks. Different types of casks might be 

used in the Callaway ISFS. The types of dry storage cask whose testing under flawed the [sic] 

QA system noted in the NRC audit report referenced in the ‘Supporting Information’ below is not 

known.

Significant information sources that the NRC and industry rely on to design and manufacture 

components and to execute the operations described above are suspect. In event of incident or 

accident, reliance on the same flawed information might lead to critical mistakes at times when 

good information is needed quickly. The potential safety implications are grave. Academic and 

other references cited in the ‘Supporting Information’ section describe these problems in more 

detail. 

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Appendix A

During the Indian Point relicensing hearing, one judge described poor control of information (not 

directly related to the cladding information problems described below): ‘I know we’re not looking 

at great science.’ Although technical limitations are involved, these problems arose mainly due 

to limitations in the ‘human factors’ in nuclear safety described by the NRC. The same phrase 

appropriately describes significant amounts of NRC and industry information on fuel rod 

cladding of the type used at Callaway: I know we’re not looking at great science. 

Until the NRC and industry demonstrate that they are relying on ‘Great Science,’ no additional 

activities that will produce more spent nuclear fuel should be allowed. The Callaway license 

renewal should not be granted. 

Comment 17-1: I told my 97-year-old husband that I was preparing comments to submit to the 

Nuclear Regulatory Commission about our electric utility’s efforts to extend its Callaway nuclear 

power plant operating license for another 20 years. Leo responded, ‘Wouldn’'t it be dangerous 

if they operated the Callaway plant for another 20 years?’ I answered, ‘[Yes].’ 

The following comments will focus on some of the many reasons for my ‘yes’ response. 

Daniel F. Ford, in his book Three Mile Island, 1982, p. 29, included a disturbing list of common 

problems at nuclear power plants. ‘All nuclear-power-plant systems, structures, components, 

procedures, and personnel are potential sources of failures and malfunctions. Problems can 

arise from defects in design, manufacturing, installation, and construction; from testing, 

operational, and maintenance errors; from explosions and fires; from excessive corrosion, 

vibration, stress, heating, cooling, radiation damage, and other physical phenomena; from 

deterioration due to component aging; and from externally initiated events such as floods, 

earthquakes, tornadoes, and sabotage.’ 

(1) Known fuel rod hazards—and unknowns:

Extended storage for irradiated fuel rods is inevitable at Callaway because the spent fuel pool is 

already dangerously overcrowded and because no safe, permanent, politically acceptable 

location has been found in the United States, and may never be found, for the nation’s irradiated 

fuel rods—for the rods already accumulated and for those that would accumulate in the future if 

the Callaway operating license were to be extended.

When the Callaway plant was designed, Union Electric expected to use fuel rods containing 

3.5-percent fissionable uranium-235. Currently, high-burnup fuel is posing major concerns—

that is, reactor fuel that is enriched to a higher level of uranium-235 and that is left in the fuel 

storage pool under water for a much longer duration.

In 2012, the official publication of the National Academy of Engineering of the National Academy 

of Sciences raised concerns about the viability of high-burnup fuel by noting, ‘the technical basis 

for the spent fuel currently being discharged (high utilization, burnup fuels) is not well 

established....the NRC has not yet granted a license for the transport of the higher burnup fuels 

that are now commonly discharged from reactors. In addition, spent fuel that may have 

degraded after extended storage may present new obstacles to safe transport.’ (National 

Academy of Engineering: Managing Nuclear Waste. Summer 2012 - pp. 21, 31. Emphasis 

added. http://www.nae.edu/File.aspx?id=60739).

In 2012 the Nuclear Regulatory Commission indicated that spent nuclear fuel in surface storage 

may extend to 100 years. In 2011 the U.S. Energy Department indicated that consideration is 

being given for a 300-year period before geologic disposal.

The United States Nuclear Waste Technical Review Board, created under the 1982 Nuclear 

Waste Policy Act, issued the following key finding: ‘Insufficient information is available yet on 

high-burnup fuels to allow reliable predictions of degradation processes during extended dry 

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Appendix A

storage, and no information was found on inspections conducted on high-burnup fuels to 

confirm the predictions that have been made.’ (Evaluation of the Technical Basis for Extended 

Dry Storage and Transportation of Used Nuclear Fuel. December 10, 2010.) 

Comment 17-2: Of great concern, then, is that the fuel rods are becoming more and more 

dangerous because of their content (that is, the more highly enriched uranium), and because of 

the many unknowns about the condition of the cladding and of the highly radioactive fuel—

during operation, storage, and transport to some hypothetical disposal location in the 

unforeseeable future.

Some questions about the Callaway fuel that merit consideration:

(1) What is the radioactive inventory of the spent nuclear fuel in the Callaway fuel pool, 

and what are the burnup characteristics of the cores?

(2) Has the NRC evaluated the period at which the Callaway power plant is expected to 

run out of wet storage space—that is, in the spent fuel pool?

(3) Does Ameren/UE have plans to install dry-cask storage? And if so, starting when, 

for what volume, and over what period of time?

Response:

The NRC is aware that a repository for SNF may not be available in the timeframe that was 

originally envisioned. As an alternative, the Commission has considered the storage of SNF on 

reactor sites where it is generated, or in away-from reactor sites, as part of the Continued 

Storage Rule. 

The NRC is committed to ensuring that both SNF and low-level radioactive wastes are managed 

to prevent health impacts to the public. Spent nuclear fuel is currently stored at Callaway in its 

spent fuel pool. It is expected that in the future, SNF will also be stored in an independent spent 

fuel storage installation (ISFSI). This storage of SNF is expected to continue until DOE is ready 

to take possession of the SNF. At this time, it is uncertain when this will happen. The 

environmental impacts associated with onsite storage of SNF during the license renewal term 

are discussed in Chapter 6 of the SEIS and in the license renewal GEIS. 

For the period beyond the licensed life for reactor operations, historically, the NRC’s Waste 

Confidence Decision and Rule represented the Commission’s generic determination that spent 

fuel can continue to be stored safely and without significant environmental impacts for a period 

of time after the end of a reactor’s licensed life for operation. This generic determination meant 

that the NRC did not need to consider the storage of spent fuel after the end of a reactor’s 

licensed life for operation in NEPA documents that supported its reactor and spent fuel storage 

application reviews. The NRC first adopted the Waste Confidence Decision and Rule in 1984. 

The NRC amended the Decision and Rule in 1990, reviewed it in 1999, and amended it again in 

2010 (49 FR 34658 and 34694, 55 FR 38474, 64 FR 68005, and 75 FR 81032 and 81037). The 

Waste Confidence Decision provided a regulatory basis and NEPA analysis to support the 

Waste Confidence Rule (10 CFR 51.23).

On December 23, 2010, the Commission published in the Federal Register a revision of the 

Waste Confidence Rule, supported again by a Waste Confidence Decision, to reflect 

information gained from experience in the storage of spent fuel and the increased uncertainty in 

the siting and construction of a permanent geologic repository for the disposal of SNF and highlevel waste (75 FR 81032 and 81037). In response to the 2010 Waste Confidence Rule, the 

States of New York, New Jersey, Connecticut, and Vermont—along with several other parties—

challenged the Commission’s NEPA analysis in the decision, which provided the regulatory 

basis for the rule. On June 8, 2012, the United States Court of Appeals, District of Columbia 

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Appendix A

Circuit in New York v. NRC, 681 F.3d 471 (D.C. Cir. 2012) vacated the NRC’s 

Waste Confidence Rule, after finding that it did not comply with NEPA.

In response to the court’s ruling, the Commission, in CLI-12-16, determined that it would not 

make final decisions for licensing actions that depend upon the Waste Confidence Rule until the 

court’s remand is appropriately addressed. The Commission also noted that all licensing 

reviews and proceedings should continue to move forward. In addition, the Commission 

directed in SRM-COMSECY-12-0016 that the NRC staff proceed with a rulemaking that 

includes the development of a Generic Environmental Impact Statement. 

The generic EIS, which provides a regulatory basis for the revised rule, would provide NEPA

analyses of the environmental impacts of spent fuel storage at a reactor site or at an 

away-from-reactor storage facility after the end of a reactor’s licensed life for operation 

(“continued storage”). As directed by the Commission, the NRC would not make final decisions 

regarding renewed license applications until the court’s remand is appropriately addressed. 

This would ensure that there would be no irretrievable or irreversible resource commitments or 

potential harm to the environment before the impacts of continued storage have been 

appropriately considered. 

On August 26, 2014, the Commission approved a revised rule at 10 CFR 51.23 and associated 

Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel 

(NUREG-2157, ADAMS Accession No. ML14188B749). Subsequently, on 

September 19, 2014, the NRC published the revised rule (79 FR 56238) in the Federal Register 

along with NUREG-2157 (79 FR 56263). The revised rule adopts the generic impact 

determinations made in NUREG-2157 and codifies the NRC’s generic determinations regarding 

the environmental impacts of continued storage of spent nuclear fuel beyond a reactor’s 

operating license (i.e., those impacts that could occur as a result of the storage of spent nuclear 

fuel at at-reactor or away-from-reactor sites after a reactor’s licensed life for operation and until 

a permanent repository becomes available). By rule, those impacts are deemed incorporated 

into this SEIS.

NUREG-2157 supports the revised rule and includes, among other things, the staff’s analyses 

related to the particular deficiencies identified by the D.C. Circuit in the vacated Waste 

Confidence decision and rule. The NRC staff’s consideration of the issues identified by the 

D.C. Circuit was aided considerably by the public’s extensive participation in the process, 

including comments received during scoping, on the draft NUREG- 2157 and revised rule, and 

participation in nationwide public meetings, among other things.

The revised Continued Storage Rule does not require any changes to the management 

(i.e., handling, storage, and disposition) of SNF at a reactor site. As previously stated, the 

revised 10 CFR 51.23 documents the environmental impacts of continued storage of SNF. 

Therefore, there are no potential changes in direct, indirect, and cumulative impacts that result 

from the revised rule.

The NRC staff intends to address any impacts from the Continued Storage Rule subsequently in 

a Record of Decision or as a supplement to this SEIS, as appropriate.

A.4.7 Text Clarification (CL) 

The original sources for the comments in this category (clarification) can be found in Section A.5 

and are labeled with the following identifiers: 12-9, 12-13, 19-1 to 21. These comments are 

extracted from the original sources.

Comment 12-9: Table 1-1 in Chapter 1 Purpose and Need for Action lists all of the current 

permits applicable to the operation of the Callaway Plant. Several of these permits, issued by 

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Appendix A

Missouri Department of Natural Resources, specifically the NPDES permit, CAA Title V Part 70 

Air Permit, and CWA Section 401 Water Quality Certification, have reached their expiration 

dates at the time of issuance of this DSEIS. Section 2.2.2.1 Air Quality states that ‘Existing 

emission sources at Callaway are regulated under Operating Permit No. OP2008-045. This 

operating permit expires on September 17, 2013. It is expected that MDNR will issue a 

renewed operating permit for an additional 5 years, incorporating any changes to emission 

sources at Callaway during the 5-year period of the existing permit.’ Additionally, Section 2.2.4

indicates that Callaway’s surface water discharges are permitted under a NPDES permit, which

expired on February 12, 2014. This section states that ‘On August 17, 2012, Ameren submitted 

a letter to MDNR asking for confirmation that the license extension would not violate Missouri’s 

Water Quality Standards. The letter also asked for confirmation that the Clean Water Act 

Section 401 Water Quality Certification would be required by MDNR or whether a letter of 

approval, based on the existing Section 401 Water Quality Certification, coupled with the 

ongoing NPDES permit authorization, would be issued.’ At the time the DSEIS was written, a 

letter response on this issue from MDNR had not yet been received. EPA requests that the 

FSEIS include the current status of each of these permits. Additionally, including either copies 

of the licenses and permits currently issued to Callaway in the Appendices section, or at 

minimum, including links to these documents somewhere within the narrative of the FSEIS 

would be beneficial.

Comment 12-13: The DSEIS refers to many other documents as can be seen in the list of 

references provided at the end of each section. Because the underlying basis for most of the 

information provided in this supplement are contained in these documents, a complete 

comprehensive review would have to include the information contained in these documents. 

The need for the underlying information and analyses is most noticed in Section 2 Affected 

Environment of this DSEIS. Therefore, it is suggested that all pertinent information and backup 

analyses needed to understand and evaluate the provided consequences of the proposed 

license renewal be included in the FSEIS to the extent feasible. If a complete standalone SEIS

cannot be developed for this project, the FSEIS should provide the specific document, section, 

and page where referenced documentation and analyses can be obtained to support the 

information provided. If appropriate, the specific NRC docket [Web] location should be 

provided. One option would be to make the supporting reference documents available in 

electronic format on the NRC [Web] site where the DSEIS is currently posted.

Comment 19-1: Ameren is in the process of constructing an ISFSI with completion expected in 

2015. The water-filled excavation that was made for Callaway Unit 2 is being filled in, in 

preparation of ISFSI construction. 

Comment 19-2: The Chamois Power Plant ceased operation in September 2013.

Comment 19-3: The prior excavation referred to in this section was from initial site construction 

in the early 1980s.

Comment 19-4: Callaway does not use reverse osmosis as a treatment method for liquid 

radioactive waste.

Comment 19-5: Line 1-4 states ‘Offgases from the main condenser are the major source of 

gaseous radioactive waste. Other radioactive gas sources collected by the system include 

leakage from steam piping and equipment in the reactor building, turbine generator building, 

and radioactive waste building.’ This is not correct. In fact, the major source of gaseous 

radioactive waste is purging of the volume control tank and discharge of tank vents and other 

equipment in the containment, radioactive waste, and auxiliary buildings.

A-60
Appendix A

Comment 19-6: A statement is made that most of the water in the circulating system is lost to 

the atmosphere; this is misleading as only about 1 [percent] is lost through evaporation.

Comment 19-7: Should state the water flowing down the discharge pipeline and discharged to 

the Missouri River has a maximum temperature near 90 °F. Cooling tower blowdown 

temperatures (Outfall 002) vary with season and range from about 60 [to] 90 °F. The current 

NPDES Permit does not contain an upper temperature limit or stipulate that the discharge must 

not cause the temperature of the mixing zone (or the area where the discharge water meets and 

mixes with the river) to increase by more than [37] °F (2.8 °C).

Comment 19-8: Incorrectly estimates the volume of water returned to the river. Over the past 

[3] years the volume of water returned to the river has averaged near 4400 gpm with the losses 

to evaporation near 11,000 gpm. Therefore, approximately 25 [percent] of the water withdrawn 

is returned to the river.

Comment 19-9: The unit 2 prior excavation hole is in the process of being filled in and will be 

completely filled in by 2015. The GWS pump is used to dewater the structural fill area 

underlying the power block.

Comment 19-10: Concerning the 401 Water Quality Certification, Ameren did receive a 

response letter from the Missouri DNR (dated October 8, 2013) stating that the department 

considers the permit to provide appropriate environmental protection under the Missouri Clean 

Water Law and compliance with the Clean Water Act. 

Comment 19-11: Number of Callaway employees does not match what is listed on page 2-57.

Comment 19-12: The Chamois Power Plant ceased operation in September 2013 and is no 

longer a cumulative effect on the aquatic resources.

Comment 19-13: The sentence appears to be misleading. Sentence inappropriately implies 

that the ‘license renewal’ contributes to the ‘LARGE’ cumulative impact when in fact other major 

factors outside of existing or future operation of Callaway result in this impact.

Comment 19-14: The fire PRA CDF number has been reduced from [2.0×10-5] to [1.68×10-5] 

since the original LAR was submitted. 

Comment 19-15: The Missouri–Kansas–Texas Railroad in central Missouri is now a state hiking 

trail (Katy Trail State Park), with no rails remaining. The Callaway rail spur could not be 

reconstructed to provide rail access.

Comment 19-16: The stated CDF of [7.6×10-6] has an incorrect exponent.

Comment 19-17: Safety related water system is incorrectly listed as emergency service water.

Comment 19-18: Two additional sedimentation ponds are currently being designed with 

installation planned during 2015 as the existing treatment lagoons are approaching capacity.

Comment 19-19: The current NPDES Permit does not contain a temperature limitation for 

discharge such that the discharge must not cause the temperature of the mixing zone (or the 

area where the discharged water meets and mixes with the river) to increase by more than 5 °F 

(3 °C). Temperature is required to be monitored.

Comment 19-20: The statement in the Draft SEIS that ‘All plant outfalls except one connect into 

a single pipeline...’ is not completely accurate.

Comment 19-21: This section fails to acknowledge the buoyancy and strong photopositive 

response of pallid [larvae] as mentioned in Section H.4.1 in contrast to the water intake opening 

of the Callaway intake that may preclude larval impingement and/or entrainment. Emphasis 

should also be added to note relative small component of river water extracted due to minimal 

A-61
Appendix A

amount of water required by a cooling tower [versus] a once-through cooling water system, i.e., 

mitigating factor/impacts.

Response:

These comments are editorial or clarification in nature (many contain suggested word changes

as listed in the original sources, Section A.5). The comments are incorporated into the SEIS, as 

appropriate. The SEIS sections being revised are listed as follows: 

A-62
Appendix A

Comment SEIS Section Summary

Comment 12-9

(a)

(b)

(c)

1.9

2.2.2.1 

2.2.4

The staff updated Table 1-1 in Section 1.9 to incorporate the most 

recent information on licenses and permits.

On February 19, 2013, Ameren submitted an air permit renewal 

application for Callaway to the MDNR. MDNR has notified the NRC that 

the facility will operate under the previous permit until the department 

issues a new operating permit. Section 2.2.2.1 has been updated 

accordingly to reflect this information.

On October 8, 2013, Ameren received a letter from MDNR that the 

NPDES permit provides appropriate environmental protection under the 

Missouri Clean Water Law and compliance with the Clean Water Act. 

Ameren submitted a permit renewal application to MDNR on 

August 1, 2013, and is still awaiting permit issuance. A copy of the 

current NPDES permit, maps of outfalls, schematic flow diagrams, and 

the renewal application is available in ADAMS under the following 

accession numbers ML101310076, ML12271A451, ML13240A302, 

ML13240A303, ML13240A304, and ML13240A306. The letter of 

401 certification from the State of Missouri can be found at 

ML13283A182. These documents have been added to the references 

in the SEIS.

Comment 12-13 Chapter 2

references

The staff developed the SEIS in accordance with the NRC standard 

review plan (NUREG-1555, Supplement 1). All information gathered 

from (a) public comments, (b) correspondences with the applicant, and 

(c) consultation process are listed as a part of the reviewing docket and 

documented in Appendix E of this SEIS, along with the agency record 

numbering (ADAMS accession number). ADAMS records are readily 

accessible from the NRC home page. Publicly available information 

such as information posted on the Internet are documented in the 

reference sections in the SEIS, along with the Web addresses. No 

changes have been made to the SEIS as a result of this comment. 

Comment 19-1 4.12 The staff considers the SFP capacity and the construction of ISFSI as a 

part of reasonably foreseeable future action in Section 4.12, 

“Cumulative Impacts.” The staff revised Section 4.12 to reflect that the 

ISFSI will be available by 2015, as noted.

Comment 19-2 4.12 The NRC staff agrees with this comment. Consideration of the 

continued operation of the Chamois Power Plant has been removed 

from the cumulative impact analysis, as the facility ceased operations in 

September 2013. Staff has updated analysis of cumulative impacts in 

the SEIS as a result of this comment. 

Comment 19-3 2.1 The staff revised 2.1 to clarify that prior excavation was from initial 

construction of Callaway, Unit 1, as noted by the comment.

Comment 19-4 2.1.2.1 The NRC staff agrees with this comment to remove the discussion on 

the use of “reverse osmosis” in the radioactive waste section. Section 

2.1.2.1 of the SEIS has been changed to address this comment.

Comment 19-5 2.1.2.2 The NRC staff agrees with this comment to remove the discussion 

declaring “offgases from the main condenser are the main source of 

gaseous radioactive waste.” Section 2.1.2.2 of the SEIS has been 

changed to state: “The major source of gaseous radioactive waste is 

purging of the volume control tank and discharge of tank vents and 

other equipment in the containment, radioactive waste, and auxiliary

buildings.”

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Appendix A

Comment SEIS Section Summary

Comment 19-6 2.1.6.1 This comment was withdrawn and no changes have been made to the 

SEIS as a result of this comment.

Comment 19-7 2.1.6.1 The text in Section 2.1.6.1 has been revised to clarify that the water 

discharged to Missouri River has a “maximum” temperature near 90 °F 

and that the NPDES Permit does not contain any temperature limits.

Comment 19-8 2.1.7.1 To characterize the rate of Missouri River water intake and consumptive 

use, the DSEIS referenced numbers from the license renewal 

application. This comment reports that over the “past 3 years” the 

volume of water returned to the river has averaged near 4,400 gpm 

(16,655 L/min), with losses to evaporation of near 11,000 gpm (41,639 

L/min). The SEIS (Section 2.1.7.1) estimates losses to evaporation of 

12,200 gpm and 15,000 gpm (46,177 L/min to 56,775 L/min). The 

analysis of water use impacts (Section 4.4.2 in the SEIS) is based on 

the estimated maximum rate of Missouri River water intake described in 

the application. It considered losses to evaporation of 21,768 gpm 

(82,402 L/min). The SEIS analysis considered more severe potential 

impacts from water consumption and concluded that impacts on water 

resources were SMALL. While this new information is informative, 

considering a lower rate of water consumption will not change the 

ranking. No changes have been made to the SEIS as a result of this

comment.

Comment 19-9 2.1.7.2 The text in Section 2.1.7.2 has been revised to incorporate new 

information that the Unit 2 prior excavation hole is in the process of 

being filled in with fill material.

Comment 19-10 401 

certification, 

2.2.4

The SEIS has been revised to note that on October 8, 2013, Ameren 

received a letter from the Missouri Department of Natural Resources

indicating that the Department considers the permit to provide 

appropriate environmental protection under the Missouri Clean Water 

Law and compliance with the Clean Water Act. However, a water 

quality control permit may still be required for specific projects at the 

facility for Clean Water Act Section 404 Permits.

Comment 19-11 2.2.9 The NRC staff does not agree with this comment. Table 2-16 shows the 

largest employers within the ROI while Section 2.2.9 discusses the most 

current information provided by Ameren on Callaway’s permanent 

workforce. The data sources for each are from two different timeframes

(2009 and 2011, respectively) but are representative of the region as a 

whole. Therefore, no changes have been made to the SEIS as a result 

of this comment. 

Comment 19-12 4.12.3.1 The NRC staff agrees with this comment. The staff changed the text in 

this section, as noted by the comment.

Comment 19-13 4.12.3.5 The staff disagrees with this comment and finds that this sentence when 

read in context of the paragraph is not misleading. The paragraph 

characterizes the role of the Callaway plant in cumulative impact. 

Further, cumulative impact is defined as the aggregate of past, present, 

and future actions, including the Callaway plant. Hence, the staff made 

no changes to the SEIS.

A-64
Appendix A

Comment SEIS Section Summary

Comment 19-14 5.3.2 In Chapter 5.3 “Severe Accident Mitigation Alternatives”, the staff stated: 

“the NRC staff concludes that these SAMA do not relate to adequately 

managing the effects of aging during the period of extended operation. 

Therefore, they need not be implemented as part of license renewal in 

accordance with 10 CFR Part 54.” The information provided by this 

comment about a prospective change in the fire CDF does not change

this determination (the staff’s conclusion). Hence, the staff made no 

changes to the SEIS.

Comment 19-15 8.2.9 The NRC staff revised Section 8.2.9 and other affected portions of this

SEIS for clarity with respect to the current status of the abandoned rail 

spur.

Comment 19-16 Appendix F The NRC staff updated Appendix F, Page F-10, to correct the typing 

mistake of 7.6×10-6 to 7.6×10-5, as noted by the comment.

Comment 19-17 Appendix F The NRC staff updated Appendix F, Page F-18, to correct the typing 

mistake of emergency service water to essential service water, as noted 

by the comment.

Comment 19-18 Appendix H This comment is on the final biological assessment. The staff agrees 

with this comment but observes that the planned sedimentation ponds 

do not affect possible impacts from impingement, entrainment, or 

thermal effects. The NRC staff is discussing this information with the 

FWS. Therefore, the staff made no changes to the SEIS.

Comment 19-19 Appendix H This comment is on the final biological assessment. The NRC staff is 

discussing this information with the FWS. Therefore, the staff made no 

changes to the SEIS.

Comment 19-20 Appendix H This comment is on the biological assessment. The information is for 

discussion with the FWS. The staff made no changes to the SEIS.

Comment 19-21 H.4.3.2 The photopositive behavior of pallid sturgeon larvae is discussed on 

page H-7, lines 37–39, and the relationship of such behavior to 

impingement risk is discussed on page H-9, line 40, through page H-10, 

line 3, and on page H-10 in Section H.4.3.3, “Benthic Larvae and 

Juveniles.” The fraction of river flow diverted to the plant and its effect 

on impingement and entrainment is discussed on page H-9, lines 5–12. 

Therefore, the staff made no changes to the SEIS.

A.4.8 Water Resource (WR)

The original sources for the comments in this category (water) can be found in Section A.5 and

are labeled with the following identifiers: 10-1, 10-2, 12-8. These comments are extracted from 

the original sources.

Comment 10-1: 

Clean Water Act Section 401 Water Quality Certification (WQC): The department has

previously determined that a WQC would not be needed for the [renewal] of the 

Nuclear Regulatory Commission license since the current National Pollutant Discharge 

Elimination System Permit No. MO-0098001 effectively addresses water quality protection at 

the facility. However, future projects that would impact water resources, such as expansion of 

ponds, stream crossings, or Missouri River dredging activities, may require a Section 404 

permit. Maintenance activities may or may not be covered under a precertified permit 

depending on the type, size, and location of the activity. In such events, the licensee would 

A-65
Appendix A

need to contact the USACE’s Regulatory Branch in the Kansas City District at (816) 389-3990 

and the department’s 401 Certification Unit at (573) 751-1300 for more information.

National Wetland Inventory: Mapping data shows that there are potentially several wetlands 

near the Missouri River intake structure. Dredged material may not be placed in wetlands 

without proper due diligence.

Ecological Drainage Unit: The facility lies within the Ozark/Moreau/Loutre Ecological Drainage

Unit.

Watersheds: The northwest part of the facility area drains to the north into Hydrologic Unit 

Code 10300102 15 04 Cow Creek Sub-Watershed; the eastern half of the facility drains to the 

east and south into Hydrologic Unit Code 10300102 16 05 Logan Creek Sub-Watershed; and 

the southwest part of the facility drains to the south into Hydrologic Unit Code 10300102 16 06 

Deer Creek–Missouri River Sub-Watershed.

Ecological drainage units and watershed locations may be needed should, after avoiding and

minimizing impacts to water resources, mitigation be required.

Classified Streams: Logan Creek, Water Body Identification Number 704, is classified for 5.8

miles as an intermittently flowing water with the designated beneficial uses of protection of

aquatic life and human health-fish consumption, livestock and wildlife watering, and whole body

contact recreation-Category B. The Missouri River, Water Body Identification Number 701, is

classified for 135 miles as a permanently flowing water with the designated beneficial uses of

protection of aquatic life and human health-fish consumption, livestock and wildlife watering,

drinking water supply, industry, irrigation, secondary contact recreation and whole body contact

recreation-Category B. Through their designated beneficial uses, the streams shall be 

protected by numeric water quality criteria contained in 10 CSR 20-7.031(4) and Table A.

Unclassified Streams: The proposed project area contains many unclassified streams. 

Unclassified streams are protected by the general water quality criteria outlined in 10 CSR 20-

7.031(3).

The licensee should ensure that all proper Best Management Practices are in place to protect 

the stream’s chemical, physical, and biological characteristics.

Sensitive Waters: According to the department’s current water quality standards, there are no

cold-water fisheries, losing streams, outstanding state and national resource waters, 

metropolitan no-discharge streams, or biocriteria reference locations within or near the property.

Impaired Waters: This segment of the Missouri River is listed as impaired for bacteria from

multiple point and nonpoint sources according to the 2012 U.S. Environmental Protection

Agency’s approved 303(d) List. The Missouri River has an approved Total Maximum Daily Load 

for Chlordane and Polychlorinated Biphenyl (approved November 3, 2006,

http://www.dnr.mo.gov/env/wpp/tmdl/0226-0356-0701-1604-missouri-r-tmdl.pdf). No activities

related to the project should increase the amount of pollutants impairing the river nor 

re-suspend any pollutants that might be bound to sediment.

Geospatial Data: Department geospatial data is available upon request, and all published data 

is available on the Missouri Spatial Data Information Service Web site at 

http://msdis.missouri.edu/. 

Land Disturbance Permits: Future construction work disturbing an area of [1] acre or more will

require a Land Disturbance Permit prior to any earth work being initiated. Valuable resource

waters may require additional conditions or a site-specific permit. Valuable resource waters

include losing streams, outstanding resource waters, public drinking water supplies, critical

habitat for endangered species, impairments due to sediment or unknown pollutants, permanent

A-66
Appendix A

streams or major reservoirs, biocriteria reference locations, wetlands, or sinkholes or other 

direct conduits to groundwater. Applicants with land disturbance permitting questions are 

encouraged to visit http://www.dnr.mo.gov/env/wpp/epermit/help.htm, or call the department’s 

ePermitting Technical Customer Assistance toll-free number at (855) 789-3889. The licensee 

may contact the department’s Northeast Regional Office at (660) 385-8000 with any additional 

questions.

Response:

The NRC acknowledges the State’s comment and the information provided about actions that 

must be taken by the licensee should the licensee undertake activities in the future that could 

impact surface water resources. However, this is not new and significant information with 

respect to the water quality issues evaluated by the NRC or information that would change the 

conclusions of the SEIS. The NRC recognizes that every NRC-licensed nuclear power plant 

must comply with all health, safety, and environmental requirements contained within its license 

as well as comply with all other Federal, State, and local requirements for continued operation. 

This would apply to future projects or actions that an NRC licensee might undertake. No 

changes have been made to the SEIS in response to this comment.

Comment 10-2: 

Water Quality Citation Clarifications

Table 1-1, Pages 1-10. In the event that the U.S. Army Corps of Engineers (USACE) should

determine that a Clean Water Act Section 404 Permit would be required for any future activities

on the property; a Clean Water Act Section 401 Water Quality Certification (WQC) would likely

be required. The department recommends that the licensee consults with the department to

determine if a WQC would be required, whether the project would be precertified or an

individual WQC would be required.

The Section 404 Nationwide Permit 3 for ‘Maintenance’ expires every [5] years. The current

permit and associated precertified 401 conditions expire on March 18, 2017. The table seems 

to indicate that this permit never expires, which is incorrect.

The USACE File No. 2004-00468 is for an individual 404 permit, not a Nationwide Permit 3 for

‘Maintenance’ according to our database. This information should be corrected in the table. 

The department issued an individual WQC on May 3, 2004, for that specific individual 404 

permit.

Page 2-21, Line 3. Intake Well 2 is listed twice in this sentence. Should one instance be Intake

Well 1 and the other Intake Well 2?

Page 2-29, Line 40. The most recent data provided by the U.S. Geological Survey for Gaging

Station No. 06934500 Missouri River at Hermann, Missouri, appears to be more recent than

2008. Provisional data exists to present day with verified data typically up through September

30, 2013.

Page 2-33, Lines 8–14. According to our records there was no WQC issued for the initial

licensing of the facility. The Section 402 National Pollutant Discharge Elimination System

Permit No. MO-0098001 addresses water quality concerns regarding the general operation of 

the facility. The department sent a letter to Ameren on October 17, 2013, discussing this 

matter. However, a WQC may still be required for specific projects at the facility for Clean 

Water Act Section 404 Permits.

Chamois Power Plant: The department understands that the Chamois Power Plant has closed. 

There are numerous references to this coal-fired power plant.

A-67
Appendix A

Geology, Hydrology, Surface Water and Groundwater Resources

This section of our review focuses on sections pertaining to geology, hydrology, surface water

and groundwater resources. In general, several sections used terminology that is inconsistent

with current nomenclature used by the Missouri Geological Survey and the U.S. Geological

Survey, which may have resulted from referring to previous site-related documents. For those

instances, comments offered here are intended to help update the record. However, in other

sections of the SEIS, inappropriate references were used to describe conditions and draw

conclusions concerning water resource impacts. The impacts evaluated in Section 4.12.2.2

should be reevaluated, as mentioned in specific comments below. Selected references are 

listed at the end of the specific comments that follow.

Section 2.2.3.1 Physiography and Geology, Figure 2–9. General Geologic Column, page 2-27: 

This illustration uses some geologic nomenclature that is out of date. The figure should be

modified to reflect the current unit names. The ‘Graydon Chert Conglomerate’ is now known as

the Graydon Conglomerate. The ‘Burlington Formation’ is properly the Burlington Limestone. 

The unit [labeled] ‘Bushberg Formation’ is [now] likely the Bushberg Sandstone. Recent 

geologic mapping by Starbuck (2008) identifies this sandstone as either the Devonian System 

Holts Summit Sandstone or the Mississippian Subsystem, Kinderhookian Series Bachelor 

Sandstone. The ‘Snyder Creek Formation’ is properly named the Snyder Creek Shale. The 

‘Callaway Formation’ is now the Cedar Valley Limestone and the ‘Cotter/Jefferson City 

Formation’ is properly the Cotter and Jefferson City Dolomites (Thompson, 1995).

Section 2.2.4 Surface Water Resources, first paragraph, page 2-29. The first sentence of this

paragraph states that ‘Callaway is located within the Missouri River Basin, Auxvasse Creek

subwatershed, approximately 5 mi (8 km) northwest of the Missouri River (Figure 2–10)

(Ameren 2011d).’ The paragraph goes on to state that a significant portion of surface water

runoff from the site, perhaps the majority, flows to Mud and Logan Creeks, which is not within

the Auxvasse Creek subwatershed as depicted on Figure 2–10, page 2-30. The first sentence 

of this paragraph and Figure 2–10 should be amended to include the Logan Creek 

subwatershed.

Section 2.2.4.1 Stormwater Retention Ponds, page 2-34. The last sentence of this paragraph

states that the stormwater ‘receiving water bodies are an unnamed tributary of Logan Creek

(Outfalls 010 and 011), an unnamed tributary of Mud Creek (Outfall 012), and Cow Branch

(Outfalls 014 and 015).’ However, the subsequent Table 2–4 indicates that Outfalls 014 and 

015 discharge to Mud Creek. Cow Branch is a tributary to Auxvasse Creek, not Mud Creek. 

The table should be corrected so that it is consistent with the text (which is consistent with the

Missouri state operating permit).

Section 2.2.5 Groundwater Resources, page 2-35 and Figure 2–12, page 2-36. Similar to

comments in regard to Section 2.2.3.1 above, some of the nomenclature used in this section 

and in Figure 2–12 is not current. Further, the bedrock aquifer names, thicknesses, and 

delineations are incorrect and inconsistent with scientific literature. The authors of the draft 

SEIS are referred to Miller and Vandike (1997) and Gann et al. (1971) for a discussion of the 

hydrology in the northeastern area of Missouri. In addition, the portion of the aquifer that is 

described as confined in Figure 2–12 is unconfined in the area of the Callaway plant; it is 

partially drained by local streams and the Missouri River. In other areas of this groundwater

province, the aquifer is confined.

Section 2.2.5 Groundwater Resources, page 2-37, lines 24 and 25. This paragraph discusses

blowdown pipeline leakage incidents that resulted in releases of tritium to soils and 

groundwater. The last sentence of this section states that sampling showed that ‘All tritium 

concentrations were well below EPA’s drinking water standard of 20,000 picocuries per litre.’ 

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Appendix A

Sample analysis reports for samples collected at the site in June and July of 2006 indicate that 

many samples exceeded that standard, some by more than 10 times the standard. These 

samples were collected along the pipeline and at manholes in response to the discovery that 

pipeline air release valves had been discharging small amounts of pipeline fluids. The 

statement in the text of the draft SEIS should be revised.

Section 4.5.2.1 page 4-5, third paragraph and Section 4.5.2.2 page 4-6, third paragraph. These

paragraphs again use an aquifer name that is inconsistent with accepted usage. The aquifer

tapped by the Callaway plant wells, as well as most of the other local wells, and the aquifer that

discharges to the Missouri River alluvial aquifer, is the Cambrian–Ordovician Aquifer.

Section 4.5.2.3 Radionuclides Released to Groundwater, page 4-6, second paragraph. As with

the comment above with respect to Section 2.2.5, this paragraph discusses blowdown pipeline

leakage incidents that resulted in releases of tritium to soils and groundwater. The second to 

the last sentence of this paragraph states that sampling showed that ‘All tritium concentrations

were well below EPA’s drinking water standard of 20,000 picocuries per litre.’ Sample analysis

reports from June and July of 2006 groundwater sampling indicate that many samples 

exceeded that standard, some by more than 10 times the standard. These samples were 

collected along the pipeline and at manholes in response to the discovery that pipeline air 

release valves had been discharging small amounts of pipeline fluids. The statement in the text 

of the draft SEIS should be revised.

Section 4.12.2.2 Cumulative Impacts on Groundwater Resources, page 4-43. The conclusions

drawn in this section are not adequately supported by the references cited. Farrar (2009) and

USGS (2013) are not pertinent to the discussion. Though the geologic formations of the Ozark

Aquifer of southern Missouri are by and large the same formations that make up the Cambrian–

Ordovician Aquifer of northeast Missouri, the Missouri River forms a hydrologic boundary which 

separates them (Imes 1985, and Miller and Vandike 1997). Czarnecki et al. (2009) is cited as a 

reference to argue that water use by the Callaway plant will have a ‘SMALL’ impact on water 

resources of the aquifer. The Czarnecki study examined a very limited area of the Ozark 

Aquifer in the southwest corner of Missouri, nearly 200 miles from the Callaway plant. The first 

sentence of the third paragraph, while not incorrect, does not support the conclusion made in 

the final sentence of the paragraph and section. The author is referred to Gann et al. (1971) 

and Miller and Vandike (1997) for a description of the groundwater aquifers of northeastern 

Missouri and to Imes (1985) as a basis to evaluate the potential impact to the water resources 

of the area of interest.

Section 4.12.8 Summary of Cumulative Impacts, Table 4–10, page 4-51. The text related to 

water resources in this table may have to be revised pending reevaluation of cumulative impacts 

to groundwater resources, as discussed in the previous comment.

Response:

Dates when permits were issued or expired were updated in Table 1–1 (Licenses and Permits).

The Chamois Power Plant is closed and references to this plant as an operating power plant 

have been removed.

The SEIS has been revised to identify each individual intake well and its pumping rate.

In the SEIS, water quality data from 2008 was chosen to illustrate the seasonal variation in 

Missouri River water quality parameters, as a reasonably complete year long record of data was 

available for 2008 (partial records are available of other years). However, a more complete 

record of discharge data is available for the Missouri River. Therefore the text has been revised 

(Sections 2.2.4 and 4.4.2) to reference stream discharge data on the Missouri River from 1958 

A-69
Appendix A

through 2013 as opposed to 1958 through 2008. Section 4.4.2 includes references to these 

more complete records. In the DSEIS, the analysis in Section 4.4.2 is a very conservative 

analysis of impacts on surface water resources and it was based on some of the lowest flows on 

record for the period between 1958 and 2008. The additional data collected for 1958 to 2013 

have not changed the very low flow values that were used in the impact evaluation.

The text has been revised to include the Logan Creek subwatershed in the description of 

surface watersheds and subwatersheds that drain the Callaway site.

The description of stormwater outfalls 014 and 015 in Table 2–4 has been corrected to identify 

them as outfalls to Cow Creek.

The SEIS has been revised to note that on October 8, 2013, Ameren received a letter from the 

Missouri Department of Natural Resources stating that the Department considers the permit to 

provide appropriate environmental protection under the Missouri Clean Water Law and 

compliance with the Clean Water Act. However, a water quality control permit may still be 

required for specific projects at the facility for Clean Water Act Section 404 Permits.

The geohydrologic nomenclature (names of geologic units) in the draft SEIS was the 

nomenclature used in the license renewal submittal, an Environmental Report submittal for a

new reactor at Callaway (application since withdrawn), and other cited documents. The 

nomenclature in the text has been changed to the presently accepted nomenclature. Former 

Figure 2–9 could not be updated for all of the units and has been removed from the document. 

However, Figure 2–11 was revised to better illustrate the known stratigraphy.

The discussion of groundwater tritium contamination has been revised to include a little more 

history and to make it clear when the text is reporting on levels of tritium in the groundwater as 

opposed to soil.

North of the Missouri River, the Cotter and Jefferson City Dolomites is designated as part of the 

Regional Cambrian–Ordovician Aquifer. South of the river is included in the regional Ozark 

Aquifer. In the draft SEIS, the Cotter and Jefferson City Dolomites Aquifer was identified to be 

part of the Ozark Aquifer. As the site is located north of the Missouri River, it is now identified 

as being part of the Cambrian–Ordovician Aquifer. The cumulative impact discussion has been 

revised to focus on countywide, as opposed to State-wide impacts.

Comment 12-8: Section 2.1.6.1 Circulating Water System includes information regarding 

settling ponds used by the facility for sludge removal storage. There are four existing settling 

ponds at the facility, two of which are currently in use, the other two of which are at maximum 

capacity. This section states that “No changes to the existing settling ponds are planned. 

However, additional settling ponds may be added as needed.” While we understand that there 

are no current specific plans in place for additional settling ponds, we feel that such future plans 

warrant further discussion. Table G–1 in Appendix G reflects an estimate of needing three 

additional sediment retention ponds over the next 20 years. However, there is no mention of 

what the plans may entail for the existing ponds. For instance, will these plans likely include the 

excavation and removal of sludge off site? Or will the existing ponds simply be

decommissioned and left in place once they reach capacity, and the additional ponds be 

constructed?

Response:

Section 2.1.6.1 of the SEIS has been updated to incorporate recent information the future and 

existing sedimentation ponds. From 2014 until the end of the license renewal period, Ameren 

expects it will construct 4 to 5 additional sedimentation ponds to support continued operation of 

Callaway during this time. Exelon plans to complete construction of two of these ponds in 2015. 

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All new ponds will be built on land that was previously disturbed by construction activities and 

has been evaluated for cultural resources. Each new sedimentation pond will cover a surface 

area of approximately 4.4 ac (1.8 ha) and will take about 6 months to construct. During 

construction Ameren will follow best management practices (PMPs) to suppress dust and 

minimize soil erosion. Appropriate permits and plan approvals from the State of Missouri will 

also be obtained. Excavated soil will be placed along the berms of the existing lagoons and 

may later be used for reclamation activities. In consultation with the Missouri Department of 

Natural Resources, the long term reclamation plan for each sedimentation pond is to cap the 

pond and return it to a natural state.

A.4.9 Air Quality (AQ)

The original source for the comment in this category (air) can be found in Section A.5 and is 

labeled with the following identifier: 10-4. The comment is extracted from the original source.

Comment 10-4: 

This section of our review focuses on air quality concerns. The department offers several

corrections and suggests substitutions that clarify and correct some of the information provided

in the document.

Page 2-23: Lines 35 to 43 reference an air permit number “06210-003.” This needs to be 

corrected to “062010-003.” 

Page 4-41: Line 10 currently reads: “Existing emission sources at Callaway are regulated 

under Operating Permit No. OP2008-045. This operating permit expires on 

September 17, 2013.” 

The department suggests the following edit: “Existing emission sources at Callaway are

regulated under Operating Permit No. OP2008-045. This operating permit expired on 

September 17, 2013. A renewal application was submitted to the department on 

February 22, 2013, and is under review. The facility will operate under the previous permit until 

the department issues a new operating permit.” 

Page 4-41: Within a 50-mi (80-km) radius of Callaway, land use is primarily rural. A few minor

emission sources are widely distributed in the area; the closest existing major emission source 

is the Chamois Power Plant, located approximately 6 mi (10 km) south of Callaway. In 2008,

Chamois emitted 2,409 tons of nitrogen oxide and 5,038 tons of sulfur dioxide and is the

dominant emission source in the region.

The department suggests the following addition: “However, Chamois’ most recent emission

reporting, in 2012, indicated they emitted 1,490 tons of nitrogen dioxide and 999 tons of sulfur

dioxide due to the shutting down of the facility. Although a permanent shutdown date is

unknown, it is expected this plant will not operate past 2015.” 

Page 8-6: The document refers to the Central Regional Air Planning Association (CENRAP) in

relation to regional haze and visibility issues.

Comment: The group mentioned above, CENRAP, no longer exists. The department suggests 

the following edit: “The State of Missouri, at the time of the initial regional haze rule was among

nine states (Nebraska, Kansas, Oklahoma, Texas, Minnesota, Iowa, Missouri, Arkansas, and

Louisiana) that were members of the Central Regional Air Planning Association (CENRAP). 

CENRAP, along with tribes, Federal agencies, and other interested parties worked together to

identify regional haze and visibility issues and develop strategies to address them. As the 

funding for this group no longer exists, the individual states work with each other and the 

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[Federal] land managers as necessary on continuing issues and updates to regional haze 

requirements.” 

Response:

The comments identify corrections to be made in the SEIS. The NRC staff agrees with the 

suggested changes and Sections 2.2.2, 4.12.1, and 8.1.1 of the SEIS have been revised 

accordingly.

A.4.10 Ecology (EC)

The original sources for the comments in this category (ecology) can be found in Section A.5 

and are labeled with the following identifiers: 2-3. These comments are extracted from the 

original sources.

Comment 2-3: Just briefly, I want to comment that the cumulative effects on aquatic resources 

are rated LARGE. The Missouri River is called a degraded ecosystem close to or past the point 

of irreparable damage, and yet nothing appears to be done about that.

Response:

As stated in the SEIS, Section 1.4, the large impact level defined by NRC means that 

“environmental effects are clearly noticeable and are sufficient to destabilize important attributes 

of the resource.” The SEIS, Section 4.12.3, points out that much has been and is being done to 

mitigate the effects of past actions and restore the river and its aquatic resources.

The comment provides no “significant new information relevant to the proposed action” for this 

SEIS and, therefore, the staff made no changes to the SEIS as a result of the comment.

A.4.11 Human Health (HH)

The original sources for the comments in this category (human health) can be found in 

Section A.5 and are labeled with the following identifiers: 2-4, 3-4, 17-3, and 17-5. These 

comments are extracted from the original sources.

Radiation Effect 

Comment 3-4: One of the concerns I have most about the Callaway Plant, and especially 

potentially extending the operating duration is exposure to workers to radiation. And the longer 

the plant operates the more crud; which is one of the earliest technical words I learned which 

has to do with the corrosion of products that build up in pipes and other structures, and the 

workers are getting badly exposed to high levels of radiation. And I think that should be dealt 

with in the Generis EIS. 

Comment 17-3: Concerns linger about the buildup of highly radioactive corrosion products that 

accumulate on and inside safety-significant equipment within nuclear power plants. Please see 

the attached set of facts and questions about the pervasive, long-lived “crud” [Chalk River 

Unidentified Deposits]. I submitted those comments to the NRC [34] years ago—about the 

health and environmental hazards of the high gamma-emitting rust and about the chelating 

agents that had been intended to resolve the crud problem, but instead exacerbated it.

Comment 17-5: Exposure to ionizing radiation increases the risk of damage to cells, tissues, 

and DNA, potentially causing mutations, cancer, birth defects, and reproductive, immune, 

cardiovascular, and endocrine disorders. Any exposure to radiation increases a person’s risk. 

The longer a nuclear plant operates, the greater is the accumulation of radioactive contaminants 

and potential occupational risk.

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Response:

The NRC’s mission is to protect the public health and safety and the environment from the 

effects of radiation from nuclear reactors, materials, and waste facilities. The NRC’s regulatory 

limits for radiological protection are set to protect workers and the public from the harmful health 

effects (i.e., cancer and other biological impacts) of radiation on humans. Radiation standards 

reflect extensive scientific study by national and international organizations. The NRC actively 

participates and monitors the work of these organizations to keep current on the latest trends in 

radiation protection.

Callaway was licensed by the NRC with the expectation that it would generate, store, and 

release radioactive material to both the air and water during normal operation. The amount of 

radioactive material released from nuclear power facilities is controlled, measured, monitored, 

and known to be small. The radiation dose received by members of the public from the 

operation of Callaway is low and within NRC and EPA dose limits.

To ensure that nuclear power plants are operated safely, the NRC licenses the plants to 

operate, licenses the plant operators, and establishes license conditions for the safe operation 

of each plant, including regulatory limits for radiological protection. The NRC provides 

continuous oversight of each plant under the NRC’s inspection and enforcement programs. 

While the NRC maintains regulatory oversight of Callaway, Ameren ensures plant operation 

complies with NRC requirements at all times.

Although radiation can cause cancers at high doses, currently there are no data to 

unequivocally establish the occurrence of cancer following exposures to low doses, below about 

10 rem (0.1 Sv). Radiation protection experts conservatively assume that any amount of 

radiation may pose some risk of causing cancer or a severe hereditary effect and that the risk is 

higher for larger radiation exposures. Therefore, a linear, no-threshold dose response 

relationship is used to describe the relationship between radiation dose and detriments such as 

cancer induction. Simply stated, any increase in dose, no matter how small, is assumed to 

result in an incremental increase in health risk. This theory is accepted by the NRC as a 

conservative model for estimating health risks from radiation exposure, recognizing that the 

model probably overestimates those risks. Based on this theory, the NRC conservatively 

establishes limits for radioactive effluents and radiation exposures for workers and members of 

the public. While the public dose limit is 100 mrem (1 mSv) for all facilities licensed by the NRC 

(10 CFR Part 20, “Standards for Protection Against Radiation”), the NRC has imposed 

additional more restrictive dose constraints on nuclear power reactors. Nuclear power reactors, 

including Callaway, have license conditions that limit the total annual whole body dose to a 

member of the public outside the facility to 25 mrem (0.25 mSv). In addition, there are other 

license conditions that limit the dose to a member of the public from radioactive material in 

gaseous effluents to an annual dose of 15 mrem (0.15 mSv) to any organ; for radioactive liquid 

effluents, a dose limit of 3 mrem (0.03 mSv) to the whole body and 10 mrem (0.1 mSv) to any 

organ.

The NRC staff reviewed Callaway radioactive effluent and environmental monitoring programs 

and concluded that radiation doses were within NRC and EPA radiation protection limits. 

Chapter 4 of the Callaway SEIS discusses the impacts to human health.

The comments provide no “significant new information relevant to the proposed action” for this 

SEIS and, therefore, the staff made no changes to the SEIS as a result of the comments.

Microbiological Hazard

Comment 2-4: I also wondered—I looked at the Final Environmental Report by Ameren—and 

attached to that, Attachment E, are helpful letters from the Missouri Department of Natural 

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Resources to Ameren concerning the possibility of thermophilic pathogens entering the Missouri 

River in cooling water discharges. And then the DNR—Missouri DNR—says that it cannot rule 

out the presence of these pathogens nor could it “conclude that this section of the Missouri 

River does not pose a significant risk of waterborne disease.” So I think further assessment of 

that issue is also warranted.

Response:

The NRC staff agrees with the comment to provide additional discussion on Section 4.9.3 

regarding microbiological organisms in the Missouri River and the potential impacts from heated 

water discharged from Callaway. The NRC provided additional information in Section 4.9.3 of 

the SEIS on Callaway’s use of chlorination, molluscicide, and temperature limits that would 

control the growth of microbiological organisms (i.e., disease in hot water). The NRC staff’s 

conclusion did not change; the microbiological hazard impact (i.e., the risk to public health from 

thermophilic microorganisms associated with the potential discharge of heated effluent to the 

Missouri River) remains SMALL.

A.4.12 Climate Change (CC) 

The original source for the comment in this category (climate change) can be found in 

Section A.5 and is labeled with the following identifier: 12-5. The comment is extracted from 

the original source.

Comment 12-5: Ameren’s discussion of climate change and greenhouse gases [GHGs] in the 

DSEIS is appreciated. CEQ issued draft guidance for public comment on when and how 

[Federal] agencies must consider GHG emissions and climate change in their proposed action. 

While this guidance is not yet final, the EPA recommends that the FSEIS explicitly reference the 

draft guidance, describe the elements of the draft guidance, and to the relevant extent, provide 

the assessments suggested by the guidance. We furthermore recommend a discussion of best 

management practices to reduce GHGs and other air emissions during operation of the facility 

buildings, equipment, and vehicles.

The draft guidance proposes that climate change effects should be considered in the analysis of 

projects that are designed for long-term utility and located in areas that are considered 

vulnerable to specific effects of climate change within the project’s timeframe. The focus of this 

analysis should be on those aspects of the environment that, based on the interaction between 

the proposed action and the environment, are affected by the proposed action and on the 

significance of climate change on those aspects of the environment. Agencies should consider 

the specific effects of the proposed action (including the proposed action’s effect on the 

vulnerability of affected ecosystems), the nexus of those effects with projected climate change 

effects on the same aspects of our environment, and the implications for the environment to 

adapt to the projected effects of climate change.

Efforts should be made to minimize GHG emissions to the extent feasible during the license 

renewal period. Clean energy options, such as energy efficiency and renewable energy, should 

be a consideration in the purchase of maintenance equipment and vehicles. In addition, the 

EPA recommends that the project team thoroughly consider the need for measures to manage 

potential climate-related impacts, such as potential increases in storm frequency and intensity 

resulting in increased floodwater flows, and conversely, the potential for increased drought 

events. The DSEIS does not address measures for climate change adaptation for the Callaway 

site. Though the power plant site area containing the major power generation facilities is sited 

336 feet above the average elevation of the Missouri River, the intake structure is located within 

the river floodplain and thus has a higher potential to be directly affected by high water events. 

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High water events possibly associated with regional climate change (e.g., changing precipitation 

patterns, changing hydrology) could threaten facility performance and control by interfering with 

or eliminating access to the intake structure or neighboring wells. In addition, low flows or 

drought conditions could affect access to Missouri River water through the intake structure and 

access to groundwater through wells terminating in the alluvial aquifer. Given that the 

relicensing of the Callaway facility would provide for its continued operation through 2044, we 

believe it is essential that the FSEIS address how the facility intends to adapt to reasonably 

foreseeable changes in climate which might affect the safety and performance of the facility

and, particularly, the circulating water system. Underscoring both the significance and reality of 

this issue, the NRC need only review impacts to the operation of Cooper Nuclear Station at 

River Mile 533 on the Missouri River during the high water events of 2011. Low river flows have 

also frequently affected the ability of other energy facilities withdrawing Missouri River water for 

operational purposes from accessing adequate volumes of water. Please refer to EPA's 

website (www.epa.gov/climatechange) for useful information pertaining to climate change.

Response:

The commenter provides recommendations to be incorporated in the FSEIS regarding climate 

change and GHG emissions considerations. The comments can be summarized into the 

following areas: (a) application of CEQ’s draft guidance on climate change; (b) efforts and 

practices to reduce GHG emissions during the license renewal period; and (c) impacts of 

climate change on operations and operational safety at Callaway and climate change 

adaptation. A response to the three areas identified by the commenter are discussed below.

Application of CEQ’s draft guidance on GHG and climate change

As noted by the commenter, the CEQ’s guidance is yet to be finalized and is still in a draft form. 

As it may be possible for CEQ’s guidance to change and be revised, the NRC staff believes it to 

be prudent to not reference this guidance until a final version is published. However, the NRC 

staff would like to note that a 2009 Commission Order (CLI-09-21) directs the NRC staff to 

consider GHG emissions in environmental reviews for major licensing actions. In response to 

the Commission Order, both climate change and GHG emissions are addressed in SEISs for 

License Renewal and as noted by the commenter, the Callaway SEIS includes a discussion of 

GHGs and climate change.

Efforts and practices to reduce GHG emissions during the license renewal period

Based on its limited statutory authority under the Atomic Energy Act, NRC cannot impose 

measures or standards on its nuclear power plant licensees that are not related to public health 

and safety from radiological hazards or common defense and security, such as clean energy 

options of maintenance equipment and vehicles. The licensee, not the NRC, is responsible for 

the purchase of maintenance equipment and vehicles. Nevertheless, licensees are required to 

comply with all applicable Federal, State, and local permit requirements relevant to their 

activities. Since there will be no refurbishment related activities, the NRC staff expects similar 

emissions during the license renewal period.

Impacts of climate change on operations of Callaway and climate change adaptation

The commenter recommends that the EIS address adaptation to changes in climate that may 

affect the safety and performance of the facility and specifically raises concerns regarding 

changes in flow of Missouri River on the safety and performance of the circulating water system 

and access to groundwater wells. The comment is beyond the scope of the license renewal 

environmental review. The NRC evaluates nuclear plant operating conditions and physical 

infrastructure to ensure continued safe operations (including adaptation with natural phenomena 

hazard) through its ongoing inspection and oversight process, regardless during the current 

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license term or a renewed term. The impacts of climate change on operations and safety at 

Callaway and climate change adaptation of a facility are therefore considered out of scope for 

the environmental review, which documents the potential impacts on the environment from 

continued operation.

All currently operating nuclear power plants are located in consideration of site-specific 

environmental (natural phenomena hazard) conditions. NRC regulations (10 CFR 100 and 

10 CFR Part 50, Appendix A, General Design Criteria) require that plant structures, systems, 

and components important to safety be designed to withstand the effects of natural phenomena

hazard such as flooding from severe storms, without loss of capability to perform safety 

functions. Furthermore, plant operations are dictated by NRC-issued operating license 

technical specifications which ensure that plants operate safely at all times. Technical 

specifications and operating procedures exist to ensure safe operation of the facility, including

coping with natural phenomena hazard. 

As new information that may affect plant safety becomes available, the NRC evaluates the new 

information to determine if any changes are needed at existing plants or its regulations. For 

instance, as part of the Japan lessons-learned activities resulting from the March 2011, 

earthquake and tsunami, the NRC has used its regulatory authority under 10 CFR 50.54 to 

request flood reevaluations of existing nuclear power plants (see ADAMS No. ML12053A340). 

Licensees of operating nuclear power plants have been asked to reevaluate the flooding 

hazards that could affect their sites using present-day information. These newly reevaluated 

hazards, if worse than what the plant had originally calculated upon initial licensing, will be 

analyzed to determine whether plant structures, systems, and components need to be updated 

to protect against the new hazards.

The commenter specifically raises concerns regarding changes in flow of the Missouri River on 

the safety and performance of the circulating water system and access to groundwater wells. 

Should the plant ever be completely cut off from Missouri River water, the NRC requires the 

reactor to be shut down. Even in a shutdown condition, additional water would be needed to 

cool the reactor. Therefore, the NRC requires Callaway to continuously maintain a supply of 

water that can be immediately used to cool the shutdown reactor for a period of 30 days (see 

ADAMS No. ML113540354, Attachment F).

Callaway does not use groundwater from the Missouri River alluvial aquifer. The hydrologic 

interaction between the Missouri River and the Missouri River alluvial aquifer is described in 

Section 2.2.5. The impact of plant consumption on Missouri River flows during low flow 

conditions in the Missouri River (drought) is described in Section 4.4.2. The impact of Missouri 

River water consumption on alluvial aquifer water levels by the Callaway plant during low flow 

conditions in the Missouri River is described in Section 4.5.2.2. As described in cumulative 

impact Section 4.12.2.1, the Missouri River is a managed river. River flow is managed via the 

numerous dams that have been constructed in the Missouri River watershed. The U.S. Army 

Corps of Engineers has the responsibility under Congressional Authorization for construction, 

operation, and maintenance of the Missouri River for navigation, flood control, irrigation, 

recreation, and other related purposes. During the license renewal term, the staff expects that 

the Corps of Engineers will continue to manage the river to prevent floods and maintain 

adequate river flows for downstream uses.

A.4.13 Refurbishment (RE)

The original source for the comment in this category (refurbishment) can be found in 

Section A.5 and is labeled with the following identifier: 12-10. The comment is extracted from 

the original source.

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Comment 12-10: 

Table B-1 in Appendix B. National Environmental Policy Act Issues for License Renewal of 

Nuclear Power Plants, addresses Refurbishment Impacts under the Terrestrial Ecology section 

and states that there is the potential for Small, Medium, or Large environmental significance. 

This section acknowledges that it cannot be known whether important plant and animal 

communities may be affected until the specific proposal is presented with the license renewal 

application.

Mentioned in Chapter 3.0 Environmental Impacts of Refurbishment and included in Section 4.12

Cumulative Impacts as an action or project identified during this review and considered in the 

staff’s independent analysis of the potential cumulative effects are Ameren’s plans for a reactor

vessel head replacement. This replacement is stated in Chapter 3.0 to be scheduled to occur 

10 years before the license renewal, which would effectively be at present time. Given this 

information, it would be expected that more specific and detailed information pertaining to this 

action would be provided in the SEIS. Though very briefly mentioned in Section 4.12, it is not 

shown on Figure 4-3 Projects and Actions with Potential for Cumulative Impacts. 

Section 3.0 Environmental Impacts of Refurbishment states that “the applicant did not identify 

the need to undertake any major refurbishment or replacement actions associated with license 

renewal to support the continued operation of Callaway beyond the end of the existing operating 

license.” However, the preferred alternative does not expressly address the possible need for 

facility component updates and/or refurbishing to extend plant operation for 20 additional years 

beyond the end of the current license period. Any needed updates or refurbishing should be 

identified and their associated environmental consequences and permits approvals should be 

addressed in the FSEIS. The DSEIS appears to suggest that other than changes to the onsite 

spent fuel storage and ISFSI, no major component updates or refurbishing will be needed to 

extend the Callaway Plant for the 20-year renewal period. If so, we recommend that the FSEIS 

include a general but more definitive statement indicating that Ameren believes that no 

substantive updates or refurbishing is needed for the proposed license renewal.

We recommend that the FSEIS discuss means for improving the safety, operation, and 

environmental compliance/monitoring for Callaway Plant 1. While there may essentially not be 

new construction impacts associated with the proposed renewal, improvements to ongoing 

operational protocols could conceivably result in a reduction of operational environmental 

impacts over the next 20-year timeframe. While we understand upgrading is an ongoing 

process, the proposed license renewal offers an excellent opportunity for Ameren to reassess 

any existing impacts and mitigating them procedurally and structurally (technology 

components), where appropriate.

Response:

The staff considers the best available information for its analysis in the SEIS. In the Ameren’s 

ER, Ameren does not identify the need to undertake any major refurbishment or replacement 

action associated with license renewal. Therefore, the staff deleted the refurbishment 

discussion in Chapter 3 of the SEIS. 

In the ER, Ameren states that it plans to replace the reactor vessel head, which is scheduled to 

occur 10 years before current license expiration and is being performed to meet the current

license life of the plant independent of license renewal. The current Callaway license includes 

Appendix B, “Environmental Protection Plan,” which addresses environmental protection related 

to current license activities. The staff evaluated the reactor vessel head replacement activity as 

a part of cumulative impacts as appropriate. 

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A.4.14 Agency or Tribal Information (CO)

The original sources for the comments in this category can be found in Section A.5 and are 

labeled with the following identifiers: 8-1, 12-12. These comments are extracted from the 

original sources.

Comment 8-1: The U.S. Department of the Interior has reviewed the subject document and has 

no comments.

Response:

The NRC received Federal, State, and local agencies’ information throughout its NEPA review 

process consistent with the NRC environmental standard review plan (NUREG–1555, 

Supplement 1, Revision 1) and 10 CFR 51.28(a)(3).

The comment provides no “significant new information relevant to the proposed action” for this 

SEIS and, therefore, the staff made no changes to the SEIS as a result of the comment.

Consultation

Comment 12-12a: We appreciate and support your coordination efforts with resource agencies. 

We recommend continued coordination in support of mitigation planning for ecological, cultural, 

and historic resource impacts, and in consideration and development of efforts to minimize 

direct, indirect, and cumulative impacts. 

Response:

The NRC coordinates with Federal, State, and local agencies, as appropriate, throughout its 

NEPA review process. Consistent with the NRC standard review plan, documentation of all 

coordination and consultation activities is included in the SEIS (Appendix D). No changes have 

been made to the SEIS as a result of this comment.

Comment 12-12b: The DSEIS summarizes NRC’s coordination with the U.S. Fish & Wildlife 

Service and MDNR. Specifically related to the Federally listed pallid sturgeon, the NRC 

determined that the present and future operation of the Callaway plant through 2044 may affect, 

but is not likely to jeopardize, the continued existence of the pallid sturgeon and that any 

adverse effects would accrue primarily through direct mortality caused by entrainment and 

impingement of larvae and juveniles. Given the recent and future recovery efforts of this 

endangered species, the EPA recommends close monitoring and mitigation efforts and 

continued coordination with FWS and MDNR on these issues pertaining to Threatened and 

Endangered species.

Response:

This comment is related to the discussion in the staff’s biological assessment (Appendix H). 

The staff and FWS consultation on the pallid surgeon is continuing. The staff will appropriately

condition the license if the consultation is not concluded in a timely manner.

A.5 Comment Letters and Meeting Transcripts

The following pages contain the comments, identified by commenter designation and comment 

number, from letters and public meeting transcripts on the draft SEIS.

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Appendix A

Public meeting transcript March 19, 2014, afternoon session

Comment 1-1 

(OS) 

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Appendix A

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Appendix A

Comment 1-2 

(OS) 

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Appendix A

Comment 1-3 

(OS) 

Comment 1-4 

(RW) 

Comment 2-1 

(RW) 

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Appendix A

Comment 2-2 

(AL)

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Appendix A

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Appendix A

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Appendix A

Comment 2-3 

(EC)

Comment 2-4 

(HH)

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Comment 3-1

(RW) 

Response: 

This comment is 

addressed to the 

Army Corps of 

Engineers. The 

staff will not 

respond to this 

comment.

Comment 3-2 

(OS) 

Comment 3-3 

(OS)

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Comment 3-4 

(HH)

Comment 3-5 

(RW)

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Comment 3-6 

(RW) 

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Comment 4-1 

(RW)

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Comment 4-1 

(RW), continued

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Comment 4-2 

(OS) 

Comment 4-3 

(RW) 

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Comment 4-4 

(RW) 

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Appendix A

Comment 4-5 

(PA)

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Comment 4-6 

(RW)

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Comment 5-1 

(LR)

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Appendix A

Comment 5-2 

(RW)

Comment 5-3 

(OS)

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Comment 5-4 

(LR)

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Appendix A

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Appendix A

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Appendix A

A-104
Appendix A

Comment 6-1 

(OS) 

Comment 6-2 

(OS) 

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Comment 6-3 

(OS) 

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Comment 7-1 

(GN) 

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Comment 8-1 

(CO)

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Comment 9-1 

(RW) 

Comment 9-2 

(RW)

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Comment 9-3 

(PA)

Comment 9-4 

(RW) 

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Comment 10-1 

(WR) 

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Appendix A

Comment 10-2 

(WR) 

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Appendix A

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Comment 10-4 

(AQ)

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Appendix A

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Comment 11-1 

(RW) 

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Comment 11-2 

(LR)

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Comment 12-1 

(LR) 

Comment 12-2a 

(RW) 

Comment 12-2b 

(RW) 

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Comment 12-3 

(LR) 

Comment 12-4 

(RW) 

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Comment 12-5 

(CC) 

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Comment 12-6 

(AL) 

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Comment 12-7 

(RW) 

Comment 12-8 

(RW) 

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Comment 12-9 

(CL) 

Comment 12-10 

(RE) 

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Comment 12-11 

(LR) 

Comment 12-

12a (CO)

Comment 12-

12b (CO)

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Response: 

This comment is 

directed to

Ameren. The 

staff will not 

respond to this 

comment.

Comment 12-13 

(CL)

A-131
Appendix A

A-132
Appendix A

A-133 
Appendix A

Comment 13-1 

(GN) 

A-134
Appendix A

Comment 14-1 

(RW) 

A-135
Appendix A

Comment 15-1 

(RW) 

A-136
Appendix A

A-137
Appendix A

Comment 16-1 

(RW)

Comment 16-2 

(OS)

A-138
Appendix A

A-139
Appendix A

A-140
Appendix A

A-141
Appendix A

A-142
Appendix A

A-143
Appendix A

A-144
Appendix A

Comment 17-1 

(RW)

A-145
Appendix A

Comment 17-2 

(OS)

Comment 17-3 

(HH) 

Comment 17-4 

(RW) 

A-146
Appendix A

Comment 17-5 

(HH) 

A-147
Appendix A

Response: 

This comment

is directed to 

Dresden 

nuclear power 

plant

operation, 

which is 

beyond the 

scope of this 

environmental 

review. 

Environmental 

impacts 

associated 

with Dresden 

operation are 

addressed in 

the 

Environmental 

Impacts 

Statement for 

the Dresden

plant. The 

staff will not 

respond to this 

comment.

A-148
Appendix A

A-149
Appendix A

A-150
Appendix A

A-151
Appendix A

A-152
Appendix A

A-153
Appendix A

A-154
Appendix A

A-155
Appendix A

A-156
Appendix A

A-157
Appendix A

A-158
Appendix A

A-159
Appendix A

Comment 18-1 

(RW) 

A-160
Appendix A

A-161
Appendix A

A-162
Appendix A

A-163
Appendix A

A-164
Appendix A

A-165
Appendix A

Comment 19-1 

to 21 (CL)

A-166
Appendix A

A-167

ULNRC-06112 

April7, 2014 

Enclosure 1 

4 2-8 

5 2-9 

6 2-18 

7 2-18 

28 2.1.2.1 

1·4 2.1.2.2 

30 2.1.6.1 

42.46 2.1.6.1 

Callaway does not use reverse 

osmosis as a treatment method for 

liquid radioactive waste. 

Line 1·4 states "Offgases from the 

main condenser are the major source 

of gaseous radioactive waste. Other 

radioactive gas sources collected by 

the system include leakage from 

steam piping and equipment in the 

reactor building, turbine generator 

building, and radioactive waste 

building." This is not correct. In fact, 

the major source of gaseous 

radioactive waste is purging of the 

volume control tank and discharge of 

tank vents and other equipment in 

the containment, radioactive waste, 

and auxiliary buildings. 

A statement is made that most of the 

water in the circulating system is lost 

to the atmosphere, this is misleading 

as only about 1% is lost through 

evaporation. 

Should state the water flowing down 

the discharge pipeline and discharged 

to the Missouri River has a maximum 

temperature near 90"F. Cooling 

tower blowdown temperatures 

(Outfall 0021 vary with season and 

range from about 60-90°F. The 

current NPDES Permit does not 

contain an upper temperature limit 

or stipulate that the discharge must 

not cause the temperature of the 

mixing zone (or the area where the 

discharge water meets and mixes 

with the river) to increase by more 

than 5°F (2.8°C). 

Page 3 of& 

Remove reference to 

reverse osmosis. 

Revise paragraph to 

state "The major 

source of gaseous 

radioactive waste is 

purging of the volume 

control tank and 

discharge of tank 

vents and other 

equipment in the 

containment, 

radioactive waste, and 

auxiliary buildings." 

Consider deletion or · 

revising as follows: 

"Although small in 

comparison to the 

total volume of water 

in the circulating 

water system, the 

largest loss is to the 

atmosphere." 

Revise the paragraph 

as follows: "The 

temperature of the 

water flowing down 

the blowdown 

pipeline and 

discharged to the 

Missouri River 115Ya11¥ 

has a maximum 

temperature of 

approximately 90 'F 

(32 •q (Ameren 

201 d) ~ 

peFMilleF 'a ll awa~ 

esla~lishes !he ~~~eF 

liMil el alle•.~a~le 

leMpeFaiYFe iMpaels 

~~ 'allawav eR lhe 

MissaYFi Ai•~eF. 11 
Appendix A

A-168

ULNRC-06112 

Aprll7, 2014 

Enclosure 1 

8 2·19 

9 2·21 

10 2-33 

11 2-68 

12 4-44 

32,33 2.1.7.1 

10, 11 2.1.7.2 

14 

Table 2-

16 

18 -29 4.12.3.1 

Incorrectly estimates the volume of 

water returned to the river. Over the 

past three years the volume of water 

returned to the river has averaged 

near 4400 gpm with the losses to 

evaporation near 11,000 gpm. 

Therefore, approximately 25% of the 

water withdrawn is returned to the 

river. 

The unit2 prior excavation hole is in 

the process of being filled in and will 

be completely filled in by 2015. The 

GWS pump is used to dewater the 

structural fill area underlying the 

power block. 

Concerning the 401 Water Quality 

Certification, Ameren did receive a 

response letter from the Missouri 

DNR (dated October 8, 2013) stating 

that the department considers the 

permit to provide appropriate 

environmental protection under the 

Missouri Clean Water Law and 

compliance with the Clean Water Act. 

Number of Callaway employees does 

not match what is listed on page 2-57 

The Chamois Power Plant ceased 

operation in September 2013 and is 

no longer a cumulative effect on the 

aquatic resources. 

Page 4 of 6 

sl ~wlalesl~all~e 

diSE~aFge IIIYSI A91 

eawse l~e lelll~eFalwFe 

ell~e llliMiAg l&Ae (aF 

l~e aFea w~eFe l~e 

dise~aFged waleF 

111eels a Ad llliMes wil~ 

l~e Fi•>eF)Ia iReFease 

b~ 1119Fe lhaA § 'F (~.8 

'!';) (MilNR ~919a) " 

Suggest revising 

paragraph to state 

that approximately 

25% of the water 

withdrawn is returned 

to the river. 

Consider revising this 

text to match page 2-

371ines 17 & 18. 

Consider revising. 

Consider reconciling 

the two numbers. 

Recommend removing 

reference to the 

Chamois Power plant 

or revising to state 

that it no longer 

impacts the aquatic 

resources. 
Appendix A

A-169

ULNRC.06112 

Aprll7, 2014 

Enclosure1 

13 4-45 

14 5-4 

15 8-26 

16 F·10 

17 F-18 

29 4.12.3.5 

17 5.3.2 

33 8.2.9 

8 

11 

The sentence appears to be 

misleading. Sentence inappropriately 

implies that the "license renewal" 

contributes to the "LARGE" 

cumulative impact when in fact other 

major factors outside of existing or 

future operation of Callaway result in 

this impact. 

The fire PRA CDF number has been 

reduced from 2.0E-5 to 1.68E-5 since 

the originaiLAR was submitted. 

The Missouri-Kansas-Texas Railroad 

in central Missouri is now a state 

hiking trail (Katy Trail State Park I, 

with no rails remaining. The Callaway 

rail spur could not be reconstructed 

to provide rail access. 

The stated CDF of7.6x10E-6 has an 

incorrect exponent 

Safety related water system is 

incorrectly listed as emergency 

service water 

Page 5 of& 

Consider revising the 

text as follows: 

"Because of the 

noticeable 

destabilization of 

aquatic resources 

within the lower 

Missouri River as a 

result of USACE 

intervention with 

reservoir construction 

and channel 

stabilization, 

independent of 

Callaway's existing or 

future operation, the 

NRC staff concludes 

that the cumulative 

effects have the 

potential to be 

LARGE." 

The current fire CDF is 

1.68x10-

5

• Given that 

the fire CDF has been 

reduced since the 

originaiLAR, no 

SAMAs have become 

more cost-beneficial 

and therefore changes 

to the SAMA analysis 

performed for this 

application are not 

needed. 

Consider removing the 

discussion of the rail 

spur to the Callaway 

site. 

Correct to state a CDF 

of 7 .6x10E·S. 

Change to essential 

service water. 
Appendix A

A-170
Appendix B 

NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE 

RENEWAL OF NUCLEAR POWER PLANTS

B.NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE 

RENEWAL OF NUCLEAR POWER PLANTS

NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Power 

Plants (referred to as the GEIS), document the results of the U.S. Nuclear Regulatory 

Commission (NRC) staff’s (staff's) systematic approach to evaluating the environmental impacts 

of renewing the licenses of individual nuclear power plants. The GEIS was originally published 

in 1996 and Addendum 1 to the GEIS, which only addresses transportation issues, was 

published in 1999. Of the 92 total environmental issues that the staff identified in the 1996 

GEIS, the staff determined that 69 are generic to all plants (Category 1), while 21 issues must 

be discussed on a site-specific basis (Category 2). Two other issues, environmental justice and 

the chronic effects of electromagnetic fields, are uncategorized and must be evaluated on a 

site-specific basis.

Table B-1 in this appendix lists all 92 environmental issues, including the possible 

environmental significance (SMALL, MODERATE, LARGE, or uncategorized) as appropriate. 

This table is provided in Chapter 9 of the 1996 GEIS. 

On June 20, 2013, the NRC published a final rule (78 FR 37282) revising its environmental 

protection regulation, Title 10 of the Code of Federal Regulations (10 CFR) Part 51, 

“Environmental protection regulations for domestic licensing and related regulatory functions.” 

Specifically, the final rule updates the potential environmental impacts associated with the 

renewal of an operating license for a nuclear power reactor for an additional 20 years. A 

revised GEIS (NRC 2013b), which updates the 1996 GEIS, provides the technical basis for the 

final rule. The revised GEIS specifically supports the revised list of National Environmental 

Policy Act (NEPA) issues and associated environmental impact findings for license renewal 

contained in Table B–1 in Appendix B to Subpart A of the revised 10 CFR Part 51. The revised 

GEIS and final rule reflect lessons learned and knowledge gained during previous license 

renewal environmental reviews. In addition, public comments received on the draft revised 

GEIS and rule and during previous license renewal environmental reviews were reexamined to 

validate existing environmental issues and identify new ones.

This SEIS, which discusses the environmental impacts associated with the Callaway Plant, 

Unit 1 license renewal, is reviewed against the criteria from the 1996 GEIS. However, new 

issues identified, or recategorized, in the 2013 GEIS are also included in this SEIS. The new 

Category 1 issues identified in the 2013 GEIS which are discussed and evaluated in this SEIS 

are geology and soils, exposure of terrestrial organisms to radionuclides, exposure of aquatic 

organisms to radionuclides, human health impact from chemicals, and physical occupational 

hazards. New Category 2 issues that are addressed in this SEIS are radionuclides released to 

groundwater, effects on terrestrial resources (non-cooling system impacts), minority and lowincome populations (i.e., environmental justice), and cumulative impacts.

B-1 
Appendix B

Table B–1. Generic Summary of Findings on NEPA Issues for License Renewal of Power 

Plants

Issue Type of Issue Findings

Surface Water Quality, Hydrology, and Use

Impacts of 

refurbishment on 

surface water quality

Generic SMALL. Impacts are expected to be negligible during 

refurbishment because best management practices are 

expected to be employed to control soil erosion and spills.

Impacts of 

refurbishment on 

surface water use

Generic SMALL. Water use during refurbishment will not increase 

appreciably or will be reduced during plant outage.

Altered current patterns 

at intake and discharge

structures

Generic SMALL. Altered current patterns have not been found to 

be a problem at operating nuclear power plants and are 

not expected to be a problem during the license renewal 

term.

Altered salinity 

gradients

Generic SMALL. Salinity gradients have not been found to be a 

problem at operating nuclear power plants and are not 

expected to be a problem during the license renewal term.

Altered thermal 

stratification of lakes

Generic SMALL. Generally, lake stratification has not been found 

to be a problem at operating nuclear power plants and is 

not expected to be a problem during the license renewal 

term.

Temperature effects on 

sediment transport 

capacity

Generic SMALL. These effects have not been found to be a 

problem at operating nuclear power plants and are not 

expected to be a problem during the license renewal term.

Scouring caused by 

discharged cooling 

water

Generic SMALL. Scouring has not been found to be a problem at 

most operating nuclear power plants and has caused only 

localized effects at a few plants. It is not expected to be a 

problem during the license renewal term.

Eutrophication Generic SMALL. Eutrophication has not been found to be a 

problem at operating nuclear power plants and is not 

expected to be a problem during the license renewal term.

Discharge of chlorine or 

other biocides

Generic SMALL. Effects are not a concern among regulatory and 

resource agencies, and are not expected to be a problem 

during the license renewal term.

Discharge of sanitary 

wastes and minor 

chemical spills

Generic SMALL. Effects are readily controlled through National 

Pollutant Discharge Elimination System (NPDES) permit 

and periodic modifications, if needed, and are not 

expected to be a problem during the license renewal term.

Discharge of other 

metals in wastewater

Generic SMALL. These discharges have not been found to be a 

problem at operating nuclear power plants with coolingtower-based heat dissipation systems and have been 

satisfactorily mitigated at other plants. They are not 

expected to be a problem during the license renewal term.

B-2 
Appendix B

Issue Type of Issue Findings

Water use conflicts 

(plants with oncethrough cooling 

systems) 

Generic SMALL. These conflicts have not been found to be a 

problem at operating nuclear power plants with oncethrough heat dissipation systems.

Water use conflicts 

(plants with cooling 

ponds or cooling towers 

using makeup water 

from a small river with 

low flow)

Site-specific SMALL OR MODERATE. The issue has been a concern 

at nuclear power plants with cooling ponds and at plants 

with cooling towers. Impacts on in-stream and riparian 

communities near these plants could be of moderate 

significance in some situations. See § 51.53(c)(3)(ii)(A). 

Aquatic Ecology (all plants)

Refurbishment Generic SMALL. During plant shutdown and refurbishment there 

will be negligible effects on aquatic biota because of a 

reduction of entrainment and impingement of organisms or 

a reduced release of chemicals.

Accumulation of 

contaminants in

sediments or biota

Generic SMALL. Accumulation of contaminants has been a 

concern at a few nuclear power plants but has been 

satisfactorily mitigated by replacing copper alloy 

condenser tubes with those of another metal. It is not 

expected to be a problem during the license renewal term.

Entrainment of 

phytoplankton and 

zooplankton

Generic SMALL. Entrainment of phytoplankton and zooplankton 

has not been found to be a problem at operating nuclear 

power plants and is not expected to be a problem during 

the license renewal term.

Cold shock Generic SMALL. Cold shock has been satisfactorily mitigated at 

operating nuclear plants with once-through cooling 

systems, has not endangered fish populations, or been 

found to be a problem at operating nuclear power plants 

with cooling towers or cooling ponds, and is not expected 

to be a problem during the license renewal term.

Thermal plume barrier 

to migrating fish

Generic SMALL. Thermal plumes have not been found to be a 

problem at operating nuclear power plants and are not 

expected to be a problem during the license renewal term.

Distribution of aquatic 

organisms

Generic SMALL. Thermal discharge may have localized effects 

but is not expected to affect the larger geographical 

distribution of aquatic organisms.

Premature emergence 

of aquatic insects

Generic SMALL. Premature emergence has been found to be a 

localized effect at some operating nuclear power plants 

but has not been a problem and is not expected to be a 

problem during the license renewal term.

B-3 
Appendix B

Issue Type of Issue Findings

Gas supersaturation 

(gas bubble disease)

Generic SMALL. Gas supersaturation was a concern at a small 

number of operating nuclear power plants with 

once-through cooling systems but has been satisfactorily 

mitigated. It has not been found to be a problem at 

operating nuclear power plants with cooling towers or 

cooling ponds and is not expected to be a problem during 

the license renewal term.

Low dissolved oxygen 

in the discharge

Generic SMALL. Low dissolved oxygen has been a concern at one 

nuclear power plant with a once-through cooling system,

but it has been effectively mitigated. It has not been found 

to be a problem at operating nuclear power plants with 

cooling towers or cooling ponds and is not expected to be 

a problem during the license renewal term. 

Losses from predation, 

parasitism, and disease 

among organisms 

exposed to sublethal 

stresses

Generic SMALL. These types of losses have not been found to be 

a problem at operating nuclear power plants and are not 

expected to be a problem during the license renewal term.

Stimulation of nuisance 

organisms 

(e.g., shipworms)

Generic SMALL. Stimulation of nuisance organisms has been 

satisfactorily mitigated at the single nuclear power plant 

with a once-through cooling system where previously it 

was a problem. It has not been found to be a problem at 

operating nuclear power plants with cooling towers or 

cooling ponds and is not expected to be a problem during 

the license renewal term.

Aquatic Ecology (for plants with once-through and cooling pond heat dissipation systems)

Entrainment of fish and 

shellfish in early life 

stages

Site-specific SMALL, MODERATE, OR LARGE. The impacts of 

entrainment are small at many plants but may be 

moderate or even large at a few plants with once-through

and cooling-pond cooling systems. Further, ongoing 

efforts in the vicinity of these plants to restore fish 

populations may increase the numbers of fish susceptible 

to intake effects during the license renewal period, such 

that entrainment studies conducted in support of the 

original license may no longer be valid. 

See § 51.53(c)(3)(ii)(B). 

Impingement of fish and 

shellfish

Site-specific SMALL, MODERATE, OR LARGE. The impacts of 

impingement are small at many plants but may be 

moderate or even large at a few plants with once-through

and cooling-pond cooling systems. 

See § 51.53(c)(3)(ii)(B). 

Heat shock Site-specific SMALL, MODERATE, OR LARGE. Because of continuing 

concerns about heat shock and the possible need to 

modify thermal discharges in response to changing 

environmental conditions, the impacts may be of moderate 

or large significance at some plants. 

See § 51.53(c)(3)(ii)(B). 

B-4 
Appendix B

Issue Type of Issue Findings

Aquatic Ecology (for plants with cooling-tower-based heat dissipation systems)

Entrainment of fish and 

shellfish in early life 

stages

Generic SMALL. Entrainment of fish has not been found to be a 

problem at operating nuclear power plants with this type of 

cooling system and is not expected to be a problem during 

the license renewal term.

Impingement of fish and 

shellfish

Generic SMALL. The impacts of impingement have not been 

found to be a problem at operating nuclear power plants 

with this type of cooling system and are not expected to be 

a problem during the license renewal term.

Heat shock Generic SMALL. Heat shock has not been found to be a problem 

at operating nuclear power plants with this type of cooling 

system and is not expected to be a problem during the 

license renewal term.

Groundwater Use and Quality

Impacts of 

refurbishment on 

groundwater use and 

quality

Generic SMALL. Extensive dewatering during the original 

construction on some sites will not be repeated during 

refurbishment on any sites. Any plant wastes produced 

during refurbishment will be handled in the same manner 

as in current operating practices and are not expected to 

be a problem during the license renewal term.

Groundwater use 

conflicts (potable and 

service water; plants 

that use <100 gallons 

per minute [gpm])

Generic SMALL. Plants using less than 100 gpm are not expected 

to cause any groundwater use conflicts.

Groundwater use 

conflicts (potable and 

service water, and 

dewatering plants that 

use >100 gpm)

Site-specific SMALL, MODERATE, OR LARGE. Plants that use more 

than 100 gpm may cause groundwater use conflicts with 

nearby groundwater users. See § 51.53(c)(3)(ii)(C). 

Groundwater use 

conflicts (plants using 

cooling towers 

withdrawing makeup 

water from a small river)

Site-specific SMALL, MODERATE, OR LARGE. Water use conflicts 

may result from surface water withdrawals from small 

water bodies during low flow conditions that may affect 

aquifer recharge, especially if other groundwater or 

upstream surface water users come on line before the 

time of license renewal. See § 51.53(c)(3)(ii)(A). 

Groundwater use 

conflicts (Ranney wells) 

Site-specific SMALL, MODERATE, OR LARGE. Ranney wells can 

result in potential groundwater depression beyond the site 

boundary. Impacts of large groundwater withdrawal for 

cooling tower makeup at nuclear power plants using 

Ranney wells must be evaluated at the time of application 

for license renewal. See § 51.53(c)(3)(ii)(C). 

B-5 
Appendix B

Issue Type of Issue Findings

Groundwater quality 

degradation (Ranney 

wells) 

Generic SMALL. Groundwater quality at river sites may be 

degraded by induced infiltration of poor-quality river water 

into an aquifer that supplies large quantities of reactor

cooling water. However, the lower quality infiltrating water 

would not preclude the current uses of groundwater and is 

not expected to be a problem during the license renewal 

term.

Groundwater quality 

degradation (saltwater 

intrusion)

Generic SMALL. Nuclear power plants do not contribute 

significantly to saltwater intrusion.

Groundwater quality 

degradation (cooling 

ponds in salt marshes)

Generic SMALL. Sites with closed-cycle cooling ponds may 

degrade groundwater quality. Because water in salt 

marshes is brackish, this is not a concern for plants 

located in salt marshes.

Groundwater quality 

degradation (cooling 

ponds at inland sites)

Site-specific SMALL, MODERATE, OR LARGE. Sites with 

closed-cycle cooling ponds may degrade groundwater

quality. For plants located inland, the quality of the 

groundwater in the vicinity of the ponds must be shown to 

be adequate to allow continuation of current uses. 

See § 51.53(c)(3)(ii)(D). 

Terrestrial Ecology

Refurbishment impacts Site-specific SMALL, MODERATE, OR LARGE. Refurbishment 

impacts are insignificant if no loss of important plant and 

animal habitat occurs. However, it cannot be known 

whether important plant and animal communities may be 

affected until the specific proposal is presented with the 

license renewal application. See § 51.53(c)(3)(ii)(E). 

Cooling tower impacts 

on crops and 

ornamental vegetation

Generic SMALL. Impacts from salt drift, icing, fogging, or 

increased humidity associated with cooling tower 

operation have not been found to be a problem at 

operating nuclear power plants and are not expected to be 

a problem during the license renewal term.

Cooling tower impacts 

on native plants

Generic SMALL. Impacts from salt drift, icing, fogging, or 

increased humidity associated with cooling tower 

operation have not been found to be a problem at 

operating nuclear power plants and are not expected to be 

a problem during the license renewal term.

Bird collisions with 

cooling towers

Generic SMALL. These collisions have not been found to be a 

problem at operating nuclear power plants and are not 

expected to be a problem during the license renewal term.

Cooling pond impacts 

on terrestrial resources

Generic SMALL. Impacts of cooling ponds on terrestrial ecological 

resources are considered to be of small significance at all 

sites.

B-6 
Appendix B

Issue Type of Issue Findings

Power line right-of-way

management (cutting 

and herbicide 

application)

Generic SMALL. The impacts of right-of-way maintenance on 

wildlife are expected to be of small significance at all sites.

Bird collisions with 

power lines

Generic SMALL. Impacts are expected to be of small significance 

at all sites.

Impacts of 

electromagnetic fields

on flora and fauna

Generic SMALL. No significant impacts of electromagnetic fields

on terrestrial flora and fauna have been identified. Such 

effects are not expected to be a problem during the license 

renewal term.

Floodplains and 

wetland on power line 

right-of-way

Generic SMALL. Periodic vegetation control is necessary in 

forested wetlands underneath power lines and can be 

achieved with minimal damage to the wetland. No 

significant impact is expected at any nuclear power plant 

during the license renewal term.

Threatened or Endangered Species

Threatened or 

endangered species

Site-specific SMALL, MODERATE, OR LARGE. Generally, plant 

refurbishment and continued operation are not expected to 

adversely affect threatened or endangered species. 

However, consultation with appropriate agencies would be 

needed at the time of license renewal to determine 

whether threatened or endangered species are present 

and whether they would be adversely affected. 

See § 51.53(c)(3)(ii)(E). 

Air Quality

Air quality during 

refurbishment

(nonattainment and 

maintenance areas)

Site-specific SMALL, MODERATE, OR LARGE. Air quality impacts 

from plant refurbishment associated with license renewal 

are expected to be small. However, vehicle exhaust 

emissions could be cause for concern at locations in or 

near nonattainment or maintenance areas. The 

significance of the potential impact cannot be determined 

without considering the compliance status of each site and 

the numbers of workers expected to be employed during 

the outage. See § 51.53(c)(3)(ii)(F). 

Air quality effects of 

transmission lines

Generic SMALL. Production of ozone and oxides of nitrogen is 

insignificant and does not contribute measurably to 

ambient levels of these gases.

Land Use

Onsite land use Generic SMALL. Projected onsite land use changes required 

during refurbishment and the renewal period would be a 

small fraction of any nuclear power plant site and would 

involve land that is controlled by the applicant.

Power line right-of-way Generic SMALL. Ongoing use of power line rights-of-way would 

continue with no change in restrictions. The effects of 

these restrictions are of small significance.

B-7 
Appendix B

Issue Type of Issue Findings

Human Health

Radiation exposures to 

the public during 

refurbishment

Generic SMALL. During refurbishment, the gaseous effluents 

would result in doses that are similar to those from current 

operation. Applicable regulatory dose limits to the public 

are not expected to be exceeded.

Occupational radiation 

exposures during 

refurbishment

Generic SMALL. Occupational doses from refurbishment are 

expected to be within the range of annual average 

collective doses experienced for pressurized-water 

reactors and boiling water reactors. Occupational 

mortality risk from all causes, including radiation, is in the 

mid-range for industrial settings.

Microbiological 

organisms 

(occupational health)

Generic SMALL. Occupational health impacts are expected to be 

controlled by the continued application of accepted 

industrial hygiene practices to minimize worker exposures.

Microbiological 

organisms (public 

health) (plants using 

lakes or canals, or 

cooling towers or 

cooling ponds that 

discharge to a small 

river)

Site-specific SMALL, MODERATE, OR LARGE. These organisms are 

not expected to be a problem at most operating plants, 

except possibly at plants using cooling ponds, lakes, or 

canals that discharge to small rivers. Without site-specific 

data, it is not possible to predict the effects generically. 

See § 51.53(c)(3)(ii)(G). 

Noise Generic SMALL. Noise has not been found to be a problem at 

operating plants and is not expected to be a problem at 

any plant during the license renewal term.

Electromagnetic fields: 

acute effects (electric 

shock)

Site-specific SMALL, MODERATE, OR LARGE. Electric shock 

resulting from direct access to energized conductors or 

from induced charges in metallic structures has not been 

found to be a problem at most operating plants and 

generally is not expected to be a problem during the 

license renewal term. However, site-specific review is 

required to determine the significance of the electric shock 

potential at the site. See § 51.53(c)(3)(ii)(H). 

Electromagnetic fields: 

chronic effects 

Uncategorized UNCERTAIN. Biological and physical studies of 60-Hz 

electromagnetic fields have not found consistent evidence 

linking harmful effects with field exposures. However, 

research is continuing in this area and a consensus 

scientific view has not been reached.

Radiation exposures to 

public (license renewal 

term)

Generic SMALL. Radiation doses to the public will continue at 

current levels associated with normal operations.

Occupational radiation 

exposures (license 

renewal term)

Generic SMALL. Projected maximum occupational doses during 

the license renewal term are within the range of doses 

experienced during normal operations and normal 

maintenance outages and would be well below regulatory 

limits.

B-8 
Appendix B

Issue Type of Issue Findings

Socioeconomic Impacts

Housing impacts Site-specific SMALL, MODERATE, OR LARGE. Housing impacts are 

expected to be of small significance at plants located in a 

medium or high population area and not in an area where 

growth control measures, that limit housing development, 

are in effect. Moderate or large housing impacts of the 

workforce, associated with refurbishment, may be 

associated with plants located in sparsely populated areas 

or in areas with growth control measures that limit housing 

development. See § 51.53(c)(3)(ii)(I). 

Public services: public 

safety, social services, 

and tourism and 

recreation

Generic SMALL. Impacts to public safety, social services, and 

tourism and recreation are expected to be of small 

significance at all sites.

Public services: public 

utilities

Site-specific SMALL OR MODERATE. An increased problem with 

water shortages at some sites may lead to impacts of 

moderate significance on public water supply availability. 

See § 51.53(c)(3)(ii)(I). 

Public services: 

education

(refurbishment)

Site-specific SMALL, MODERATE, OR LARGE. Most sites would 

experience impacts of small significance but larger 

impacts are possible depending on site- and projectspecific factors. See § 51.53(c)(3)(ii)(I). 

Public services: 

education (license 

renewal term)

Generic SMALL. Only impacts of small significance are expected.

Offsite land use 

(refurbishment)

Site-specific SMALL OR MODERATE. Impacts may be of moderate 

significance at plants in low population areas. 

See § 51.53(c)(3)(ii)(I). 

Offsite land use 

(license renewal term)

Site-specific SMALL, MODERATE, OR LARGE. Significant changes in 

land use may be associated with population and tax 

revenue changes resulting from license renewal. 

See § 51.53(c)(3)(ii)(I). 

Public services: 

transportation

Site-specific SMALL, MODERATE, OR LARGE. Transportation 

impacts (level of service) of highway traffic generated

during plant refurbishment and during the term of the 

renewed license are generally expected to be of small 

significance. However, the increase in traffic associated 

with the additional workers and the local road and traffic 

control conditions may lead to impacts of moderate or 

large significance at some sites. See § 51.53(c)(3)(ii)(J). 

B-9 
Appendix B

Issue Type of Issue Findings

Historic and 

archaeological 

resources

Site-specific SMALL, MODERATE, OR LARGE. Generally, plant 

refurbishment and continued operation are expected to 

have no more than small adverse impacts on historic and 

archaeological resources. However, the National Historic 

Preservation Act requires the Federal agency to consult 

with the State Historic Preservation Officer to determine 

whether there are properties present that require 

protection. See § 51.53(c)(3)(ii)(K). 

Aesthetic impacts 

(refurbishment)

Generic SMALL. No significant impacts are expected during 

refurbishment.

Aesthetic impacts 

(license renewal term)

Generic SMALL. No significant impacts are expected during the 

license renewal term.

Aesthetic impacts of 

transmission lines

(license renewal term)

Generic SMALL. No significant impacts are expected during the 

license renewal term.

Postulated Accidents

Design-basis accidents Generic SMALL. The NRC staff has concluded that the 

environmental impacts of design-basis accidents are of 

small significance for all plants.

Severe accidents Site-specific SMALL. The probability weighted consequences of 

atmospheric releases, fallout onto open bodies of water, 

releases to groundwater, and societal and economic 

impacts from severe accidents are small for all plants. 

However, alternatives to mitigate severe accidents must 

be considered for all plants that have not considered such 

alternatives. See § 51.53(c)(3)(ii)(L). 

Uranium Fuel Cycle and Waste Management

Offsite radiological 

impacts (individual 

effects from other than 

the disposal of spent 

fuel and high-level 

waste)

Generic SMALL. Offsite impacts of the uranium fuel cycle have 

been considered by the Commission in Table S-3 of this 

part. Based on information in the GEIS, impacts on 

individuals from radioactive gaseous and liquid releases, 

including radon-222 and technetium-99, are small.

B-10
Appendix B

Issue Type of Issue Findings

Offsite radiological 

impacts (collective 

effects)

Generic The 100-year environmental dose commitment to the 

U.S. population from the fuel cycle, high-level waste, and 

spent fuel disposal is calculated to be about 

14,800 person-rem, or 12 cancer fatalities, for each 

additional 20-year power reactor operating term. Much of 

this, especially the contribution of radon releases from 

mines and tailing piles, consists of tiny doses summed 

over large populations.

This same dose calculation can theoretically be extended 

to include many tiny doses over additional thousands of 

years, as well as doses outside the United States. The 

result of such a calculation would be thousands of cancer 

fatalities from the fuel cycle, but this result assumes that 

even tiny doses have some statistical adverse health 

effects that will not ever be mitigated (for example, no 

cancer cure in the next 1,000 years), and that these doses 

projected over thousands of years are meaningful. 

However, these assumptions are questionable. In 

particular, science cannot rule out the possibility that there 

will be no cancer fatalities from these tiny doses. For 

perspective, the doses are very small fractions of 

regulatory limits, and even smaller fractions of natural 

background exposure to the same populations.

Nevertheless, despite all the uncertainty, some judgment 

as to the implications of these matters with respect to 

NEPA regulations should be made, and it makes no sense 

to repeat the same judgment in every case. Even taking 

the uncertainties into account, the Commission concludes 

that these impacts are acceptable in that these impacts 

would not be sufficiently large to require the NEPA 

conclusion, for any plant, that the option of extended 

operation under 10 CFR Part 54 should be eliminated. 

Accordingly, while the Commission has not assigned a 

single level of significance for the collective effects of the 

fuel cycle, this issue is considered Category 1 (Generic).

B-11
Appendix B

Issue Type of Issue Findings

Offsite radiological 

impacts (spent fuel and 

high-level waste

disposal)

Generic For the high-level waste and spent fuel disposal 

component of the fuel cycle, there are no current 

regulatory limits for offsite releases of radionuclides for the 

current candidate repository site. However, if it is 

assumed that limits are developed along the lines of the 

1995 National Academy of Sciences (NAS) report, 

“Technical Bases for Yucca Mountain Standards,” and 

that, in accordance with the Commission’s Waste 

Confidence Decision in 10 CFR 51.23, a repository can 

and likely will be developed at some site that will comply 

with such limits, peak doses to virtually all individuals will 

be 100 milliroentgen-equivalent man (millirem) per year or 

less. 

However, while the Commission has reasonable 

confidence that these assumptions will prove correct, there 

is considerable uncertainty since the limits are yet to be 

developed, no repository application has been completed 

or reviewed, and uncertainty is inherent in the models 

used to evaluate possible pathways to the human 

environment. The NAS report indicated that 100 millirem 

per year should be considered as a starting point for limits 

for individual doses, but it notes that some measure of 

consensus exists among national and international bodies 

that the limits should be a fraction of the 100 millirem per 

year. The lifetime individual risk from 100 millirem annual 

dose limit is about 3x10-3. 

Estimating cumulative doses to populations over 

thousands of years is more problematic. The likelihood 

and consequences of events that could seriously 

compromise the integrity of a deep geologic repository 

were evaluated by the U.S. Department of Energy in the 

“Final Environmental Impact Statement: Management of 

Commercially Generated Radioactive Waste,” 

October 1980. The evaluation estimated the 70-year 

whole-body dose commitment to the maximum individual 

and to the regional population resulting from several 

modes of breaching a reference repository in the year of 

closure, after 1,000 years, after 100,000 years, and after 

100,000,000 years. Subsequently, the NRC and other 

Federal agencies have expended considerable effort to 

develop models for the design and for the licensing of a 

high-level waste repository, especially for the candidate 

repository at Yucca Mountain. More meaningful estimates 

of doses to the population may be possible in the future as 

more is understood about the performance of the 

proposed Yucca Mountain repository. Such estimates 

would involve great uncertainty, especially with respect to 

cumulative population doses over thousands of years. 

The standard proposed by the NAS is a limit on maximum 

individual dose. The relationship of potential new 

regulatory requirements, based on the NAS report, and 

cumulative population impacts has not been determined,

B-12
Appendix B

Issue Type of Issue Findings

Offsite radiological 

impacts (spent fuel and 

high-level waste

disposal)

(continued from 

previous page) 

Generic although the report articulates the view that protection of 

individuals will adequately protect the population for a 

repository at Yucca Mountain. However, the 

Environmental Protection Agency’s (EPA) generic 

repository standards in 40 CFR Part 191 generally provide 

an indication of the order of magnitude of cumulative risk 

to the population that could result from the licensing of a 

Yucca Mountain repository, assuming the ultimate 

standards will be within the range of standards now under 

consideration. The standards in 40 CFR Part 191 protect 

the population by imposing the amount of radioactive 

material released over 10,000 years. The cumulative 

release limits are based on the EPA’s population impact 

goal of 1,000 premature cancer deaths worldwide for a 

100,000 metric ton (MTHM) repository.

Nevertheless, despite all the uncertainty, some judgment 

as to the implications of these matters with respect to 

NEPA regulations should be made, and it makes no sense 

to repeat the same judgment in every case. Even taking 

the uncertainties into account, the Commission concludes 

that these impacts are acceptable in that these impacts 

would not be sufficiently large to require the NEPA 

conclusion, for any plant, that the option of extended 

operation under 10 CFR Part 54 should be eliminated. 

Accordingly, while the Commission has not assigned a 

single level of significance for the impacts of spent fuel

and high-level waste disposal, this issue is considered in 

Category 1 (Generic).

Nonradiological impacts 

of the uranium fuel 

cycle

Generic SMALL. The nonradiological impacts of the uranium fuel 

cycle resulting from the renewal of an operating license for 

any plant are found to be small.

Low-level waste storage 

and disposal

Generic SMALL. The comprehensive regulatory controls that are 

in place and the low public doses being achieved at 

reactors ensure that the radiological impacts to the 

environment will remain small during the term of a 

renewed license. The maximum additional onsite land that 

may be required for low-level waste storage during the 

term of a renewed license and associated impacts will be 

small.

Nonradiological impacts on air and water will be negligible. 

The radiological and nonradiological environmental 

impacts of long-term disposal of low-level waste from any 

individual plant at licensed sites are small. In addition, the 

Commission concludes that there is reasonable assurance 

that sufficient low-level waste disposal capacity will be 

made available when needed for facilities to be 

decommissioned consistent with NRC decommissioning 

requirements.

B-13
Appendix B

Issue Type of Issue Findings

Mixed waste storage 

and disposal

Generic SMALL. The comprehensive regulatory controls and the 

facilities and procedures that are in place ensure proper 

handling and storage, as well as negligible doses and 

exposure to toxic materials for the public and the 

environment at all plants. License renewal will not 

increase the small, continuing risk to human health and 

the environment posed by mixed waste at all plants. The 

radiological and nonradiological environmental impacts of 

long-term disposal of mixed waste from any individual 

plant at licensed sites are small. In addition, the 

Commission concludes that there is reasonable assurance 

that sufficient mixed waste disposal capacity will be made 

available when needed for facilities to be decommissioned 

consistent with NRC decommissioning requirements.

Onsite spent fuel Generic SMALL. The expected increase in the volume of spent 

fuel from an additional 20 years of operation can be safely 

accommodated on site with small environmental effects 

through dry or pool storage at all plants if a permanent 

repository or monitored retrievable storage is not available.

Nonradiological waste Generic SMALL. No changes to generating systems are 

anticipated for license renewal. Facilities and procedures 

are in place to ensure continued proper handling and 

disposal at all plants.

Transportation Generic SMALL. The impacts of transporting spent fuel enriched 

up to 5 percent uranium-235 with average burnup for the 

peak rod to current levels approved by the NRC up to 

62,000 megawatt days per metric ton uranium 

(MWd/MTU) and the cumulative impacts of transporting 

high-level waste to a single repository, such as Yucca 

Mountain, Nevada, are found to be consistent with the 

impact values contained in 10 CFR 51.52(c), Summary 

Table S-4, “Environmental Impact of Transportation of 

Fuel and Waste to and from One Light-Water-Cooled 

Nuclear Power Reactor.” If fuel enrichment or burnup 

conditions are not met, the applicant must submit an 

assessment of the implications for the environmental 

impact values reported in 10 CFR 51.52, “Environmental 

Effects of Transportation of Fuel and Waste—Table S-4”.

B-14
Appendix B

Issue Type of Issue Findings

Decommissioning

Radiation doses Generic SMALL. Doses to the public will be well below applicable 

regulatory standards regardless of which decommissioning 

method is used. Occupational doses would increase no 

more than 1 man-rem caused by the buildup of long-lived 

radionuclides during the license renewal term.

Waste management Generic SMALL. Decommissioning at the end of a 20-year license 

renewal period would generate no more solid wastes than 

at the end of the current license term. No increase in the 

quantities of Class C or greater than Class C wastes 

would be expected.

Air quality Generic SMALL. Air quality impacts of decommissioning are 

expected to be negligible either at the end of the current 

operating term or at the end of the license renewal term.

Water quality Generic SMALL. The potential for significant water quality impacts 

from erosion or spills is no greater whether 

decommissioning occurs after a 20-year license renewal 

period or after the original 40-year operation period, and 

measures are readily available to avoid such impacts.

Ecological resources Generic SMALL. Decommissioning after either the initial operating 

period or after a 20-year license renewal period is not 

expected to have any direct ecological impacts.

Socioeconomic impacts Generic SMALL. Decommissioning would have some short-term 

socioeconomic impacts. The impacts would not be 

increased by delaying decommissioning until the end of a 

20-year license renewal period, but they might be 

decreased by population and economic growth.

Environmental Justice

Environmental justice Uncategorized NONE. The need for and the content of an analysis of 

environmental justice will be addressed in plant-specific 

reviews.

Source: 10 CFR Part 51 (61 FR 28467, June 5, 1996)

B-15

Appendix C 

APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS

C.APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS

The Atomic Energy Act (42 USC § 2021) authorizes the U.S. Nuclear Regulatory Commission 

(NRC) to enter into agreement with any state to assume regulatory authority for certain 

activities. Missouri is a non-agreement state; thus, the NRC has regulatory responsibility over 

byproducts, sources, and quantities of special nuclear materials.

In addition to carrying out some Federal programs, state legislatures develop their own laws. 

State statutes supplement, as well as implement, Federal laws for protection of air, water 

quality, and groundwater. State legislation may address solid waste management programs, 

locally rare or endangered species, and historic and cultural resources.

The Clean Water Act (CWA) allows for primary enforcement and administration through state 

agencies, given that the state program is at least as stringent as the Federal program. The 

state program must conform to the CWA and to the delegation of authority for the Federal 

National Pollutant Discharge Elimination System (NPDES) Program from the Environmental 

Protection Agency (EPA) to the state. The primary mechanism to control water pollution is the 

requirement for direct dischargers to obtain an NPDES permit, or in the case of states where the 

EPA has delegated authority, a State Pollutant Discharge Elimination System permit, under the 

CWA. In Missouri, the Missouri Department of Natural Resources issues and enforces NPDES 

permits.

One important difference between Federal regulations and certain state regulations is the 

definition of waters regulated by the state. Certain state regulations may include underground 

waters, while the CWA regulates only surface waters.

C.1 Federal and State Environmental Requirements

Callaway Plant, Unit 1 (Callaway) is subject to Federal and state requirements for its 

environmental program. Those requirements are briefly described below. See Section 1.9 of 

this supplemental environmental impact statement for Callaway’s compliance status with these 

requirements.

Table C–1 lists the principal Federal regulations (and associated state environmental 

regulations, as allowed for the state agencies to be the primary enforcement and administration 

agencies, given that the state program is at least as stringent as the Federal program) and laws 

that are applicable to the review of the environmental resources potentially affected by this 

project that may affect license renewal applications for nuclear power plants.

C-1 
Appendix C

Table C–1. Federal (and Associated State) Environmental Requirements

Law/regulation Requirements

Current operating license and license renewal

42 U.S.C. § 2011 et seq., 

Atomic Energy Act of 1954, 

as amended

Covers the laws for the development, regulation, and disposal of nuclear 

materials and facilities in the United States.

10 CFR Part 51. Code of 

Federal Regulations (CFR), 

Title 10, Energy, Part 51

“Environmental Protection Regulations for Domestic Licensing and Related 

Regulatory Functions.” This part contains environmental protection 

regulations applicable to NRC's domestic licensing and related regulatory 

functions.

10 CFR Part 54 “Requirements for Renewal of Operating Licenses for Nuclear Power 

Plants.” This part focuses on managing adverse effects of aging rather 

than noting all aging mechanisms. The rule is intended to ensure that 

important systems, structures, and components will maintain their intended 

function during the period of extended operation.

10 CFR Part 50 “Domestic Licensing of Production and Utilization Facilities.” Regulations 

issued by the NRC under the Atomic Energy Act of 1954, as amended 

(68 Stat. 919), and Title II of the Energy Reorganization Act of 1974 

(88 Stat. 1242) provide for the licensing of production and utilization 

facilities. This part also gives notice to all persons who knowingly supply—

to any licensee, applicant, contractor, or subcontractor—components, 

equipment, materials, or other goods or services, that relate to a licensee’s 

or applicant's activities subject to this part that they may be individually 

subject to NRC enforcement action for violation of § 50.5.

Air quality protection

Clean Air Act (CAA) 

(42 USC § 7401 et seq.)

The CAA is a comprehensive Federal law that regulates air emissions. 

Under the CAA, Federal actions cannot thwart state and local efforts to 

remedy long-standing air quality problems that threaten public health issues 

associated with the six criteria air pollutants (ozone, nitrogen dioxide, sulfur 

dioxide, particulate matter, carbon monoxide, and lead).

Water resources protection

Clean Water Act (CWA) 

(33 USC 1251 et seq.) and 

the NPDES (40 CFR 122)

The CWA establishes the basic structure for regulating discharges of 

pollutants into the waters of the United States and regulating quality 

standards for surface waters.

Wild and Scenic River Act 

(16 USC 1271 et seq.)

The Wild and Scenic River Act created the National Wild and Scenic Rivers 

System, which was established to protect the environmental values of 

free-flowing streams from degradation by impacting activities, including 

water resources projects.

C-2 
Appendix C

Law/regulation Requirements

Waste management and pollution prevention

Resource Conservation and 

Recovery Act (RCRA) 

(42 USC § 6901 et seq.)

Before a material can be classified as a hazardous waste, it must first be a 

solid waste, as defined under the RCRA. Hazardous waste is classified 

under Subtitle C of the RCRA. Parts 261 and 262 of Title 40 CFR contain 

all applicable generators of hazardous waste regulations. Part 261.5 (a) 

and (e) contains requirements for conditionally exempt small quantity 

generators. Part 262.34(d) contains requirements for small quantity 

generators. Parts 262 and 261.5(e) contain requirements for large quantity 

generators.

Pollution Prevention Act 

(42 USC § 13101 et seq.)

The Pollution Prevention Act formally established a national policy to 

prevent or reduce pollution at its source whenever possible. The Act 

supplies funds for state and local pollution prevention programs through a 

grant program to promote the use of pollution prevention techniques by 

business.

Protected species

Endangered Species Act

(ESA) (16 USC § 1531 et 

seq.)

The ESA forbids any government agency, corporation, or citizen from taking 

(harming or killing) endangered animals without an Endangered Species 

Permit. The ESA also requires Federal agencies to consult with the Fish 

and Wildlife Service or the National Marine Fisheries Service (NMFS) if any 

Federal action may adversely affect any listed species or designated critical 

habitat.

Magnuson-Stevens Fishery 

Conservation and 

Management Act (MSA) 

(P.L. 94-265) as amended 

through January 12, 2007

The MSA includes requirements for Federal agencies to consider the 

impact of Federal actions on essential fish habitat and to consult with the 

NMFS if any activities may adversely affect essential fish habitat.

Marine Mammal Protection 

Act (MMPA)

The MMPA prohibits the harassment, capture, killing, or collecting of marine 

mammals in U.S. waters or by U.S. citizens on the high seas without a 

MMPA Take Permit issued by the NMFS.

Fish and Wildlife 

Coordination Act

(16 USC § 661 et seq.)

To minimize adverse impacts of proposed actions on fish and wildlife 

resources and habitat, the Fish and Wildlife Coordination Act requires that 

Federal agencies consult government agencies regarding activities that 

affect, control, or modify waters of any stream or bodies of water. It also 

requires that justifiable means and measures be used in modifying plans to 

protect fish and wildlife in these waters.

Historic preservation

National Historic 

Preservation Act (NHPA) 

(16 USC § 470 et seq.)

NHPA directs Federal agencies to consider the impact of their actions on 

historic properties and consult with the State Historic Preservation Officer. 

NHPA also encourages state and local preservation societies. 

C-3 

Appendix D 

CONSULTATION CORRESPONDENCE

D.CONSULTATION CORRESPONDENCE

D.1 Background

The Endangered Species Act of 1973, as amended; the Magnuson Stevens Fisheries 

Management Act of 1996, as amended, and the National Historic Preservation Act of 1966 

require that Federal agencies consult with applicable state and Federal agencies and groups 

before taking action that may affect threatened or endangered species, essential fish habitat, or 

historic and archaeological resources, respectively. This appendix contains consultation 

documentation.

Table D-1 lists the consultation documents sent between the U.S. Nuclear Regulatory 

Commission (NRC) and other agencies. The NRC staff is required to consult with these 

agencies based on the National Environmental Policy Act of 1969 requirements.

D-1 
Appendix D

Table D–1. Consultation Correspondence 

Author Recipient Date of letter/e-mail

Fells, C., NRC Hunter, A., Osage Nation March 12, 2012

(ML12206A080)

Hunter, A., Osage Nation Fells, C., NRC March 12, 2012

(ML12206A080)

Wrona, D., NRC Blanchard, G., Absentee-Shawnee Tribe 

of Indians of Oklahoma

March 30, 2012

(ML12061A444)

Wrona, D., NRC Edwards, B., Caddo Nation March 30, 2012

(ML12061A444)

Wrona, D., NRC Baker, B., Cherokee Nation March 30, 2012

(ML12061A444)

Wrona, D., NRC Chief-Boswell, J., Cheyenne and Arapaho 

Tribes of Oklahoma

March 30, 2012

(ML12061A444)

Wrona, D., NRC Anoatubby, B., Chickasaw Nation of 

Oklahoma

March 30, 2012

(ML12061A444)

Wrona, D., NRC Pyle, G., Choctaw Nation of Oklahoma March 30, 2012

(ML12061A444)

Wrona, D., NRC Barrett, J., Citizen Potawatomi Nation March 30, 2012

(ML12061A444)

Wrona, D., NRC Holton, K., Delaware Nation March 30, 2012

(ML12061A444)

Wrona, D., NRC Wallace, G., Eastern Shawnee Tribe of 

Oklahoma

March 30, 2012

(ML12061A444)

Wrona, D., NRC Rhodd, T., Iowa Tribe of Kansas and 

Nebraska

March 30, 2012

(ML12061A444)

Wrona, D., NRC Rowe-Kurak, J., Iowa Tribe of Oklahoma March 30, 2012

(ML12061A444)

Wrona, D., NRC Gamble, T., Miami Tribe of Oklahoma March 30, 2012

(ML12061A444)

Wrona, D., NRC Tiger, G., Muscogee (Creek) Nation of 

Oklahoma

March 30, 2012

(ML12061A444)

Wrona, D., NRC Sheridan, A., Omaha Tribe of Nebraska & 

Iowa

March 30, 2012

(ML12061A444)

Wrona, D., NRC Red Eagle, J., Osage Nation March 30, 2012

(ML12061A444)

Wrona, D., NRC Shotton, J., Otoe-Missouria Tribe of 

Oklahoma

March 30, 2012

(ML12061A444)

Wrona, D., NRC Gover, M., Pawnee Nation of Oklahoma March 30, 2012

(ML12061A444)

Wrona, D., NRC Froman, J., Peoria Tribe of Oklahoma March 30, 2012

(ML12061A444)

Wrona, D., NRC Rhodd, D., Ponca Tribe of Indians of 

Oklahoma

March 30, 2012

(ML12061A444)

Wrona, D., NRC White, R., Ponca Tribe of Nebraska March 30, 2012

(ML12061A444)

Wrona, D., NRC Ortiz, S., Prairie Band of Potawatomi 

Indians

March 30, 2012

(ML12061A444)

Wrona, D., NRC Berrey, J., Quapaw Tribe of Oklahoma March 30, 2012

(ML12061A444)

Wrona, D., NRC Dougherty, M., Sac and Fox Nation of 

Missouri in Kansas and Nebraska

March 30, 2012

(ML12061A444)

Wrona, D., NRC Thurman, G., Sac and Fox Nation of 

Oklahoma

March 30, 2012

(ML12061A444)

D-2 
Appendix D

Author Recipient Date of letter/e-mail

Wrona, D., NRC Blackcloud, F., Sac and Fox Tribe of the 

Mississippi in Iowa

March 30, 2012

(ML12061A444)

Wrona, D., NRC Sparkman, R., Shawnee Tribe March 30, 2012

(ML12061A444)

Wrona, D., NRC Wickliffe, G., United Keetoowah Band of 

Cherokee Indians of Oklahoma

March 30, 2012

(ML12061A444)

Wrona, D., NRC Blackhawk, J., Winnebago Tribe of 

Nebraska

March 30, 2012

(ML12061A444)

Wrona, D., NRC Friend, B., Wyandotte Nation March 30, 2012

(ML12061A444)

Wrona, D., NRC Sternberg, J., Missouri Department of 

Conservation

March 30, 2012

(ML12103A242)

Larson, E., NRC Hunter, A., Osage Nation April 13, 2012

(ML12207A620)

Susco, J., NRC Melius, T., U.S. Fish and Wildlife Service

Midwest Region

April 20, 2012

(ML12096A369)

Wrona, D., NRC Salveter, A., U.S. Fish and Wildlife 

Service, Midwest Region

April 23, 2012

(ML12103A209)

Wrona, D., NRC Pauley, S., State Historic Preservation 

Office

April 25, 2012

(ML12102A072)

Wrona, D., NRC Nelson, R., Advisory Council on Historic 

Preservation

April 25, 2012

(ML12103A393)

Wrona, D., NRC Buntin, D., Missouri Department of Natural 

Resources

April 26, 2012

(ML12114A067)

Balsam, B., NRC Salveter, A., U.S. Fish and Wildlife 

Service, Midwest Region

April 26, 2012

(ML12263A255)

Ledwin, J., U.S. Fish and Wildlife 

Service, Midwest Region

Balsam, B., NRC May 8, 2012

(ML12263A255)

Thompson, I., Choctaw Nation of 

Oklahoma

Wrona, D., NRC May 18, 2012

(ML12156A264)

Susco, J., NRC Clancy, E., Missouri Department of 

Conservation

June 1, 2012

(ML12128A093)

Wrona, D., NRC Hunter, A., Osage Nation Historic 

Preservation Office

June 6, 2012

(ML12150A306)

Balsam, B., NRC Campbell-Allison, J., Missouri Department 

of Conservation

June 18, 2012

(ML12263A255)

Balsam, B., NRC Hansen, R., U.S. Fish and Wildlife 

Service Midwest Region

June 18, 2012

(ML12263A255)

Wyatt, D., U.S. Fish and Wildlife 

Service Midwest Region

Briana, B., NRC June 28, 2012

(ML12263A255)

Bass, N., U.S. Army Corps of 

Engineers 

Riley, K., SC&A July 13, 2012

(ML13211A013)

Demand, J., Missouri Department of 

Conservation

Riley, K., SC&A August 9, 2012

(ML13211A013)

Hansen, R., U.S. Fish and Wildlife 

Service Midwest Region

Logan, D., NRC September 10, 2012

(ML12256A931)

Clancy, E., Missouri Department of 

Conservation

Fells, C., NRC November 16, 2012

(ML12325A071)

Deel, J., State Historic Preservation 

Office, Missouri Department of Natural 

Resources

Wong, M., NRC January 30, 2013

(ML13029A324)

Miles, M., State Historic Preservation 

Office, Missouri Department of Natural 

Resources

Wong, M., NRC February 14, 2013

(ML13078A364)

D-3 
Appendix D

Author Recipient Date of letter/e-mail

Wrona, D., NRC Melius, T., U.S. Fish and Wildlife 

Service Midwest Region

February 24, 2014

(ML13176A379)

Nelson, R., Advisory Council on Historic 

Preservation

Wrona, D., NRC February 24, 2014

(ML14042A381)

Wrona, D., NRC Friend, B., Wyandotte Nation February 24, 2014

(ML14042A437)

Wrona, D., NRC Blackhawk, J., Winnebago Tribe of 

Nebraska 

February 24, 2014

(ML14042A437)

Wrona, D., NRC Wickliffe, G., United Keetoowah Band of 

Cherokee Indians of Oklahoma

February 24, 2014

(ML14042A437)

Wrona, D., NRC Sparkman, R., Shawnee Tribe February 24, 2014

(ML14042A437)

Wrona, D., NRC Sanache, A., Sac and Fox Tribe of the 

Mississippi in Iowa

February 24, 2014

(ML14042A437)

Wrona, D., NRC Thurman, G., Sac and Fox Nation of 

Oklahoma 

February 24, 2014

(ML14042A437)

Wrona, D., NRC Dougherty, M., Sac and Fox Nation of 

Missouri in Kansas and Nebraska 

February 24, 2014

(ML14042A437)

Wrona, D., NRC Berrey, J., Quapaw Tribe of Oklahoma February 24, 2014

(ML14042A437)

Wrona, D., NRC Ortiz, S., Prairie Band of Potawatomi 

Indians 

February 24, 2014

(ML14042A437)

Wrona, D., NRC White, R., Ponca Tribe of Nebraska February 24, 2014

(ML14042A437)

Wrona, D., NRC Rhodd, D., Ponca Tribe of Indians of 

Oklahoma 

February 24, 2014

(ML14042A437)

Wrona, D., NRC Froman, J., Peoria Tribe of Oklahoma February 24, 2014

(ML14042A437)

Wrona, D., NRC Gover, M., Pawnee Nation of Oklahoma February 24, 2014

(ML14042A437)

Wrona, D., NRC Shotton, J., Otoe-Missouria Tribe of 

Oklahoma 

February 24, 2014

(ML14042A437)

Wrona, D., NRC Red Eagle, J., Osage Nation February 24, 2014

(ML14042A437)

Wrona, D., NRC Morris, R., Omaha Tribe of Nebraska & 

Iowa

February 24, 2014

(ML14042A437)

Wrona, D., NRC Tiger, G., Muscogee (Creek) Nation of 

Oklahoma

February 24, 2014

(ML14042A437)

Wrona, D., NRC Lankford, D., Miami Tribe of Oklahoma February 24, 2014

(ML14042A437)

Wrona, D., NRC Rowe-Kurak, J., Iowa Tribe of Oklahoma February 24, 2014

(ML14042A437)

Wrona, D., NRC Rhodd, T., Iowa Tribe of Kansas and 

Nebraska 

February 24, 2014

(ML14042A437)

Wrona, D., NRC Wallace, G., Eastern Shawnee Tribe of 

Oklahoma

February 24, 2014

(ML14042A437)

Wrona, D., NRC Watkins, C.J., Delaware Nation February 24, 2014

(ML14042A437)

Wrona, D., NRC Barrett Jr., J., Citizen Potawatomi Nation February 24, 2014

(ML14042A437)

Wrona, D., NRC Pyle, G., Choctaw Nation of Oklahoma February 24, 2014

(ML14042A437)

Wrona, D., NRC Anoatubby, B., Chickasaw Nation of 

Oklahoma

February 24, 2014

(ML14042A437)

D-4 
Appendix D

Author Recipient Date of letter/e-mail

Wrona, D., NRC Chief-Boswell, J., Cheyenne and Arapaho 

Tribes of Oklahoma

February 24, 2014

(ML14042A437)

Wrona, D., NRC Baker, B., Cherokee Nation February 24, 2014

(ML14042A437)

Wrona, D., NRC Edwards, B., Caddo Nation February 24, 2014

(ML14042A437)

Wrona, D., NRC Blanchard, G., Absentee-Shawnee Tribe 

of Indians of Oklahoma

February 24, 2014

(ML14042A437)

Pauley, S., Missouri State Historic 

Preservation Office, Missouri 

Department of Natural Resources

Wrona, D., NRC February 26, 2014

(ML14050A016)

Bilyeu, L., Choctaw Nation of Oklahoma Larson, E., NRC March 18, 2014

(ML14077A516)

D-5 

Appendix E 

CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE

E.CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE

This appendix contains a chronological listing of correspondence between the U.S. Nuclear 

Regulatory Commission (NRC) and external parties as part of its environmental review for 

Callaway Plant, Unit 1 (Callaway). All documents, with the exception of those containing 

proprietary information, are available electronically from the NRC’s Public Electronic Reading 

Room, which is found on the Internet at the following Web address: 

http://www.nrc.gov/reading-rm.html. From this site, the public can gain access to the NRC’s 

Agencywide Documents Access and Management System (ADAMS), which provides text and 

image files of the NRC’s public documents. The ADAMS accession number for each document 

is included in the following list. To locate a reference in ADAMS, click on the “Simple Search” 

tab at the top of the Web page and enter the ADAMS accession number in the search box.

E.1 Environmental Review Correspondence

Table E–1 lists the environmental review correspondence in date order beginning with the 

request by Union Electric Company, a subsidiary of Ameren Corporation and doing business as 

Ameren Missouri (Ameren or the applicant), to renew the operating license for Callaway.

E-1 
Appendix E

Table E–1. Environmental Review Correspondence

Date Correspondence Description ADAMS No.

December 15, 2011 Letter from Ameren forwarding the Callaway license 

renewal application and request to renew the 

operating license for an additional 20 years

ML113530367

December 19, 2011 Applicant’s Environmental Report ML113540349

ML113540352

ML113540354

December 23, 2011 Letter from the NRC to Ameren, “Receipt and 

Availability of the License Renewal Application for the 

Callaway Plant, Unit 1” 

ML11343A060

December 23, 2011 Federal Register notice, “Notice of Receipt and 

Availability of Application for Renewal of Callaway 

Plant, Unit 1”

ML11343A087

February 14, 2012 Letter from the NRC to Ameren, “Determination of 

Acceptability and Sufficiency for Docketing, Proposed 

Review Schedule, and Opportunity for a Hearing 

Regarding the Application from Union Electric 

Company, for Renewal of the Operating License for 

Callaway Plant, Unit 1”

ML12024A262

February 14, 2012 Letter from the NRC to Ameren, “Notice of Intent to 

Prepare an Environmental Impact Statement and 

Conduct Scoping Process for License Renewal for 

Callaway Plant, Unit 1”

ML12040A215

February 14, 2012 Federal Register notice, “Notice of Intent to Prepare 

an Environmental Impact Statement and Conduct 

Scoping Process for License Renewal for Callaway 

Plant, Unit 1”

ML12040A225

February 16, 2012 Federal Register, “Notice of Acceptance for Docketing 

of the Application, Notice of Opportunity for Hearing, 

Regarding Renewal of Facility Operating License 

No. NPF–30 for an Additional 20-Year Period, Union 

Electric Company, Callaway Plant, Unit 1”

ML12024A254

February 29, 2012 Letter from unknown, “Comment on License Renewal 

Application for Callaway Plant, Unit 1, Union Electric 

Company; Intent to Prepare Environmental Impact 

Statement”

ML12062A071

March 14, 2012 Letter from Kurt Wadzinski, Bureau of Land 

Management, “Comment on License Renewal 

Application for Callaway Plant, Unit 1, Union Electric 

Company; Intent To Prepare Environmental Impact 

Statement”

ML12076A124

March 28, 2012 Letter from Ameren, “Callaway Plant, Unit 1 Union 

Electric Co. Facility Operation License NPF–30 

License Renewal Application Online LR Library”

ML12088A351

March 30, 2012 Letters from the NRC to Tribal Governments within 

the Plant’s Vicinity, “Request for Comments 

Concerning Callaway Plant, Unit 1, License Renewal 

Application Review”

ML12061A444

April 11, 2012 Summary of Public Scoping Meetings Conducted 

Related to the Review of the Callaway Plant, Unit 1, 

License Renewal Application

ML12089A099

E-2 
Appendix E

Date Correspondence Description ADAMS No.

April 20, 2012 Letter from the NRC to Mr. Tom Melius, Midwest 

Regional Director, U.S. Fish and Wildlife Service,

“Request for Concurrence with list of Federally 

Protected Species and Habitats for the Proposed 

Callaway Plant License Renewal”

ML12096A369

April 23, 2012 Letter from the NRC to Ms. Amy Salveter, Field 

Supervisor, U.S. Fish and Wildlife Service, “Callaway 

Plant, Unit 1, License Renewal Application 

Environmental Review”

ML12103A209

April 23, 2012 Letter from the NRC to Ms. Janet Sternberg, Policy 

Coordination Unit, Missouri Department of 

Conservation, “Callaway Plant, Unit 1, License 

Renewal Application Environmental Review”

ML12103A242

April 25, 2012 Letter from the NRC to Ms. Sara Parker Pauley, State 

Historic Preservation Office, Missouri Department of 

Natural Resources, “Callaway Plant, Unit 1, License 

Renewal Application Environmental Review (MO 

SHPO LOG #008-CY-10) 

ML12102A072

April 25, 2012 Letter from the NRC to Mr. Reid Nelson, Director, 

Office of Federal Agency Programs, Advisory Council 

on Historic Preservation, “Callaway Plant, Unit 1, 

License Renewal Application Environmental Review”

ML12103A393

April 26, 2012 Letter from the NRC to Mr. Dru Buntin, Director’s 

Office, Missouri Department of Natural Resources, 

“Callaway Plant, Unit 1, License Renewal Application 

Environmental Review” 

ML12114A067

May 15, 2012 Letter from the NRC to Ameren, “Environmental Site 

Audit Regarding Callaway Plant, Unit 1 (TAC 

Nos. ME7715 and ME7716)”

ML12125A181

May 18, 2012 Letter from Choctaw Nation of Oklahoma, “Re: 

Renewal of the operating license for Callaway Plant, 

Unit 1 (Callaway) located near Fulton in Callaway 

County, Missouri”

ML12156A264

June 1, 2012 Letter from the NRC to Ms. Emily Clancy, Missouri 

Department of Conservation, “Request for Heritage 

Review for the Proposed Callaway Plant License 

Renewal”

ML12128A093

June 6, 2012 Letter from the NRC to Dr. Andrea A. Hunter, Tribal 

Historic Preservation Officer, Osage Nation Historic 

Preservation Office, “Transmittal of Historic and 

Cultural Information to the Osage Nation re: Callaway 

Nuclear Plant License Renewal Review”

ML12150A306

June 22, 2012 Letter from the NRC to Ameren, “Summary of Site 

Audit Related to the Review of the License Renewal 

Application for Callaway Plant, Unit 1 (TAC 

Nos. ME7715 and ME7716)”

ML12159A154

July 12, 2012 Letter from the NRC to Ameren, “Requests for 

Additional Information for the Review of the Callaway 

Plant, Unit 1 License Renewal Application (TAC 

Nos. ME7715 and ME7716)”

ML12173A017

E-3 
Appendix E

Date Correspondence Description ADAMS No.

July 18, 2012 Letter from the NRC to Ameren “Requests for 

Additional Information on Severe Accident Mitigation 

Alternatives for Callaway Plant, Unit 1 (TAC 

No. ME7716)”

ML12180A022

April 20, 2012 Letter from the NRC to Mr. Tom Melius, Midwest 

Regional Director, U.S. Fish and Wildlife Service,

“Request for Concurrence with List of Federally 

Protected Species and Habitats for the Proposed 

Callaway Plant License Renewal”

ML12096A369

April 25, 2012 Letter from the NRC to Sara Parker Pauley, State 

Historic Preservation Office, Missouri Department of 

Natural Resources, “Callaway Plant, Unit 1 License 

Renewal Application Environmental Review 

(MO SHOP Log #008-CY-10)”

ML12102A072

August 6, 2012 Letter from the NRC to Ameren, “Requests for 

Additional Information for the Review of the Callaway 

Plant, Unit 1, License Renewal Application, Set 2 

(TAC Nos. ME7715 and ME7716)”

ML12206A048

August 13, 2012 Package containing Letter from Ameren, “Response 

to Environmental RAI Set 1 to the Callaway Plant, 

Unit 1 License Renewal Application” and Enclosures

ML122710518

August 30, 2012 Package containing Letter from Ameren, “Callaway 

Plant, Unit 1 Union Electric Co. Facility Operation 

License NPF–30, Responses to E–RAI Set 2 to the 

Callaway LRA” and Enclosures

ML122440687

February 14, 2013 Letter from Mark A. Miles, Director and Deputy, State 

Historic Preservation Office, Missouri Department of 

Natural Resources, “Re: Callaway Plant, Unit 1, 

License Renewal Application (NRC) Callaway County, 

Missouri”

ML13078A364

October 9, 2013 Letter from Ameren, “Follow-Up to E-RAI Set #2 

Responses to the Callaway LRA”

ML13283A182

February 12, 2014 (FRN) Notice Of Availability Of The Draft PlantSpecific Supplement 51 To The Generic 

Environmental Impact Statement For License 

Renewal Of Nuclear Plants Regarding Callaway Plant, 

Unit 1.

ML14043A536

February 12, 2014 (Letter) Notice of Availability of the Draft Plant-Specific 

Supplement 51 to the Generic Environmental Impact 

Statement for License Renewal of Nuclear Plants 

Regarding Callaway Plant, Unit 1. 

ML14043A048

February 20, 2014 Callaway, License Renewal Public Meeting Slides 

February 20, 2014.

ML14050A402

February 21, 2014 Press Release-14-009: NRC Seeks Public Comment 

on Draft Environmental Report for Callaway Nuclear 

Plant License Renewal - Meetings Scheduled for 

March 19, 2014. 

ML14052A396

February 21, 2014 Notice of Availability of the Draft Plant-Specific 

Supplement 51 to the Generic Environmental Impact 

Statement for License Renewal of Nuclear Plants 

Regarding Callaway Plant, Unit 1.

ML14050A064

E-4 
Appendix E

Date Correspondence Description ADAMS No.

February 24, 2014 Notice of Availability of the DSEIS for License 

Renewal of Callaway Plant, Unit 1 for Public 

Comment.

ML14042A381

February 24, 2014 NRC to FWS, Request for Concurrence on the Effects 

of the Proposed Callaway License Renewal on 

Federally Threatened and Endangered Species.

ML13176A379

February 26, 2014 Draft Environmental Impact Statement for Callaway 

License Renewal Available for Comment - Missouri 

SHPO.

ML14050A016

March 7, 2014 03/19/2014, Notice of Forthcoming Category 3 Public 

Meeting to Discuss the Draft Supplement 51 to the 

Generic Environmental Impact Statement for License 

Renewal of Nuclear Plants (NUREG-1437) for 

Callaway, Unit 1, Issued in February 2014.

ML14066A497

March 18, 2014 2014/03/18, NRR E-mail Capture - RE: Notice of 

Availability of the Draft Supplemental Environmental 

Impacts Statement for License Renewal of Callaway 

Plant, Unit 1, Fulton, Callaway Co, MO

ML14077A516

March 19, 2014 Draft Environmental Impact Statement for Callaway 

Plant License Renewal Public Meeting - Afternoon 

Session.

ML14112A380

March 19, 2014 Draft Environmental Impact Statement for Callaway 

Plant License Renewal Public Meeting - Evening 

Session.

ML14112A366

March 19, 2014 Preliminary Site-Specific Results of the License 

Renewal Environmental Review for Callaway Plant, 

Unit 1.

ML14112A355

March 20, 2014 Comment (3) of Arlene Sandler Opposing Draft 

Supplement 51 to the GEIS for License Renewal of 

Nuclear Plants for Callaway, Unit 1.

ML14092A183

March 20, 2014 Comment (1) of Steve Dinolfo Supporting the 

Renewal of Callaway Nuclear Plant, Unit 1 License 

Application.

ML14084A319

March 28, 2014 Comment (2) Robert F. Stewart on behalf of 

U.S. Dept. of Interior on Draft Environmental Impact 

Statement (DEIS), Generic - Renewal of Nuclear 

Plants, NUREG- 1437, Supplement 51, Regarding 

Callaway, Unit 1.

ML14090A401

April 4, 2014 Comment (4) of Robert Stout, on behalf of State of 

Missouri Department of Natural Resources, on 

License Renewal Application for Callaway Plant, Unit 

1; Draft Supplemental Generic Environmental Impact 

Statement. 

ML14107A066

April 7, 2014 Callaway Plant Unit 1 - Review of the Draft 

Supplement 51 for NUREG-1437.

ML14097A499

April 7, 2014 Comment (6) of Jeffery Robichaud on behalf of 

U.S. Environmental Protection Agency, Region 7 on 

License Renewal Application for Callaway Plant, 

Unit 1; Draft Supplemental Generic Environmental 

Impact Statement.

ML14107A108

E-5 
Appendix E

Date Correspondence Description ADAMS No.

April 7, 2014 Comment (5) of Edward Smith on behalf of Missouri 

Coalition for the Environment on License Renewal 

Application for Callaway Plant, Unit 1; Draft 

Supplemental Generic Environmental Impact 

Statement.

ML14107A067

April 7, 2014 Comment (10) of Mark Kelly on License Renewal 

Application for Callaway Plant, Unit 1; Draft 

Supplemental Generic Environmental Impact 

Statement.

ML14107A068

April 7, 2014 Comment (7) of Unknown Individual on License 

Renewal Application for Callaway Plant, Unit 1; 

Correction.

ML14107A112

April 7, 2014 Comment (8) of Unknown Individual, Opposing 

License Renewal Application for Callaway Plant, Unit 

1; Correction.

ML14107A130

April 7, 2014 Comment (9) of Mary Mosley Opposing the Renewal 

of Callaway, Unit 1, License Application.

ML14107A131

April 7, 2014 Comment (13) of Sarah Kovaleski on behalf of 

Ameren Missouri on Draft Supplement 51 for 

NUREG–1437.

ML14113A372

April 10, 2014 Comment (12) of Kevin Kamps on behalf of Beyond 

Nuclear on SEIS for Proposed Callaway 20 Year 

License Extension.

ML14107A007

April 11, 2014 Comment (11) of Kay Drey, on behalf of Beyond 

Nuclear, on NUREG 1437 - Supplement 51: the Draft 

Supplemental EIS re Ameren/UE’s Application to 

extend the Operating License for the Callaway for an 

Additional 20 Years.

ML14107A006

April 15, 2014 Callaway Plant, Unit 1 - Supplement to the Callaway 

LRA - NFPA 805 Gap Analysis and LRA 

Amendment 33.

ML14105A475

April 23, 2014 Project Manager Change for the License Renewal of 

Callaway Plant, Unit 1 (TAC NO. ME7716).

ML14112A450

May 7, 2014 Summary of public meetings to discuss draft 

Supplement 51 to the generic environmental impact 

statement for license renewal of nuclear plants 

regarding Callaway Plant, Unit 1 (TAC NO. ME7716). 

ML14112A276

May 19, 2014 Callaway Plant, Unit 1 - Update to License Renewal 

Application environmental Permits.

ML14139A497

June 3, 2014 Callaway, Unit 1 – Update to License Renewal 

Application Environmental Permits

ML14154A493

July 19, 2014 2014/07/18 NRR E-mail Capture – Callaway: 

conference call on ongoing ESA section 7 

consultation for pallid sturgeon

ML14202A585

August 7, 2014 2014/08/07 NRR E-mail Capture – FW: Callaway 

Updated Status of Compliance Table

ML14227A065

September 18, 2014 Request for Information Concerning the Endangered 

Species Act Section 7 Consultation for the Proposed 

Callaway Plant, Unit 1, License Renewal

ML14246A095

September 29, 2014 FWS, Response to NRC Letter on Callaway Pallid 

Sturgeon Consultation

ML14273A031

E-6 
Appendix F 

U.S. NUCLEAR REGULATORY COMMISSION STAFF EVALUATION 

OF SEVERE ACCIDENT MITIGATION ALTERNATIVES FOR

CALLAWAY PLANT, UNIT 1, IN SUPPORT OF 

LICENSE RENEWAL APPLICATION REVIEW

F.U.S. NUCLEAR REGULATORY COMMISSION STAFF EVALUATION OF 

SEVERE ACCIDENT MITIGATION ALTERNATIVES FOR CALLAWAY 

PLANT, UNIT 1, IN SUPPORT OF LICENSE RENEWAL APPLICATION 

REVIEW 

F.1 Introduction

Union Electric Company, a subsidiary of Ameren Corporation and doing business as Ameren 

Missouri (Ameren or the applicant), submitted an assessment of severe accident mitigation 

alternatives (SAMA) for Callaway Plant, Unit 1 (Callaway), as part of the Environmental Report 

(ER) (Ameren 2011a). This assessment was based on the most recent Callaway probabilistic 

risk assessment (PRA) available at that time, a plant-specific offsite consequence analysis 

performed using the MELCOR Accident Consequence Code System 2 (MACCS2) computer 

code, and insights from the Union Electric Company Callaway individual plant examination (IPE) 

(Union Electric 1992) and individual plant examination of external events (IPEEE) (Union 

Electric 1995). In identifying and evaluating potential SAMA, Ameren considered SAMA that 

addressed the major contributors to core damage frequency (CDF) and release frequency at 

Callaway, as well as SAMA candidates for other operating plants that have submitted license 

renewal applications (LRAs). Ameren initially identified 171 potential SAMA. This list was 

reduced to 64 unique SAMA candidates by eliminating SAMA because of (1) Callaway having a 

different design, (2) the SAMA having already been implemented at Callaway or already having 

had its intent met by other means, (3) combining the SAMA with another SAMA candidate that 

is similar in nature, (4) excessive implementation cost, or (5) being related to a nonrisk 

significant system and therefore of very low benefit. Ameren assessed the costs and benefits 

associated with each of the 64 potential SAMA and concluded in its original assessment that 

three of the candidate SAMA evaluated were potentially cost-beneficial.

Based on a review of the SAMA assessment and a plant audit trip conducted 

May 23 and 24, 2012, the U.S. Nuclear Regulatory Commission (NRC) staff issued requests for

additional information (RAI) to Ameren by letters dated July 18, 2012 (NRC 2012a), 

November 5, 2012 (NRC 2012b), and March 11, 2013 (NRC 2013). Key questions concerned: 

the contributions to CDF by initiating event; internal and external review comments on the PRA 

model including the 2000 peer review; a 2006 self-assessment against the 2005 American 

Society of Mechanical Engineers (ASME) PRA standard (ASME 2005) and focused scope peer 

review on the human reliability analysis (HRA); insights from the fire PRA performed in support 

of the Callaway National Fire Protection Association (NFPA) 805 Licensing Amendment 

Request (Ameren 2011b); insights from internal flooding analysis of the Callaway reactor; and 

the correlation between Level 1 and Level 2 PRA importance analyses and the identification and 

evaluation of candidate SAMA. Ameren submitted additional information by letters dated 

September 24, 2012 (Ameren 2012a), October 17, 2012 (Ameren 2012b), January 15, 2013 

(Ameren 2013a), and April 2, 2013 (Ameren 2013b). Ameren also provided clarifications to the 

RAI responses in a conference call held on November 5, 2012 (NRC 2012b). In the responses, 

Ameren provided: a listing of initiating event contributions to the CDF, a discussion of open 

gaps and “key findings” from the PRA reviews and an assessment of their impact on the SAMA 

analysis; clarification of Level 2 PRA modeling details and assumptions; further details on the 

Callaway fire PRA and the internal flooding models and potential additional SAMA; analyses of 

other additional SAMA; and additional information regarding several specific SAMA.

As a result of NRC staff RAI, Ameren identified 18 additional SAMA candidates, six of which 

were qualitatively screened, leaving 12 for further analysis. Ameren also reevaluated several of 

the initial SAMA candidates identified in the ER. As a result of these evaluations, Ameren 

F-1 
Appendix F

identified 13 additional cost-beneficial SAMA in addition to the original three. Ameren has 

indicated that all 16 potentially cost-beneficial SAMA will be entered into Callaway’s long-range 

plan development process for further implementation consideration.

An assessment of SAMA for Callaway is presented below.

F.2 Estimate of Risk for Callaway

Ameren’s estimates of offsite risk at Callaway are summarized in Section F.2.1. The summary 

is followed by the NRC staff’s review of Ameren’s risk estimates in Section F.2.2.

F.2.1 Ameren’s Risk Estimates

Ameren combined two distinct analyses to form the basis for the risk estimates used in the 

SAMA analysis: (1) the Callaway Levels 1 and 2 PRA models, Level 1 being an updated 

version of the IPE (Union Electric 1992) and Level 2 being essentially new, and 

(2) a supplemental analysis of offsite consequences and economic impacts (essentially a 

Level 3 PRA model) developed specifically for the SAMA analysis. The Callaway SAMA 

analysis is based on the most recent Callaway Level 1 and Level 2 PRA model available at the 

time of the ER, referred to as the Callaway PRA (Update 4B). The scope of this Callaway PRA 

does not include external events.

The Callaway CDF from Update 4B is approximately 2.6×10-5 per year (Table 3–3 of the ER and 

Table 1.a of the RAI responses (Ameren 2012a)). A CDF of 1.7×10-5 per year (Table 3–1 of the 

ER) for internal events excluding the contribution from internal flooding was used as the 

baseline CDF in the SAMA evaluations (Ameren 2011a). Ameren did not explicitly include the 

contribution from external events or internal flooding within the Callaway SAMA risk estimates; 

however, it did account for the potential risk reduction benefits associated with external events 

and internal flooding by multiplying the estimated benefits for internal events by a factor of 4.57. 

This is discussed further in Sections F.2.2 and F.6.2.

The breakdown of CDF by initiating event is provided in Table F–1 (Ameren 2012a). As shown 

in this table, events initiated by internal flooding, small loss-of-coolant accidents (LOCAs), and 

loss of offsite power (LOSP) are the dominant contributors to the CDF. Ameren identified that 

station blackout (SBO) contributes 7.9×10-7 per year, or 3 percent, to the total internal events 

and internal flooding CDF, while anticipated transients without scram (ATWS) contribute 

3.1×10-7 per year, or 1.2 percent of the total CDF (Ameren 2012a, 2013). 

The Level 2 Callaway PRA model that forms the basis for the SAMA evaluation is essentially a 

complete revision of the original IPE Level 2 model. The Level 2 model uses two containment 

event trees (CETs), one for SBO and one for non-SBO sequences, each containing both 

phenomenological and systemic events. The Level 1 core damage sequences are binned into 

accident classes or plant damage states that provide the interface between the Level 1 and 

Level 2 CET analysis. The CETs are linked directly to the Level 1 event trees and CET nodes 

are evaluated using supporting fault trees and logic rules.

The result of the Level 2 PRA is a set of eight release or source term categories, with their 

respective frequency and release characteristics. The results of this analysis for Callaway are 

provided in Table 3–13 of ER Attachment F (Ameren 2011a). The categories were defined 

based on the types of sequences found at Callaway: five with early releases, two with late 

releases, and one for intact containment with very small releases. The frequency of each 

release category was obtained by summing the frequency of the individual accident progression 

CET endpoints binned into the release category. Source terms were developed for each of the 

F-2 
Appendix F

eight release categories using the results of Modular Accident Analysis Program (MAAP) 

Version 4.0.7 computer code calculations (Ameren 2012a).

Table F–1. Callaway Core Damage Frequency for Internal Events

Initiating Event CDF

(per year)

Percent 

Contribution 

to CDF

Internal Flooding(a) 9.1×10-6 35

Small LOCA 5.9×10-6 23

LOSP 5.6×10-6 21

Steam Generator Tube Rupture (SGTR) 2.3×10-6 9

Turbine Trip with Main Feedwater Available 1.1×10-6 4

Intermediate LOCA 3.6×10-7 1

Main Steamline Break Outside Containment 3.5×10-7 1

Reactor Vessel Rupture 3.0×10-7 1

Very Small LOCA 2.1×10-7 1

Loss of Main Feedwater 1.9×10-7 1

Interfacing-systems LOCA (ISLOCA) 1.7×10-7 1

Loss of Component Cooling Water (CCW) 1.2×10-7 1

Loss of Service Water (SW) 1.2×10-7 <1

Feedwater Line Breaks 9.8×10-8 <1

Loss of Direct-Current (dc) Vital Buses 8.0×10-8 <1

Large LOCA 4.2×10-8 <1

Main Steamline Break Inside Containment 1.5×10-8 <1

Total (internal events)(b) 2.6×10-5 100

(a) The Level 1 internal events PRA used for the SAMA analysis do not include internal flooding.

(b) Column totals may be different because of rounding.

Source: Table 1.a of RAI responses (Ameren 2012a)

The offsite consequences and economic impact analyses use the MACCS2 code to determine 

the offsite risk impacts on the surrounding environment and public. Inputs for these analyses 

include plant-specific and site-specific input values for core radionuclide inventory, source term 

and release characteristics, site meteorological data, projected population distribution (within a 

50-mi radius) for the year 2044, emergency response evacuation modeling, and economic data. 

The core radionuclide inventory corresponds to the end-of-cycle values for Callaway operating 

at 3,565 megawatts thermal (MWt). The magnitude of the onsite impacts (in terms of cleanup 

and decontamination costs and occupational dose) is based on information provided in 

NUREG/BR–0184, the Regulatory Analysis Technical Evaluation Handbook (NRC 1997a).

In the ER, Ameren estimated the dose to the population within 80 km (50 mi) of the Callaway 

site to be approximately 0.0460 person-sievert (Sv) (4.60 person–roentgen equivalent man 

(rem)) per year (Ameren 2011a). The breakdown of the total population dose by containment 

release mode is summarized in Table F–2. Containment bypass events (such as 

SGTR-initiated large early release frequency (LERF) accidents) and late containment failures 

without feedwater dominate the population dose risk at Callaway.

F-3 
Appendix F

Table F–2. Breakdown of Population Dose by Containment Release Mode

Containment Release Mode –

Release Category Designation

Population Dose

(person-rem(a) per year)

Percent 

Contribution

Steam generator rupture (noninduced) –

LERF-SG

2.13 47

Containment overpressure (late) –

LATE-COP

1.72 37

Interfacing system LOCA – LERF-IS 0.35 7.1

Induced steam generator tube rupture –

LERF-ITR

0.27 5.7

Basemat melt-through (late) – LATE-BMT 0.10 2.2

Containment intact – INTACT 0.02 <1

Early containment failure – LERF-CF 0.01 <1

Containment isolation failure – LERF-CI negligible negligible

Total(b) 4.60 100.

(a) One person-rem = 0.01 person-Sv 

(b) Column totals may be different because of rounding.

Sources: Table E.3-14 of the ER and Table 4.f-1 of RAI responses (Ameren 2011a, 2012a)

F.2.2 Review of Ameren’s Risk Estimates

Ameren’s determination of offsite risk at the Callaway site is based on the following three major 

elements of analysis:

• the Level 1 risk model that forms the bases for the 1992 IPE submittal (Union 

Electric 1992) and the external event analyses of the 1995 IPEEE submittal 

(Union Electric 1995);

• the major modifications to the IPE model that have been incorporated in the 

Callaway PRA, including a complete revision of the Level 2 risk model; and

• the MACCS2 analyses performed by Ameren to translate fission product 

source terms and release frequencies from the Level 2 PRA model into offsite 

consequence measures.

Each of these analyses was reviewed by the NRC staff to determine the acceptability of 

Ameren’s risk estimates for the SAMA analysis, as summarized below.

The NRC staff’s review of the Callaway IPE is described in an NRC memorandum (NRC 1996). 

Based on a review of the original IPE submittal, the NRC staff concluded that the applicant’s 

IPE process is capable of identifying the most likely severe accidents and severe accident

vulnerabilities and, therefore, that the IPE has met the intent of Generic Letter (GL) 88-20 

(NRC 1988). Although no vulnerabilities were identified in the IPE, several plant enhancements, 

including hardware changes as well as procedural improvements, were identified by the 

applicant and have been implemented before, and in conjunction with, the IPE analysis. These 

improvements are discussed in Section F.3.2.

F-4 
Appendix F

There have been six revisions to the IPE model since the 1992 IPE submittal. A listing of the 

major changes made to the Callaway PRA since the original IPE submittal was provided in the 

ER (Ameren 2012a) and is summarized in Table F–3 below. A comparison of the internal 

events CDF between the 1992 IPE and the current PRA model indicates a decrease of about 

55 percent in the total CDF (from 5.9×10-5 per year to 2.6×10-5 per year).

Table F–3. Callaway PRA Historical Summary

PRA Update Summary of Changes From Previous Model CDF

(per year)

IPE

(09/1992)

IPE Submittal 5.9×10-5

First Update

(02/1999)

• Updated internal flooding analysis

• Incorporated the normal charging pump

• Incorporated the swing battery chargers

4.0×10-5

Second Update 

(10/2000)

• Revised emergency diesel generator (EDG) mission times

• Incorporated self-assessment findings (self-assessment 

conducted in preparation for owners’ group peer review)

3.1×10-5

Third Update

(05/2004)

• Updated internal flooding analysis

• Expanded common cause failure modeling

• Incorporated plant-specific LOSP frequency

• Credited recovery of only offsite power following SBO

4.4×10-5

Fourth Update 

(04/2006)

• Updated HRA for risk-significant human failure events 

(HFEs)

• Implemented very low quantification cutset truncation value 

to comply with Mitigating System Performance Index 

(MSPI) requirements

5.2×10-5

Update 4A 

(11/2010)

• Incorporated nonsafety auxiliary feedwater pump

• Incorporated temporary diesel generator modification

2.6×10-5

Update 4B

(04/2011)

• Incorporated the alternate emergency power system 

(AEPS) modification

2.6×10-5

The CDF values from the 1992 IPE (5.9×10-5 per year) are in the middle range of the CDF 

values reported in the IPEs for Westinghouse four-loop plants. Figure 11.6 of NUREG–1560, 

Individual Plant Examination Program: Perspectives on Reactor Safety and Plant Performance,

shows that the IPE-based total internal events CDF for Westinghouse four-loop plants ranges 

from 2×10-6 per year to 2×10-4 per year, with an average CDF for the group of 6×10-5 per year 

(NRC 1997b). Other plants have updated their values for CDF subsequent to the IPE 

submittals to reflect modeling and hardware changes. The current internal events CDF results 

for Callaway (2.6×10-5 per year) are comparable to those for other plants of similar vintage and 

characteristics. 

The CDF given for Update 4B above and as given in Table F–1 is different from that used in the 

SAMA analysis. The PRA model used to evaluate the SAMA did not include the internal 

flooding CDF or the reactor vessel rupture CDF, and had a total baseline CDF of approximately 

F-5 
Appendix F

1.7×10-5 per year. The internal flooding was accounted for in the external and internal flooding 

events multiplier, as discussed below. The reactor vessel rupture is a relatively small 

contributor to the risk and assumed to go directly to core damage. Therefore, it is not affected 

by any SAMA (Ameren 2012a).

The NRC staff considered the peer review performed for the Callaway PRA, and the potential 

impact of the review findings on the SAMA evaluation. In the ER (Ameren 2011a), Ameren 

described the results of the October 2000 Westinghouse Owners Group peer review of the 

second update of the Callaway PRA. Ameren stated that all but five significance-level A 

(expected impact to be significantly nonconservative) and significance-level B (expected impact 

to be nonconservative but small) Facts and Observations (F&Os) generated during the peer 

review have been addressed in the PRA model used for the SAMA analysis. The open F&Os, 

and an assessment of their impact on this application, are summarized in Table 3–8 of ER 

Attachment F. Of the five open F&Os, one was a documentation issue and two were related to 

the Level 2 analysis which has subsequently been completely updated. In response to an NRC 

staff RAI, Ameren provided additional information concerning the other two open F&Os 

(Ameren 2012a).

In the RAI response, Ameren stated that the first F&O, IE–7, had two parts. The first concern, 

to consider interfacing system LOCAs (ISLOCAs) inside containment, is considered not valid 

since LOCAs inside containment are not ISLOCAs where the concern is failure of mitigating 

systems as well as a containment bypass. The second part of IE–7 was the lack of treatment of 

parametric uncertainty in the ISLOCA evaluation of redundant isolation valves. Ameren noted 

that the ISLOCA CDF is a very minor contributor to the total CDF (less than 1 percent) and that 

the uncertainty factor used in the 95th percentile sensitivity study would cover any impact of this 

contributor to the total uncertainty. Ameren also stated that the ISLOCA analysis included 

consideration of common cause failure of redundant isolation valves. The NRC staff notes that 

while the inclusion of the parametric uncertainty, or the state-of-knowledge correlation, in the 

ISLOCA would tend to increase the mean CDF for the ISLOCA sequences over the point 

estimate CDF, the impact of this is mitigated to some extent by the inclusion of common cause 

failures in the model.

The second open F&O (ST–1) concerned the basis for the overpressure failure probabilities 

used in the ISLOCA analysis. In the RAI response, Ameren indicated that the ISLOCA analysis 

has been updated and, while the use of the recommended methodology resulted in an increase 

in overpressure failure probability for some piping, the overall ISLOCA CDF was reduced by 

14 percent (from 1.7×10-7 per year to 1.5×10-7 per year) (Ameren 2012a).

The NRC staff has determined that Ameren’s disposition of the peer review findings is 

consistent with the guidance in Nuclear Energy Institute (NEI) 05-01, Severe Accident Mitigation 

Alternative (SAMA) Analysis Guidance Document (NEI 2005) and that the final resolution of the 

findings provides reasonable assurance of minimal impact to the results of the SAMA analysis.

Ameren also stated that there had been a contractor review in 2006 of the Callaway PRA 

against the Capability Category II requirements 2005 revision of the ASME PRA standard 

(ASME 2005). In response to an NRC staff RAI, Ameren provided the disposition of any 

deficiencies found (Ameren 2012a). Based on the NRC staff review of this information, 

including the resolution of the NRC staff RAI, the NRC staff concluded that the disposition of 

these deficiencies relative to the SAMA analysis provides reasonable assurance of minimal 

impact to the results of the SAMA analysis.

The NRC staff asked Ameren to identify the freeze date for the Update 4B PRA and any 

changes to the plant, including physical and procedural modifications since that date 

(NRC 2012a). Ameren indicated that Update 4B reflected the as-built, as-operated plant as of 

F-6 
Appendix F

February 2011 and that there have been no physical or procedural changes since that would 

have a significant impact on the PRA results or SAMA analysis (Ameren 2012a).

The NRC staff noted in an RAI that several different values of the SBO CDF were given in the 

ER and RAI responses and asked for the reasons for the differences (NRC 2012b). In response 

to the RAI, Ameren discussed the bases for these values and provided the updated correct SBO 

CDF value of 7.9×10–7 per year (Ameren 2013a). Ameren indicated that this value accounts for 

the use of Callaway’s Alternate Emergency Power System (AEPS) to supply alternating current 

(ac) power to prevent an SBO (Ameren 2013a). As indicated in Section F.2.1, this SBO 

contribution is only 3 percent of the total internal events CDF. This is significantly lower than 

that found for other pressurized-water reactor (PWR) plants. This relatively low value for the 

SBO contribution to the total internal events CDF is considered by the NRC staff to be justified 

based on the credit for the AEPS, which is not commonly available at other PWR plants. 

In response to an NRC staff RAI concerning the SBO frequency, Ameren indicated that the 

LOSP frequency and consequently the SBO frequency did not include consequential LOSP 

events occurring as a result of other plant transients. The response states that for the new 

Revision 5 model, consequential LOSP accounts for 28 percent of the SBO frequency and only 

2.5 percent of the CDF (Ameren 2012a). Based on this information, the NRC staff determined 

that the benefit from an SBO- or LOSP-mitigating SAMA should be increased to account for the 

omission of consequential LOSP. The impact on the selection of cost-beneficial SAMA is 

discussed in Sections F.4 and F.6.2 below.

Given that the Ameren internal events PRA model has been peer-reviewed, that the NRC staff 

has determined the peer review findings will have minimal impact on the results of the SAMA

analysis, that Ameren has satisfactorily addressed NRC staff questions regarding the PRA, and 

that the issue concerning the consequential LOSP discussed above is addressed in the NRC 

staff’s review of the SAMA evaluation, the NRC staff concludes that the internal events Level 1 

PRA model is of sufficient quality to support the SAMA evaluation.

As indicated above, the Callaway PRA used for the SAMA analysis does not include external 

events. In the absence of such an analysis, Ameren used the Callaway IPEEE and other 

analyses to identify the highest risk accident sequences and the potential means of reducing the 

risk posed by those sequences, as discussed below and in Section F.3.2.

The Callaway IPEEE was submitted in June 1995 (Union Electric 1995), in response to 

Supplement 4 of Generic Letter 88-20 (NRC 1991a). The submittal included a seismic margins 

assessment (SMA), a fire assessment using the Electric Power Research Institute (EPRI) Fire 

Induced Vulnerability Evaluation (FIVE) guidance (EPRI 1992), and a screening analysis for 

other external events. While no fundamental weaknesses or vulnerabilities to severe accident

risk in regard to the external events were identified, several potential enhancements were 

identified as discussed below. In its Safety Evaluation Report (SER) (NRC 1999), the NRC staff 

concluded that the applicant’s IPEEE process is capable of identifying the most likely severe 

accidents and severe accident vulnerabilities for external events and, therefore, that the 

Callaway IPEEE has met the intent of Supplement 4 to GL 88-20.

The Callaway IPEEE seismic analysis was a focused scope SMA following NRC guidance 

(NRC 1991a, 1991b). The SMA approach is deterministic in nature and does not result in 

probabilistic risk information. The SMA was performed using a Safe Shutdown Equipment List 

(SSEL) with plant walkdowns in accordance with the guidelines and procedures documented in 

EPRI Report NP-6041-SL (EPRI 1991). Two success paths, each capable of mitigating the 

effects of a seismically induced small break LOCA, were identified based on a review of the 

guidance and plant documentation. The components on the SSEL were then evaluated for 

seismic capacity. This evaluation was based upon a review of the plant’s seismic qualification 

F-7 
Appendix F

documentation and scaled Floor Response Spectra (FRS) that largely enveloped the Review 

Level Earthquake (RLE) FRS. This initial evaluation was then verified by a Seismic Capability 

Walkdown, which also evaluated the equipment for spatial systems interactions, and anchorage 

adequacy. The walkdown identified 21 open seismic issues, for which the applicant proposed 

resolutions. These issues were resolved by demonstrating a high confidence in low probability 

of failure capacity in excess of the RLE; by further walkdowns, observations, judgments, or 

analyses; and by implementing a few minor fixes and four improvements (NRC 1999; Union 

Electric 1995). These improvements and two of the minor fixes were included as SAMA

candidates. This is discussed further in Section F.3.2. 

For the purposes of the SAMA evaluation, Ameren assumed a seismic CDF of 5×10-6 per year 

in the development of the external and internal flooding events multiplier (Ameren 2011a). 

Since the SMA approach used in the IPEEE does not involve the determination of seismic CDF, 

the NRC asked Ameren to provide the basis for this seismic CDF (NRC 2012a). In its response 

to the RAI (Ameren 2012a), Ameren indicated that this seismic CDF was conservatively taken to 

be approximately twice that given in the Generic Issue (GI) 199 risk assessment for the 

Callaway site (NRC 2010a). Ameren indicated that the GI 199 risk assessment calculated a 

seismic CDF of 2.3×10-6 using the weakest link model for Callaway, and that to account for 

modeling uncertainties, the calculated value was doubled and rounded up for use in developing 

the seismic contribution to the total external events multiplier. 

Since the seismic CDF of 5×10-6 per year is significantly greater than that estimated by the NRC 

staff in the GI 199 risk assessment, the NRC staff finds use of this seismic CDF in the 

determination of the external and internal flooding events multiplier to be conservative relative to 

the NRC staff’s estimate and reasonable and therefore acceptable for use in the SAMA

analysis.

The Callaway IPEEE fire analysis employed EPRI’s FIVE methodology (EPRI 1992) enhanced 

by drawing heavily upon the research and insights documented in the Fire Risk Analysis 

Implementation Guide (EPRI 1994). The FIVE methodology allows fire areas or compartments 

to be sequentially screened. The simplified methods for calculating core damage because of 

fire were augmented with event tree quantification using the Callaway IPE models. Also, 

extensive cable and raceway databases were developed to support the FIVE effort.

The only fire areas with a CDF exceeding the FIVE Screening Threshold (1×10-6 per year) are 

as follows:

• Fire Area C-27 (control room) – 2.7×10-6 per year,

• Fire Area C-9 (safety-related ac switchgear room) – 2.3×10-6 per year, and

• Fire Area C-10 (safety-related ac switchgear room) – 1.3×10-6 per year.

The overall CDF because of fire is given as 8.9×10-6 per year. There were no vulnerabilities or 

beneficial design changes identified from the IPEEE fire assessment. The IPEEE did discuss 

some updates in the accident management plans for fire events involving fire-induced hot short 

failures and fire-induced loss of containment penetration room cooling. The applicant stated 

that these updates would be included in the Severe Accident Management Guideline process 

(Union Electric 1995). The IPEEE SER (NRC 1999) confirmed that these updates have been 

implemented.

After the IPEEE, in August 2011, Ameren submitted a license amendment request (LAR) to 

transition the Callaway fire protection program to a National Fire Protection Association 

(NFPA) 805 Performance-Based Fire Protection Program (Ameren 2011b). This involved 

developing a new fire PRA model using the recent research and guidance reported in 

F-8 
Appendix F

NUREG/CR–6850, EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, and 

Supplement 1, Fire Probabilistic Risk Assessment Methods Enhancement (NRC 2005, 2010b). 

The ER indicated that the total fire CDF from this assessment was 2.0×10-5 per year.

In response to an NRC staff RAI, Ameren provided a listing and description of the top 10 fire 

core damage contributors (Ameren 2012a). The dominant fire core damage contributors, 

representing about 79 percent of the fire CDF, are listed in Table F–4. The largest contributors 

to fire CDF are fires in the turbine building, the control room ac unit room, and the switchgear 

room.

Table F–4. Important Fire Areas and Their Contribution to Fire CDF

Fire Area Description CDF

(per year)

Percent 

Contribution to 

Fire CDF

TB-1 Turbine Building 6.5×10–6 32

A-21 Control Room AC Units Room 5.1×10–6 25

C-10 Safety-Related AC Switchgear Room 1.7×10–6 10

C-22 Upper Cable Spreading Room 1.4×10–6 6

YD-1 Yard Area Inside the Power Block 1.0×10–6 6

The NRC staff notes that a SAMA evaluation should be performed using the best available risk 

information. The NRC staff has determined that the associated fire risk assessment in 

Callaway’s NFPA 805 transition application represents the best available fire risk information 

and, therefore, the fire CDF of 2.0×10-5 per year is appropriate for use in the SAMA analysis.

The Ameren IPEEE analysis of high winds and tornadoes, external floods, and transportation 

and other nearby facility accidents (HFO events) followed the screening and evaluation 

approaches specified in Supplement 4 to GL 88-20 (NRC 1991a). For these events, the IPEEE 

concluded that the Callaway design conforms to the 1975 Standard Review Plan criteria 

(NRC 1975) and, therefore, the contribution to CDF from these events meets the IPEEE 

screening criterion of 1×10-6 per year in NUREG–1407 (NRC 1991b). While no vulnerabilities or 

plant improvements were identified in the IPEEE for HFO events, the SAMA submittal included 

a high wind CDF of 2.5×10-5 per year in determining the external and internal flooding events 

multiplier. In response to an NRC staff RAI, Ameren stated that this value was the product of

the tornado frequency of 5×10-4 per year (from the FSAR Site Addendum, Section 2.3.1.2.6.1), 

0.5 (assuming that 50 percent of the potential tornados would be strong enough to damage 

unprotected equipment) and 0.1 (the probability of core damage given unprotected equipment is 

damaged). Since the tornado frequency quoted is that for a tornado striking the eight-county 

area surrounding the plant, and since it is conservative to assume that all tornados striking the 

eight-county area will directly affect the plant, the NRC staff considers the high wind-induced 

CDF to be a conservative estimate and, therefore, acceptable for use in the SAMA evaluation. 

Also, as indicated in NUREG–1407, a plant meeting the 1975 SRP criteria is judged to have a 

CDF from high winds of less than 1×10-6 per year.

As indicated above, the Callaway internal events Update 4B PRA does not include internal 

flooding. A total internal flooding CDF of 9.1×10-6 per year based on that determined in the 

Callaway IPE was used to develop the external and internal flooding events multiplier. In 

response to an NRC staff RAI to provide the results of the most current internal flooding 

analysis, Ameren indicated that the PRA Update 5 internal flooding CDF is 6.2×10-6 per year 

(Ameren 2012a). Based on this result, the NRC staff finds use of the internal flooding CDF of 

F-9 
Appendix F

9.1×10-6 per year in the determination of the external and internal flooding events multiplier is 

conservative relative to the value used in PRA Update 5 and is, therefore, acceptable for use in 

the SAMA analysis.

Based on the aforementioned results, the total external and internal flooding events CDF is 

approximately 5.9×10-5 per year, or 3.57 times the internal events CDF (based on a seismic

CDF of 5.0×10-6 per year, a fire CDF of 2.0×10-5 per year, an HFO CDF of 2.5×10-5 per year, 

and an internal flooding CDF of 9.1×10-6 per year). The total CDF (internal and external) is, 

then, approximately 7.6×10-5 per year, or 4.57 times the internal events CDF of 1.7×10-5 per 

year. This multiplier was used in the SAMA analysis to account for the impact of external and 

internal flooding events on the benefits determined from the internal events PRA. The NRC 

staff agrees with the applicant’s overall conclusion concerning the multiplier used to represent 

the impact of external and internal flooding events and finds that the applicant’s use of a 

multiplier of 4.57 will reasonably account for external and internal flooding in the SAMA 

evaluation. This is discussed further in Section F.6.2.

The NRC staff reviewed the general process used by Ameren to translate the results of the 

Level 1 PRA into containment releases, as well as the results of the Level 2 analysis, as 

described in the ER and in response to NRC staff RAI (Ameren 2012a). The current Level 2 

model is essentially a complete revision of the IPE Level 2 model. Ameren indicated that the 

IPE Level 2 model was abandoned, with the exception of LERF, and that this was subsequently 

updated in 2000 for the second update Level 1 model. The current Level 2 model was created 

incorporating current industry guidance as part of the transition to PRA Update 4B 

(Ameren 2012a).

The current Callaway Level 2 model uses two CETs: one for SBO and one for non-SBO 

sequences, each containing both phenomenological and systemic events. The Level 1 core 

damage sequences are grouped into core damage accident classes, or plant damage states 

(PDSs), for which the progression of core damage, the release of fission products from the fuel, 

the status of the containment and its safeguards systems, and the potential for mitigating the 

potential radiological source terms are similar. The PDSs are defined based on the following 

attributes: (1) containment bypass (ISLOCA or SGTR), (2) status of offsite/emergency power 

(LOSP or SBO), (3) reactor coolant system (RCS) pressure (high, medium, or low), and 

(4) reactor cavity (wet or dry). The detailed containment event tree then analyzes each PDS as 

a group.

All of the sequences in a PDS are, then, input to the CET by linking the Level 1 event tree 

sequences with the Level 2 CETs. SBO sequences are assigned to the SBO CET while all 

other sequences are assigned to the non-SBO tree. The CET is analyzed by the linking of fault 

trees that represent each CET node or by logic statements based on the PDS. Ameren, in 

response to an NRC staff RAI, described each of the top events of the CET and states that 

branch point probabilities for each top event are based on previous Callaway Level 2 analyses, 

recent accident progression research, and industry guidance (Ameren 2012a).

Each CET end state represents a radionuclide release to the environment and is assigned to a 

release category based on the types of sequences found at Callaway: five with early releases, 

two with late releases, and one for intact containment with very small releases. Intermediate 

time sequences do not generally occur, and so no such category was needed (Ameren 2012a). 

The large early release categories are for the containment bypass or failure conditions that lead 

to the release: unisolated ISLOCAs, containment isolation failures, early containment failures, 

noninduced SGTRs, and pressure- or thermal-induced SGTRs. The two late-release categories 

are for containment overpressure failure and basemat melt through.

F-10
Appendix F

Ameren obtained the frequency of each release category by summing the frequency of the 

contributing CET end states. The release characteristics for each release category were 

developed by using the results of MAAP Version 4.0.7 computer code calculations. 

Representative MAAP cases for each release category were chosen to represent the most likely 

initiators in the release category (intact-containment and late-release categories) or were 

chosen based on both the likelihood and potential for offsite effects (early-release categories 

only) (Ameren 2012a). For the latter, in response to an NRC staff RAI (NRC 2012b), Ameren 

further explained that the dominant Level 1 and Level 2 sequences were identified and 

considered down to at least a 10 percent contribution, and based on engineering judgment, 

none of these dominant sequences were expected to increase the consequences more than the 

chosen representative sequence. More severe (bounding) scenarios could have been 

considered, but would have a much lower frequency (at most a 10-percent contribution) 

(Ameren 2013a).

The NRC questioned Ameren as to why it did not also use representative cases that bound the 

consequences for the late-release categories (NRC 2012a). In response to the RAI, Ameren 

stated that, because the late-release categories take more time to evolve than the early-release 

categories, the late-release categories are less affected by the initial accident conditions, and so 

result in more uniform consequences than the early-release categories. Since the accident 

sequences assigned to the late-release categories yielded similar consequences, Ameren 

selected representative MAAP cases that represented the most likely initiators within those 

release categories (Ameren 2012a). The release categories, their frequencies, and release 

characteristics are presented in Tables 3–13 and 3–14 of Attachment F to the ER 

(Ameren 2011a).

Ameren determined that the total Level 2 release frequency is approximately 1.7×10-5 per year. 

This value is essentially the total internal events CDF given in Table F–1 without the 

contributions from internal flooding and reactor pressure vessel (RPV) rupture (Ameren 2012a). 

The internal flooding contribution to risk is included using the external events multiplier. The 

RPV rupture (about 1 percent of the total internal events CDF) goes directly to core damage and 

would not be affected by SAMA and, hence, not including it in the baseline risk will not affect the 

net benefit from any SAMA. 

In response to an NRC staff RAI to describe steps taken to ensure the technical adequacy of 

the revised Callaway Level 2 PRA model, Ameren indicated that the usual contractor and 

Ameren reviews were augmented by a self-assessment by the contractor against the Capability 

Category II, LE (large early release) supporting requirements of the ASME PRA standard 

(Ameren 2012a). Ameren determined that no gaps related to the Level 2 were identified.

The NRC staff has reviewed the Level 2 methodology and determined that Ameren has 

satisfactorily addressed NRC staff RAI, that the Level 2 model was assessed against the LE 

supporting requirements of the ASME PRA standard, and that there were no findings that 

affected the SAMA analysis. The NRC staff, therefore, concludes that the Level 2 PRA is of 

sufficient quality to support the SAMA evaluation.

The NRC staff reviewed the process used by Ameren to extend the containment performance 

(Level 2) portion of the PRA to an assessment of offsite consequences (essentially a Level 3 

PRA). This included consideration of the source terms used to characterize fission product 

releases for the applicable containment release categories and the major input assumptions 

used in the offsite consequence analyses. The MACCS2 code (Version 1.13) was used to 

estimate offsite consequences. Plant-specific input to the code includes the source terms for 

each source term category and the reactor core radionuclide inventory (both discussed above), 

site-specific meteorological data, projected population distribution within an 80-km (50-mi) 

F-11
Appendix F

radius for the year 2044, emergency evacuation modeling, and economic data. As indicated in 

the ER, the reactor core radionuclide inventory used in the consequence analysis was based on 

end-of-cycle power of 3,565 MWt. This information is provided in Section 3.4 of Attachment F to 

the ER (Ameren 2011a). In response to an NRC staff RAI, Ameren provided additional 

information related to population distribution used in the MACCS2 code to estimate offsite 

consequences (Ameren 2012a).

Ameren modeled all releases as being from mid-height of the reactor containment building and 

at zero thermal content. Ameren performed sensitivity studies using 1×107 plume energy, 

except for intact containment (which maintained zero energy). With plume heat included, the 

dose risk decreased approximately 2.1 percent and the cost risk increased approximately 

1.7 percent (Ameren 2012a). Based on the information provided, the staff concludes that the 

release parameters used follow accepted practices and are, therefore, appropriate for the 

purposes of the SAMA evaluation.

Ameren used site-specific meteorological data for the 2008 calendar year as input to the 

MACCS2 code. The development of the meteorological data is discussed in Section 3.4.5 of 

Attachment F to the ER. The data were collected from onsite and local meteorological 

monitoring systems. Missing data were filled in by using interpolation, substituting data from the 

previous or subsequent day, or using precipitation data from the nearby Prairie Fork 

Conservation area. Sensitivity analyses were performed using MACCS2 and the meteorological 

data for the years 2007 and 2009 (Ameren 2012a). The dose risk for the year 2008 data was 

slightly higher than for the years 2007 and 2009. The economic cost risk for the year 2008 data 

was slightly lower (0.5 percent) than for the year 2007. However, the year 2008 was more 

complete and used only onsite meteorological data to fill in data gaps. The NRC staff notes that 

previous SAMA analyses overall results have shown little sensitivity to year-to-year differences 

in meteorological data and concludes that the use of the 2008 meteorological data in the SAMA 

analysis is reasonable.

The population distribution the applicant used as input to the MACCS2 analysis was estimated 

for the year 2044 using year 2000 census data, as accessed by the program 

SECPOP2000 (NRC 2003), as a starting point. In response to an NRC staff RAI, Ameren 

stated that the transient population was included in the 10-mi emergency planning zone (EPZ) 

and in the population projection from the year 2000 to the year 2044 (Ameren 2012a). 

A 25-year population growth rate was estimated using the year 2000 SECPOP2000 data and 

population growth estimates from the Missouri Office of Administration (MOA) to the year 2025. 

The MOA year 2025 population estimate was then scaled to year 2044 using this growth rate to 

obtain the distribution in 2044. The baseline population was determined for each of 

160 sectors, consisting of 16 directions for each of 10 concentric distance rings to a radius of 

50 mi surrounding the site. Individual county growth rates were applied at each grid element. 

Some grid elements include land from multiple counties. A weighted growth rate was used for 

those grid elements based on the fraction of land in that grid element associated with each 

county. Counties that were projected to have negative growth rates were conservatively 

assumed to have zero-growth rates. In response to an NRC staff RAI, Ameren stated that three 

recently publicized SECPOP2000 code errors were accounted for in the Callaway analysis 

(Ameren 2012a). The NRC staff considers these methods and assumptions for estimating 

population to be reasonable and acceptable for purposes of the SAMA evaluation.

The emergency evacuation model was modeled as a single evacuation zone and stated to 

extend out 16 km (10 mi) from the plant (the EPZ) (Ameren 2012a). In response to an NRC 

staff RAI, Ameren identified an error in the EPZ evacuation radius assumed in the analysis 

(20 mi versus 10 mi). Ameren corrected the EPZ evacuation radius and the resulting total 

population dose risk increased from 4.60 person-rem (0.0460 person-Sv) per year to 

F-12
Appendix F

4.65 person-rem (0.0465 person-Sv) per year (approximately 1 percent) (Ameren 2012a). The 

containment-release modes affected by this error, and the associated revised population dose 

risk contributions, are as follows: 

• LERF-SG – 2.18 person-rem (0.0218 person-Sv)/year (increase from 

2.13 person-rem (0.0213 person-Sv)/year or 2.3 percent),

• LATE-COP – 1.74 person-rem (0.0174 person-Sv)/year (increase from 

1.72 person-rem (0.0172 person-Sv)/year or 1.2 percent), and

• LERF-IS – 0.33 person-rem (0.0033 person-Sv)/year (decrease from 

0.35 person-rem (0.0035 person-Sv)/year or 6.1 percent). 

The total cost risk did not change, nor did the cost risk for individual containment release 

modes. The NRC staff considers these impacts negligible and to not affect the results of the 

SAMA evaluation. Ameren assumed that 95 percent of the population would evacuate. This 

assumption is conservative relative to the NUREG–1150 study, Severe Accident Risks: An 

Assessment for Five U.S. Nuclear Power Plants (NRC 1990), which assumed evacuation of 

99.5 percent of the population within the EPZ.

The evacuated population was assumed to move at an average radial speed of approximately 

2.14 m/s (4.8 mph) with a delayed start time of 105 minutes after declaration of a general 

emergency (Ameren 2011a). The evacuation speed is a time-weighted average value 

accounting for season, day of week, time of day, and weather conditions (Ameren 2002). 

A general emergency declaration was assumed to occur when plant conditions degraded to 

when it was judged as credible there was risk to the public. A daytime winter weekday 

evacuation was used in the time estimate study, as Ameren judged this to be conservative 

compared to other potential time periods (e.g., nighttime, summer, weekend). Sensitivity 

studies on these assumptions indicate that there is minor impact to the population dose or 

offsite economic cost by the assumed variations. The sensitivity study reduced the evacuation 

speed by 50 percent to 1.07 m/s (2.4 mph), and increased the delay time by a factor of 2 to 

210 minutes. In response to an NRC staff RAI, Ameren stated that the decrease in evacuation 

speed resulted in a dose risk increase of 6 percent and no change in cost risk (Ameren 2012a). 

The increase in delay time resulted in a dose risk increase of 2.7 percent. The NRC staff 

concludes that (with the exception of the above described error in the size of the EPZ, which 

has a negligible impact on the SAMA analysis) the evacuation assumptions and analysis are 

reasonable and acceptable for the purposes of the SAMA evaluation.

Site-specific agriculture and economic parameters were developed manually using data in the 

2007 National Census of Agriculture, the Bureau of Economic Analysis, and the Bureau of 

Labor Statistics for each of the 23 counties surrounding Callaway, to a distance of 50 mi. The 

values used for each of the 160 sectors were the data from each of the surrounding counties 

multiplied by the fraction of that county’s area that lies within that sector. Food ingestion was 

modeled using the new MACCS2 ingestion pathway model COMIDA2 (NRC 1998). For 

Callaway, approximately 12 percent of the total population dose risk is because of food 

ingestion (0.552 person-rem (0.00552 person-Sv)/year) (Ameren 2011a). In response to an 

NRC staff RAI, Ameren identified that water ingestion data were based on NUREG/CR-4551 

and food ingestion modeled using the COMIDA sample problem A output (SAMP_A.bin) 

(NRC 1993). Food ingestion dose limits were based on 1998 U.S. Food and Drug 

Administration (FDA) Guidance, Accidental Radioactive Contamination of Human Food and 

Animal Feeds: Recommendations for State and Local Agencies (FDA 1998). In addition, 

generic economic data that is are applied to the region as a whole were revised from the 

MACCS2 sample problem input to account for cost escalation since 1986, the year that input 

was first specified. A factor of 2.0, representing cost escalation from 1986 to May 2010, was 

F-13
Appendix F

applied to parameters describing cost of evacuating and relocating people, land 

decontamination, and property condemnation.

The NRC staff concludes that the methodology used by Ameren to estimate the offsite 

consequences for Callaway provides an acceptable basis from which to proceed with an 

assessment of risk reduction potential for candidate SAMA. Accordingly, with the exception of 

the impact of consequential LOSP discussed earlier, the NRC staff based its assessment of 

offsite risk on the CDF and offsite doses reported by Ameren.

F.3 Potential Plant Improvements

The process for identifying potential plant improvements, an evaluation of that process, and the 

improvements evaluated in detail by Ameren are discussed in this section.

F.3.1 Process for Identifying Potential Plant Improvements

Ameren’s process for identifying potential plant improvements (SAMA) consisted of the following 

elements:

• review of the most significant basic events from the current, plant-specific 

PRA,

• review of potential plant improvements identified in the Callaway IPE and 

IPEEE,

• review of generic SAMA candidates from NEI 05-01 (NEI 2005) as well as 

cost-beneficial SAMA from recent industry SAMA submittals, and

• input from the Callaway plant staff.

Based on this process, an initial set of 171 candidate SAMA, referred to as Phase I SAMA, was 

identified and is listed in Table 5–1 of Attachment F of the ER (Ameren 2011a). In response to 

NRC staff RAI, 18 additional candidate SAMA were added and incorporated in a revised 

Table 5–1 (Ameren 2012b, 2013a). In Phase I of the evaluation, Ameren performed a 

qualitative screening of the initial list of SAMA and eliminated SAMA from further consideration 

using the following criteria:

• Criterion A – The SAMA is not applicable to Callaway plant design.

• Criterion B – The SAMA has already been implemented or intent met at 

Callaway.

• Criterion C – The SAMA is similar in nature and could be combined with 

another SAMA.

• Criterion D – The SAMA requires extensive changes that would exceed the 

maximum benefit.

• Criterion E – The SAMA has a very low benefit.

Based on the screening of the original 171 SAMA, 107 SAMA were eliminated, leaving 64 for 

further evaluation. For the additional 18 SAMA candidates added in response to NRC staff RAI, 

6 were screened, leaving 12 additional SAMA for further analysis. The results of the Phase I 

screening analysis are provided in revised Table 6–1 of Attachment F to the ER 

(Ameren 2013a). The remaining SAMA, referred to as Phase II SAMA, are listed in revised 

Table 7–1 of Attachment F to the ER (Ameren 2013a). In Phase II, a detailed evaluation was 

performed for each of the 76 remaining SAMA candidates, as discussed in Sections F.4 and F.6 

F-14
Appendix F

below. To account for the potential impact of external and internal flooding events, the 

estimated benefits based on internal events were multiplied by a factor of 4.57, as previously 

discussed.

F.3.2 Review of Ameren’s Process

Ameren’s efforts to identify potential SAMA focused primarily on areas associated with internal 

initiating events (excluding internal floods). The initial list of SAMA generally addressed the 

accident sequences considered to be important to CDF from functional, initiating event, and risk 

reduction worth (RRW) perspectives at Callaway.

Ameren’s SAMA identification process began with a review of the list of potential PWR 

enhancements in Table 14 of NEI 05-01 (NEI 2005). Review of this generic SAMA list resulted 

in all of the SAMA from this table being identified as Phase I SAMA, for a total of 153 Phase I 

SAMA.

Ameren provided in the ER a tabular listing of the Level 1 PRA basic events sorted according to 

their RRW (Ameren 2011a). SAMA affecting these basic events would have the greatest 

potential for reducing risk. Ameren used an RRW cutoff of 1.005, which corresponds to about a 

half-percent change in CDF, given 100-percent reliability of the SAMA. This equates to a 

benefit of approximately $16,000 (after the benefits have been multiplied by a factor of 4.57 to 

account for external and internal flooding events). Ameren also provided in the ER tabular 

listings of the Level 2 PRA basic events for the combined LERF categories and the combined 

Late Release categories, which contribute approximately 60 percent and 37 percent of the 

population dose-risk, respectively. Ameren also used an RRW cutoff of 1.005 when reviewing 

these basic events for SAMA candidates. The Level 2 sequences for the intact-release 

category were not included in the review so as to prevent high-frequency/low-consequence 

events from biasing the importance listing. Ameren’s review of the Level 1 and Level 2 

importance lists resulted in the identification of three additional SAMA candidates.

Ameren states in the ER that “The basic events were reviewed to ensure that each basic event 

on the importance lists is covered by an existing SAMA item or added to the list if not.” 

In reviewing these importance lists the NRC staff noted the following:

• The SAMA associated with each basic event was, in most cases, identified 

with only a general SAMA description such as “Safety Injection SAMA” or 

“Service Water SAMA,” so that it was not possible to determine which SAMA 

candidates were mitigating each basic event.

• No SAMA candidates were identified for several of the initiator basic events 

for no reason other than they were “initiating events.”

• For most basic events identified as operator actions no SAMA candidates 

were identified for the following reason: “The current plant procedures and 

training meet current industry standards. There are no additional specific 

procedure improvements that could be identified that would affect the result 

of the HEP [human error probability] calculations. Therefore, no SAMA items 

were added to the plant-specific list of SAMA as a result of the human actions 

on the list of basic events with RRW greater than 1.005.”

In response to RAI on these issues, Ameren provided revisions to the importance lists 

(i.e., Tables 3–2, 3–6 and 3–7 of Attachment F to the ER) that cited specific SAMA candidates 

for all of the basic events, except for some of the operator actions. In the process of revising 

these tables and in response to other RAI, Ameren identified three additional SAMA: 

F-15
Appendix F

SAMA 178, “Improvements to UHS [ultimate heat sink] cooling tower electrical room HVAC 

[heating, ventilation, and air conditioning]”; SAMA 184, “Improvements in the reliability of the 

Steam Line Isolation automatic signal”; and SAMA 185, “Automate initiation of CCW flow to the 

residual heat removal (RHR) heat exchangers” (Ameren 2012a).

For the operator actions for which no specific SAMA was identified, Ameren reiterated the 

statement concerning plant procedures and training meeting current industry standards, but 

provided a discussion of the details of the HRA, which included reviews of the procedures and 

training. This supports the conclusion that there are no specific procedure improvements that 

would be cost-beneficial for the cited operator action basic events (Ameren 2012a). Also, in 

response to an NRC staff RAI, Ameren discussed whether any of the risk significant operator 

action failures could be addressed by options other than training or procedures, such as 

automated functions, testing, and maintenance to reduce failure or event rates, and concluded 

that no cost-beneficial SAMA would be expected from these sources (Ameren 2012a). Based 

on this information, the NRC staff concludes that the opportunity for SAMA candidates to 

improve or automate operator actions has been adequately explored, and it is unlikely that there 

are cost-beneficial SAMA candidates to improve or automate operator actions.

Ameren considered the potential plant improvements described in the IPE in the identification of 

plant-specific candidate SAMA for internal events. Although the IPE did not identify any 

vulnerabilities, the IPE report identified five enhancements in IPE Section 6.2.1, “Plant 

improvements to be implemented,” and an additional five enhancements in IPE Section 6.2.2, 

“Plant improvements to be considered.” The NRC staff noted that only four of the five 

enhancements identified in IPE Section 6.2.1 (SAMA 166, 167, 168, and 169) and none of the 

enhancements identified in IPE Section 6.2.2 were included as SAMA candidates in the ER. 

The NRC staff requested Ameren provide the status of the remaining enhancements 

(NRC 2012a). In response to the RAI, Ameren added the remaining six IPE enhancements as 

SAMA candidates: SAMA 172, 173, 174, 175, 176, and 177 (Ameren 2012a). All 10 of these 

SAMA were screened in the Phase I evaluation as already having been implemented 

(Ameren 2011a, 2012a).

Ameren reviewed the SAMA candidates from prior SAMA analyses for four Westinghouse 

four-loop PWR sites to aid in the identification of additional SAMA candidates. Ameren’s review 

resulted in the identification of three additional SAMA candidates. In response to an NRC staff 

RAI concerning this review, Ameren provided a discussion of each of the cost-beneficial SAMA 

at these plants and added SAMA 187, “Install modification to power the normal charging pump 

from an existing spare breaker from the AEPS,” and SAMA 188, “Install a permanent, dedicated 

generator for the NCP, and a motor-driven auxiliary feedwater (AFW) pump and battery charger 

to address SBO events in which the turbine-driven auxiliary feedwater pump (TDAFP) is 

unavailable,” to the list of SAMA candidates to be evaluated further (Ameren 2012b).

Ameren’s SAMA identification process included the opportunity for Callaway plant staff to 

identify potential plant improvements, which included convening an Expert Panel to review the 

SAMA analysis. This process resulted in the identification of two additional SAMA candidates 

(i.e., SAMA 160 and 164).

As noted above, internal floods were not included in the base PRA model and, consequently, 

they were not included in the importance analysis. Therefore, no Phase I SAMA were identified 

other than SAMA 160, “Modifications to lessen the impact of internal flooding through control 

building dumbwaiter,” which was identified by Callaway plant staff as a potential plant 

improvement. Ameren stated that the internal flooding was not included in the SAMA 

importance analysis because, at the time of the SAMA analysis, the internal flood model had not 

been updated since 2004 and had not been integrated with the SAMA PRA. Ameren also 

F-16
Appendix F

provided the internal flood CDF from a subsequent revision (Update 5) as 6.2×10-6 per year 

(Ameren 2012a). In response to an NRC staff RAI to use the latest internal flooding analysis to 

identify potential SAMA, Ameren identified one additional SAMA, SAMA 189 (perform analysis 

to determine if it is possible to modify current plant doors to withstand higher flood heights. 

Either perform modifications to install improved doors or revise flooding analysis to incorporate 

results that doors will withstand higher flooding heights without propagating the flood) 

(Ameren 2013a). This SAMA is discussed further in Section F.6.2.

In further response to the RAI, Ameren also provided a listing of the important internal flooding 

scenarios and their CDF along with a discussion of the impact of the recent decision by Ameren 

to install the SHIELDTM (no-leakage) reactor coolant pump (RCP) seals in Refueling Outage 19 

(RF19), Spring 2013, on the results of the internal flooding analysis and on the important 

flooding scenarios (Ameren 2013a). Ameren indicated that a number of the important internal 

flooding scenarios are primarily seal LOCA events and their frequency would be expected to be 

reduced by the installation of the new seal design. The NRC staff noted that the top six of the 

important internal flood scenarios are not seal LOCA events and thus would not benefit from the 

planned RCP seal installation, and that at least one (Zone 1 scenario F1A) was important 

enough that its elimination might be cost-beneficial (NRC 2013). In response, Ameren indicated 

that this scenario would not be mitigated by the results of SAMA 189 and that no potentially 

cost-beneficial SAMA could be identified (Ameren 2013b).

Based on this information, the NRC staff concludes that the set of SAMA evaluated in the ER, 

together with those identified in response to NRC staff RAI, addresses the major contributors to 

internal event CDF. 

Although the IPEEE did not identify any fundamental vulnerabilities or weaknesses related to 

external events, six plant improvements were identified from the IPEEE to improve seismic risk 

and these were included as SAMA candidates (Ameren 2011a). All six of these SAMA 

candidates were screened in the Phase I evaluation as having already been implemented. 

An additional two seismic SAMA were identified from the NEI 05-01 generic SAMA list. These 

were combined with the IPEEE improvements and subsequently screened in the Phase I 

evaluation. Based on the preceding discussion, the NRC staff concludes that the opportunity for 

seismic-related SAMA has been adequately explored and that it is unlikely that there are any 

cost-beneficial, seismic-related SAMA candidates.

As discussed in Section F.2.2, Ameren submitted a LAR to transition the Callaway fire 

protection program to an NFPA 805 Performance-Based Fire Protection Program 

(Ameren 2011b). This involved developing a new fire PRA. The ER indicated that the total fire 

CDF from this assessment was 2.0×10-5 per year. The NRC staff requested that Ameren 

identify and evaluate SAMA based on plant-specific insights from the posttransition fire PRA. In 

response, Ameren identified SAMA 180, “Install lower amperage fuses for various 14 AWG 

(American wire gauge) control circuits in main control room (MCR)”; SAMA 181, “Install 

redundant fuses and isolation switches for MCR evacuation procedure OTO-ZZ-00001”; 

SAMA 182, “To protect against multiple spurious operation scenarios, cable runs will be 

changed to run a single wire in a protected metal jacket such that spurious valve opening 

because of a hot short affecting the valve control circuit is eliminated for the fire area”; and 

SAMA 183, “Quick response sprinkler heads in cable chases A–11, C–30, and C–31 will be 

modified to be in accordance with the applicable requirements of NFPA 13—1976 edition” 

(Ameren 2012a). These SAMA are discussed further in Section F.6.2.

Subsequently, Ameren also identified and described the important fire scenarios and discussed 

the impact of the recent decision by Ameren to install the SHIELDTM (no-leakage) RCP seals in 

RF19, Spring 2013, on the results of the fire risk analysis and on these important scenarios 

F-17
Appendix F

(Ameren 2013a). Ameren indicated that a number of the important fire scenarios are primarily 

seal LOCA events and their frequency would be expected to be reduced by the installation of 

the new seal design. The NRC staff noted that while the most important scenarios are seal 

LOCA events and thus would benefit from the planned RCP seal installation, there are several 

whose frequencies would not be reduced by the installation of new seals. Two scenarios, in 

particular, are very similar and result from large turbine building area fires. Both lead to core 

damage because of the loss of AFW upon depleting the condensate storage tank (CST) water 

inventory. The contribution to core damage for these two scenarios is such that procedures for 

providing alternate sources of water for AFW might be cost-beneficial (NRC 2013). In response, 

Ameren explained that procedures already exist for supplying water to the AFW system in the 

event that normal makeup to the CST and both trains of essential service water (ESW), the 

safety-related water supply to the AFW system, are unavailable. These procedures include 

providing makeup to the CST from fire water and supplying fire water directly to the TDAFP

(Ameren 2013b). Based on this information, the NRC staff agrees that a SAMA to supply 

alternate sources of water for AFW is unlikely to be cost beneficial.

As stated earlier, the Ameren IPEEE analysis of other external hazards (high winds, tornadoes,

external floods, and other external events) did not identify opportunities for improvements for 

these events.

The NRC staff questioned Ameren about potentially lower cost alternatives to some of the 

SAMA evaluated (NRC 2012a), including:

• SAMA to modify procedures to avoid clearing of RCS cold leg water seals in 

the event of core damage;

• SAMA similar to SAMA 64, “Implement procedure and hardware 

modifications to allow manual alignment of the fire water system to the 

component cooling water system, or install a component cooling water 

header cross-tie,” but used to provide fire water to the ESW system; and

• SAMA that address the more important loss of HVAC contributors to CDF

rather than SAMA 80, “Provide a redundant train or means of ventilation.”

In response to the RAI, Ameren identified two additional SAMA candidates that addressed the 

first two items: SAMA 179, “Modify procedures such that the water loop seals in the RCS cold 

legs are not cleared following core damage,” and SAMA 186, “Develop a procedure and obtain 

equipment to provide a temporary hookup of fire water as a replacement for ESW.” In addition, 

Ameren determined that SAMA 178, “Improvements to UHS cooling tower electrical room 

HVAC,” which had already been identified in response to another RAI and was discussed 

above, addressed the third item. In further addressing the third item, Ameren modified 

SAMA 80, “Provide a redundant train or means of ventilation,” to consider implementing 

procedures to open doors or provide temporary ventilation for the EDGs, motor-driven AFW 

(MDAFW) pumps, and charging pumps. Procedures for opening doors to the dc switchgear 

rooms already exist at Callaway (Ameren 2012a). These SAMA are discussed further in 

Section F.6.2.

The NRC staff reviewed the screening of Phase I candidate SAMA as described in Table 6–1 of 

ER Attachment F and had a number of RAI concerning the basis for the screening 

(NRC 2012a). The staff’s concerns for all SAMA, except SAMA 144, were adequately resolved 

by the additional information provided in the RAI responses (Ameren 2012a) with no change to 

the Phase I screening results.

F-18
Appendix F

For SAMA 144 (install additional transfer and isolation switches) the screening as “intent met” 

was supported by the identification of the fire-related modification being carried out as part of 

the Callaway NFPA 805 transition.

The NRC staff notes that the set of SAMA submitted is not all-inclusive, since additional, 

possibly even less expensive, design alternatives can always be postulated. However, the NRC 

staff concludes that the benefits of any additional modifications are unlikely to exceed the 

benefits of the modifications evaluated and that the alternative improvements would not likely 

cost less than the least expensive alternatives evaluated, when the subsidiary costs associated 

with maintenance, procedures, and training are considered.

The NRC staff concludes that Ameren used a systematic and comprehensive process for 

identifying potential plant improvements for Callaway, and that the set of potential plant 

improvements identified by Ameren is reasonably comprehensive and, therefore, acceptable. 

This search included reviewing insights from the plant-specific risk studies, and reviewing plant 

improvements considered in previous SAMA analyses. While explicit treatment of external 

events in the SAMA identification process was limited, the NRC staff has determined that (a) the 

prior implementation of plant modifications for fire and seismic risks and (b) the absence of 

external event vulnerabilities reasonably justify examining primarily the internal events risk 

results for this purpose.

F.4 Risk Reduction Potential of Plant Improvements

Ameren evaluated the risk-reduction potential of the 64 SAMA retained for the Phase II 

evaluation in the ER (Ameren 2011a) and the 12 SAMA retained for the Phase II evaluation 

identified as a result of NRC staff RAI (Ameren 2012a, 2012b, 2013). The SAMA evaluations 

were generally performed by Ameren in a bounding fashion, in that the SAMA was assumed to 

eliminate all of the risk associated with the proposed enhancement. The NRC staff notes that 

this bounding approach overestimates the benefit and is conservative. 

The NRC staff notes that Ameren used model requantification to determine the potential 

benefits. The CDF, population dose reductions, and offsite economic cost reductions were 

estimated using the Callaway PRA model. The changes made to the model to quantify the 

impact of SAMA are described in the revised Table 7–1 of Attachment F to the ER as well as in 

the Ameren response to several RAI (Ameren 2012a, 2012b, 2013). Table F–5 lists the 

analysis case and associated assumptions used to estimate the risk reduction for each of the 

evaluated SAMA, the estimated risk reduction in terms of percent reduction in CDF and

population dose, and the estimated total benefit (present value) of the averted risk. The 

estimated benefits reported in Table F–5 reflect the combined benefit in both internal and 

external events. The determination of the benefits for the various SAMA is further discussed in 

Section F.6.

The NRC staff questioned the assumptions used in evaluating the benefit or risk reduction 

estimate of a number of SAMA (NRC 2012a).

Ameren’s analysis case NOSBO, used for SAMA 2, “Replace lead-acid batteries with fuel cells,” 

was intended to determine the benefit of eliminating all SBO sequences. In ER Attachment F 

Table 7–1 this case is indicated to result in approximately a 12-percent reduction in CDF. In an 

RAI the NRC staff noted that is equivalent to a CDF of SBO of 2.0×10-6 per year, which is 

different from the originally stated SBO contribution of 4.7×10-6 per year (Ameren 2012a) and 

the subsequently revised value of 7.9×10-7 per year (Ameren 2012b). In response to the RAI, 

Ameren indicated that the original value was because of eliminating only the failures of the 

onsite EDGs and did not consider the failure of ac power because of support systems for the 

F-19
Appendix F

EDGs nor the benefit associated with preventing SBO by the AEPS. Based on the information 

provided, the NRC staff concludes that the continued use of Case NOSBO’s 12-percent 

reduction in CDF is conservative and acceptable for the SAMA analysis.

For SAMA 1, “Provide additional dc battery capacity,” the staff noted the risk reduction was 

originally evaluated using Case DC01, which assumed that the turbine driven auxiliary 

feedwater pump had no dc power dependency, while the similar SAMA 2, “Replace lead-acid 

batteries with fuel cells,” was evaluated by Case NOSBO, which assumed that there were no 

SBO events (NRC 2012a). In response to the RAI to justify the different treatment of the two 

SAMA that accomplish essentially the same thing, Ameren revised the SAMA 1 benefit to be 

based on the NOSBO case (Ameren 2012a). 

The NRC staff noted that the failure of dc power intended to be mitigated by SAMA 5, “Provide 

dc bus cross-ties,” was evaluated using Case DC01, which assumed that TDAFP had no dc 

power dependency. This would have additional impacts on the plant beyond the failure of the 

TDAFP (NRC 2012b). In response to the RAI, Ameren indicated that the loss of dc power also 

affects the availability of instrumentation (Ameren 2013a). While inclusion of the loss of dc 

power in the evaluation of this SAMA would increase the benefit, Ameren pointed to existing 

Emergency Coordinator Supplemental Guidelines for the use of portable generators to provide 

backup power on extended SBO events. Ameren indicated that this backup portable power is 

not credited in the PRA and would have a greater benefit for prolonged SBOs than the SAMA 5 

cross-tie (Ameren 2013a). The NRC staff concludes that further pursuing this SAMA is not 

needed because of the availability of the portable generator and associated guidelines for its 

use.

SAMA 15, “Install tornado protection on gas turbine generator,” was evaluated by Ameren using 

SAMA Case LOSP1, which is described as leading to no tornado LOSP events. Given 

Callaway has AEPS diesel generators rather than a gas turbine and that internal events models 

do not normally explicitly include the high wind and tornado external events, the NRC staff 

asked Ameren to clarify the model changes made and their applicability to this SAMA 

(NRC 2012a). In response to the RAI, Ameren indicated that the Callaway internal events 

model includes an event for the conditional probability that a tornado event initiates a LOSP 

event and directly causes the loss of AEPS. Ameren stated that this event, which is normally 

set to the estimated fraction of LOSP caused by tornados, was set to zero for case LOSP1 

(Ameren 2012a). The NRC staff considers the preceding explanation to be reasonable and, 

therefore, acceptable for purposes of the SAMA evaluation.

SAMA 25, 26, and 39, all involving additional independently powered safety injection capability, 

were evaluated by Ameren using Case LOCA12, which assumes that there is no failure of 

charging or safety injection pumps. In response to an NRC staff RAI concerning the assumption 

of no failure of charging or safety injection pumps relative to the availability of ac power for this 

case, Ameren responded that the original analysis did not include the benefit associated with 

the ability of these SAMA to operate without site ac power. The results of a revised Case 

LOCA 12 were provided in response to the RAI and incorporated in the cost-benefit analysis 

(Ameren 2013a). The NRC staff considers Ameren’s revision of case LOCA12 and its 

incorporation into the cost-benefit analysis to be reasonable and, therefore, acceptable for use 

in the SAMA analysis. 

SAMA 28, “Add a diverse low-pressure injection system,” was evaluated by Ameren using 

Case LOCA03, described as assuming no failure of low-pressure injection. In response to an 

NRC staff RAI, Ameren confirmed that this case eliminated low-pressure pump failures for all 

sequences where credit was taken for these pumps, but did not include failure because of loss 

of ac or other support systems (Ameren 2012a). The NRC staff considers that, while the benefit 

F-20
Appendix F

would increase with the inclusion of credit for mitigating support system failures, given the 

significant margin between maximum benefit ($140,000) and cost (more than $1 million), the 

benefit assessment is acceptable for purposes of the SAMA evaluation.

SAMA 46, “Add a service water pump,” was evaluated by Ameren using Case SW02, which was 

stated to assume there were no failures of ESW pumps. In response to an NRC staff RAI to 

clarify whether this included ESW pump unavailability because of test and maintenance, 

Ameren indicated that it did not, and provided the results of an updated assessment that did 

include the risk reduction from eliminating the test and maintenance unavailability 

(Ameren 2012a). The NRC staff considers Ameren’s updated assessment that included the risk 

reduction from eliminating the test and maintenance unavailability to be reasonable and, 

therefore, acceptable for use in the SAMA analysis. 

SAMA 55, 56, and 58, involving modifications that reduce the likelihood of RCP seal LOCAs, 

were evaluated by Ameren using Case RCPLOCA. In response to an NRC staff RAI, Ameren 

provided more details on the modeling changes made to evaluate these SAMA (Ameren 2012a; 

NRC 2012b). The evaluation eliminated all causes of RCP seal failures except those resulting 

from loss of support system initiating events, but did include loss of ac power. The NRC staff 

considers the aforementioned explanation to be reasonable and, therefore, acceptable for the 

purposes of the SAMA evaluation.

In response to NRC staff RAI, Ameren reevaluated the benefit of SAMA 64, “Implement 

procedure and hardware modifications to allow manual alignment of the fire water system to the 

component cooling water system, or install a component cooling water header cross-tie,” to 

credit fire water for providing cooling to the RHR heat exchangers instead of the original 

assumption in the ER of no failure of the CCW pumps (Ameren 2011a, 2012a). The NRC staff 

notes that Ameren’s revised evaluation increased the benefit of SAMA 64. The NRC staff 

considers Ameren’s reevaluation of the benefit of SAMA 64 to be reasonable and, therefore, 

acceptable for use in the SAMA analysis. 

In response to an NRC staff RAI concerning the SBO frequency, Ameren indicated that the 

LOSP frequency and consequently the SBO frequency did not include consequential LOSP 

events occurring as a result of other plant transients (Ameren 2012a). The response states that 

for the new Revision 5 model, consequential LOSP events account for 28 percent of the SBO 

frequency and only 2.5 percent of the CDF (Ameren 2012a). The NRC staff noted in a request 

for clarification that this indicates that the benefit from an SBO- or LOSP-mitigating SAMA

should be increased to account for the omission of consequential LOSP events and that the 

impact on other SAMA of the increase in total CDF should be considered (NRC 2012b). 

The NRC staff made the following evaluation to quantify the increase in the benefit from an 

SBO- or LOSP-mitigating SAMA. If it is assumed that the likelihood of an SBO is the same for 

the consequential LOSP as it is for the LOSP initiator, the above indicates that the total SBO 

frequency (and therefore total LOSP frequency) is approximately 39 percent higher than the 

frequency due solely to the LOSP initiator alone. Incorporating these observations in the 

Revision 4B PRA results used in the SAMA evaluation yields an increase in CDF of 2.2×10-6 per 

year (39 percent of 5.6×10-6 per year) or 13 percent of the SAMA baseline CDF of 1.7×10-5 per 

year. Based on this evaluation the NRC staff concluded that the risk reduction and associated 

benefit for cases that mitigate SBO events should be increased by 39 percent while those that 

mitigate LOSP events should be increased by 13 percent. These changes are incorporated in 

the NRC staff’s evaluation in Section F.6.2 below.

The NRC staff has reviewed Ameren’s bases for calculating the risk reduction for the various 

plant improvements and concludes, with the above clarifications, that the rationale and 

assumptions for estimating risk reduction are reasonable and generally conservative (i.e., the 

F-21
Appendix F

estimated risk reduction is higher than what would actually be realized). Accordingly, the NRC 

staff based its estimates of averted risk for the various SAMA on Ameren’s risk reduction 

estimates adjusted, as discussed above, for the additional benefit because of including the 

impact of consequential LOCAs.

F-22
F-23

Table F–5. SAMA Cost/Benefit Screening Analysis for Callaway Plant(a)

Analysis Case and

Applicable SAMA Modeling Assumptions

% Risk Reduction Total Benefit ($)

CDF Population 

Dose

Baseline 

(Internal 

+ 

External)

Baselin

With 

Uncertain

NOSBO

1(m) – Provide additional dc battery 

capacity

2 – Replace lead-acid batteries with fuel 

cells

Completely eliminate failure of 

the EDGs

12 11 360K

(b) (500K)

760K

(b) (1.06M

DC01

5 – Provide dc bus cross-ties

Completely eliminate TDAFP

dependency on dc power

<1 <1 <1K <1K

4KV2

11(c) – Improve 4.16-kV bus cross-tie 

ability

Modifying the SBO model to 

include a cross-tie to the other 

4-kV ac bus and diesel 

generator

<1 1 13K

(b) (15K)

27K

(b) (45k

LOSP1

15(d) – Install tornado protection on gas 

turbine generator

Completely eliminate tornado 

failure of AEPS diesel 

generators

3 4 91K 190K

NOLOSP

24 – Bury offsite power lines

Completely eliminate LOSP 

events

41 41 1.2M

(b) (1.4M)

2.6M

(b) (2.9M
F-24

Analysis Case and

Applicable SAMA Modeling Assumptions

% Risk Reduction Total Benefit ($)

CDF Population 

Dose

Baseline 

(Internal 

+ 

External)

Baselin

With 

Uncertain

LOCA03

28 – Add a diverse low-pressure 

injection system

Completely eliminate failure of 

the low-pressure injection 

system

3 2 65K 140K

29(e) – Provide capability for alternate 

injection via diesel-driven fire pump

NOT EVALUATED(e)

LOCA12

25(l) – Install an independent active or 

passive high-pressure injection system

Completely eliminate failure of 

the high-pressure injection 

pumps

16 <1 620K 980K

26(l) – Provide an additional 

high-pressure injection pump with 

independent diesel

39(l) – Replace two of the four electric 

safety injection pumps with dieselpowered pumps

DEPRESS

41 – Create a reactor coolant 

depressurization system

Completely eliminate the 

depressurization failures

1 <1 12K 25K
F-25

Analysis Case and

Applicable SAMA Modeling Assumptions

% Risk Reduction Total Benefit ($)

CDF Population 

Dose

Baseline 

(Internal 

+ 

External)

Baselin

With 

Uncertain

SW01

43 – Add redundant dc control power 

for SW pumps

Completely eliminate the 

dependency of the service water 

pumps on DC power

1 <1 1K 3K

SW02

46 – Add a service water pump

Completely eliminate the failure 

of service water pumps

18 28 640K 1.3M

CHG01

54 – Increase charging pump lube oil 

capacity

Completely eliminate charging 

pump dependency on cooling 

water

12 22 4K 9K

RCPLOCA

55 – Install an independent RCP seal 

injection system, with dedicated diesel

Completely eliminate all RCP 

seal LOCA events

9 <1 94K 200K

56 – Install an independent RCP seal 

injection system, without dedicated 

diesel

58 – Install improved reactor pump 

seals
F-26

Analysis Case and

Applicable SAMA Modeling Assumptions

% Risk Reduction Total Benefit ($)

CDF Population 

Dose

Baseline 

(Internal 

+ 

External)

Baselin

With 

Uncertain

CCW01

59 – Install an additional CCW pump

Completely eliminate failure of 

the CCW pumps

4 <1 59K 120K

FWCCW2

64(m) – Implement procedure and 

hardware modifications to allow 

manual alignment of the fire water 

system to CCW system, or install a 

CCW header cross-tie

Add fire water as a backup 

source of cooling to the RHR 

heat exchangers with failure 

probability of 0.1

5 1 104K 220K

FW01

65 – Install a digital feedwater upgrade

Completely eliminate all loss of 

feedwater initiating events

2 <1 29K 62K

77 – Provide a passive, secondary-side 

heat-rejection loop consisting of a 

condenser and heat sink

CST01

71 – Install a new condensate storage 

tank (auxiliary feedwater storage tank)

Condensate storage tank (CST) 

is always available

1 <1 18K 39K
F-27

Analysis Case and

Applicable SAMA Modeling Assumptions

% Risk Reduction Total Benefit ($)

CDF Population 

Dose

Baseline 

(Internal 

+ 

External)

Baselin

With 

Uncertain

FB01

79 – Replace existing pilot-operated 

relief valves with larger ones, such that 

only one is required for successful feed 

and bleed

Change success logic so that 

one pilot-operated relief valve 

(PORV) is required for feed and 

bleed

3 2 79K 170K

HVAC

80(f) – Provide a redundant train or 

means of ventilation (Develop 

procedures to open doors or provide 

temporary ventilation for the EDGs, 

MDAFW pumps, and charging 

pumps)

Remove the HVAC dependency 

of the MDAFW pumps, the 

charging pumps, the emergency 

diesel generators and the DC 

switchgear

6 4 160K 331K

INSTAIR

87 – Replace service and instrument air 

compressors with more reliable 

compressors which have self-contained 

air cooling by shaft driven fans

Completely eliminate instrument 

air and SG PORV backup 

nitrogen supply failures

<1 <1 2K 4K

CONT01

91 – Install a passive containment 

spray system

Completely eliminate all 

containment failures because of 

overpressurization

20 37 1.2M 310K
F-28

Analysis Case and

Applicable SAMA Modeling Assumptions

% Risk Reduction Total Benefit ($)

CDF Population 

Dose

Baseline 

(Internal 

+ 

External)

Baselin

With 

Uncertain

93 – Install an unfiltered hardened 

containment vent

94 – Install a filtered containment vent 

to remove decay heat; Option 1: Gravel 

Bed Filter; Option 2: Multiple Venturi 

Scrubber

99 – Strengthen primary/secondary 

containment (e.g., add ribbing to 

containment shell)

102 – Construct a building to be 

connected to primary/secondary 

containment and maintained at a 

vacuum

107 – Install a redundant containment 

spray system

H2BURN

96 – Provide post-accident containment 

inerting capability

Completely eliminate all 

hydrogen burns and detonations

0.5 0 10K 21K
F-29

Analysis Case and

Applicable SAMA Modeling Assumptions

% Risk Reduction Total Benefit ($)

CDF Population 

Dose

Baseline 

(Internal 

+ 

External)

Baselin

With 

Uncertain

108 – Install an independent power 

supply to the hydrogen control system 

using either new batteries, a nonsafety-grade portable generator, 

existing station batteries, or existing 

ac/dc independent power supplies, 

such as the security system diesel

109 – Install a passive hydrogen control 

system
F-30

Analysis Case and

Applicable SAMA Modeling Assumptions

% Risk Reduction Total Benefit ($)

CDF Population 

Dose

Baseline 

(Internal 

+ 

External)

Baselin

With 

Uncertain

MAB(g) 

97 – Create a large concrete crucible 

with heat removal potential to contain 

molten core debris

98 – Create a core melt source 

reduction system

100 – Increase depth of the concrete 

basemat or use an alternate concrete 

material to ensure melt-through does 

not occur

110 – Erect a barrier that would provide 

enhanced protection of the containment 

walls (shell) from ejected core debris 

following a core melt scenario at high 

pressure

NOT EVALUATED(g)

LOCA05

104 – Improve leak detection procedure

Completely eliminate all piping 

LOCA events

39 2 685K 1.5M

147 – Install digital large break LOCA 

protection system
F-31

Analysis Case and

Applicable SAMA Modeling Assumptions

% Risk Reduction Total Benefit ($)

CDF Population 

Dose

Baseline 

(Internal 

+ 

External)

Baselin

With 

Uncertain

CONT02

112 – Add redundant and diverse limit 

switches to each containment isolation 

valve

Completely eliminate failure of 

containment isolation failure

0.3 0 1K 2K

114 – Install self-actuating containment 

isolation valves

ISLOCA

111 – Install additional pressure or leak 

monitoring instruments for detection of 

ISLOCAs

Completely eliminate all ISLOCA 

events

1 9 120K 260K

113 – Increase leak testing of valves in 

ISLOCA paths

115 – Locate RHR inside containment 

116 – Ensure ISLOCA releases are 

scrubbed. One method is to plug drains 

in potential break areas so that the 

break point will be covered
F-32

Analysis Case and

Applicable SAMA Modeling Assumptions

% Risk Reduction Total Benefit ($)

CDF Population 

Dose

Baseline 

(Internal 

+ 

External)

Baselin

With 

Uncertain

NOSGTR

119 – Institute a maintenance practice 

to perform a 100% inspection of steam 

generator tubes during each refueling 

outage

121 – Increase the pressure capacity of 

the secondary side so that an SGTR 

would not cause the relief valves to lift

122 – Install a redundant spray system 

to depressurize the primary system 

during an SGTR

125 – Route the discharge from the 

main steam safety valves through a 

structure where a water spray would 

condense the steam and remove most 

of the fission products

126 – Install a highly reliable (closed 

loop) steam generator shell-side heat 

removal system that relies on natural 

circulation and stored water sources

129 – Vent main steam safety valves in 

containment

Completely eliminate all SGTR 

events

20 63 1.4M 2.9M
F-33

Analysis Case and

Applicable SAMA Modeling Assumptions

% Risk Reduction Total Benefit ($)

CDF Population 

Dose

Baseline 

(Internal 

+ 

External)

Baselin

With 

Uncertain

NOATWS

130 – Add an independent boron 

injection system

131 – Add a system of relief valves to 

prevent equipment damage from 

pressure spikes during an ATWS

133 – Install an ATWS-sized filtered 

containment vent to remove decay heat

136 – Install motor generator set trip 

breakers in control room

Completely eliminate all 

anticipated ATWS events

2 2 63K 130K

NOSLB

153 – Install secondary side guard 

pipes up to the main steam isolation 

valves

Completely eliminate all steam 

line break events

3 0 51K 110K

160(h) – Modifications to lessen 

impact of internal flooding path 

through Control Building 

dumbwaiter

NOT EVALUATED(h)
F-34

Analysis Case and

Applicable SAMA Modeling Assumptions

% Risk Reduction Total Benefit ($)

CDF Population 

Dose

Baseline 

(Internal 

+ 

External)

Baselin

With 

Uncertain

PORV

161 – Improvements to PORV 

performance that will lower the 

probability of failure to open

Completely eliminate failure of 

PORVs to open

1 <1 18K 39K

EDGFUEL

162 – Install a large volume EDG fuel 

oil tank at an elevation greater than 

the EDG fuel oil day tanks

Completely eliminate EDG fuel 

oil transfer system failures

1 8 120K 260K

FW02

163 – Improve feedwater check valves 

reliability to reduce probability of failure 

to open

Completely eliminate feedwater 

check valves fail to open

6 2 130K 270K

SW03

164 – Provide the capacity to power the 

normal service water pumps from AEPS

Provide AEPS power to SW 

Train A pumps.

6 8 190K 400K
F-35

Analysis Case and

Applicable SAMA Modeling Assumptions

% Risk Reduction Total Benefit ($)

CDF Population 

Dose

Baseline 

(Internal 

+ 

External)

Baselin

With 

Uncertain

LOCA04

171 – Increase the size of the RWST or 

otherwise improve the availability of the 

RWST

Refueling water storage tank 

(RWST) always available

1 <1 13K 27K

HVAC02

178 – Improvements to UHS cooling 

tower electrical room HVAC 

(implementation of temporary 

ventilation or opening doors)

Eliminate failure of all UHS 

cooling tower electrical room 

HVAC fans

3 5 110K 240K

RAI7a

179 – Modify procedures such that 

the water loop seals in the RCS cold 

legs are not cleared following core 

damage

Eliminate thermally induced 

steam generator tube ruptures

0 3 63K 130K

180(i) – Install lower amperage fuses 

for various 14 AWG control circuits 

in the MCR. The majority of the 

modification centers around the trip 

circuit fuses on NB, NG, PA, PB, and 

PG system breakers

NOT EVALUATED(i)
F-36

Analysis Case and

Applicable SAMA Modeling Assumptions

% Risk Reduction Total Benefit ($)

CDF Population 

Dose

Baseline 

(Internal 

+ 

External)

Baselin

With 

Uncertain

181(i) – Install redundant fuses and 

isolation switches for MCR 

evacuation procedure OTO-ZZ-00001

NOT EVALUATED(i)

182(i) – To protect against multiple 

spurious operation scenarios, cable 

runs will be changed to run a single 

wire in a protected metal jacket such 

that spurious valve opening because 

of a hot short affecting the valve 

control circuit is eliminated for the 

fire area. This modification will be 

implemented in multiple fire areas

NOT EVALUATED(i)

183(i) – Quick response sprinkler 

heads in cable chases A–11, C–30, 

and C–31 will be modified to be in 

accordance with the applicable 

requirements of NFPA 13—1976 

edition

NOT EVALUATED(i)

SLIS

184 – Improvements in the reliability of 

the steam line isolation automatic signal

Eliminate failure of the main 

steam line isolation system

1 1 28K 59K
F-37

Analysis Case and

Applicable SAMA Modeling Assumptions

% Risk Reduction Total Benefit ($)

CDF Population 

Dose

Baseline 

(Internal 

+ 

External)

Baselin

With 

Uncertain

HEP

185(j) – Automate initiation of CCW 

flow to the RHR heat exchangers

Eliminate failure of the operator 

to initiate CCW flow to the RHR 

heat exchangers

4 <1 62K 130K

FWCCW

186 – Develop a procedure and obtain 

equipment to provide a temporary 

hookup of fire water as a replacement 

for ESW

Add fire water as a backup 

source of cooling to a single 

train of CCW heat exchangers 

with failure probability of 0.1

<1 <1 1K 2K

SBOMOD

187 – Install modification to power 

the normal charging pump from an 

existing spare breaker from the 

AEPS

Reduce the frequency of SBO 

sequences by 90%

4 8 170K

(b) (240K)

370K

(b) (510K

SBOMOD2

188 – Install a permanent, dedicated 

generator for the normal charging 

pump (NCP), and an MDAFW pump 

and battery charger to address SBO 

events in which the TDAFP is 

unavailable

Reduce the frequency of SBO 

sequences by 95%

4 8 180K

(b) (250K)

385K

(b) (535K
F-38

Analysis Case and

Applicable SAMA Modeling Assumptions

% Risk Reduction Total Benefit ($)

CDF Population 

Dose

Baseline 

(Internal 

+ 

External)

Baselin

With 

Uncertain

189(k) – Perform analysis to 

determine if it is possible to modify 

current plant doors to withstand 

higher flood heights. Either perform 

modifications to install improved 

doors or revise flooding analysis to 

incorporate results that doors will 

withstand higher flooding heights 

without propagating the flood

NOT EVALUATED(k)
F-39

Analysis Case and

Applicable SAMA Modeling Assumptions

% Risk Reduction Total Benefit ($)

CDF Population 

Dose

Baseline 

(Internal 

+ 

External)

Baselin

With 

Uncertain

(a) SAMA in bold are potentially cost-beneficial.

(b) Value in parentheses is NRC staff estimate of benefit after adjusting Ameren’s results to account for lack of inclusion of consequenti

SAMA model. See the discussion in Sections F.4 and F.6.2.

(c) The benefit of a 4-kV cross-tie did not consider the availability of a cross-tie to the other 4-kV AC bus and diesel generator. In respo

RAI, Ameren concluded that this SAMA was potentially cost-beneficial since only SBO sequences were evaluated and, therefore, th

reduction and benefit was underestimated (Ameren 2012b). The implementation cost was also reduced to include only the developm

and analysis to allow use of the cross-tie.

(d) This generic SAMA, although identified against a gas turbine generator, was evaluated against the Callaway AEPS diesel generator

(e) This SAMA has been identified as potentially cost-beneficial in Section 9 of Attachment F of the ER, but has not been evaluated bec

to be of low cost. It is currently being evaluated by a plant improvement program and would involve use of “unborated” water and a 

(e.g., fire truck). The evaluation will consider the impacts of injection of nonborated water (Ameren 2011a).

(f) In response to an NRC staff RAI, Ameren revised the implementation cost based on the determination that procedures to open door

temporary ventilation may be cost-beneficial for the EDGs, MDAFW pumps, and charging pumps. Procedures for opening doors to 

rooms already exist (Ameren 2012a).

(g) SAMA costing over $10 million were not further evaluated because the implementation cost exceeds the maximum benefit from elim

accidents at Callaway (Ameren 2011a).

(h) The risk reduction of this SAMA was not evaluated and it was not assigned to a SAMA case; however, it was identified as potentially 

the ER and entered into the Callaway long-range plan development process for further consideration (Ameren 2011a). 

(i) The risk reduction of these SAMA was not evaluated and it was not assigned to a SAMA case. Each of these risk reductions, howev

as potentially cost-beneficial in response to an NRC staff RAI and entered into the Callaway long-range plan development process f

consideration. Each of these SAMA was considered potentially cost-beneficial without benefit or cost determination. Regardless, th

amendment request committed to performing the modification (Ameren 2012a).

(j) In response to an NRC staff RAI, Ameren considers this SAMA to be cost-beneficial even though the implementation cost exceeds t

accounting for analysis uncertainties (Ameren 2012b).

(k) The risk reduction of this SAMA was not evaluated and it was not assigned to a SAMA case. It was identified, however, as potentia

response to an NRC staff RAI and is currently being implemented at the direction of plant management (Ameren 2013a).

(l) The estimated benefit of analysis case LOCA12 and the implementation costs for SAMA 25, 26, and 39 were revised in response to 

(Ameren 2013a).

(m)The modeling assumptions, risk reduction, estimated benefits, and implementation costs for these SAMA were revised in response t

(Ameren 2012a).
Appendix F

F.5 Cost Impacts of Candidate Plant Improvements

Ameren estimated the costs of implementing the Phase II candidate SAMA primarily through the 

use of an Expert Panel. Initially it was estimated that that the minimum cost of making a change 

to a procedure and for conducting the necessary training on a procedure change was $15,000. 

Similarly, the minimum cost associated with development and implementation of an integrated 

hardware modification package including post-implementation costs (e.g., training) is expected 

to exceed $100,000. These values were used for initial comparison with the benefit of SAMA.

The Expert Panel (consisting of senior staff members from the PRA group, the design group, 

operations and license renewal) reviewed the benefit calculation results and, based upon their 

experience with developing and implementing modifications at the plant, judged whether a 

modification could be made to the plant that would be cost-beneficial in comparison with the 

calculated benefit. The estimated minimum cost for each Phase II SAMA is presented in 

Table 7–1 of Attachment F to the ER and in response to NRC staff RAIs (Ameren 2011a, 

2012a, 2012b, 2013). Seven Phase II SAMA are accepted as potentially cost-beneficial without 

performing cost estimates (i.e., SAMA 29, 160, 180, 181, 182, 183, and 189). Detailed cost 

estimates were not developed for SAMA that were judged to have implementation costs that far 

exceeded the estimated benefit.

In response to an NRC staff RAI on the cost development process and the level of detail 

included, Ameren indicated that the general categories of costs considered were materials, 

analyses to support implementation and feasibility, procedure development, replacement power

costs, and the costs of ongoing training and surveillance. Inputs such as cost of implementation 

at other plants and implementation of similar modifications and equipment replacements were 

also considered. Some estimates included costs of a structure to house the equipment if the 

Expert Panel felt that sufficient space did not exist within the current plant structures. In 

general, the estimate of the implementation cost for an individual SAMA would start out 

relatively low and more detail and refinement would take place after comparison of the cost 

estimate to the benefit at 95 percent CDF, which was always the highest benefit from the 

sensitivity evaluations. The cost estimates did not consider inflation. Contingency costs were 

not specifically considered (Ameren 2012a).

In response to an RAI requesting a more detailed description of the changes associated with 

SAMA 11, 15, 64, 94, 104, 116, 163, and 164, Ameren provided additional information on the 

plant modifications included in the cost estimate of each improvement or other support for the 

cost estimate (Ameren 2012a). Ameren also reduced the implementation cost of SAMA 64 to 

less than $150,000, which includes only development of a procedure and use of temporary 

connections, from more than $500,000 in the ER, which included making permanent plant 

modifications. The staff reviewed the costs and found them to be reasonable, and generally 

consistent with estimates provided in support of other plants’ analyses.

For certain improvements, the NRC staff compared the cost estimates to estimates developed 

elsewhere for similar improvements, including estimates developed as part of other licensees’ 

analyses of SAMA for operating reactors.

For SAMA 24, “Bury offsite power lines,” the NRC staff noted that Ameren’s cost estimate of 

more than $3 million is significantly higher than that used in other SAMA submittals, such as 

Seabrook’s estimate of more than $1 million (NextEra 2010). Ameren responded that to 

achieve the estimated benefit the offsite power lines would need to be buried out to the next 

transmission substation, which for Callaway is 21 mi. Using the industry-accepted cost estimate 

for burying power lines of approximately $1 million per mile, the modification would cost 

approximately $21 million (Ameren 2012a).

F-40
Appendix F

For SAMA 113, “Increase leak testing of valves in ISLOCA paths,” the NRC staff noted that 

Ameren’s cost estimate of more than $1 million seems high, as there are no hardware 

modifications necessary and it is significantly higher than that used in other SAMA submittals 

such as Seabrook’s estimate of more than $100,000 (NextEra 2010). Ameren responded that 

the valves in the ISLOCA pathways are currently tested every refueling outage. To test these 

valves the plant must be in Cold Shutdown/Refueling conditions when the valves are accessible 

and the systems can be aligned or configured to allow installation of test equipment and the 

performance of the testing. Leak testing on a more frequent basis would require plant 

shutdown. The cost of replacement power to support shutdowns to test the valves was 

estimated to be significantly greater than $1 million (Ameren 2012a).

For SAMA 119, “Institute a maintenance practice to perform a 100 percent inspection of steam 

generator tubes during each refueling outage,” the NRC staff noted that the Ameren estimate of 

more than $3 million seems high, as it does not require hardware modification, and is 

considerably higher than that used in other SAMA submittals, such as Seabrook’s estimate of 

more than $500,000 (NextEra 2010). Ameren responded that because of the recent 

replacement of steam generators and the associated reduced inspection requirements, 

performing a 100-percent inspection every refueling outage would extend the duration of many 

outages. In addition, testing of steam generator tubes requires considerable radiological dose, 

testing equipment costs, and vendor costs for data analysis and reporting. The sum of these 

costs was estimated to be in excess of the estimated $3 million for this SAMA (Ameren 2012a).

Given that Ameren followed the guidance in NEI 05-01 (NEI 2005) and satisfactorily addressed 

NRC questions regarding cost estimates, the NRC staff concludes that the cost estimates 

provided by Ameren are sufficient and appropriate for use in the SAMA evaluation.

F.6 Cost-Benefit Comparison

Ameren’s cost-benefit analysis and the NRC staff’s review are described in the following 

sections.

F.6.1 Ameren’s Evaluation

The methodology used by Ameren was based primarily on NRC’s guidance for performing costbenefit analysis, i.e., NUREG/BR–0184 (NRC 1997a). The guidance involves determining the 

net value for each SAMA according to the following formula:

Net Value = (APE + AOC + AOE + AOSC) – COE, where

APE = present value of averted public exposure ($)

AOC = present value of averted offsite property damage costs ($)

AOE = present value of averted occupational exposure costs ($)

AOSC = present value of averted onsite costs ($)

COE = cost of enhancement ($)

If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the 

benefit associated with the SAMA and it is not considered cost-beneficial. Ameren’s derivation 

of each of the associated costs is summarized below.

NUREG/BR–0058, Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission, 

has been revised recently to reflect the NRC’s policy on discount rates. Revision 4 of 

NUREG/BR–0058 states that two sets of estimates should be developed, one at 3 percent and 

one at 7 percent (NRC 2004). Ameren provided a base set of results using the 7 percent 

discount rate, and a sensitivities study using the 3 percent discount rate (Ameren 2011a).

F-41
Appendix F

F.6.1.1 Averted Public Exposure (APE) Costs

The APE costs were calculated using the following formula:

APE = Annual reduction in public exposure (Δ person-rem/year)

× monetary equivalent of unit dose ($2,000 per person-rem ($20 per person-Sv))

× present value conversion factor (10.76 based on a 20-year period with a 

7 percent discount rate)

As stated in NUREG/BR–0184 (NRC 1997a), it is important to note that the monetary value of 

the public health risk after discounting does not represent the expected reduction in public 

health risk because of a single accident. Rather, it is the present value of a stream of potential 

losses extending over the remaining lifetime (in this case, the renewal period) of the facility. 

Thus, it reflects the expected annual loss because of a single accident, the possibility that such 

an accident could occur at any time over the renewal period, and the effect of discounting these 

potential future losses to present value. For the purposes of initial screening, which assumes 

elimination of all severe accidents, Ameren calculated an APE of approximately $98,900 for the 

20-year license renewal period (Ameren 2011a).

F.6.1.2 Averted Offsite Property Damage Costs (AOC)

The AOC were calculated using the following formula:

AOC = Annual CDF reduction

× offsite economic costs associated with a severe accident (on a per-event basis) 

× present value conversion factor

This term represents the sum of the frequency-weighted offsite economic costs for each release 

category, as obtained for the Level 3 risk analysis. For the purposes of initial screening, which 

assumes elimination of all severe accidents caused by internal events, Ameren calculated an

AOC of about $23,300 based on the Level 3 risk analysis (Ameren 2011a). This results in a 

discounted value of approximately $223,000 for the 20-year license renewal period.

F.6.1.3 Averted Occupational Exposure (AOE) Costs

The AOE costs were calculated using the following formula:

AOE = Annual CDF reduction

× occupational exposure per core damage event

× monetary equivalent of unit dose

× present value conversion factor

Ameren derived the values for AOE from information provided in Section 5.7.3 of NUREG/BR–

0184 (NRC 1997a). Best estimate values provided for immediate occupational dose

(3,300 person-rem (33 person-Sv)) and long-term occupational dose (20,000 person-rem 

(200 person-Sv) over a 10-year cleanup period) were used. The present value of these doses 

was calculated using the equations provided in the handbook in conjunction with a monetary 

equivalent of unit dose of $2,000 per person-rem ($20 per person-Sv), a real discount rate of 

7 percent, and a time period of 20 years to represent the license renewal period. For the 

purposes of initial screening, which assumes elimination of all severe accidents caused by 

internal events, Ameren calculated an AOE of approximately $6,300 for the 20-year license 

renewal period (Ameren 2011a).

F-42
Appendix F

F.6.1.4 Averted Onsite Costs

Averted onsite costs (AOSC) include averted cleanup and decontamination costs (ACC) and 

averted power replacement costs. Repair and refurbishment costs are considered for 

recoverable accidents only and not for severe accidents. Ameren derived the values for AOSC 

based on information provided in Section 5.7.6 of NUREG/BR–0184, the regulatory analysis 

handbook (NRC 1997a).

Ameren divided this cost element into two parts: the onsite cleanup and decontamination cost, 

also commonly referred to as averted cleanup and decontamination costs, and the replacement 

power cost (RPC).

ACC were calculated using the following formula:

ACC = Annual CDF reduction

× present value of cleanup costs per core damage event

× present value conversion factor

The total cost of cleanup and decontamination subsequent to a severe accident is estimated in 

NUREG/BR–0184 to be $1.5 billion (undiscounted). This value was converted to present costs 

over a 10-year cleanup period and integrated over the term of the proposed license extension. 

For the purposes of initial screening, which assumes elimination of all severe accidents caused 

by internal events, Ameren calculated an ACC of approximately $193,000 for the 20-year 

license renewal period.

Long-term RPCs were calculated using the following formula:

RPC = Annual CDF reduction

× present value of replacement power for a single event

× factor to account for remaining service years for which replacement power is 

required

× reactor power scaling factor

Ameren based its calculations on a Callaway net output of 1,236 megawatts electric (MWe) and 

scaled up from the 910-MWe reference plant in NUREG/BR–0184 (NRC 1997a). Therefore, 

Ameren applied a power scaling factor of 1236/910 to determine the replacement power costs. 

For the purposes of initial screening, which assumes elimination of all severe accidents caused 

by internal events, Ameren calculated an RPC of approximately $176,500 and AOSC of 

approximately $369,500 for the 20-year license renewal period.

Using the above equations, Ameren estimated the total present dollar value equivalent 

associated with completely eliminating severe accidents from internal events at Callaway to be 

about $698,000, also referred to as the Maximum Averted Cost Risk (MACR). Use of a 

multiplier of 4.57 to account for external events increases the value to $3.19 million and 

represents the dollar value associated with completely eliminating all internal and external event 

severe accident risk for the Callaway, also referred to as the modified MACR.

F.6.1.5 Ameren’s Results

If the implementation costs for a candidate SAMA exceeded the calculated benefit, the SAMA 

was considered not to be cost-beneficial. In the baseline analysis contained in the ER (using a 

7-percent discount rate), Ameren identified no potentially cost-beneficial SAMA. However, 

Ameren identified two potentially cost-beneficial SAMA, without estimating the benefit, that were 

F-43 
Appendix F

judged to be of low cost (SAMA 29 and 160). Based on the consideration of analysis 

uncertainties, Ameren identified one additional potentially cost-beneficial SAMA (SAMA 162). 

These potentially cost-beneficial SAMA for Callaway are as follows:

• SAMA 29 – Provide capability for alternate injection via diesel-driven fire 

pump.

• SAMA 160 – Modifications to lessen impact of internal flooding path through 

Control Building dumbwaiter.

• SAMA 162 – Install a large volume EDG fuel oil tank at an elevation greater 

than the EDG fuel oil day tanks.

In response to NRC staff RAI Ameren identified thirteen additional cost-beneficial SAMA

(Ameren 2012a, 2012b, 2013a). The potentially cost-beneficial SAMA, and Ameren’s plans for 

further evaluation of these SAMA, are discussed in more detail in Section F.6.2.

F.6.2 Review of Ameren’s Cost-Benefit Evaluation

The cost-benefit analysis performed by Ameren was based primarily on NUREG/BR–0184 

(NRC 1997a) and discount rate guidelines in NUREG/BR–0058 (NRC 2004) and was executed 

consistent with this guidance.

The NRC staff notes that SAMA identified primarily on the basis of the internal events analysis 

could provide benefits in certain external and internal flooding events, in addition to their 

benefits in internal events. Ameren accounted for the potential risk reduction benefits 

associated with external and internal flooding events by applying a multiplier to the estimated 

benefits for internal events. In the analysis reported in the ER, Ameren multiplied the estimated 

benefits for internal events by a factor of 4.57 incorporating an external and internal flooding 

events multiplier of 3.57 to account for external and internal flooding events (Ameren 2011a). 

As discussed in Section F.2.2, this factor was based on a high winds CDF of 2.5×10-5 per year, 

an internal flooding CDF of 9.1×10-6 per year, a fire CDF of 2.0×10-5 per year, and a seismic

CDF of 5.0×10-6 per year. The external and internal flooding events CDF of 5.9×10-5 per year is 

thus 3.57 times the internal events CDF of 1.7×10-5 per year resulting in a total multiplier of 4.57 

that was used in the SAMA analysis. The NRC staff notes that no SAMA were determined to be 

cost-beneficial in Ameren’s baseline analysis; however, Ameren originally identified two 

potentially cost-beneficial SAMA, without estimating the benefit, that were judged to be low cost 

(SAMA 29 and 160, as described above). Ameren stated that these SAMA would be entered 

into the Callaway long-range plan development process for further implementation consideration 

(Ameren 2011a).

Ameren includes evaluation of SAMA 15, “Install tornado protection on gas turbine generator,” 

as a weather-related contributor to LOSP and presents a tornado-related event 

(i.e., TORNADO-T1-EVENT) in the LERF importance list in Table 3–6 (Ameren 2011a). The 

NRC staff notes that this SAMA was not found to be potentially cost beneficial notwithstanding 

the use of the conservative external and internal flooding events multiplier. The process that 

Ameren used overestimates the benefits from external events and, therefore, results in 

conservative estimates of the SAMA benefits. Therefore, the NRC staff considers the process 

Ameren used to disposition SAMA 15 acceptable for the SAMA evaluation.

Ameren considered the impact that possible increases in benefits from analysis uncertainties 

would have on the results of the SAMA assessment. In the ER, Ameren presents the results of 

an uncertainty analysis of the internal events CDF which indicates that the 95th percentile value 

is a factor of 2.11 times the point estimate CDF for Callaway. Since none of the Phase I SAMA 

F-44
Appendix F

were screened out using excessive cost or very low benefit criteria, a reexamination of the 

Phase I SAMA based on the upper bound benefits was not necessary. Ameren examined the 

Phase II SAMA to determine if any would be potentially cost-beneficial if the baseline benefits 

were increased by a factor of 2.11. As a result, one SAMA became cost-beneficial (SAMA 162, 

as described above). Although not cost-beneficial in the baseline analysis, Ameren stated that 

this SAMA would be entered into the Callaway long-range plan development process for further 

implementation consideration (Ameren 2011a).

Ameren provided the results of additional sensitivity analyses in the ER, including use of 3- and 

8.3-percent discount rates, variations in MACCS2 input parameters (as discussed in 

Section F.2.2), and a 33-year analysis period representing the remaining operating life of the 

plant accounting for the expected 20-year period of extended operation. Ameren determined 

that these analyses did not identify any additional potentially cost-beneficial SAMA

(Ameren 2011a, 2013).

NRC staff asked Ameren about SAMA listed in Table 7–1 of Attachment F of the ER, for which 

the calculated benefit does not seem consistent with the percent reduction in CDF or offsite 

dose, or for which there was no CDF or offsite dose information to compare to the calculated 

benefit (NRC 2012a). In response, Ameren indicated that two of the SAMA identified (SAMA 29 

and 160, as discussed above) were assumed to be cost-beneficial without determining a value 

of the benefit and the missing information was provided for the others. In addition, Ameren 

provided corrected values where apparent errors were noted in the NRC review 

(Ameren 2012a). These corrected results are included in Table F–5.

As discussed in Sections F.2.2 and F.4, the Callaway PRA did not include the LOSP occurring 

as a result of another initiating event and thus underestimated the benefit associated with SAMA

that mitigate LOSP events, in general, or SBO events, in particular. The increased benefit, as 

estimated by the NRC staff, because of this nonconservatism is included in Table F–5. For 

SAMA 1 and 2, both related to increasing DC power availability for prolonged SBO, the benefit 

including uncertainty increases to $1.06 million, which compares to the estimated 

implementation cost for these SAMA of greater than $1 million. Considering that the estimated 

benefit is conservative in that the SAMA are assumed to completely eliminate failure of the 

EDGs and the implementation cost is expected to significantly exceed $1 million, the NRC 

concludes that these SAMA would not be cost- beneficial. The benefit of SAMA 24, burying the 

offsite power lines, is affected by the offsite power adjustment. The increased benefit is still 

below the estimated cost, and hence this SAMA is accepted by the NRC staff as not costbeneficial.

For SAMA 11, “Improve 4.16-kV bus cross-tie ability,” Ameren determined, in response to an 

NRC staff RAI, that a physical cross-tie already exists, but there is no analysis or procedures to 

allow its use except in specific outage conditions, and that the benefit calculated is 

underestimated since it was evaluated for only SBO sequences. Based on this, Ameren 

concluded that this SAMA is cost-beneficial without revising the calculated benefit, although, as 

reported in Table F-5, the implementation cost was reduced to only include development of 

procedures and performing analysis to allow use of the cross-tie (Ameren 2012b).

As discussed in Section F.4, in response to an NRC staff RAI, Ameren reevaluated the benefit 

of SAMA 64, “Implement procedure and hardware modifications to allow manual alignment of 

the fire water system to the component cooling water system, or install a component cooling 

water header cross-tie,” to credit fire water for providing cooling to the RHR heat exchangers 

instead of the original assumption of no failure of the CCW pumps (Ameren 2011a, 2012a). The 

revised cost-benefit evaluation of this SAMA candidate is provided in Table F–5 and was 

determined to not be cost-beneficial in the baseline evaluation. However, after consideration of 

F-45
Appendix F

analysis uncertainties, this SAMA was determined by Ameren to be potentially cost-beneficial 

(Ameren 2012a).

As discussed in Section F.3.2, in response to an NRC staff RAI to consider SAMA that would 

reduce the risk from fires based on the results of the Callaway NFPA 805 transition application 

fire PRA, Ameren added the following four fire-related modifications from this application as 

Phase II SAMA, which are included in Table F–5: SAMA 180, “Install lower amperage fuses for 

various 14 AWG control circuits in main control room (MCR),” SAMA 181, “Install redundant 

fuses and isolation switches for MCR evacuation procedure OTO-ZZ-00001,” SAMA 182, “To 

protect against multiple spurious operation scenarios, cable runs will be changed to run a single 

wire in a protected metal jacket such that spurious valve opening because of a hot short 

affecting the valve control circuit is eliminated for the fire area,” and SAMA 183, “Quick 

response sprinkler heads in cable chases A–11, C–30, and C–31 will be modified to be in 

accordance with the applicable requirements of NFPA 13—1976 edition.” Ameren concluded 

these SAMA were potentially cost-beneficial without a formal cost-benefit evaluation 

(Ameren 2012a).

As discussed in Section F.3.2, SAMA 184, “Improvements in the reliability of the Steam Line 

Isolation automatic signal,” was added as a Phase II SAMA in response to an NRC staff RAI

(Ameren 2012a). The cost-benefit evaluation of this SAMA candidate is provided in Table F–5 

and was determined by Ameren to not be cost-beneficial in either the baseline evaluation or the 

uncertainty evaluation.

As discussed in Section F.3.2, SAMA 185, “Automate initiation of CCW flow to the RHR heat 

exchangers,” was added as a Phase II SAMA in response to an NRC staff RAI (Ameren 2012b). 

The cost-benefit evaluation of this SAMA candidate is provided in Table F–5 and was 

determined by Ameren to not be cost-beneficial in either the baseline evaluation or the 

uncertainty evaluation. Nevertheless, the Callaway Expert Panel concluded that this SAMA was 

potentially cost-beneficial since (1) this modification had been implemented at Wolf Creek, 

(2) the estimated benefit after consideration of analysis uncertainties and implementation cost 

are close, and (3) the implementation cost may be lower than estimated if Ameren can get 

design information from Wolf Creek (NRC 2012b).

As discussed in Section F.3.2, Ameren added SAMA 187, “Install modification to power the 

normal charging pump from an existing spare breaker from the AEPS,” and SAMA 188, “Install 

a permanent, dedicated generator for the NCP, and an MDAFW pump and battery charger to 

address SBO events in which the TDAFW pump is unavailable,” as Phase II SAMA in response 

to an NRC staff RAI (Ameren 2012b). The cost-benefit evaluation of these SAMA candidates is 

provided in Table F–5 and neither was determined by Ameren to be cost-beneficial in the 

baseline evaluation. After consideration of analysis uncertainties, SAMA 187 was determined to 

be potentially cost-beneficial, while SAMA 188 was determined to not be cost-beneficial. 

Ameren, however, explained that while the AEPS as presently configured does not go through 

the Callaway switchyard and, therefore, cannot be used to power the equipment cited in these 

SAMA, the AEPS has a spare breaker that would allow the AEPS to power this additional 

Callaway equipment directly. Based on this, Ameren concluded that both SAMA 187 and 188 

are potentially cost-beneficial (Ameren 2012b; NRC 2012b).

As discussed in Section F.3.2, Ameren added SAMA 189, “Perform analysis to determine if it is 

possible to modify current plant doors to withstand higher flood heights. Either perform 

modifications to install improved doors or revise flooding analysis to incorporate results that 

doors will withstand higher flooding heights without propagating the flood,” as a Phase II SAMA 

in response to an NRC staff RAI. Ameren concluded this SAMA was potentially cost-beneficial 

without a formal cost-benefit evaluation (Ameren 2013a).

F-46
Appendix F

As indicated in Section F.3.2, the NRC staff asked the applicant to evaluate several potentially 

lower cost alternatives to the SAMA considered in the ER (NRC 2012a). Ameren’s responses 

and disposition of the alternatives are summarized below:

• SAMA 179, “Modify procedures such that the water loop seals in the RCS 

cold legs are not cleared following core damage,” was added as a Phase II 

SAMA (Ameren 2012a). The cost-benefit evaluation of this SAMA candidate 

is provided in Table F–5 and was determined to not be cost-beneficial in the 

baseline evaluation. However, after consideration of analysis uncertainties, 

SAMA 179 was determined to be potentially cost-beneficial.

• SAMA 186, “Develop a procedure and obtain equipment to provide a 

temporary hookup of fire water as a replacement for ESW,” was added as a 

Phase II SAMA (Ameren 2012a). This SAMA was identified by Ameren as an 

alternative to SAMA 64, “Implement procedure and hardware modifications to 

allow manual alignment of the fire water system to component cooling water 

system, or install a component cooling water header cross-tie,” because it 

has a greater benefit by mitigating a wider range of ESW failures than just the 

RHR heat exchangers assumed in SAMA 64. Ameren’s initial analysis of 

SAMA 186 indicated a baseline benefit of approximately $640,000; however, 

it noted that larger fire pumps may be needed (Ameren 2012a). 

Subsequently, Ameren reevaluated the benefit of this SAMA by crediting fire 

water as a source of backup cooling for the CCW heat exchangers which 

reduced the benefit to $1,000 (Ameren 2012b), which is included in 

Table F–5, and was determined to not be cost-beneficial in either the 

baseline evaluation or the uncertainty evaluation. The stated reason for this 

revised evaluation is that Callaway already has an emergency procedure to 

provide backup cooling to the EDGs using onsite fire trucks in the event that 

ESW cooling is lost and therefore the initial SAMA 186 scope, to mitigate all 

ESW failures, duplicates this capability and is not necessary (Ameren 2013a). 

Ameren further explained that all important ESW and CCW loads currently 

have procedures in place to provide backup cooling on loss of these systems 

except the RHR heat exchanger, which is addressed by SAMA 64 

(Ameren 2013b). Based on this information, the NRC staff considers that a 

SAMA to mitigate total failure of ESW by using fire water to carry all ESW 

loads is not necessary and would not be cost-beneficial.

• SAMA 178, “Improvements to UHS cooling tower electrical room HVAC,” was 

added as a Phase II SAMA (Ameren 2012a). The cost-benefit evaluation of 

this SAMA candidate is provided in Table F–5 and was determined to be 

cost-beneficial in both the baseline evaluation and the uncertainty evaluation.

• The implementation cost of SAMA 80, “Provide a redundant train or means of 

ventilation,” was modified to implement procedures to open doors or provide 

temporary ventilation for the EDGs, MDAFW pumps, and charging pumps. 

The revised cost-benefit evaluation of this SAMA candidate is provided in 

Table F–5 and was determined to be cost beneficial in both the baseline 

evaluation and the uncertainty evaluation (Ameren 2012a).

Ameren stated that the 16 potentially cost-beneficial SAMA (11, 29, 64, 80, 160, 162, 178, 179, 

180, 181, 182, 183, 185, 187, 188, and 189) will be entered into Callaway’s long-range plan 

development process for further implementation consideration. Four of the SAMA (180, 181, 

182, and 183) are associated with fire risk and are being implemented as part of the NFPA 805 

F-47
Appendix F

transition application. SAMA 189 is associated with internal flooding risk and is currently being 

implemented at Callaway. All of these SAMA are identified and discussed in Table 9–1 of the 

revised ER, Attachment F (Ameren 2013a).

Given that Ameren’s cost-benefit evaluations have been reviewed by the NRC staff, and that 

Ameren has satisfactorily addressed NRC staff questions regarding the evaluations, the NRC 

staff concludes that the cost-benefit evaluations are of sufficient quality to support the SAMA

evaluation. Therefore, the NRC staff concludes that, with the exception of the potentially 

cost-beneficial SAMA discussed above, the costs of the other SAMA evaluated would be higher 

than their associated benefits.

F.7 Conclusions

Ameren initially compiled a list of 171 SAMA based on a review of: (1) the most significant 

basic events from the plant-specific PRA and insights from the Callaway PRA group and expert 

site panel, (2) insights from the plant-specific IPE and IPEEE, (3) Phase II SAMA from license 

renewal applications for other plants, and (4) the generic SAMA candidates from NEI 05-01. An 

initial qualitative screening removed SAMA candidates that: (1) are not applicable to Callaway 

because of design differences, (2) have already been implemented or have had their intent met 

at Callaway, (3) could be combined with another similar SAMA under consideration, (4) require 

extensive changes that would exceed the maximum benefit, or (5) have very low benefit. Based 

on this screening, 107 SAMA were eliminated leaving 64 candidate SAMA for evaluation. 

For the remaining 64 SAMA candidates, benefit and cost estimates were developed as shown in 

Table F–5. The cost-benefit analyses in the ER showed that none of the SAMA candidates 

were potentially cost-beneficial in the baseline analysis. Nevertheless, Ameren identified two 

potentially cost-beneficial SAMA without estimating the benefit (SAMA 29 and 160). Ameren 

performed additional analyses to evaluate the impact of parameter choices and uncertainties on 

the results of the SAMA assessment. As a result, one additional SAMA was identified as 

potentially cost-beneficial (SAMA 162). In response to NRC staff RAI, Ameren identified and 

evaluated 18 additional SAMA candidates, qualitatively screened 6 of these SAMA candidates, 

and either performed cost-benefit analyses for the remaining 12 SAMA candidates or 

determined these additional SAMA candidates were cost-beneficial without a cost-benefit 

analysis. In response to other NRC staff RAI, Ameren reevaluated several of the initial SAMA 

candidates identified in the ER. As a result of these evaluations, Ameren identified 13 additional 

cost-beneficial SAMA (11, 64, 80, 178, 179, 180, 181, 182, 183, 185, 187, 188, and 189). Four

of these SAMA (180, 181, 182, and 183) are associated with fire risk and are being 

implemented as part of the NFPA 805 transition application. SAMA 189 is associated with 

internal flooding risk and is currently being implemented at Callaway. Ameren has indicated 

that all 16 potentially cost-beneficial SAMA will be entered into Callaway’s long-range plan 

development process for further implementation consideration.

The NRC staff reviewed the Ameren analysis and concludes that the methods used and the 

implementation of those methods was sound. The treatment of SAMA benefits and costs 

support the general conclusion that the SAMA evaluations performed by Ameren are 

reasonable and sufficient for the license renewal submittal. Although the treatment of SAMA for 

external events was somewhat limited, the NRC staff determined that the likelihood of there 

being cost-beneficial enhancements in this area was minimized by improvements that have 

been realized as a result of the IPEEE process, and inclusion of a multiplier to account for 

external events.

Based on the NRC staff’s review of Ameren’s SAMA evaluations, including Ameren’s response 

to NRC staff questions regarding the evaluations, the NRC staff concludes that Ameren has 

F-48
Appendix F

adequately identified areas in which risk can be further reduced in a cost-beneficial manner 

through the implementation of the identified, potentially cost-beneficial SAMA. Given the 

potential for cost-beneficial risk reduction, the NRC staff agrees that further evaluation of these 

SAMA by Ameren is warranted. Additionally, the NRC staff evaluated the 16 potentially costbeneficial SAMA to determine if they are in the scope of license renewal, i.e., they are subject to 

aging management. This evaluation considers whether the systems, structures, and 

components (SSCs) associated with these SAMA: (1) perform their intended function without 

moving parts or without a change in configuration or properties and (2) that these SSCs are not 

subject to replacement based on qualified life or specified time period. The NRC staff 

determined that these SAMA do not relate to adequately managing the effects of aging during 

the period of extended operation. Therefore, they need not be implemented as part of license 

renewal in accordance with Title 10 of the Code of Federal Regulations Part 54, “Requirements 

for renewal of operating licenses for nuclear power plants.”

F.8 References

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Emergency Planning Zone. Appendix G of Radiological Emergency Response Plan (RERP) 

Revision 36. July 2002. Non-publicly available. 

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Document Control Desk, U.S. Nuclear Regulatory Commission. Subject: Docket number 50-483 

Callaway Plant Unit 1, Union Electric Co., Facility Operating License NPF-30, request for

license amendment to adopt NFPA 805, “Performance-based standard for fire protection for 

light water reactor generating plants (2001 edition),” (License Amendment Request 

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number 50-483, Callaway Plant Unit 1, Union Electric Co., Facility Operating License NPF-30, 

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number 50-483, Callaway Plant Unit 1, Union Electric Co., Facility Operating License NPF-30, 

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[Ameren] Ameren Missouri. 2013a. Letter from L.H. Kanuckel, Director Engineering Design, to 

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number 50-483, Callaway Plant Unit 1, Union Electric Co., Facility Operating License NPF-30, 

clarification of responses to SAMA RAIs to the Callaway LRA. January 15, 2013. ADAMS 

No. ML130160235. 

F-49
Appendix F

[Ameren] Ameren Missouri. 2013b. Letter from L.H. Kanuckel, Director Engineering Design, to 

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F-50
Appendix F

[NRC] U.S. Nuclear Regulatory Commission. 1991b. Procedural and Submittal Guidance for the 

Individual Plant Examination of External Events (IPEEE) for Severe Accident Vulnerabilities.

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Consequence, and Risk Integration Analyses. Washington, DC: NRC. NUREG/CR–4551

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Handbook. Washington, DC: NRC. NUREG/BR–0184. 303 p. January 1997. ADAMS 

No. ML050190193. 

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Perspectives on Reactor Safety and Plant Performance. Washington, DC: NRC. NUREG–1560. 

December 1997. ADAMS No. ML063550244, ML063550228, and ML063470259. 

[NRC] Chanin D (Technadyne Engineering), Young ML (Sandia National Laboratories), Randall 

J (U.S. Nuclear Regulatory Commission (NRC)). 1998. Code Manual for MACCS2: User’s

Guide. Washington, DC: NRC. NUREG/CR–6613 SAND97-0594, Volume 1. May 1998. ADAMS 

No. ML110030976. 

[NRC] U.S. Nuclear Regulatory Commission. 1999. Staff Evaluation Report by the Office of 

Nuclear Reactor Regulation Individual Plant Examination of External Events (IPEEE) Union 

Electric Company Callaway Plant, Unit 1, Docket No. 50-483. Washington, DC: NRC. Nonpublicly available.

NRC] Bixler NE, Shannon SA, Morrow CW, Meloche BE (Sandia National Laboratories), 

Ridgely JN (U.S. Nuclear Regulatory Commission (NRC)). 2003. SECPOP2000: Sector 

Population, Land Fraction, and Economic Estimation Program. Washington, DC: NRC. 

NUREG/CR–6525, Revision 1. August 2003. 410 p. ADAMS No. ML032310279. 

[NRC] U.S. Nuclear Regulatory Commission. 2004. Regulatory Analysis Guidelines of the 

U.S. Nuclear Regulatory Commission. Washington, DC: NRC. NUREG/BR–0058, Revision 4. 

September 2004. 56 p. ADAMS No. ML003738939.

[NRC] U.S. Nuclear Regulatory Commission and Electric Power Research Institute. 2005. 

EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities. Rockville, MD: NRC. 

NUREG/CR–6850 / EPRI TR-1011989, Volumes 1 and 2. September 2005. 722 p. ADAMS 

Nos. ML052580075 and ML052580118.

[NRC] U.S. Nuclear Regulatory Commission. 2010a. NRC Information Notice 2010-18: Generic 

Issue 199, “Implications of Updated Probabilistic Seismic Hazard Estimates in Central and 

Eastern United States on Existing Plants.” Washington, DC: NRC. September 2, 2010. 

ADAMS No. ML101970221.

[NRC] U.S. Nuclear Regulatory Commission and Electric Power Research Institute. 2010b. Fire 

Probabilistic Risk Assessment Methods Enhancements, Supplement 1 to NUREG/CR–6850 

and EPRI 1011989. Palo Alto, CA: EPRI. 1019259. September 2010. 155 p. ADAMS 

Nos. ML052580075 and ML052580118.

F-51
Appendix F

[NRC] U.S. Nuclear Regulatory Commission. 2012a. Letter from C. Fells to A.C. Heflin, 

Union Electric Company. Subject: Request for additional information on severe accident

mitigation alternatives for Callaway Plant, Unit 1 (TAC No. ME7716). July 18, 2012. ADAMS 

No. ML12180A022.

[NRC] U.S. Nuclear Regulatory Commission. 2012b. Summary of telephone conference call on 

November 5, 2012, with Union Electric Company, regarding requests for clarification of 

responses to the severe accident mitigation alternatives requests for additional information 

concerning the Callaway Plant, Unit 1, license renewal application (TAC. No. ME7716). 

November 29, 2012. ADAMS No. ML12310A392.

[NRC] U.S. Nuclear Regulatory Commission. 2013. Summary of telephone conference call on 

February 21, 2013, with Union Electric Company, regarding requests for clarification of 

responses to the severe accident mitigation alternatives requests for additional information 

concerning the Callaway Plant, Unit 1, license renewal application (TAC. No. ME7716). 

March 11, 2013. ADAMS No. ML13059A800.

[Union Electric] Union Electric Company. 1992. Letter from D.F. Schnell to NRC Document 

Control Desk. Subject: Docket number 50-483, Callaway Plant individual plant examination. 

September 29, 1992. ADAMS No. ML080150292.

[Union Electric] Union Electric Company. 1995. Letter from D.F. Schnell to NRC Document 

Control Desk. Subject: Docket number 50-483, Callaway Plant response to Generic 

Letter 88-20, Supplement No. 4, individual plant examination of external events (IPEEE). 

June 30, 1995. ADAMS No. ML080150355.

F-52
Appendix G 

DESCRIPTION OF PROJECTS CONSIDERED IN THE CUMULATIVE 

IMPACT ANALYSIS

G.DESCRIPTION OF PROJECTS CONSIDERED IN THE CUMULATIVE 

IMPACTS ANALYSIS

G.1 Description of Projects Considered

To evaluate cumulative impacts, the incremental impacts of the proposed action, as described 

in Sections 4.1 to 4.9, are combined with other past, present, and reasonably foreseeable future 

actions, regardless of what agency (Federal or non-Federal) or person undertakes such other 

actions. The U.S. Nuclear Regulatory Commission (NRC) staff used the information in the 

Environmental Report (ER); responses to requests for additional information (RAI); information 

from other Federal, state, and local agencies; scoping comments; and information gathered 

during the visits to the Callaway Plant, Unit 1 (Callaway) site to identify other past, present, and 

reasonably foreseeable actions. Other actions and projects that were identified during this 

review, and considered in the staff’s independent analysis of the potential cumulative effects, 

are described in Table G–1 and shown on Figure 4–3.

G-1 
Appendix G

Table G–1. Projects and Actions Considered in the Cumulative Impacts Analysis

Project Name Summary of Project Location Status

Callaway Plant Site

Reactor Vessel 

Head 

Replacement

Union Electric Company, a subsidiary of Ameren 

Corporation and doing business as Ameren Missouri 

(Ameren), has future plans to replace the reactor

vessel head during the normal refueling outage for 

Callaway (Number 20), scheduled for October 2014 

(Ameren 2011).

Callaway site Planned for 

2014

Independent 

Spent Fuel 

Storage 

Installation

(ISFSI)

An ISFSI is a complex designed and constructed for 

the interim storage of spent nuclear fuel and other 

associated radioactive material. The existing spent 

fuel pool at Callaway does not have sufficient 

storage capacity to take the plant to the end of its 

current operating license. Ameren’s ER estimated 

that, by 2020, the spent fuel pool will reach capacity. 

An ISFSI is proposed for the plant, although specific 

plans have not been prepared (Ameren 2011).

Callaway site Proposed; time 

frame uncertain

Water Treatment 

and Sediment 

Retention Ponds

The wastewater treatment system at Callaway 

includes the use of sediment retention ponds. 

Ameren estimates the average lifespan of a pond to 

be 6 to 8 years, depending on the amount of silt 

carried by the Missouri River). Ameren estimates 

needing three additional sediment retention ponds 

over the next 20 years (Ameren 2012).

Callaway site Over the next 

20 years, 

Ameren 

anticipates 

construction of 4 

to 5 new 

sedimentation 

(settling) ponds.

Routine 

Transmission 

Line 

Maintenance

Ameren will continue to maintain vegetation in 

transmission line corridors in accordance with their 

“Transmission Vegetation Management Program.” 

Vegetation exceeding height and clearance 

requirements will be controlled using mechanical 

methods (e.g., mowing, cutting) or the application of 

herbicides approved by the U.S. Environmental 

Protection Agency (EPA). 

Callaway 

transmission 

line corridors

Ongoing and 

into the future

G-2 
Appendix G

Project Name Summary of Project Location Status

Energy Projects

Chamois Power 

Plant

The Central Electric Power Cooperative (CEPC) 

operates the Chamois Power Plant, a 73-MW coalfired power plant in Chamois, Missouri (CEPC 2006). 

The power plant is located on the Missouri River, 

approximately 1.5 miles (2.4 km) upstream of the 

Callaway water intake and discharge structures. The 

Chamois plant has one 18-MW coal-fired stoker unit 

and one 55-MW coal-fired cyclone unit 

(CEPC 2012b). There are no plans to close the 

plant, although it is 50 years old and will be affected 

by recent EPA emissions-control requirements.

According to the Missouri Major Water Users Report 

for 2001 to 2005, the plant withdraws roughly 

22 billion gal (83.3 million m3

) per year 

(MDNR 2006). Withdrawal rates have not changed 

significantly since that period (CEPC 2012a). 

Because the plant operates using a once-through

cooling system, the majority of the water extracted 

from the Missouri River for plant cooling is returned 

after treatment (CEPC 2012b).

According to the plant’s Part 70 permit to operate, 

during the 2005 to 2009 time period, the Chamois 

plant released the following:

From 9.7 to 247.7 tons/year of particulate matter 

≤ 2.5 microns.

From 30.2 to 266.0 tons/year of particulate matter 

≤ 10 microns.

From 2,727.9 to 6,044 tons/year of sulfur oxides.

From 2,131.4 to 2,650.1 tons/year of nitrogen oxides.

From 12.8 to 17.6 tons/year of volatile organic 

compounds.

From 67.3 to 89.7 tons/year of carbon monoxide.

From 0.02 to 0.08 tons/year of lead

From 30.4 to 145.1 tons/year of hazardous air 

pollutants.

Air emissions have not changed significantly since 

that period (CEPC 2012a; MDNR 2011).

About 6 mi 

(10 km) south 

of Callaway 

site

Currently 

operational

Generation or 

Transmission 

Expansion

The Midwest Independent Transmission System 

Operator (MISO) projects that the 11-state region it 

services, which includes Missouri, has a surplus of 

electrical power through 2021. Therefore, additional, 

significant, near-term generation or transmission 

projects in the immediate area would be unlikely 

(NERC 2011).

11-state MISO 

service area, 

which includes 

Missouri

Generation and 

transmission 

expansion 

projects are 

unlikely 

according to 

projections 

through 2021

G-3 
Appendix G

Project Name Summary of Project Location Status

Transportation Projects

Callaway County 

Connector

The Missouri Department of Transportation’s 

(MoDOT’s) Callaway County Connector project 

considers improvements to transportation 

infrastructure in central to southeastern Callaway 

County. A component of this project considers 

improving access from Route 54 to the east, 

including worker access to Callaway. Ameren’s 

proposed funding of the improvements to State 

Highway CC and County Road 459 would be 

dependent on plans for construction of a new Unit 2 

reactor (MoDOT 2012a, 2012b).

Central to 

southeastern 

Callaway 

County, from 

Route 54 to the 

Reform 

Conservation 

Area and the 

Callaway site

Potential; time 

frame uncertain

Improvements to 

Interstate 70

The Interstate 70 (I–70) corridor is the primary 

highway in Missouri, connecting the two largest 

cities, St. Louis and Kansas City. The highway was 

designed and built in the 1950s and is in need of 

repair. MoDOT has prepared a final supplemental 

environmental impact statement that selected a 

preferred alternative that included constructing 

truck-only lanes in the center of the highway and 

general-purpose lanes on the outside of the highway 

in rural areas (MoDOT 2009, 2012b).

Northern 

Callaway 

County, about 

10 mi (16 km) 

north of 

Callaway site

Proposed; time 

frame uncertain

G-4 
Appendix G

Project Name Summary of Project Location Status

Other Projects

Missouri River 

Mitigation 

Project, Part of 

the Missouri 

River Recovery 

Program 

(MRRP)

The Missouri River Mitigation Project, part of the 

MRRP, is a U.S. Army Corps of Engineers (USACE) 

project to mitigate for the loss of fish and wildlife 

habitats resulting from the past channelization of the 

Missouri River, extending from Sioux City, Iowa, to 

the confluence of the Missouri and Mississippi rivers 

(USACE 2012c, 2012d). The goal of the project is to 

acquire and restore 166,750 ac (67,481 ha) of land 

throughout four states (Nebraska, Iowa, Kansas, and 

Missouri).

Two mitigation sites are located within 10 river miles 

(RM) (16 river kilometers (RKm)) downstream of the 

Callaway water intake and discharge structures 

(USACE 2012b, 2012c):

(1) Tate Island: a 423-ac (171-ha) site owned by the 

Missouri Department of Conservation (MDC) 

between Missouri RM 110 and 113, about 6 mi 

(10 km) southeast of the Callaway site. The site 

consists of side channels, scrub-shrub wetlands, and 

deciduous forest habitats.

(2) Heckman Island: a two-parcel, 543-ac (220-ha) 

site owned by the USACE between RM 105 and 108, 

about 10 mi (16 km) southeast of the Callaway site. 

The site consists of a number of undeveloped 

habitats including wetlands, forestland, shrubland, 

grassland, and agricultural areas, which will be 

converted to floodplain wetlands.

The overarching MRRP also includes biological 

opinion compliance as part of the Endangered 

Species Act for the pallid sturgeon (USACE 2012a).

Within 10 RM 

(16 RKm) 

downstream of 

the Callaway 

discharge and 

intake; within 6 

to 10 mi (9.7 to 

16 km) 

southeast of 

Callaway site 

Ongoing; time 

frame uncertain

G-5 
Appendix G

Project Name Summary of Project Location Status

Big Muddy 

National Fish 

and Wildlife 

Refuge

The Big Muddy National Fish and Wildlife Refuge 

system is a complex of roughly 11,000 to 16,000 ac 

(4,452 to 6,475 ha) of Missouri River floodplain and 

adjoining habitats spread throughout various portions 

of the Lower Missouri River. The objectives of the 

refuge are to restore portions of the Missouri River 

floodplain, improve and restore wetland habitat, and

improve fishery and wildlife resources. 

The refuge is part of a major migration corridor for 

waterfowl and other migratory birds. Habitat consists 

of bottomland forests, lakes, sloughs, and cropland. 

For the refuge, the U.S. Fish and Wildlife Service

(FWS) performs wetland rehabilitation, reforestation, 

water management, and archaeological resource 

protection. The FWS has approval to acquire an 

additional 60,000 ac (24,281 ha) of similar lands 

between Kansas City and St. Louis, Missouri. The 

closest parcel to the Callaway water intake and 

discharge structure is the St. Aubert Island Unit, an 

operational unit containing over 1,100 ac (445 ha) of 

bottomland, forestland, and grassland (FWS 2008, 

2012).

Northern 

Osage County; 

St. Aubert 

Island Unit is 

about 6 mi 

(9.7 km) 

southwest of 

Callaway site

Ongoing and 

into the future

G-6 
Appendix G

Project Name Summary of Project Location Status

Missouri 

Department of 

Conservation 

Natural and

Conservation 

Areas

The MDC has five state natural and conservation 

areas in the vicinity of the Callaway site and for 

which ongoing and future maintenance activities are 

planned:

(1) Reform Conservation Area: a 6,759-ac 

(2,735-ha) area in Callaway County that Ameren 

bought in the 1970s (to build the Callaway plant) and 

now leases back to the MDC. A 512-ac (207-ha) 

portion of the conservation area, used by Ameren for 

power generating activities, is withheld from public 

use. The Reform Conservation Area contains 

openlands (cropland, pastureland, and other 

grasslands), forest, and woodlands and a small 

portion of the Missouri River floodplain. Ameren has 

a cooperative agreement with the MDC to manage 

the property as a public use area combining fish, 

forest, and wildlife management with public 

recreation (MDC 2012e). 

(2) Auxvasse Natural Area: a 110-ac (44.5-ha) area 

in Callaway County, adjoining the Reform 

Conservation Area. The Auxvasse Natural Area has 

40 ac (16 ha) under glade management and 70 ac 

(28 ha) under woodland and savannah management. 

The area is about 3 mi (5 km) west of the Callaway 

site. The dolomite glades are large and diverse. 

The glade and woodland areas provide habitat for 

over 220 identified plant species (MDC 2012c).

(3) Prairie Fork Conservation Area: a 711-ac 

(288-ha) area in Callaway County, with 320 ac 

(129 ha) under prairie management and 100 ac 

(40 ha) of woodland savannah. The area is about 

8 mi (13 km) north of the Callaway site. The project 

is one of the top five conservation projects in 

Missouri, with over 240 species identified in MDC’s 

plantings (MDC 2012c, 2012d).

(4) Whetstone Creek Conservation Area: a 5,147-ac 

(2,083-ha) area in Callaway County, with 100 ac 

(40 ha) under prairie management, 10 ac (4 ha) 

under glade management, and 950 ac (384 ha) of 

woodland savanna. The area is about 12 mi (19 km) 

north of the Callaway site. The woodlands and 

savannahs are currently undergoing restoration, with 

a focus on selective harvests, timber stand 

improvement, prescribed burning, and exotic species 

control (MDC 2012c).

(5) Danville Conservation Area: a 2,655-ac 

(1,074-ha) area in Montgomery County, of which 

361 ac (146 ha) are a Designated Natural Area. The 

area is about 15 mi (24 km) northeast of the 

Callaway site. The area has 363 native species and 

contains high-quality woodland and glade habitats, 

including the largest high-quality limestone glade 

complex north of the Missouri River (MDC 2012a, 

2012b).

Callaway 

County and

Montgomery 

County; 

maximum of 

15 mi (24 km) 

from Callaway 

site, depending 

on the area

Ongoing and 

into the future

G-7 
Appendix G

Project Name Summary of Project Location Status

Mark Twain 

National Forest

The Mark Twain National Forest consists of 

1.5 million ac (607,000 ha) across 29 southern and 

central Missouri counties. The closest part of the 

national forest to the Callaway site is about 12 mi 

(19 km) to the west. The U.S. Department of 

Agriculture performs active management across the 

national forest, including prescribed burns, wildlife 

habit improvement, watershed improvement, 

protection of rare or endangered species, vegetation 

management, forest and timber management, 

grazing management, enhancement of natural 

communities, land management, and recreation 

management (USDA 2012).

Numerous 

parts of 

Missouri, 

including 

western 

Callaway 

County, about 

12 mi (19 km) 

west of 

Callaway site

Ongoing and 

into the future

G.2 References

[Ameren] Ameren Missouri. 2007. “Ameren Transmission Vegetation Management Program.” 

Fulton, MO: Ameren. 2007. Agencywide Documents Access and Management System 

(ADAMS) No. ML12244A575.

[Ameren] Ameren Missouri. 2011. ”License Renewal Application, Callaway Plant Unit 1, 

Appendix E, Applicant’s Environmental Report, Operating License Renewal Stage.” Fulton, MO: 

Ameren. December 15, 2011. ADAMS Nos. ML1135403490, ML1135403520, and 

ML1135403540.

[Ameren] Ameren Missouri. 2012. “Responses to Environmental RAI Set #1 to the Callaway 

LRA.” Fulton, MO: Ameren. Docket Number 50–483, Callaway Plant Unit 1, Union Electric Co., 

Facility Operating License NPF–30. August 13, 2012. ADAMS No. ML12271A423.

[CEPC] Central Electric Power Cooperative. 2006. “Mission Statement.” May 3, 2006. Available 

at <http://www.cepc.net/mission.htm> (accessed 26 July 2012).

[CEPC] Central Electric Power Cooperative. 2012a. E-mail from M. Stiefermann, Environmental 

and Operations Engineer, Chamois Power Plant, to K. Riley, SC&A. Subject: Chamois Plant 

operations and potential environmental impact. July 19, 2012. 

[CEPC] Central Electric Power Cooperative. 2012b. Teleconference between M. Stiefermann, 

Environmental and Operations Engineer, Chamois Power Plant, and K. Riley, SC&A, on 

Chamois Plant operations and potential environmental impact. July 18, 2012. 

[FWS] U.S. Fish and Wildlife Service. 2008. “Big Muddy National Wildlife Refuge—Midwest 

Region, fact sheet.” May 16, 2008. Available at 

<http://www.fws.gov/midwest/BigMuddy/factsheet.html> (accessed 13 August 2012).

[FWS] U.S. Fish and Wildlife Service. 2012. “Big Muddy National Wildlife Refuge—Midwest 

Region.” May 15, 2012. Available at <http:www.fws.gov/Midwest/bigmuddy/> (accessed 

26 July 2012).

[MDC] Missouri Department of Conservation. 2012a. “Conservation Atlas, Danville Conservation 

Area.” Available at 

<http://mdc4.mdc.mo.gov/applications/moatlas/AreaSummaryPage.aspx?txtAreaID=6507> 

(accessed 13 August 2012).

G-8 
Appendix G

[MDC] Missouri Department of Conservation. 2012b. “Danville Glades.” Available at 

<http://mdc.mo.gov/discover-nature/places-go/natural-areas/danville-glades> (accessed 

13 August 2012). 

[MDC] Missouri Department of Conservation. 2012c. E-mail from Jeff Demand, Wildlife 

Management Biologist, MDC, to Karene Riley, SC&A, regarding conservation projects in the 

vicinity of the Callaway site. August 9, 2012.

[MDC] Missouri Department of Conservation. 2012d. “Prairie Fork Conservation Area.” Available 

at <http://mdc4.mdc.mo.gov/applications/moatlas/AreaSummaryPage.aspx?txtAreaID=9701> 

(accessed 6 November 2012). 

[MDC] Missouri Department of Conservation. 2012e. “Reform Conservation Area.” Available at 

<http://mdc4.mdc.mo.gov/applications/moatlas/AreaSummaryPage.aspx?txtAreaID=7501> 

(accessed 13 August 2012).

[MDNR] Missouri Department of Natural Resources. 2006. “Missouri Major Water Users, 

2001–2005 Water Use Data.” Record number 151300002. Available at 

<http://www.dnr.mo.gov/env/wrc/mwu/measure.pdf#page=253> (accessed 27 July 2012).

[MDNR] Missouri Department of Natural Resources. 2011. “Part 70 Permit to Operate.” Issued 

to Central Electric Power Cooperative—Chamois. Jefferson City, MO: Missouri DNR. Operating 

Permit Number OP2011–035. July 20, 2011. Available at 

<http://www.dnr.mo.gov/env/apcp/permits/centralelectric-chamois2011opf.pdf#page=4> 

(accessed 27 July 2012).

[MoDOT] Missouri Department of Transportation. 2009. “Improve I–70.” Available at 

<http://www.improvei70.org/> (accessed 14 August 2012).

[MoDOT] Missouri Department of Transportation. 2012a. “Callaway County.” Available at 

<http://www.modot.mo.gov/central/major_projects/callaway.htm> (accessed 27 July 2012).

[MoDOT] Missouri Department of Transportation. 2012b. Teleconference between Gayle Unruh, 

Environmental and Historic Preservation Manager, MoDOT, and Karene Riley, SC&A, on 

transportation projects in the vicinity of the Callaway site. July 16, 2012.

[NERC] North American Electric Reliability Corporation. 2011. 2011 Long-Term Reliability 

Assessment. November 2011. Available at <http://www.nerc.com/files/2011LTRA_Final.pdf> 

(accessed 1 August 2012).

[USACE] U.S. Army Corps of Engineers. 2012a. E-mail from N. Bass to K. Riley, SC&A.

Subject: USACE projects in the vicinity of the Callaway site. July 13, 2012.

[USACE] U.S. Army Corps of Engineers. 2012b. Missouri River Recovery Program maps. 

Available at <http://www.moriverrecovery.com/> (accessed 13 August 2012).

[USACE] U.S. Army Corps of Engineers. 2012c. “Mitigation.” Missouri River Mitigation Project, 

addressed as a part of the Missouri River Recovery Program. Available at 

<http://www.moriverrecovery.org/mrrp/f?p=136:133:0::NO:::> (accessed 26 July 2012).

[USACE] U.S. Army Corps of Engineers. 2012d. Teleconference between N. Bass and K. Riley, 

SC&A. Subject: USACE projects in the vicinity of the Callaway site. July 13, 2012.

[USDA] U.S. Department of Agriculture. 2012. “Mark Twain National Forest, Land & Resources 

Management.” Available at <http://www.fs.usda.gov/land/mtnf/landmanagement> (accessed 

13 August 2012).

G-9 

Appendix H 

BIOLOGICAL ASSESSMENT OF THE POTENTIAL EFFECTS 

ON FEDERALLY LISTED PALLID STURGEON FROM 

THE PROPOSED LICENSE RENEWAL FOR 

THE CALLAWAY PLANT, UNIT 1

H.BIOLOGICAL ASSESSMENT OF THE POTENTIAL EFFECTS ON 

FEDERALLY LISTED PALLID STURGEON FROM 

THE PROPOSED LICENSE RENEWAL FOR THE 

CALLAWAY PLANT, UNIT 1 

H.1 Introduction and Purpose

The U.S. Nuclear Regulatory Commission (NRC) prepared this biological assessment in 

conjunction with the draft supplemental environmental impact statement (DSEIS) for the 

renewal of the operating licenses for the Callaway Plant, Unit 1 (Callaway), located on the 

northern shore of the Missouri River about 10 mi (16 km) southeast of the city of Fulton, 

Callaway County, Missouri. The current 40-year license expires in October 2024. The 

proposed license renewal period, for which this biological assessment has been prepared, 

would begin with the granting of the renewed license and extend until October 2044.

In accordance with Section 7 of the Endangered Species Act of 1973, as amended 

(16 U.S.C. 1531 et seq., herein referred to as the ESA), the NRC staff requested in a letter 

dated April 20, 2012, (NRC 2012) that the U.S. Fish and Wildlife Service (FWS) provide 

information on Federally listed endangered or threatened species, as well as on proposed or 

candidate species, and on any designated critical habitats that may be located near Callaway. 

In reply by e-mail on September 10, 2012, the FWS (2012) identified two Federally listed 

species that may occur on the project site: pallid sturgeon (Scaphirhyncus albus) and Indiana 

bat (Myotis sodalis). Under Section 7, the NRC is responsible for providing information on the 

potential impact that the continued operation of Callaway could have on Federally listed 

endangered or threatened species. This biological assessment concerns the effects that 

ongoing operation of Callaway would have on the endangered pallid sturgeon. The assessment 

for Indiana bat, which is shorter, is included in the main body of this SEIS.

H.2 Proposed Action

The proposed action considered is whether or not to renew the Callaway license for an 

additional 20 years beyond the period of the existing license. The NRC has prepared this 

biological assessment at this time because of its Federal action and its obligation to protect 

endangered species under the ESA. 

If the NRC grants the operating license renewal, Union Electric Company, a subsidiary of 

Ameren Corporation and doing business as Ameren Missouri (Ameren), can operate and 

maintain the nuclear unit, the cooling system, and the transmission lines and corridors as they 

are now until 2044. If the NRC does not grant the license renewal, the present operating 

license would allow Callaway to operate through 2024.

H.3 Site Description

Callaway is located in Callaway County, approximately 10 mi (16 km) southeast of Fulton, 

Missouri, and 80 mi (129 km) west of St. Louis, Missouri. The state capital, Jefferson City, is 

approximately 25 mi (40 km) southwest of the site, and the Missouri River flows 5 mi (8.0 km) 

south of the site. Figure H–1 (Figure 2–2 in the DSEIS) shows the plant with a 50-mi (81-km) 

radius.

H-1 
Appendix H

Figure H–1. Location of the Callaway Plant, Showing a 50-Mile Radius

H-2 
Appendix H

Callaway is a single-unit nuclear power plant that began commercial operation on 

December 19, 1984. The Callaway site encompasses approximately 7,354 ac (2,976 ha). 

Figure H–2 (Figure 2–3 of the DSEIS) shows the Callaway site layout and property boundary. 

The property is comprised of three main areas:

(1) The first area is the 2,765-ac (1,119-ha) power plant site area containing the major 

power generation facilities, which include the following: the containment building and 

related structures; a natural draft cooling tower; a switchyard; the ultimate heat sink 

retention pond and cooling tower; a water treatment plant; and administration 

buildings, warehouses, and other features. The majority of these facilities are 

located on about 512 ac (207 ha) of the 2,765-ac (1,119-ha) plant site area. Ameren 

planned to build a Callaway Unit 2 near the Unit 1 reactor and submitted a combined 

license application (COLA) to the NRC in 2008. In 2009, Ameren suspended its 

efforts to build the new Unit 2 because of financial and legislative complications. 

After initiating licensing for Unit 2, Ameren started excavation for the new reactor, 

and the excavation still exists at the site (Ameren 2011).

(2) The second area is a 2,135-ac (865-ha) corridor area containing the intake and 

blowdown pipelines between the plant and the river intake structure.

(3) The third area comprises 2,454 ac (993 ha) that are not used for power generation.

Of the total 7,354 ac (2,978 ha), Ameren has made available approximately 6,300 ac 

(2,550 ha)—known as the Reform Conservation Area—for public access. The Missouri 

Department of Conservation (MDC) manages the conservation area (Ameren 2011).

The potential effects of Callaway on pallid sturgeon occur through operation of the cooling and 

auxiliary water systems. The following description of these systems is based on information 

provided by Ameren (2011, 2012).

The cooling water intake structure lies on the northern shore of the Missouri River. The river 

water enters the intake structure through one of three bays oriented perpendicular to the river 

(Figure H–3). The water then passes through vertical trash racks designed to stop large objects 

and debris from entering. The vertical trash racks are made of 0.5-in. (1.3-cm) bars that allow 

only objects smaller than 0.5 in. (1.3 cm) to pass into the structure. Each pump bay has a 

vertical traveling screen of 0.5-in (1.3-cm) mesh with an automatic spray wash. Traveling 

screens typically rotate for 30 minutes every 8 hours. The intake velocity at the traveling screen 

is 0.307 feet per second (fps) 9 cm/s) based on a normal flow of 9,000 gallons per minute (gpm) 

(34 cubic meters per minute) and a normal water level of 16 ft (4.8 m) of water in the pump bay. 

The highest theoretical velocity is 0.595 fps (18 cm/s) and is based on maximum pump flow and 

low river water levels. Each bay has a fish escape opening in the side wall, but traveling 

screens have no fish return system to return impinged fish back to the river after being washed 

off the screens. Electric boilers and electric heaters provide warmed water to the intake 

structure for freeze protection in winter.

H-3 
Appendix H

Figure H–2. Callaway Plant Site Layout and Property Boundary

H-4 
Appendix H

Figure H–3. Cross-Section of the Callaway Plant Intake Structure Showing Trash Racks, 

Traveling Screens, and Fish Escape Gates

Source: Union Electric Company 1986

Water is pumped from the intake structure through pipeline to the water treatment plant, which 

is located about 5.5 mi (8.9 km) on the southeastern side of the plant. Because of the high 

levels of suspended solids in the Missouri River, the water treatment plant treats the river water 

to reduce the suspended solids before providing makeup water to the circulating water system 

and cooling tower. Suspended solids are removed in three clarifiers using flocculants; when 

necessary, sodium hypochlorite (bleach) and a molluscicide are also added. The water 

treatment plant used bleach during the summer when temperatures exceed 60 °F (16 °C); the 

bleach is added at a ratio of 200 gal (757 L) per clarifier per week. The water treatment plant 

uses molluscicide once every three weeks when the river temperature exceeds 60 °F (16 °C) in 

spring through June and again starting in September. Additionally, the water is treated with a 

coagulant aid, which is added during the winter when the temperature is less than 40 °F (4 °C) 

and only when red colloidal clay is present. A cationic polymer is added for water clarification. 

Sludge removed from the clarifiers of the water treatment plant is pumped to two settling ponds. 

There are currently four settling ponds, but two are filled with sediment and have no additional 

H-5 
Appendix H

capacity to receive sludge. Following completion of settlement, the supernatant from the 

settling ponds is recycled back to the head end of the water treatment plant. The four existing 

ponds, inclusive of those that are at capacity, total approximately 30 ac (12 ha) and support 

aquatic and terrestrial wildlife. There are no changes planned for the current settling ponds, but 

additional ponds would be required if NRC were to grant a 20-year license extension. Following 

treatment, the makeup water is pumped to the cooling tower.

Waste heat from normal operations is removed using a 555-ft (169-m)-high hyperbolic, naturaldraft cooling tower. As a result of evaporation and drift from the cooling tower, the dissolved 

solids concentrate in the water of the circulating water system. To prevent the precipitation of 

salts in the system circuit, some water is discharged to the Missouri River a short distance 

downstream of the intake structure on the river. The National Pollutant Discharge Elimination 

System (NPDES) Permit for Callaway stipulates that the discharge must not cause the 

temperature of the mixing zone (or the area where the discharged water meets and mixes with 

the river) to increase by more than 5 °F (3 °C) (MDNR 2010).

All plant outfalls except one connect into a single pipeline that discharges to the Missouri River 

immediately downstream of the surface water intake structure. The average daily discharge to 

the Missouri River is 7.5 cubic feet per second (cfs) (0.2 m3

/s), while the maximum daily 

permitted discharge is 25 cfs (0.71 m3

/s) (MDNR 2010b). Based on the daily average discharge 

rate of 7.5 cfs (0.2 m3

/s), Callaway replaces approximately 13 percent of the plant’s daily 

maximum water withdrawal of 56 cfs (1.6 m3

/s) to the river.

Because of the extensive treatment, no entrained organisms would survive passage through the 

cooling water system.

H.4 Status Review of Pallid Sturgeon

H.4.1 Life History

Sturgeons are members of an order of fish (Acipenseriformes) that probably evolved in the 

Devonian age. Living members of this order in North America include the paddlefish and eight 

sturgeon species. The paddlefish Polyodon spathula and three sturgeon species, the lake 

sturgeon Acipenser fulvescens, pallid sturgeon Scaphirhynchus albus, and the shovelnose 

sturgeon S. platorynchus, live in the Missouri and Mississippi Rivers. In the past, commercial 

fishermen harvested all three of the sturgeon species in the Missouri and Mississippi Rivers. 

Today pallid sturgeon is a Federally listed endangered species. The life history information 

below is from Dryer and Sandvol (1993) and the FWS (2007) if not otherwise cited.

Pallid sturgeon have a flattened snout, a long tail, and rows of bony armor plates. The upper 

side is convex and the lower side is straight. They have an inferior (bottom-facing) mouth and 

eat invertebrates, such as the immature stages of insects, and fish. The body shape is well 

adapted to swimming close to the bottom of relatively fast flowing, large rivers. The diet, inferior 

mouth, and barbels in front of the mouth are well adapted to feeding on or near the bottom in 

highly turbid environments. 

The FWS listed pallid sturgeon as endangered in 1990 (55 FR 36641). The historic abundance 

of pallid sturgeon is somewhat vague since biologists did not recognize it as a separate species 

from shovelnose sturgeon until 1905, but its historical range probably extended from the middle 

and lower Mississippi River in the south up through the Missouri River and lower reaches of the 

Platte, Kansas and Yellowstone Rivers in the north and west. The pallid sturgeon is one of the 

largest fish species in those rivers. Available information suggests that the pallid sturgeon was 

not a common species since the time of European settlement. Today, pallid sturgeon are 

H-6 
Appendix H

among the rarest fish of the Missouri and Mississippi River basins, and the present range 

includes the States of Montana, North and South Dakota, Nebraska, Iowa, Kansas, Missouri, 

Illinois, Kentucky, Arkansas, Mississippi, and Louisiana. The populations are largely older fish 

that will die off in the near future.

Fisheries biologists know little about pallid sturgeon reproduction or even preferred spawning 

habitats and conditions. Hurleya et al. (2004) tracked sonically tagged pallid sturgeon in the 

Mississippi River and found that they exhibited positive selection for the main-channel border, 

downstream island tips, between-wing-dam, and wing-dam-tip habitats and negative selection 

for main-channel, downstream of wing dams, and upstream of wing dam habitats. The sturgeon 

exhibited little habitat selection for temperature or dam discharge. The authors concluded that 

habitat enhancement and restoration of habitat diversity might be necessary for recovery of 

pallid sturgeon.

Reports of pallid sturgeon reproduction are rare. The U.S. Geological Survey (USGS 2007), the 

Nebraska Game and Parks Commission, and the U.S. Army Corps of Engineers confirmed 

spawning of two female pallid sturgeon in the upstream reaches of the lower Missouri River in 

May 2007. Hrabik et al. (2007) found that the capture of young pallid sturgeon that would verify 

natural reproduction is also rare: none were captured between capture of a single 4-year-old 

fish in 1978 and a Mississippi River trawl survey in 1998 through 2000 using equipment 

designed to capture larval fish in deep, turbulent water. That study concluded that those latest 

captures verified reproduction, possibly from the lower Missouri River to the upper and lower 

Mississippi River, although they also found no evidence of recruitment of pallid sturgeon 

because they captured no juveniles after 374 trawl hauls that captured over 21,735 fish in that 

1998–2000 survey. Wildhaber et al. (2007) suggest that one or more of the following factors 

may be responsible for the difficulty in finding larval pallid sturgeon or evidence of recruitment: 

 lack of successful spawning,

 low recruitment,

 high mortality,

 ineffective sampling methods,

 inadequate sampling of drift and settling locations, or

 rapid dispersal and washout of sturgeon larvae in the Missouri and 

Mississippi Rivers.

Pallid sturgeon larvae are indistinguishable from those of the congeneric shovelnose sturgeon, 

which may also help to explain the paucity of reported collections in the past. Also, the 

construction of dams and other structures with resulting habitat change and the elimination of 

shallow areas in the river with little or no flow have probably deprived sturgeon of critical nursery 

areas needed for the survival of immature sturgeon (MDC 2009).

Larval pallid and shovelnose sturgeon become strongly photopositive and migrate upwards 

toward the light starting the first day after hatching. As a result, they remain far above the 

bottom, even at the water surface, and migrate far downriver (Kynard et al. 2002). Cultured 

yearling pallid sturgeon in laboratory studies also migrate downstream during summer and fall, 

which suggests a two-stage (larval, then yearling) downriver migration in the first year of life. 

Adult sturgeon are also highly migratory and often migrate hundreds of miles in a year.

The young of both shovelnose and pallid sturgeon eat invertebrates, but as pallid sturgeon 

grow, they become more piscivorous. Gerrity et al. (2006) found that the diet of juvenile pallid 

sturgeon between the ages of 6 and 7 was mostly fish, compared to the diet of shovelnose 

sturgeon, which is mainly aquatic insects. Sturgeon chub (Macrhybopsis gelida) and sicklefin 

H-7 
Appendix H

chub (M. meeki) together comprised 79 percent of the number of identifiable fish in juvenile 

pallid sturgeon stomachs. Populations of these two cyprinid minnows have declined throughout 

much of the Missouri River because of the construction of dams and other human-made 

alterations of river habitat, and the State of Nebraska lists sicklefin chub as threatened and 

sturgeon chub as endangered. While the population of the piscivorous pallid sturgeon has 

declined in the Missouri and Mississippi Rivers, the population of its similar, insectivorous 

congener, shovelnose sturgeon, has not declined. Gerrity and Guy (2006) concluded that the 

prevalence of sicklefin chub and sturgeon chub as a food resource of juvenile pallid sturgeon 

may help explain the decline of pallid sturgeon populations and that recovery and management 

of native cyprinids is a potentially important step in the recovery of pallid sturgeon.

Male pallid sturgeon are believed to mature at 7 to 9 years, after which they spawn at intervals 

of 2 to 3 years. Females may reach sexual maturity at 7 to 15 years and spawn at intervals up 

to 10 years. Individuals may reach ages of 60 years or more and reach lengths of 6 ft (2 m). 

Like many other fish species, the largest individuals are found farthest north in the species’ 

range and maximum size decreases as it goes southward. For example, the maximum weight 

of pallid sturgeon is 39 kg (86 lb) in the upper Missouri River in Montana and North Dakota, 

21 kg (46 lb) in the Missouri River in South Dakota and Nebraska, and 12 kg (26 lb) in the 

Mississippi River. They become much larger than shovelnose sturgeon, which rarely weigh 

more than 8 lb (4 kg).

H.4.2 Status of Pallid Sturgeon in the Missouri River

While pallid sturgeon were successful in the historical Missouri and Mississippi Rivers, with the 

high flow and turbidity and diverse habitats of floodplains, backwaters, chutes, sloughs, islands, 

sand and gravel bars, and both braided and main channels, they are not so well adapted to the 

Missouri and Mississippi Rivers of today, with the construction of dams that have isolated 

subpopulations, promoted channelization, controlled flow, and eliminated habitat diversity. The 

FWS (2007) concludes that human activities have harmed all of the 3,350 mi (5,390 km) of river 

habitat within their range, and habitat alteration and loss may be the biggest threat to their 

existence. Other threats may include hybridization with shovelnose sturgeon, commercial 

fishing, and exposure to environmental contaminants such as polychlorinated biphenyls, 

cadmium, mercury, selenium, chlordane DDT, DDE, and dieldrin, all of which have been found 

in pallid sturgeon tissue in the past.

During the early 1990s, the MDC developed “action plans” for lake and pallid sturgeon a goal of 

reestablishing self-sustaining populations so they can be delisted as endangered species and 

ultimately provide limited sport fisheries. These plans stress the restoration of both species 

through habitat improvement, artificial propagation, protection, research, management, and 

education (MDC 2009). As part of this effort, the MDC’s Blind Pony Fish Hatchery has raised 

and stocked over 13,000 fingerling pallid sturgeon and 200,000 fingerling lake sturgeon into the 

Missouri and Mississippi Rivers (MDC 2009). In addition to these efforts, the U.S. Geological 

Survey (Wildhaber et al. 2007) has developed a conceptual life history to organize the 

understanding about the complex life history of Scaphirhynchus sturgeons and improve 

understanding of the effects of management actions on the ecological requirements of pallid 

and shovelnose sturgeons. The FWS’s Pallid Sturgeon Recovery Plan 

(Dryer and Sandvol 1993) designated six recovery priority management areas (RPMAs) for 

implementation of recovery tasks, and Callaway is located within RPMA 4.

H-8 
Appendix H

H.4.3 Effects Assessment of Callaway Nuclear Plant on Pallid Sturgeon

H.4.3.1 Past Direct Evidence of Impingement, Entrainment, and Thermal Effects

Callaway began commercial operation in December 1984. From that time until the present, 

direct observations of entrainment, impingement, or thermal effects are lacking. 

Ichthyoplankton entrainment rates were estimated from hydraulic entrainment rates (plant 

withdrawal rate divided by flow past the plant) and estimated ichthyoplankton densities from 

weekly 0.5 m diameter conical 0.570 micron mesh net collections from April 1 through 

September 23, 1984 (Union Electric Company 1986). Pallid sturgeon were not reported in the 

net collections. The estimated rate of ichthyoplankton entrainment was less than 0.2 percent of 

transport past the plant, with a worst-case estimate that does not exceed 0.75 percent (Union 

Electric Company 1986). The NRC (2012a) recently found that in low-flow conditions, the 

hydraulic entrainment rate is about 0.9 percent.

Fish impingement on intake screens and corresponding pump flow rates were monitored for one 

year from February 1985 through January 1986. Once a week on a randomly assigned day, 

fish impingement was monitored by diverting traveling screen wash flow in troughs to a 

collection basket constructed of 0.5-in square mesh identical to that on the traveling screens 

during a 24-hour collection period from 8 a.m. to 8 p.m. No pallid sturgeon were collected in the 

51 weekly samples (Union Electric Company 1986).

The studies that would provide direct evidence, including fish studies of river populations, 

entrainment, and impingement at Callaway, date from the 1980s. Since that time, however, the 

population of pallid sturgeon has increased. Hatchery-reared pallid sturgeon have been 

released into RPMA 4 since 1992; the population of fish over 1 year of age in the lower Missouri 

River has increased, as measured by a gill net sampling program from 2006 through 2008, and 

the age structure of the population is improving (Missouri River Recovery Program 2012). Even 

though studies performed in the 1980s and before did not provide direct evidence of the 

adverse effects to pallid sturgeon, the present and projected population increase because of 

recovery projects increases the chance that young pallid sturgeon are and will be subject to 

entrainment, impingement, and thermal effects during the renewed licensing period, which 

would be from the date of issuance through October 2044, or about 32 years.

H.4.3.2 Pelagic Larvae

Callaway’s cooling water intake is located on the north shore of the Missouri River at river 

mile 115.4 (Ameren 2011). River miles are measured from the mouth of the river to its origin. 

DeLonay et al. (2012) have confirmed that pallid sturgeon spawning has occurred about 

85 miles upriver of the plant between river mile 202.0 and 202.4. That study also noted that in 

the lower Missouri River spawning typically occurs from the end of April through May. After 

hatching, larval pallid sturgeon drift downstream and transition from pelagic to benthic life 

stages for 11 to 17 days, during which time they may drift from 245 to 530 km (394 to 853 mi) 

downstream (Braaten et al. 2008). These findings indicate that larval pallid sturgeon spawn 

upstream and drift past Callaway in the pelagic stage and perhaps in the benthic stage.

The transition from pelagic to benthic behavior occurs at larval lengths of 18.1 to 20.3 mm 

(about 0.7 to 0.8 in.) (Braaten et al. 2008). The traveling screens at Callaway are made of 

0.5-in. square mesh screens (Ameren 2012). If entrained, pallid sturgeon larvae in the pelagic 

stage would pass through the screens and be killed in the cooling water system. Although 

larvae in the benthic stage might be impinged on the screens if their long dimension was at right 

angles to the screens, fish larvae in nets are typically extruded through nets head first, and the 

NRC staff expects that most benthic stage larvae would also pass through the screens and be 

H-9 
Appendix H

killed. As stated above, traveling screens typically rotate for 30 minutes every 8 hours, during 

which time pallid sturgeon larvae that might be impinged on the screens would probably 

suffocate or die of injuries.

In a conversation between NRC and FWS staff (E & E 2012), the FWS stated that studying the 

effect of cooling water intake on pallid sturgeon is difficult because one cannot easily distinguish 

between shovelnose sturgeon and pallid sturgeon and is more difficult if only body parts are

collected from intake screens. The FWS further explained that very few, if any, larval pallid 

sturgeon have been identified in the lower Missouri River, and that even with the use of DNA 

sampling techniques, no pallid sturgeon have been identified out of 600 sturgeon larvae 

collected over the past 5 years. 

The lack of identified pallid sturgeon larvae in experimental collections should not be surprising 

because of the rarity of the species and the extremely low volume of experimental collections 

compared to Missouri River flow. As stated above, multiple factors may explain the difficulty in 

finding larval pallid sturgeon or evidence of recruitment (Wildhaber et al. 2007). French et al. 

(2010) found that vulnerability of age-0 pallid sturgeon to predation by channel catfish and 

smallmouth bass is low in laboratory studies, especially in the presence of alternative prey. 

Even so, other predatory species inhabit the lower Missouri River and might prey on young 

pallid sturgeon.

H.4.3.3 Benthic Larvae and Juveniles

Pallid sturgeon remain in the benthic larval stage (“metalarvae”) until complete metamorphosis, 

which occurs at least at 200 mm (8 in.) in total length (Snydor 2002). Juvenile shovelnose 

sturgeon (5–21 cm (2–8 in.)) have been collected in the Mississippi River in main channel 

border areas where river velocities over the bottom range from 20 to 80 cm/s (0.7 fps to 2.6 fps) 

(Adams et al. 2003). Such velocities are higher than the intake through-screen velocity at 

Callaway.

Ameren (2012) reports that the “[i]ntake velocity at the traveling screen at a normal flow of 

9000 gpm and a normal water level of 16’ [ft] of water in the pump bay was calculated to be 

0.307 fps.” This velocity is close to that predicted by the NRC (1975). Intake velocity through 

the traveling screens varies according to river flow, which affects water depth at the intake, and 

may range up to 0.6 fps (18 cm/s) (Ameren 2012).

Adams et al. (1999) observed that juvenile pallid sturgeon exhibit three swimming behaviors to 

maintain station. Pelagic or free swimming is infrequent and occurs in mid-water column. 

Skimming, performed by propulsion from the body and caudal (tail) fin undulation with the 

ventral body surface in contact with the bottom, occurs frequently. Juvenile pallid sturgeon may 

also appress themselves to the bottom using negative lift from downturned pectoral fins and 

maintain station without body or caudal fin undulation.

The swimming speed that fish can endure varies with the length of the fish and water 

temperature. Adams et al. (1999) reported sustained swimming speeds of two length groups of 

pallid sturgeon at 19 °C (66 °F): the larger (17.0–20.5 cm fork length (FL) (6.69–8.07 in. FL) 

has a sustained swimming speed of less than 30 cm/s and the smaller (13.0–16.8 cm FL 

(5.12–6.61 in. FL)) of less than 15 cm/s. For pallid sturgeon of about 20 cm, Adams et al. 

(2003) found that the critical swimming speed decreased with decreasing temperature from 

33.93 cm/s at 20 °C to 15.05 cm/s at 10 °C (13.36 in/s at 68 °F to 5.93 in/s at 50 °F). These 

numbers suggest that benthic pallid metalarvae sturgeon swimming close to the intake may not 

be able to avoid impingement or entrainment. 

Post-larval juvenile pallid sturgeon may be able to swim against the intake current, avoid the 

intake screens, and escape through fish escape openings along the side of the intake structure 

H-10
Appendix H

(Ameren 2012). They may be able to move downstream past the plant by appressing 

themselves to the bottom or skimming. In a conversation between NRC and FWS staff 

(E & E 2012), the FWS stated that a juvenile pallid sturgeon had recently been captured during 

impingement and entrainment studies at a power plant in Iowa on the Lower Missouri River. 

Although some juvenile pallid sturgeon might be impinged at Callaway, at some point early in 

the juvenile life stage, pallid sturgeon should become strong enough swimmers to avoid 

impingement.

H.4.3.4 Trophic Considerations

The diet of juvenile pallid sturgeon changes as the fish grow. In the first year of life, the diet of 

young-of-the-year pallid sturgeon is comprised of insects in the aquatic life stages, particularly 

Diptera (fly) larvae, Diptera pupae, and Ephemeroptera (mayfly) nymphs (Braaten et al. 2012). 

Young juveniles less than about 600 mm (23.6 in.) “FL rely on macroinvertebrates, primarily 

insect larvae, as their primary prey; however, at ages of 5 to 7 years and lengths above 600 mm 

FL, juvenile and adult pallid sturgeon become piscivorous and prey primarily on native minnow 

(cyprinid) species, although insect larvae remain an important part of the diet 

(Grohs et al. 2008).

As stated above, Gerrity et al. (2006) found that cyprinid minnows, primarily sturgeon chub and 

sicklefin chub, constitute an important part of the diet of juvenile hatchery-reared pallid sturgeon 

between the ages of 6 and 7 and captured from the Missouri River above Fort Peck Reservoir, 

Montana. While these two cyprinids have declined throughout much of the Missouri River, they 

have been increasing in the lower Missouri River, where Callaway is located. Gerrity et al. 

(2006) speculate that the severed trophic links might partially explain the decline of pallid 

sturgeon. Human alterations to habitats (e.g., damming, channeling) in much of the Missouri 

River have harmed sicklefin chub and sturgeon chub populations. Where these two species are 

rare, pallid sturgeon ages 2 through 9 feed opportunistically on other fish species, including 

johnny darters (Etheostoma nigrum), young channel catfish (Ictalurus punctatus), and other 

cyprinid minnows (Grohs et al. 2008). Juvenile pallid sturgeon also consume other fish species; 

insects, including Chironomidae (nonbiting midges), mayflies, Trichoptera (caddisflies), and true 

fly larvae; and detritus (Gerrity et al. 2006, Grohs et al 2008).

Callaway entrains and impinges fish species that are prey of pallid sturgeon (Union Electric 

Company 1986). Samples of macroinvertebrates drifting with the current past the plant also 

include those taxa preyed on by pallid sturgeon (CDM 1981). Because the plant withdraws less 

than 1 percent of the Missouri River flow past the plant, any effects on pallid sturgeon through 

the food web are likely to be insignificant.

H.4.3.5 Cumulative Analysis

Human activities that transformed the ever-changing habitat of floodplains, backwaters, chutes, 

sloughs, islands, and main channels of this large river ecosystem into a series of 

impoundments, regulated flows, and controlled channels have harmed the pallid sturgeon 

population in the Missouri and Mississippi Rivers. The FWS (1993) listed habitat destruction 

and loss, commercial harvest, and pollution and contaminants among the reasons for decline in 

the population. The FWS noted also that habitat elements that have changed because of 

human modification include river morphology, hydrology, temperature regime, cover, and 

transport of sediment and organic matter. In a separate publication, the FWS (55 FR 36641) 

found that of the approximately 5,725 km (3,550 mi) of the pallid sturgeon’s former habitat, 

virtually all of it has been drastically altered, with 51 percent being channelized, 28 percent 

impounded, and the remaining 21 percent affected by upstream impoundments and altered flow 

regimes. These changes have also harmed populations of smaller native fish, such as sturgeon 

chub and sicklefin chub, that are the primary prey of juvenile and adult pallid sturgeon, thus 

H-11
Appendix H

severing the food web to pallid sturgeon (Gerrity et al. 1996) in a process ecologists sometimes 

term bottom-up trophic cascade. The hot summer of 2012 caused the Missouri River to heat to 

temperatures that killed about 40,000 shovelnose sturgeon and many pallid sturgeon in Iowa 

(Schulte 2012), and climate change may make such adverse thermal effects in the Missouri 

River more common in the future. Dams have blocked migration routes and segmented the 

population (FWS 1993), increasing the extinction probabilities of the now smaller, isolated 

populations.

The U.S. Army Corps of Engineers, in accordance with a biological opinion (BO) issued by the 

FWS, is undertaking the design, implementation, and maintenance of a number of restoration 

projects on the Missouri River and within its floodplain. One goal of these projects is to improve 

habitats for the least tern (Sternula antillarum), piping plover (Charadrius melodus), and pallid 

sturgeon. The ultimate goal is to restore and acquire for permanent easement over 166,000 ac 

(67,000 ha) of land throughout the four states of the lower Missouri River (Nebraska, Iowa, 

Kansas, and Missouri). Two projects near Callaway, Tate Island (423 ac (171 ha)) and 

Heckman Island (543 ac (220 ha)), are designed to preserve and restore existing side-channel, 

wetland, riparian, and adjoining lands. These actions will provide some level of benefit to the 

Missouri River aquatic ecosystem. In addition, a number of land preservation or restoration 

activities are planned with the expansion of the Big Muddy National Wildlife Refuge and a 

number of MDC Natural/Conservation Areas. Both of these projects would involve restoring and 

preserving portions of the lower Missouri River’s aquatic ecosystem and should provide some 

level of benefit to pallid sturgeon near Callaway.

H.5 Conclusion

The past operation of Callaway may have had little, if any, effect on pallid sturgeon because of 

their rarity. Pallid sturgeon population in the lower Missouri River has been increasing because 

of projects such as restocking and should continue to increase because of further restocking, 

maturation and reproduction of stocked fish, and improved habitat from habitat restoration

projects. The recent and projected growth of the pallid sturgeon population in the lower 

Missouri River increases the chance that young pallid sturgeon are, and will continue to be, 

harmed by operation of Callaway. The recent identification of a spawning site upstream of 

Callaway and life history information indicating that larval and juvenile pallid sturgeon may drift 

past the plant suggests that the young may be subject to entrainment and impingement

because of operation of Callaway’s cooling water system. The extensive intake water treatment 

and closed cycle cooling water system would kill entrained fish. The lack of a fish return system 

from the traveling screens would result in the death of impinged fish. Such adverse effects may 

occur at present and would continue through 2044, a period of over 3 decades, if the operating 

license was renewed, and through 2024 if the license was not renewed.

Some lethal takes of pallid sturgeon because of plant operation over this period are probable 

and most likely inevitable. The NRC staff cannot confirm such takes because the plant does not 

monitor entrainment and impingement for endangered fish species. Seasonal monitoring of 

entrainment and impingement would be necessary to quantify present and future levels of pallid 

sturgeon takes. The Callaway action area is a small portion of the species’ river habitat of 

approximately 5,725 km (3,550 mi) (55 FR 36641). Because of the dams, the pallid sturgeon 

population is segmented, and any effect of Callaway would not affect population segments 

upriver of the Gavins Point Dam.

Within the action area, Callaway diverts less than 1 percent of the flow past the plant, and, 

under the assumption that entrainment and impingement of pallid sturgeon larvae and juveniles 

is about equal to hydraulic entrainment, the plant would entrain and impinge less than 1 percent 

H-12
Appendix H

of the larvae and juveniles drifting by the plant. At some point early in the juvenile life stage, 

changes in behavior and size would allow the young pallid sturgeon to escape the intake and 

adverse effects. Even with an increasing pallid sturgeon population size, the increasing number 

of future lethal takes through entrainment of impingement should be small and discountable and 

not affect population segments above Gavins Point Dam.

The NRC staff concludes that the present and future operation of the Callaway plant through 

2044 may affect, but is not likely to adversely affect, the continued existence of, pallid sturgeon, 

and that any adverse effects would accrue primarily through direct mortality because of 

entrainment and impingement of larvae and juveniles.

H.6 References

55 FR 36641. U.S. Fish and Wildlife Service. Endangered and threatened wildlife and plants; 

determination of endangered status for the pallid sturgeon. Federal 

Register 55(173):36641–36647. September 8, 1990.

Adams SR, Adams GL, Parsons, GR. 2003. Notes: Critical swimming speed and behavior of 

juvenile shovelnose sturgeon and pallid sturgeon. Transactions of the American Fisheries 

Society 132:392–397.

Adams SR, Hoover, JJ, Killgore, KJ. 1999. Swimming endurance of juvenile pallid sturgeon 

(Scaphirhynchus albus). Copeia 1999(3):802–807.

[Ameren] Ameren Missouri. 2011. License Renewal Application, Callaway Plant Unit 1, 

Appendix E, Applicant’s Environmental Report, Operating License Renewal Stage. Fulton, MO:

Ameren. December 15, 2011. Agencywide Documents Access and Management System 

(ADAMS) Nos. ML113540349, ML113540352, and ML113540354.

[Ameren] Ameren Missouri. 2012. Responses to Environmental RAI Set #1 to the Callaway 

LRA. Fulton, MO: Ameren. Docket Number 50-483, Callaway Plant Unit 1, Union Electric Co., 

Facility Operating License NPF–30. August 13, 2012. Enclosure 5, “Evaluation of Cooling Water 

Intake Impacts on the Missouri River,” Revision 4, July 1986. 

Braaten PJ, Fuller DB, Lott RD, Haddix TM, Holte LD, Wilson RH, Bartron ML, Kalie JA, 

DeHaan PW, Ardren WR, Holm RJ, Jaeger ME. 2012. Natural growth and diet of known-age 

pallid sturgeon (Scaphirhynchus albus) early life stages in the upper Missouri River basin, 

Montana and North Dakota. Journal of Applied Ichthyology 28:496–504.

Braaten DB, Holte LD, Lott RD, Viste W, Brandt RF, and Lenore RG. 2008. Drift dynamics of 

larval pallid sturgeon and shovelnose sturgeon in a natural side channel of the upper Missouri 

River, Montana. North American Journal of Fisheries Management 28:808–826.

[CDM] Camp Dresser & McKee, Inc. 1981. Water Quality and Aquatic Biological Peropational 

Monitoring Program for the Callaway Nuclear Plant, June 1980 through May 1981. Milwaukee, 

WI: Environmental Planning & Sciences Division. Two volumes. Annual Report to Union Electric 

Company, St. Louis, Missouri. 

DeLonay AJ, Jacobson RB, Papoulias DM, Wildhaber ML, Chojnacki KA, Pherigo EK, Haas JD, 

Mestl GE. 2012. Ecological Requirements for Pallid Sturgeon Reproduction and Recruitment in 

the Lower Missouri River: Annual Report 2010. Reston, VA: U.S. Geological Survey. Open-File 

Report 2012–1009. 51 p. Available at <http://pubs.usgs.gov/of/2012/1009/of2012-1009.pdf> 

(accessed 9 July 2013). 

H-13
Appendix H

Dryer MP, Sandvol AJ. 1993. Recovery plan for the pallid sturgeon Scaphirhynchus albus. 

Bismarck, ND: U.S. Fish and Wildlife Service. Endangered Species Bulletins and Technical 

Reports, Paper 34. 55 p. Available at 

<http://digitalcommons.unl.edu/endangeredspeciesbull/34/> (accessed 9 July 2013).

[E & E] Ecology and Environment, Inc. 2012. Teleconference regarding the Callaway Nuclear 

Plant and data on pallid sturgeon in the Missouri River. Participants included Wyatt Doyle and 

Lane Ledwin, FWS, and Sean Meegan, fisheries biologist for E & E. July 27, 2012. ADAMS 

No. ML ML13214A126.

French WB, Graeb BDS, Chipps SR, Bertrand KN, Selch TM, Klumb RA. 2010. Vulnerability of 

age-0 pallid sturgeon Scaphirhynchus albus to fish predation. Journal of Applied 

Ichthyology 26:6–10. Available at <http://digitalcommons.unl.edu/usgsstaffpub/595/> (accessed 

9 July 2013).

[FWS] U.S. Fish and Wildlife Service. 1993. Pallid Sturgeon Recovery Plan. Bismarck, ND:

U.S. Fish and Wildlife Service. 55 p. Available at 

<http://www.fws.gov/yellowstonerivercoordinator/pallid%20recovery%20plan.pdf> (accessed 

25 September 2012). 

[FWS] U.S. Fish and Wildlife Service. 2007. “Species Profile, Pallid sturgeon, Scaphirhynchus 

albus.” Available at <http://www.fws.gov/moriver/PSPROFILE.htm> (accessed 16 March 2007).

[FWS] U.S. Fish and Wildlife Service. 2012. E-mail from Rick Hansen to Dennis Logan, NRC. 

Subject: Section 7 Listed Species, Callaway Nuclear Plant. September 10, 2012. ADAMS 

No. ML12256A931.

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conserving native cyprinids. Transactions of the American Fisheries Society 135:604–609. 

Available at <http://www.montana.edu/mtcfru/Guy/Publication%20pdf/Gerrity%20et%20al.pdf> 

(accessed 9 July 2013).

Grohs KL, Klumb RA, Chipps SR, Wanner GA. 2008. Ontogenetic patterns in prey use by pallid 

sturgeon in the Missouri River, South Dakota and Nebraska. Journal of Applied 

Ichthyology 25(Suppl. 2):48–53. Available at <http://pubstorage.sdstate.edu/wfs/509-f.pdf> 

(accessed 9 July 2013).

Hrabik RA, Herzog DP, Ostendorf DE, Petersen MD. 2007. Larvae provide first evidence of 

successful reproduction by pallid sturgeon, Scaphirhynchus albus, in the Mississippi River.

Journal of Applied Ichthyology 23(4):436–443.

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Mississippi River Pallid Sturgeon. Transactions of the American Fisheries 

Society 133:1033–1041. Available at <http://opensiuc.lib.siu.edu/zool_pubs/25/> (accessed 

9 July 2013).

Kynard B, Henyey E, Horgan M, 2002. Ontogenetic behavior, migration, and social behavior of 

pallid sturgeon, Scaphirhynchus albus, and shovelnose sturgeon, S. platorynchus, with notes on 

the adaptive significance of body color. Environmental Biology of Fishes 63:389–403.

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Dinosaurs.” Updated 2009. Available at <http://mdc.mo.gov/fish/sport/sturgeon/info/> (accessed 

5 May 2009).

H-14
Appendix H

Missouri River Recovery Program. 2012. Missouri River Recovery Program: Integrated Science, 

Program General Science Questions, and Key Findings. Draft. October 2010, updated through 

January 2012. In: U.S. Army Corps of Engineers, Omaha District, Kansas City District, and 

U.S. Fish and Wildlife Service (2012). 2011 Annual Report for the Biological Opinion on the 

Operation of the Missouri River Main Stem System, Operation and Maintenance of the Missouri 

River Bank Stabilization and Navigation Project, and Operation of the Kansas River Reservoir 

System. Appendix B, ISP – Science Questions and Findings. March 2012. Available at 

<http://moriverrecovery.usace.army.mil/mrrp/

MRRP_PUB_DEV.download_documentation?p_file=7521> (accessed 9 July 2013).

[NRC] U.S. Nuclear Regulatory Commission. 1975. Final Environmental Statement Related to 

the Proposed Callaway Plant Units 1 and 2, Union Electric Company, Docket Nos. STN 50-483 

and STN 50-486. Washington, DC: NRC. Office of Nuclear Reactor Regulation. ADAMS 

No. ML092430114.

[NRC] U.S. Nuclear Regulatory Commission. 2012. Letter from Jeremy Susco to Tom Melius, 

FWS, Ft. Snelling, Missouri. Subject: Request for List of Federally Protected Species for the 

Proposed Callaway Plant License Renewal. April 20, 2012. ADAMS No. ML12096A369.

Schulte G. 2012. “Thousands of fish die as Midwest streams heat up.” Associated Press. 

Reproduced in USA Today, August 7, 2012. Available at 

<http://usatoday30.usatoday.com/weather/news/story/2012-08-07/fish-kill-midwest-summer-hotrivers/56859874/1> (accessed 3 October 2012).

Snydor DE. 2002. Pallid and shovelnose sturgeon larvae – morphological description and 

identification. Journal of Applied Ichthyology 18:240–265.

Union Electric Company. 1986. Callaway Plant, Evaluation of Cooling Water Intake Impacts on 

the Missouri River, Section 316b, PL 92-500, NPDES Permit No. MO-0098001, Section 4.0, 

Entrainment Study. July 1986. St. Louis, MO: Environmental Services Department. 

[USGS] U.S. Geological Survey. 2007. Sturgeon Research Update: Confirmed Pallid Sturgeon 

Spawning in the Missouri River in 2007. USGS Fact Sheet 2007–3053. July 2007. Available at 

<http://pubs.usgs.gov/fs/2007/3053/pdf/FS2007-3053.pdf> (accessed 9 July 2013).

Wildhaber ML, DeLonay AJ, Papoulias DM, Galat DL, Jacobson RB, Simpkins DG, Braaten, PJ, 

Korschgen CE, Mac MJ. 2007. A conceptual life-history model for pallid and shovelnose 

sturgeon. Reston, VA: U.S. Geological Survey. U.S. Geological Survey Circular 1315. 18 p. 

Available at <http://pubs.usgs.gov/circ/2007/1315/pdf/circ_1315.pdf> (accessed 9 July 2013).

H-15




UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

------------------

OFFICIAL BUSINESS
NUREG-1437

Final

Supplement 51

Generic Environmental Impact Statement for License Renewal of Nuclear Plants 

Regarding Callaway Plant, Unit 1