Generic Environmental

Impact Statement for

License Renewal of

Nuclear Plants

Supplement 40

Regarding 

Kewaunee Power Station 

Final Report 

Office of Nuclear Reactor Regulation

NUREG-1437

Supplement 40
Generic Environmental 

Impact Statement for

License Renewal of

Nuclear Plants

Supplement 40

Regarding

Kewaunee Power Station 

Final Report 

Manuscript Completed: July 2010 

Date Published: August 2010 

Office of Nuclear Reactor Regulation 

NUREG-1437

Supplement 40

August 2010 iii NUREG-1437, Supplement 40

ABSTRACT

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

application submitted by Dominion Energy Kewaunee, Inc. (DEK) to renew the operating license 

for Kewaunee Power Station (KPS) for an additional 20 years.

This SEIS 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 supercritical coal-fired generation and natural gas combined-cycle generation; 

a combination of alternatives that included natural gas combined-cycle generation, 

conservation/efficiency, wood-fired generation, and wind power; and not renewing the operating 

license (the no-action alternative).

The Nuclear Regulatory Commission’s recommendation is that the adverse environmental 

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

for energy-planning decision makers. This determination is based on: (1) the analysis and 

findings in the Generic Environmental Impact Statement for License Renewal of Nuclear Plants

(GEIS), NUREG-1437 (NRC, 1996), (NRC, 1999); (2) the Environmental Report submitted by 

DEK; (3) consultation with Federal, State, and local agencies; (4) the staff’s own independent 

review; and (5) the staff’s consideration of public comments received during the scoping 

process and draft SEIS comment period.
1
August 2010 v NUREG-1437, Supplement 40

TABLE OF CONTENTS

Abstract......................................................................................................................................iii

Table of Contents........................................................................................................................v

Figures.......................................................................................................................................xi

Tables .......................................................................................................................................xi

Executive Summary ..................................................................................................................xv

Background ...........................................................................................................................xv

Proposed Action ....................................................................................................................xv

Purpose and Need for Action.................................................................................................xv

Environmental Impacts of License Renewal ......................................................................... xvi

Land Use .......................................................................................................................... xvi

Air Quality ......................................................................................................................... xvi

Groundwater Use and Quality........................................................................................... xvi

Surface Water Use and Quality......................................................................................... xvi

Aquatic Resources............................................................................................................ xvi

Terrestrial Resources........................................................................................................ xvi

Threatened and Endangered Species.............................................................................. xvii

Human Health.................................................................................................................. xvii

Socioeconomics............................................................................................................... xvii

Severe Accident Mitigation Alternatives...............................................................................xviii

Alternatives..........................................................................................................................xviii

Comparison of Alternatives..................................................................................................xviii

Recommendation ................................................................................................................. xix

Abbreviations and Acronyms.................................................................................................... xxi

1.0 Purpose and Need for Action .......................................................................................... 1-1

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

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

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

1.4 Generic Environmental Impact Statement.................................................................... 1-3

1.5 Supplemental Environmental Impact Statement .......................................................... 1-5

1.6 Cooperating Agencies ................................................................................................. 1-6

1.7 Consultations............................................................................................................... 1-6

1.8 Correspondence .......................................................................................................... 1-7

1.9 Status of Compliance................................................................................................... 1-8

1.10 References .............................................................................................................. 1-10

2.0 Affected Environment...................................................................................................... 2-1

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

2.1.1 Reactor and Containment Systems....................................................................... 2-5
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NUREG-1437, Supplement 40 vi August 2010

2.1.2 Radioactive Waste Management........................................................................... 2-5

2.1.2.1 Radioactive Liquid Waste ............................................................................... 2-6

2.1.2.2 Radioactive Gaseous Waste........................................................................... 2-6

2.1.2.3 Radioactive Solid Waste................................................................................. 2-6

2.1.3 Nonradioactive Waste Management ..................................................................... 2-7

2.1.3.1 Hazardous Waste ........................................................................................... 2-8

2.1.3.2 General Plant Trash........................................................................................ 2-8

2.1.3.3 Universal Waste ............................................................................................. 2-8

2.1.3.4 Low-Level Mixed Waste.................................................................................. 2-9

2.1.3.5 Permitted Discharges ..................................................................................... 2-9

2.1.3.6 Pollution Prevention and Waste Minimization ................................................. 2-9

2.1.4 Plant Operation and Maintenance....................................................................... 2-10

2.1.5 Power Transmission Systems ............................................................................. 2-10

2.1.6 Cooling and Auxiliary Water Systems.................................................................. 2-13

2.1.7 Facility Water Use and Quality ............................................................................ 2-14

2.1.7.1 Groundwater Use ......................................................................................... 2-14

2.1.7.2 Surface Water Use ....................................................................................... 2-14

2.1.7.3 Dredging....................................................................................................... 2-14

2.2 Affected Environment ................................................................................................ 2-14

2.2.1 Land Use ............................................................................................................ 2-15

2.2.2 Air Quality and Meteorology ................................................................................ 2-15

2.2.2.1 Regional Air Quality Impacts......................................................................... 2-16

2.2.3 Groundwater Resources ..................................................................................... 2-17

2.2.3.1 Kewaunee Power Station Water Supply Wells.............................................. 2-18

2.2.3.2 Kewaunee Power Station Groundwater Monitoring....................................... 2-19

2.2.4 Surface Water Resources ................................................................................... 2-19

2.2.5 Aquatic Resources.............................................................................................. 2-21

2.2.6 Terrestrial Resources.......................................................................................... 2-26

2.2.7 Threatened and Endangered Species................................................................. 2-28

2.2.7.1 Aquatic Threatened and Endangered Species.............................................. 2-28

2.2.7.2 Terrestrial Threatened and Endangered Species.......................................... 2-29

2.2.8 Socioeconomic Factors....................................................................................... 2-32

2.2.8.1 Housing ........................................................................................................ 2-33

2.2.8.2 Public Services ............................................................................................. 2-34

2.2.8.3 Offsite Land Use........................................................................................... 2-37

2.2.8.4 Visual Aesthetics and Noise ......................................................................... 2-38

2.2.8.5 Demography................................................................................................. 2-38

2.2.8.6 Economy ...................................................................................................... 2-43

2.2.9 Historic and Archaeological Resources ............................................................... 2-50

2.2.9.1 Cultural Background ..................................................................................... 2-50
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August 2010 vii NUREG-1437, Supplement 40

2.2.9.2 Historic and Archaeological Resources at the Kewaunee Power 

Station Site...................................................................................................... 2-53

2.3 Related Federal and State Activities .......................................................................... 2-54

2.4 References ................................................................................................................ 2-54

3.0 Environmental Impacts of Refurbishment........................................................................ 3-1

3.1 References .................................................................................................................. 3-2

4.0 Environmental Impacts of Operation ............................................................................... 4-1

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

4.2 Air Quality.................................................................................................................... 4-1

4.3 Generic GroundWater Issues ...................................................................................... 4-2

4.4 Generic Surface Water Issues ..................................................................................... 4-2

4.4.1 Water Use Conflicts .............................................................................................. 4-2

4.5 Aquatic Resources....................................................................................................... 4-2

4.5.1 Generic Aquatic Ecology Issues............................................................................ 4-3

4.5.2 Entrainment of Fish and Shellfish in Early Life Stages .......................................... 4-3

4.5.2.1 Nalco Environmental Sciences, 1975–1976.................................................... 4-4

4.5.2.2 EA Engineering, Science, and Technology, Inc., 2006–2007.......................... 4-6

4.5.3 Impingement ......................................................................................................... 4-9

4.5.3.1 Nalco Environmental Sciences, 1975–1976.................................................. 4-10

4.5.3.2 EA Engineering, Science and Technology, Inc., 2006–2007......................... 4-11

4.5.4 Heat Shock ......................................................................................................... 4-15

4.5.5 Total Impacts on Aquatic Resources................................................................... 4-18

4.6 Terrestrial Resources ................................................................................................ 4-18

4.7 Threatened and Endangered Species........................................................................ 4-19

4.7.1 Aquatic Species .................................................................................................. 4-19

4.7.2 Terrestrial Species .............................................................................................. 4-19

4.8 Human Health............................................................................................................ 4-20

4.8.1 Radiological Human Health Issues...................................................................... 4-21

4.8.1.1 Radiological Environmental Monitoring......................................................... 4-21

4.8.1.2 Radioactive Effluent and Dose Information ................................................... 4-22

4.8.2 Electromagnetic Fields – Acute Shock ................................................................ 4-23

4.8.3 Electromagnetic Fields – Chronic Effects ............................................................ 4-24

4.9 Socioeconomics ........................................................................................................ 4-25

4.9.1 Generic Socioeconomic Issues ........................................................................... 4-25

4.9.2 Housing Impacts ................................................................................................. 4-26

4.9.3 Public Services: Public Utilities............................................................................ 4-26

4.9.4 Offsite Land Use ................................................................................................. 4-27

4.9.4.1 Population-Related Impacts.......................................................................... 4-27

4.9.4.2 Tax-Revenue-Related Impacts ..................................................................... 4-27

4.9.5 Public Services: Transportation Impacts During Operations................................ 4-28

4.9.6 Historic and Archaeological Resources............................................................... 4-28
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NUREG-1437, Supplement 40 viii August 2010

4.9.7 Environmental Justice......................................................................................... 4-31

4.9.7.1 Minority Population in 2000........................................................................... 4-32

4.9.7.2 Low-Income Population in 2000.................................................................... 4-34

4.9.7.3 Analysis of Impacts....................................................................................... 4-36

4.9.7.4 Subsistence Consumption of Fish and Wildlife ............................................. 4-36

4.10 Evaluation of New and Potentially Significant Information........................................ 4-38

4.11 Cumulative Impacts ................................................................................................. 4-39

4.11.1 Cumulative Impacts on Water and Aquatic Resources...................................... 4-39

4.11.2 Cumulative Impacts on Terrestrial Resources ................................................... 4-40

4.11.3 Cumulative Impacts on Human Health .............................................................. 4-41

4.11.4 Cumulative Impacts on Socioeconomics ........................................................... 4-42

4.11.5 Cumulative Impacts on Air Quality .................................................................... 4-43

4.11.6 Summary of Cumulative Impacts....................................................................... 4-44

4.12 References .............................................................................................................. 4-45

5.0 Environmental Impacts of Postulated Accidents.............................................................. 5-1

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

5.2 Severe Accident Mitigation Alternatives ....................................................................... 5-2

5.2.1 Introduction ........................................................................................................... 5-2

5.2.2 Estimate of Risk .................................................................................................... 5-3

5.2.3 Potential Plant Improvements ............................................................................... 5-5

5.2.4 Evaluation of Risk Reduction and Costs of Improvements .................................... 5-5

5.2.5 Cost Benefit Comparison ...................................................................................... 5-6

5.2.6 Conclusions .......................................................................................................... 5-7

5.3 References .................................................................................................................. 5-7

6.0 Environmental Impacts of The Uranium Fuel Cycle, Solid Waste Management, 

and Greenhouse Gas .................................................................................................. 6-1

6.1 The Uranium Fuel Cycle and Solid Waste Management.............................................. 6-1

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

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

6.2.1.1 Qualitative Studies.......................................................................................... 6-3

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

6.2.1.3 Summary of Nuclear Greenhouse Gas Emissions Compared to Coal ............ 6-5

6.2.1.4 Summary of Nuclear Greenhouse Gas Emissions Compared to Natural 

Gas ................................................................................................................... 6-6

6.2.1.5 Summary of Nuclear Greenhouse Gas Emissions Compared to 

Renewable Energy Sources .............................................................................. 6-6

6.2.2 Conclusions: Relative Greenhouse Gas Emissions............................................... 6-7

6.3 References .................................................................................................................. 6-9

7.0 Environmental Impacts of Decommissioning ................................................................... 7-1

7.1 References .................................................................................................................. 7-1
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August 2010 ix NUREG-1437, Supplement 40

8.0 Environmental Impacts of Alternatives ............................................................................ 8-1

8.1 Gas-fired Generation ................................................................................................... 8-3

8.1.1 Air Quality ............................................................................................................. 8-5

8.1.2 Groundwater Use and Quality ............................................................................... 8-7

8.1.3 Surface Water Use and Quality............................................................................. 8-8

8.1.4 Aquatic and Terrestrial Ecology............................................................................. 8-8

8.1.4.1 Aquatic Ecology.............................................................................................. 8-8

8.1.4.2 Terrestrial Ecology.......................................................................................... 8-8

8.1.5 Human Health....................................................................................................... 8-9

8.1.6 Socioeconomics.................................................................................................... 8-9

8.1.6.1 Land Use........................................................................................................ 8-9

8.1.6.2 Socioeconomics ........................................................................................... 8-10

8.1.6.3 Transportation .............................................................................................. 8-11

8.1.6.4 Aesthetics..................................................................................................... 8-11

8.1.6.5 Historic and Archaeological Resources......................................................... 8-12

8.1.6.6 Environmental Justice................................................................................... 8-12

8.1.7 Waste Management............................................................................................ 8-13

8.2 Coal-Fired Generation ............................................................................................... 8-13

8.2.1 Air Quality ........................................................................................................... 8-15

8.2.1.1 Sulfur Oxides Emissions and Nitrogen Oxides Emissions............................. 8-16

8.2.1.2 Particulate Emissions ................................................................................... 8-17

8.2.1.3 Carbon Monoxide Emissions ........................................................................ 8-17

8.2.1.4 Hazardous Air Pollutants Including Mercury.................................................. 8-17

8.2.1.5 Carbon Dioxide............................................................................................. 8-18

8.2.1.6 Summary of Air Quality................................................................................. 8-18

8.2.2 Groundwater Use and Quality ............................................................................. 8-18

8.2.3 Surface Water Use and Quality........................................................................... 8-19

8.2.4 Aquatic and Terrestrial Ecology........................................................................... 8-19

8.2.5 Human Health..................................................................................................... 8-20

8.2.6 Socioeconomics.................................................................................................. 8-21

8.2.6.1 Land Use...................................................................................................... 8-21

8.2.6.2 Socioeconomics ........................................................................................... 8-21

8.2.6.3 Transportation .............................................................................................. 8-22

8.2.6.4 Aesthetics..................................................................................................... 8-22

8.2.6.5 Historic and Archaeological Resources......................................................... 8-23

8.2.6.6 Environmental Justice................................................................................... 8-23

8.2.7 Waste Management............................................................................................ 8-24

8.3 Combination Alternatives ........................................................................................... 8-24

8.3.1 Air Quality ........................................................................................................... 8-26

8.3.2 Groundwater Use and Quality ............................................................................. 8-28

8.3.3 Surface Water Use and Quality........................................................................... 8-29
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NUREG-1437, Supplement 40 x August 2010

8.3.4 Aquatic and Terrestrial Ecology........................................................................... 8-29

8.3.5 Human Health..................................................................................................... 8-30

8.3.6 Socioeconomics.................................................................................................. 8-30

8.3.6.1 Land Use...................................................................................................... 8-30

8.3.6.2 Socioeconomics ........................................................................................... 8-31

8.3.6.3 Transportation .............................................................................................. 8-32

8.3.6.4 Aesthetics..................................................................................................... 8-32

8.3.6.5 Historic and Archaeological Resources......................................................... 8-33

8.3.6.6 Environmental Justice................................................................................... 8-33

8.3.7 Waste Management............................................................................................ 8-34

8.4 Purchased Power ...................................................................................................... 8-34

8.5 Alternatives Considered but Dismissed...................................................................... 8-35

8.5.1 Wind Power......................................................................................................... 8-35

8.5.2 Wood-Fired Power .............................................................................................. 8-35

8.5.3 Energy Conservation........................................................................................... 8-36

8.5.4 Solar Power ........................................................................................................ 8-36

8.5.5 Hydroelectric Power............................................................................................ 8-36

8.5.6 Geothermal Power .............................................................................................. 8-37

8.5.7 Biofuels............................................................................................................... 8-37

8.5.8 New Nuclear Power ............................................................................................ 8-37

8.5.9 Oil-fired Power .................................................................................................... 8-37

8.5.10 Fuel Cells.......................................................................................................... 8-37

8.5.11 Municipal Solid Waste....................................................................................... 8-38

8.5.12 Delayed Retirement .......................................................................................... 8-38

8.6 No-Action Alternative ................................................................................................. 8-39

8.6.1 Air Quality ........................................................................................................... 8-40

8.6.2 Groundwater Use and Quality ............................................................................. 8-40

8.6.3 Surface Water Use and Quality........................................................................... 8-40

8.6.4 Aquatic and Terrestrial Resources ...................................................................... 8-40

8.6.5 Human Health..................................................................................................... 8-40

8.6.6 Socioeconomics.................................................................................................. 8-41

8.6.6.1 Land Use...................................................................................................... 8-41

8.6.6.2 Socioeconomics ........................................................................................... 8-41

8.6.6.3 Transportation .............................................................................................. 8-41

8.6.6.4 Aesthetics..................................................................................................... 8-41

8.6.6.5 Historic and Archaeological Resources......................................................... 8-41

8.6.6.6 Environmental Justice................................................................................... 8-42

8.6.7 Waste Management............................................................................................ 8-42

8.7 Alternatives Summary................................................................................................ 8-42

8.8 References ................................................................................................................ 8-43

9.0 Conclusion ...................................................................................................................... 9-1
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August 2010 xi NUREG-1437, Supplement 40

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

9.2 Comparison of the 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 Relationship Between Local Short-Term Uses of the Environment and the 

Maintenance and Enhancement of Long-Term Productivity .................................. 9-2

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

9.4 Recommendation......................................................................................................... 9-4

10.0 List of Preparers.......................................................................................................... 10-1

APPENDIX A Comments Received on the 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 Correspondences.........................................................................D-1

APPENDIX E Chronology of Environmental Review ...............................................................E-1

APPENDIX F U.S. Nuclear Regulatory Commission Staff Evaluation of Severe 

Accident Mitigation Alternatives for Kewaunee Power Station in Support of 

License Renewal Application Review .......................................................................... F-1

FIGURES

Figure 1-1. Environmental Review Process............................................................................. 1-2

Figure 1-2. Environmental Issues Evaluated during License Renewal .................................... 1-5

Figure 2-1. Kewaunee Power Station 50-Mile Radius ............................................................. 2-2

Figure 2-2. Kewaunee Power Station 6-Mile Radius ............................................................... 2-3

Figure 2-3. Kewaunee Power Station Site Map....................................................................... 2-4

Figure 2-4. Kewaunee Power Station Transmission Line System ......................................... 2-12

Figure 2-5. Primary Aquifers Beneath the Kewaunee Power Station Site.............................. 2-18

Figure 4-1. Minority Blocks in 2000 within a 50-Mile Radius of Kewaunee 

Power Station ....................................................................................................................... 4-33

Figure 4-2. Low-Income Block Groups within a 50-Mile Radius of Kewaunee 

Power Station ....................................................................................................................... 4-35

TABLES

Table 1-1. Consultation Correspondences. ............................................................................. 1-6

Table 1-2. Licenses and Permits............................................................................................. 1-9

Table 2-1. Potable Water Usage (Gallons) at Kewaunee Power Station ............................... 2-19

Table 2-2. Wisconsin Pollutant Discharge Elimination System Effluent Limitations

for Kewaunee Power Station................................................................................................. 2-20

Table 2-3. Listed Aquatic Species......................................................................................... 2-29

Table 2-4. Kewaunee Power Station Employee Residence by County (Wisconsin) .............. 2-33
Table of Contents

NUREG-1437, Supplement 40 xii August 2010

Table 2-5. Housing in Kewaunee, Manitowoc, and Brown Counties in Wisconsin ................. 2-34

Table 2-6. Public Water Supply Systems (thousand gallons per day).................................... 2-35

Table 2-7. Major Commuting Routes in the Vicinity of the Kewaunee Power Station

in 2006 Average Annual Daily Traffic Counts ........................................................................ 2-37

Table 2-8. Population and Percent Growth in Kewaunee, Manitowoc, and Brown 

Counties, Wisconsin, from 1970 to 2000 and Projected for 2008 to 2050.............................. 2-39

Table 2-9. Demographic Profile of the Population in the Kewaunee Power Station

Three-County Socioeconomic Region of Influence in 2000 ................................................... 2-40

Table 2-10. Demographic Profile of the Population in the Kewaunee Power Station 

Three-County Socioeconomic Region of Influence in 2005–2007, 3-Year Estimate .............. 2-41

Table 2-11. Seasonal Housing in Counties Located within 50 Miles of the 

Kewaunee Power Station...................................................................................................... 2-42

Table 2-12. Migrant Farm Workers and Temporary Farm Labor in Counties Located

within 50 Miles of the Kewaunee Power Station.................................................................... 2-43

Table 2-13. Major Employers in Kewaunee County in 2005 .................................................. 2-44

Table 2-14. Estimated Income Information for the Kewaunee Power Station 

Region of Influence, 2005–2007 3-Year Estimates ............................................................... 2-44

Table 2-15. Wisconsin Shared Revenue Utility Payments to the Town of Carlton

for Utility Property in the Town of Carlton, 2004 to 2008 ....................................................... 2-47

Table 2-16. Wisconsin Shared Revenue Utility Payments to Kewaunee County

for Utility Property in the Town of Carlton, 2004 to 2008 ....................................................... 2-48

Table 2-17. Wisconsin Shared Revenue Utility Payments to the Town of Carlton and

Kewaunee County for Utility Property in the Town of Carlton for 2009 .................................. 2-49

Table 2-18. Town of Carlton – Wisconsin Shared Revenue Utility Payments and 

Total Town Revenues, 2004 to 2008..................................................................................... 2-49

Table 2-19. Kewaunee County – Wisconsin Shared Revenue Utility Payments and 

Total Town Revenues, 2004 to 2008..................................................................................... 2-50

Table 3-1. Issues Related to Refurbishment ........................................................................... 3-1

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

Table 4-2. Air Quality Issue..................................................................................................... 4-1

Table 4-3. Category 1 Surface Water Issues........................................................................... 4-2

Table 4-4. Aquatic Resources Issues...................................................................................... 4-3

Table 4-5. Entrainment by Species, April 1975 through March 1976....................................... 4-5

Table 4-6. Estimated Entrainment by Species, March 2006 through February 2007 ............... 4-7

Table 4-7. Estimated Total Numbers of Entrained Fish. .......................................................... 4-9

Table 4-8. Impinged Fish by Species, April 1975 through March 1976.................................. 4-11

Table 4-9. Impinged Fish by Species, February 2006 through January 2007 ........................ 4-13

Table 4-10. Kewaunee Power Station Thermal Plume Characteristics in Summer

under Extreme Conditions..................................................................................................... 4-16

Table 4-11. Kewaunee Power Station Thermal Plume Characteristics in Winter

under Extreme Conditions.................................................................................................... 4-17

Table 4-12. Terrestrial Resources Issues.............................................................................. 4-19

Table 4-13. Threatened or Endangered Species................................................................... 4-19

Table 4-14. Human Health Issues......................................................................................... 4-20
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August 2010 xiii NUREG-1437, Supplement 40

Table 4-15. Category 1 Issues Applicable to Socioeconomics During the 

Renewal Term....................................................................................................................... 4-25

Table 4-16. Category 2 Issues Applicable to Socioeconomics and Environmental 

Justice During the Renewal Term ......................................................................................... 4-25

Table 4-17. Summary of Cumulative Impacts on Resource Areas......................................... 4-45

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

Table 5-2. Kewaunee Power Station Internal Events Core Damage Frequency ...................... 5-4

Table 5-3. Breakdown of Population Dose by Containment Release Mode............................. 5-4

Table 6-1. Issues Related to the Uranium Fuel Cycle and Solid Waste Management ............. 6-2

Table 6-2. Nuclear Greenhouse Gas Emissions Compared to Coal........................................ 6-5

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

Table 6-4. Nuclear Greenhouse Gas Emissions Compared to Renewable Energy Sources.... 6-7

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

Table 8-1. Summary of Environmental Impacts of Gas-Fired Combined-Cycle Generation 

Compared to Continued Kewaunee Power Station Operation................................................. 8-5

Table 8-2. Summary of Environmental Impacts of the Coal-Fired Alternative Compared

to Continued Kewaunee Power Station Operation ................................................................ 8-15

Table 8-3. Summary of Environmental Impacts of the Combination Alternative Compared

to Continued Kewaunee Power Station Operation ................................................................ 8-25

Table 8-4. Summary of Environmental Impacts of No Action Compared to Continued 

Kewaunee Power Station Operation ..................................................................................... 8-39

Table 8-5. Summary of Environmental Impacts of Proposed Action and Alternatives............ 8-43

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

Table A-1. Commenters on the Scope of the Environmental Review ......................................A-2

Table A-2. Commenters on the Draft SEIS............................................................................A-11

Table A-3. Technical Issue Groups. ......................................................................................A-12

Table B-1. Summary of Issues and Findings...........................................................................B-1

Table C-1. State Environmental Requirements .......................................................................C-2

Table C-2. Federal, State, and Local Permits and Other Requirements ..................................C-3

Table D-1. Consultation Correspondences..............................................................................D-1

Table F.2-1. Kewaunee Power Station Core Damage Frequency ........................................... F-3

Table F.2-2. Containment bypass events (such as transients with an induced SGTR 

or SGTR-initiated accidents with a stuck open safety relief valve on the ruptured 

steam generator) and late containment failures without containment spray dominate 

the population dose risk at Kewaunee Power Station.............................................................. F-3

Table F.2-3. Kewaunee Power Station Probabilistic Risk Assessment Historical Summary .... F-6

Table F.2-4. Important Fire Areas and Their Contribution to Fire Core Damage Frequency.. F-11

Table F.5-1. Severe Accident Mitigation Alternative Cost/Benefit Screening Analysis

for Kewaunee Power Station................................................................................................. F-21
THIS PAGE IS INTENTIONALLY LEFT BLANK
August 2010 xv NUREG-1437, Supplement 40

EXECUTIVE SUMMARY

BACKGROUND

By letter dated August 12, 2008, Dominion Energy Kewaunee, Inc. (DEK) submitted an 

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

license for Kewaunee Power Station (KPS) for an additional 20-year period. 

The following document and the review it encompasses are requirements of NRC regulations 

implementing Section 102 of the National Environmental Policy Act (NEPA), of the United 

States Code (42 U.S.C. 4321), in Title 10 of the Code of Federal Regulations (CFR), Part 51 

(10 CFR Part 51). In 10 CFR 51.20(b)(2), the Commission indicates that issuing a renewed 

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 that the EIS 

prepared at the operating license renewal stage will be a supplement to the Generic 

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437

(NRC, 1996), (NRC, 1999).

Upon acceptance of DEK’s application, the NRC began the environmental review process 

described in 10 CFR Part 51 by publishing a Notice of Intent to prepare an EIS and conduct 

scoping in the Federal Register on October 9, 2009 (73 FR 59678) . The staff held a public 

scoping meeting on October 22, 2008, in the town of Carlton, Wisconsin, and conducted a site 

audit at KPS in late May 2009. During the preparation of this supplemental EIS (SEIS) for KPS, 

the staff reviewed DEK’s environmental report 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 (NRC, 2000), and considered public comments 

received during the scoping process and on the draft SEIS.

PROPOSED ACTION

DEK initiated the proposed Federal action—issuance of a renewed power reactor operating 

license—by submitting an application for license renewal of KPS, for which the existing license 

(DPR-43) expires December 21, 2013. NRC’s Federal action is the decision 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 (issuance of a renewed license) is to provide an 

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

plant operating license and to meet future system generating needs, as determined by State, 

utility, and, where authorized, Federal (other than NRC) decision makers. This definition of 

purpose and need for action reflects the Commission’s recognition that, unless there are 

findings in the safety review required by the Atomic Energy Act of 1954, as amended, or 

findings in the NEPA environmental analysis that would lead the NRC to not grant a license 

renewal, 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 DEK will ultimately decide whether the 

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

within the State’s jurisdiction or the purview of the owners. If the operating license is not 
Executive Summary

NUREG-1437, Supplement 40 xvi August 2010

renewed, then the facility must be shut down on or before December 21, 2013, when the current 

operating license expires.

ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL

The SEIS evaluates the potential environmental impacts of the proposed action. The 

environmental impacts from the proposed action can be SMALL, MODERATE, or LARGE. The 

NRC has established a process for identifying and evaluating the significance of any new and 

significant information on the environmental impacts of license renewal of KPS. The NRC did 

not identify any information that is both new and significant related to Category 1 (generic)

issues that would call into question the conclusions in the GEIS. Similarly, neither the scoping

process nor the staff’s review has identified any new issue applicable to KPS that has a 

significant environmental impact. Therefore, the staff relies upon the conclusions of the GEIS for 

all the Category 1 issues applicable to KPS.

LAND USE

SMALL. The NRC did not identify any Category 2 impact issues for land use, nor did the staff 

identify any new or significant information during the environmental review. Therefore, there are 

no impacts beyond those discussed in the GEIS.

AIR QUALITY

SMALL. The NRC did not identify any Category 2 issues for air quality impacts, nor did the staff 

identify any new or significant information during the environmental review. Therefore, for plant 

operation during the license renewal term, there are no impacts beyond those discussed in the 

GEIS.

GROUNDWATER USE AND QUALITY

SMALL. The NRC did not identify any Category 2 issues for groundwater impacts, nor did the 

staff identify any new or significant information during the environmental review. Therefore, for 

plant operation during the license renewal term, there are no impacts beyond those discussed in 

the GEIS.

SURFACE WATER USE AND QUALITY

SMALL. The NRC did not identify any Category 2 issues for impacts to surface water use and 

quality, nor did the staff identify any new or significant information during the environmental 

review. Therefore, for plant operation during the license renewal term, there are no impacts 

beyond those discussed in the GEIS.

AQUATIC RESOURCES

SMALL. The NRC identified Category 2 issues related to impingement, entrainment, and heat 

shock all associated with the use of a once-through cooling system. The staff believes that the 

total impact from impingement, entrainment, and heat shock on aquatic resources would be 

SMALL through the period of license renewal. 

TERRESTRIAL RESOURCES

SMALL. The NRC did not identify any Category 2 issues for terrestrial resources, nor did the 

staff identify any new or significant information during the environmental review. Therefore, 

there are no impacts beyond those discussed in the GEIS. 
Executive Summary

August 2010 xvii NUREG-1437, Supplement 40

THREATENED AND ENDANGERED SPECIES

SMALL. Impacts to threatened and endangered species during the period of extended operation 

are a Category 2 issue. However, operation of the KPS site and its associated transmission 

lines are not expected to adversely affect any threatened or endangered species during the 

license renewal term. Therefore, the staff concludes that adverse impacts to threatened or 

endangered species during the period of extended operation would be SMALL. The staff finds 

several adequate mitigation measures currently in place at the KPS site and along its 

transmission corridors. They include: nest construction and placement for the peregrine falcon, 

environmental review checklists, environmental evaluation forms, and best management 

practices.

HUMAN HEALTH

SMALL. With regard to Category 1 human health issues during the license renewal term—

microbiological organisms (occupational health), noise, radiation exposures to public, and 

occupational radiation exposures—the staff did not identify any new or significant information 

during the environmental review. Therefore, there are no impacts beyond those discussed in the 

GEIS. 

Electromagnetic fields—acute effects (electric shock) is a Category 2 human health issue. The 

staff evaluated the potential impacts for electric shock resulting from the operation of KPS and 

its associated transmission lines. The staff concludes that the potential impacts from electric 

shock during the renewal period would be SMALL. 

For electromagnetic fields—chronic effects, the staff considers the GEIS finding of “uncertain” 

still appropriate and will continue to follow developments on this issue.

SOCIOECONOMICS

SMALL. Category 2 socioeconomic impacts include housing impacts, public services (public 

utilities), offsite land use, public services (public transportation), and historic and archaeological

resources. DEK has indicated they have no plans to add non-outage employees during the 

license renewal period; therefore, non-outage employment levels at KPS would remain relatively 

unchanged with no additional demand for public water and sewer services. Because non-outage 

employment levels at KPS would remain relatively unchanged during the license renewal 

period, there would be no land use impacts related to population or tax revenues and no 

transportation impacts. 

No impacts to known historic and archaeological resources are expected from the continued 

operation of KPS during the license renewal term. DEK has indicated no plans to engage in 

activities that could result in changes to the plant or any ground disturbing activities associated 

with license renewal at KPS. Based on the review of the Wisconsin Historical Society files, 

archaeological surveys, assessments, and other information, the potential impacts of continued 

operations and maintenance on historic and archaeological resources at KPS would be SMALL.

With respect to environmental justice, an analysis of minority and low-income populations 

residing within a 50-mile (80-kilometer) radius of KPS indicated there would be no 

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

of KPS during the license renewal period. Based on recent monitoring results, concentrations of 

contaminants in native leafy vegetation, soils and sediments, surface water, and fish in areas 

surrounding KPS have been low (at or near the threshold of detection) and seldom above 

background levels. Consequently, no disproportionately high and adverse human health 
Executive Summary

NUREG-1437, Supplement 40 xviii August 2010

impacts would be expected in special pathway receptor populations in the region as a result of 

subsistence consumption of fish and wildlife.

SEVERE ACCIDENT MITIGATION ALTERNATIVES

Since KPS had not previously considered alternatives to reduce the likelihood or potential 

consequences of a variety of highly uncommon but potentially serious accidents, NRC 

regulation 10 CFR 51.53(c)(3)(ii)(L) requires that KPS evaluate Severe Accident Mitigation 

Alternatives (SAMAs) in the course of license renewal review. SAMAs are potential 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.

Based on its review of potential SAMAs, the staff concludes that KPS made a reasonable, 

comprehensive effort to identify and evaluate SAMAs. Based on the review of the SAMAs for 

KPS and the plant improvements already made, the staff concludes that none of the potentially 

cost beneficial SAMAs relate to managing the effects of aging during the period of extended 

operation; therefore, they need not be implemented as part of the license renewal pursuant to 

10 CFR Part 54.

ALTERNATIVES

The staff considered the environmental impacts associated with alternatives to license renewal. 

These alternatives include other methods of power generation and not renewing the KPS 

operating license (the no-action alternative). Replacement power options considered were 

supercritical coal-fired generation, natural gas combined-cycle generation, and as part of the 

combination alternative, conservation/efficiency, wood-fired generation, and wind power. 

Wherever possible, the staff evaluated potential environmental impacts for these alternatives 

located both at the KPS site and at some other unspecified alternate location. The staff

evaluated each alternative using the same impact areas that were used in evaluating impacts 

from license renewal. The results of this evaluation are summarized in the table on the following 

page.

COMPARISON OF ALTERNATIVES

The NRC notes that the impacts of license renewal for KPS are similar to or smaller than the 

impacts of the alternatives considered in all resource areas, with the exception of no action. No 

action, however, would necessitate additional action on the part of other entities to either 

replace or offset the power produced by KPS, and thus would result in additional impacts similar 

to those discussed in this document.

The coal-fired alternative is the least environmentally favorable alternative, due to its impact on 

air quality and human health from nitrogen oxides, sulfur oxides, particulate matter, polycyclic 

aromatic hydrocarbons, carbon monoxide, carbon dioxide, and mercury. Construction impacts 

to aquatic, terrestrial, and potentially historic and archaeological resources are also factors that 

contribute toward the coal-fired alternative being the least environmentally favorable alternative. 

The gas-fired alternative would have slightly lower air emissions, and impacts to aquatic, 

terrestrial, and historic and archaeological resources would vary depending upon location of the 

plant.
Executive Summary

August 2010 xix NUREG-1437, Supplement 40

RECOMMENDATION

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

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

makers. This determination is based on: (1) the analysis and findings in the GEIS; (2) 

information submitted in DEK’s Environmental Report; (3) consultation with other Federal, State, 

and local agencies; (4) the staff’s own independent review; and (5) a consideration of public 

comments received during the scoping process and the draft SEIS comment period.

Alternative

Impact Area

Air Quality

Ground

water

Surface Water

Aquatic and Terrestrial 

Resources

Human Health

Socioeconomics

Waste Management

KPS Licens e 

Renewal SMALL SMALL SMALL SMALL SMALL SMALL SMALL

Supercritical 

coal-fired at the 

KPS s ite

MODERATE SMALL SMALL MODERATE SMALL SMALL to 

LARGE MODERATE

Supercritical 

coal-fired at an 

alternate s ite

MODERATE SMALL SMALL to 

MODERATE MODERATE SMALL SMALL to 

LARGE MODERATE

Gas-fired at the

KPS s ite MODERATE SMALL SMALL SMALL to 

MODERATE SMALL SMALL to 

MODERATE SMALL

Gas-fired at an 

alternative s ite MODERATE SMALL SMALL to 

MODERATE

SMALL to 

MODERATE SMALL SMALL to MODERATE SMALL

Combination of 

Alternatives #1 MODERATE SMALL SMALL SMALL to 

LARGE

SMALL to 

MODERATE

SMALL to 

MODERATE SMALL

Combination of 

Alternatives #2 MODERATE SMALL SMALL SMALL to 

LARGE

SMALL to 

MODERATE

SMALL to 

MODERATE SMALL

No-Action 

Alternative SMALL SMALL SMALL SMALL SMALL SMALL to 

MODERATE SMALL
THIS PAGE IS INTENTIONALLY LEFT BLANK
August 2010 xxi NUREG-1437, Supplement 40

ABBREVIATIONS AND ACRONYMS

AADT average annual daily traffic 

ac acre

ACC cleanup and decontamination costs

ACHP Advisory Council on Historic Preservation

ADAMS Agency-wide Documents Access and Management 

System 

AEA Atomic Energy Act of 1954

AEC U.S. Atomic Energy Commission

AEO Annual Energy Outlook 

AFW auxiliary feedwater 

ALARA as low as is reasonably achievable

AOC Averted Offsite Property Damage Costs 

AOCs Areas of Concern 

AOE Averted Occupational Exposure 

AOSC Averted onsite costs 

APE area of potential effect

Averted Public Exposure

AQCR air quality control region 

ATC American Transmission Company 

ATWS anticipated transient without scram 

AVD AVD Archaeological Services, Inc.

BPJ best professional judgment

BTA best technology available

Btu/ft3 British thermal units per cubic feet

Btu/kWh British thermal units per kilowatt hour

Btu/lb British thermal units per pound

CAA Clean Air Act 

CAIR Clean Air Interstate Rule 

CAMR Clean Air Mercury Rule 

CCW component cooling water

CDF core damage frequency
Abbreviations and Acronyms

NUREG-1437, Supplement 40 xxii August 2010

CDM clean development mechanism

CEQ Council on Environmental Quality 

CET containment event tree 

cfd cubic feet per day

CFR Code of Federal Regulations

cfs cubic feet per second 

CFT core flood tank

CH4 methane

cm centimeter

CO carbon monoxide 

CO2 carbon dioxide

CST condensate storage tank 

CVCS chemical and volume control system 

CWA Clean Water Act

dBA decibels adjusted

DBA design basis accident

DEK Dominion Energy Kewaunee, Inc. 

DG diesel generator

Diesel engine generator

DOE Department of Energy 

DOT Department of Transportation 

EAE EA Engineering, Science, and Technology, Inc.

ECCS emergency core cooling system 

EDG emergency diesel generator

EIA Energy Information Administration 

EIS environmental impact statement

ELF extremely low frequency 

EMF electromagnetic fields

EMS environmental management system

E.O. Executive Order

EPA Environmental Protection Agency 

ER environmental report
Abbreviation and Acronyms

August 2010 xxiii NUREG-1437, Supplement 40

F&O Fact & Observation

FERC Federal Energy Regulatory Commission 

FES final environmental statement

FIP Federal Implementation Plan

FIVE fire induced vulnerability evaluation

fps feet per second

FR final regulations

FSAR final safety analysis report

ft foot or feet

ft3 cubic feet

FV Fussell-Vesely

g gram

gCeq/kWh grams conversion equivalent per kilowatt-hour

GE General Electric Company 

GEIS generic environmental impact statement 

GHG greenhouse gas 

GL generic letter

GLFC Great Lakes Fishery Commission 

GLWQA Great Lakes Water Quality Agreement 

gpd gallons per day 

gpm gallons per minute 

GWh gigawatt-hours

ha hectare

HAP hazardous air pollutants

HCLPF high confidence in low probability of failure 

HEP human error probability

HFC hydrofluorocarbons

HFE hydrofluorinated ethers 

HFO high winds, floods, and other

Hg mercury

HVAC heating, ventilation, and air conditioning

Hz hertz
Abbreviations and Acronyms

NUREG-1437, Supplement 40 xxiv August 2010

IAEA International Atomic Energy Agency

IEEE Institute of Electrical and Electronics Engineers

IJC International Joint Commission 

IPA integrated plant assessment 

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

J joule

KPS Kewaunee Power Station 

kg kilogram

km kilometer

km2 square kilometer

km3 cubic kilometer

kV kilovolt

kW kilowatt

kWh kilowatt-hours

LaMPs Lakewide Management Plans 

lbs pounds

LERF large early release frequency 

LLMW low-level mixed waste 

LMMB Lake Michigan Mass Balance Study 

LOCA loss of coolant accident

Lpd liters per day

m meter

m2 square meter

m3 cubic meter

m/s meters per second 

m3

/s cubic meters per second 

mA milliampere
Abbreviation and Acronyms

August 2010 xxv NUREG-1437, Supplement 40

MAAP Modular Accident Analysis Program 

MACCS2 MELCOR Accident Consequence Code System 2 

MACT Maximum Achievable Control Technology 

MCC motor control center

movement control center

mgd millions of gallons per day 

mi mile

mi2 square mile

mi3 cubic mile

Midwest RPO Midwest Regional Planning Organization 

MISO Midwest Independent Transmission System Operator 

MIT Massachusetts Institute of Technology

MMACR Modified Maximum Averted Cost Risk

mph mile per hour

mrem milliroentgen equivalent man

mSv millisievert

MT metric ton 

MW megawatt

MWd/MTU megawatt days per metric ton of uranium 

MWe megawatts-electric 

MWh megawatt hour 

MWt megawatts-thermal

N2O nitrous oxide 

NAS National Academy of Sciences 

NCDC National Climatic Data Center 

NCI National Cancer Institute

NCore national core

NEA Nuclear Energy Agency

NEPA National Environmental Policy Act 

NES Nalco Environmental Sciences

NESC National Electric Safety Code

NF3 nitrogen trifluoride 

ng nanograms

NHPA National Historic Preservation Act 
Abbreviations and Acronyms

NUREG-1437, Supplement 40 xxvi August 2010

NIEHS National Institute of Environmental Health and Sciences

NIRS/WISE Nuclear Information and Resource Service/World 

Information Service on Energy

NOAA National Oceanic and Atmospheric Administration 

NOx Nitrogen oxides 

NPDES National Pollutant Discharge Elimination System 

NRC U.S. Nuclear Regulatory Commission 

NRHP National Register of Historic Places 

NSR New Source Review 

NUREG/BR nuclear regulatory brochure

NWS National Weather Service

ODCM offsite dose calculation manual

PBNP Point Beach Nuclear Plant

PCB polychlorinated biphenyl 

PDS plant damage state

PFC perfluorocarbons

PIC Proposal for Information Collection

PILOT payment in lieu of taxes

PM particulate matter

PMNP platform mounted nuclear plant

PORV power-operated relief valve

POST Parliamentary Office of Science and Technology

ppt parts per thousand 

PRA probabilistic risk assessment 

PWR pressurized-water reactor

RAI request for additional information 

RAP remedial action program

RCP reactor coolant pump 

RCRA Resource Conservation and Recovery Act 

RCS reactor coolant system 

rem roentgen equivalent man 

REMP radiological environmental monitoring program
Abbreviation and Acronyms

August 2010 xxvii NUREG-1437, Supplement 40

RHR residual heat removal 

RLE Review Level Earthquake 

RO reverse osmosis 

ROI region of interest 

ROP reactor oversight process

ROW right-of-way 

RPC replacement power cost 

RPO regional planning organizations 

RWST refueling water storage tank

SAMA severe accident mitigation alternative

SAR safety analysis report

SBO station blackout 

SCR selective catalytic reduction 

SEIS supplemental environmental impact statement 

SER safety evaluation report 

SF6 sulfur hexafluoride 

SGTR steam generator tube rupture 

SHPO State Historic Preservation Officer

SMA seismic margins assessment 

SO2 sulfur dioxide 

SOx sulfur oxides 

SP sampling points 

SPDES State Pollutant Discharge Elimination System 

SR supporting requirement

STC source term category

Sv sievert

TER technical evaluation report

TSP total suspended particles

TWh terawatt-hour

USFWS U.S. Fish and Wildlife Service

U.S.C. United States Code

USCB U.S. Census Bureau
Abbreviations and Acronyms

NUREG-1437, Supplement 40 xxviii August 2010

USGCRP United States Global Change Research Program

VCT volume control tank

WDHS Wisconsin Department of Health Services

WDNR Wisconsin Department of Natural Resources 

WET Whole Effluent Toxicity 

WHS Wisconsin Historical Society

WOG Westinghouse Owner’s Group 

WPDES Wisconsin Pollutant Discharge Elimination System 

WPSC Wisconsin Public Service Corporation

WSRP Wisconsin Shared Revenue Program
August 2010 1-1 NUREG-1437, Supplement 40

1.0 PURPOSE AND NEED FOR ACTION

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

in Title 10, Part 51, of the Code of Federal Regulations (10 CFR 51), which implement the 

National Environmental Policy Act (NEPA), issuance of a new nuclear power plant operating 

license requires the preparation of an environmental impact statement (EIS). 

The Atomic Energy Act of 1954 (AEA) originally specified that licenses for commercial power 

reactors be granted for up to 40 years with an option to renew for up to another 20 years. The 

40-year licensing period was based on economic and antitrust considerations rather than on the 

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 a license renewal application based on whether or not the applicant has demonstrated that 

the environmental and safety requirements in the NRC’s regulations can be met during the 

period of extended operation. 

1.1 PROPOSED FEDERAL ACTION 

Dominion Energy Kewaunee, Inc. (DEK) initiated the proposed Federal action by submitting an 

application for license renewal of the Kewaunee Power Station (KPS). KPS’s current license, 

DPR-43, expires on December 21, 2013. The NRC’s Federal action is the decision whether or 

not to renew the license for an additional 20 years. 

1.2 PURPOSE AND NEED FOR PROPOSED FEDERAL ACTION 

The purpose and need for the proposed action (issuance of a renewed license) 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. These needs may be 

determined by State, utility, and, where authorized, Federal decision makers other than the 

NRC. This definition of purpose and need reflects the Commission’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 not grant a license renewal, the NRC does 

not have a role in the energy planning decisions of State regulators and utility officials as to 

whether or not a particular nuclear power plant should continue to operate.

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

whether the plant will continue to operate. This decision will be based on factors such as the 

need for power or other matters within the State’s jurisdiction or the purview of the owners. If the 

operating license is not renewed, then the facility must be shut down on or before the expiration 

date of the current operating license: December 21, 2013.
Purpose and Need for Action

NUREG-1437, Supplement 40 1-2 August 2010

1.3 MAJOR ENVIRONMENTAL REVIEW MILESTONES

Figure 1-1. Environmental Review Process. The environmental review provides 

opportunities for public involvement.

DEK submitted an environmental report (ER) (DEK, 2008) as part of its license renewal 

application in August 2008 (DEK, 2008a). After reviewing the application for sufficiency, the staff 

published a Notice of Acceptability and Opportunity for Hearing on October 1, 2008, in the 

Federal Register (Volume 73, p. 57154, (73 FR 57154)). The NRC published another notice on 

October 9, 2008, in the Federal Register (73 FR 59678) on its intent to conduct scoping, thereby 

beginning the 60-day scoping period.

A preliminary site audit was conducted during October 21–22, 2008 (NRC, 2009b). The 

objectives of the preliminary audit were to tour KPS’s general vicinity and gain familiarity with 

the ecological, historical, and cultural resources in the area.

Review 

Application

Environmental 

Site Audit

Draft 

SEIS

Issued

Application

Submitted to 

NRC

*Scoping

Process

*Draft 

SEIS 

Process

Final SEIS 

Issued

NRC 

Decision

*Opportunity

for Public 

Involvement
Purpose and Need for Action

August 2010 1-3 NUREG-1437, Supplement 40

The agency held two public scoping meetings on October 22, 2008, in the town of Carlton, 

Wisconsin. The NRC report entitled, “Environmental Impact Statement Scoping Process 

Summary Report for Kewaunee Power Station,” dated April 2009, presents the comments 

received during the scoping process (NRC, 2009a). Appendix A to this document presents the 

comments considered to be within the scope of the environmental license renewal review and 

the associated NRC responses. 

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

from May 26–28, 2009. During the site audit, the staff met with plant personnel, reviewed 

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

The agency published a summary of that site audit and a list of the attendees in a report 

entitled, “Summary of Site Audit Related to the Review of the License Renewal Application for 

Kewaunee Power Station,” dated August 12, 2009 (NRC, 2009c). 

Upon completion of the scoping period and site audit, the staff compiled its findings in this 

document, the supplemental EIS (SEIS), as shown in Figure 1-1. This draft document was 

made available for public comment for 75 days. During this time, the agency held two public 

scoping meetings on March 24, 2010, in the town of Carlton, Wisconsin to describe the 

preliminary results of the NRC environmental review, to answer questions, and to provide 

members of the public with information to assist them in formulating comments on the draft 

SEIS. When the draft SEIS comment period ended on April 23, 2010, the staff considered and 

addressed all of the comments received. These comments are addressed in Appendix A, 

“Comments Received on the Environmental Review.” Based on the information gathered, the 

staff amended the SEIS findings, as appropriate, and published the final SEIS.

A safety review of DEK’s license renewal application is conducted simultaneously with the 

environmental review. The staff documents the findings of the safety review in a safety 

evaluation report (SER). The Commission considers the findings in both the SEIS and the SER 

in its decision to either grant or deny the issuance of a new license. 

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. The Generic 

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

NUREG-1437 (NRC, 1996) documented the results of the 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. The staff analyzed in detail and resolved 

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

The GEIS establishes 92 separate issues for the staff to consider. Of these issues, the staff 

determined that 69 are generic to all plants (Category 1) while 21 issues do not lend themselves 

to generic consideration (Category 2). Two other issues remained uncategorized: environmental 

justice and chronic effects of electromagnetic fields, which must be evaluated on a site-specific

basis. A list of all 92 issues can be found in Appendix B. 

For each potential environmental issue, the GEIS: (1) describes the activity that affects the 

environment, (2) identifies the population or resource that is affected; (3) assesses the nature 

and magnitude of the impact on the affected population or resource; (4) characterizes the 

significance of the effect for both beneficial and adverse effects; (5) determines whether or not 

the results of the analysis apply to all plants, and (6) considers whether additional mitigation 
Purpose and Need for Action

NUREG-1437, Supplement 40 1-4 August 2010

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 (CEQ) 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 or 

not the analysis of the environmental issue could 

be applied to all plants and whether or not additional mitigation measures would be warranted 

(Figure 1-2). Issues are assigned a Category 1 or a Category 2 designation. As set forth in the 

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

(1) 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.

(2) 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).

(3) 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 likely not to be sufficiently beneficial to warrant implementation. 

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

supplemental EIS unless new and significant information is identified. The process for 

identifying new and significant information is presented in Chapter 4. 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 results of that sitespecific review are documented in the SEIS. 

Significance indicates the importance 

of likely environmental impacts and is 

determined by considering two 

variables: context and intensity.

Context is the geographic, 

biophysical, and social context in 

which the effects will occur.

Intensity refers to the severity of the 

impact, in whatever context it occurs.
Purpose and Need for Action

August 2010 1-5 NUREG-1437, Supplement 40

Figure 1-2. Environmental Issues Evaluated during License Renewal. Ninety-two issues 

were initially evaluated in the GEIS. A site-specific analysis is required for 23 of those 92 issues.

1.5 SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT 

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

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

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

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

to the Commission that the environmental impacts of license renewal are not great enough to 

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

was made after consideration of comments received during the public scoping period and on the 

draft SEIS.

In the preparation of this SEIS for KPS, the staff:

● reviewed the information provided in the DEK ER; 

● consulted with other Federal, State, and local agencies;

● conducted an independent review of the issues during site audit; and
Purpose and Need for Action

NUREG-1437, Supplement 40 1-6 August 2010

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.

● considered the public comments received during the scoping process and on 

the draft SEIS.

New information can be identified from a 

number of sources, including the applicant, 

NRC, other agencies, or public comments. 

If a new issue is revealed, then it is first 

analyzed to determine whether or not it is 

within the scope of the license renewal 

evaluation. If it is not addressed in the 

GEIS, then the NRC determines its 

significance and documents its analysis in 

the SEIS. No new information was identified in this review.

1.6 COOPERATING AGENCIES

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

agencies in the preparation of the SEIS. 

1.7 CONSULTATIONS

The Endangered Species Act (ESA) of 1973, as amended, the Magnuson-Stevens Fisheries 

Management Act of 1996, as amended, and the National Historic Preservation Act (NHPA) of 

1966 require that Federal agencies consult with applicable State and Federal agencies and 

groups prior to taking action that may affect endangered species, fisheries, or historic and 

archaeological resources, respectively. Below are the agencies and groups with whom NRC 

consulted. Consultation documents are included in Appendix D.

Table 1-1. Consultation Correspondence. List of the consultation documents sent by the NRC 

to other agencies.

Recipient Date of Letter

U.S. Fish and Wildlife Service

(L. Clemency) ML082610748 September 30, 2008

Advisory Council on Historic Preservation 

(D. Klima) ML082610168 October 8, 2008

Wisconsin Historical Society

(S. Banker) ML082670685 October 10, 2008

Wisconsin Coastal Management Program 

(K. Angel) ML082680027 October 10, 2008

Wisconsin Department of Natural Resources 

(R. Kazmierczak) ML082661119 October 10, 2008

Menominee Indian Tribe of Wisconsin

(T. Virden) ML082800098 October 16, 2008(a)

(a) Similar letters were sent to 23 other Native American Tribes listed in Section 1.8 and Appendix E.
Purpose and Need for Action

August 2010 1-7 NUREG-1437, Supplement 40

1.8 CORRESPONDENCE

During the course of the environmental review, the staff contacted the following Federal, State,

regional, local, and tribal agencies. Appendix E contains a chronological list of all the documents 

sent and received during the environmental review.

Advisory Council on Historic Preservation, Washington, D.C.

Bad River Band of Lake Superior Tribe of Chippewa Indians, Odanah, Wisconsin

Bay Mills Indian Community, Brimley, Minnesota

Bureau of Indian Affairs, Ft. Snelling, Minnesota

Citizen Potawatomi Nation, Shawnee, Oklahoma

Forest County Potawatomi Community of Wisconsin, Crandon, Wisconsin

Grand Traverse Band of Ottawa and Chippewa Indians, Suttons Bay, Minnesota

Hannahville Indian Community, Wilson, Minnesota

Ho-Chuck Nation, Black River Falls, Wisconsin

Huron Potawatomi, Inc., Fulton, Minnesota

Keweenaw Bay Indian Community, Baraga, Minnesota

Little Traverse Bay Bands of Odawa Indians, Harbor Springs, Minnesota

Little River Band of Ottawa Indians, Manistee, Minnesota

Lac Vieux Desert Band of Lake Superior Chippewa Indians, Watersmeet, 

Minnesota

Lac Courte Oreilles Band of Lake Superior Chippewa Indians of Wisconsin, 

Hayward, Wisconsin

Lac du Flambeau Band of Lake Superior Chippewa Indians of Wisconsin, 

Lac du Flambeau, Wisconsin

Menominee Indian Tribe of Wisconsin, Keshena, Wisconsin

Oneida Tribe of Indians Wisconsin, Oneida, Wisconsin

Pokagon Band of Potawatomi Indians, Dowagiac, Minnesota 

Prairie Band Potawatomi Nation, Mayetta, Kansas

Red Cliff Band of Lake Superior Chippewa Indians of Wisconsin, Bayfield, 

Wisconsin

Stockbridge Munsee Community of Wisconsin, Bowler, Wisconsin

Sault Ste. Marie Tribe of Chippewa Indians of Michigan, Sault Ste. Marie, 

Minnesota

Sokagon Chippewa Community, Mole Lake Band of Lake Superior Chippewa 

Indians, Crandon, Wisconsin

St. Croix Chippewa Indians of Wisconsin, Webster, Wisconsin

U.S. Fish and Wildlife Service, Green Bay, Wisconsin 
Purpose and Need for Action

NUREG-1437, Supplement 40 1-8 August 2010

U.S. Fish and Wildlife Service, New Franken, Wisconsin

Wisconsin Coastal Management Program, Madison, Wisconsin

Wisconsin Historical Society, Madison, Wisconsin

Wisconsin Department of Natural Resources, Green Bay, Wisconsin

A list of persons who received a copy of the draft SEIS is provided below:

Chris L. Funderburk, Director, 

Nuclear Licensing and Operations 

Support Dominion Resources 

Services, Inc.

William R. Matthews, Senior Vice 

President – Nuclear Operations 

Innsbrook Technical Center

Alan J. Price

Vice President – Nuclear 

Engineering Innsbrook Technical 

Center

Michael J. Wilson, Director

Nuclear Safety & Licensing

Dominion Energy Kewaunee, Inc.

William D. Corbin, Director – Nuclear 

Engineering Innsbrook Technical 

Center

Kewaunee Resident Inspectors 

Office

U.S. Nuclear Regulatory 

Commission

Thomas L. Breene

Dominion Energy Kewaunee, Inc., 

Kewaunee Power Station

Paul C. Aitken

Supervisor – License Renewal 

Project Innsbrook Technical Center

Lillian M. Cuoco, Esq.

Senior Counsel Dominion Resources 

Services, Inc.

Stephen E. Scace, Site Vice 

President Dominion Energy 

Kewaunee, Inc.

David R. Lewis, Pillsbury Winthrop 

Shaw Pittman

Ken Paplham

Board Supervisor, Town of Carlton

Jeff Kitsembel, P.E.

Public Service Commission of 

Wisconsin

Richard Gallagher, Senior Scientist, 

License Renewal

Dominion Resources Services, Inc

Ronald Kazmierczak, 

Regional Director, Wisconsin 

Department of Natural Resources

Kathleen Angel, Federal Consistency 

and Coastal Hazards Coordinator, 

Wisconsin Coastal Management 

Program

Steven Ugoretz, Environmental 

Analyst,

Wisconsin Department of Natural 

Resources

David Siebert, Director

Office of Energy Wisconsin 

Department of Natural Resources

David A. Heacock, President and 

Chief Nuclear Officer

Dominion Energy Kewaunee, Inc.

1.9 STATUS OF COMPLIANCE

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

and local requirements. A description of some of the major Federal statutes can be found in 

Appendix C of the GEIS.

There are numerous permits and licenses issued by Federal, State, and local authorities for 

activities at KPS, as shown in Table 1-2.
Purpose and Need for Action

August 2010 1-9 NUREG-1437, Supplement 40

Table 1-2. Licenses and Permits. Existing environmental authorizations for KPS.

(Source: DEK, 2008; NRC, 2010a; NRC, 2010b)

Permit and Applicable Statute Number Dates Responsible 

Agency

License to Operate (Atomic Energy 

Act (42 USC 2011, et seq.), 10 

CFR 50.10)

DPR-43 Issued: Not Listed

Expires: 12/21/13 NRC

Approval (10 CFR 20.2002 

Disposal of Contaminated WWTF 

Sludge)

N/A Issued: 11/13/95

Expires: Not Listed NRC

Registration (49 USC 5108, 

Hazardous Materials Shipments) 061810 551 002S Issued: 06/18/10

Expires: 06/30/11

Department of 

Transportation (DOT)

Notification of Regulated Waste

Activity (Federal Resource

Conservation and Recovery Act, 42 

USC 6912; Ch. 291 Wisconsin 

Statutes)

EPA ID#

WID00713016

Issued: Not Listed

Expires: Not Listed

Environmental

Protection Agency 

(EPA)

Permit for construction of water

intake and discharge structures in 

Lake Michigan (33 USC 403)

NCCOD-S 69-10 Issued: 12/12/68

Expires: Not Listed

U.S. Army Corps of

Engineers (USACE)

Permit for construction of water

intake and discharge structures in 

Lake Michigan (Ch. 283 Wisconsin

Statutes)

2-WP-2570 Issued: 12/04/67

Expires: Not Listed

Wisconsin 

Department of 

Natural Resources 

(WDNR)

Permit to construct and operate

(Ch. 281 Wisconsin Statutes)

3430 (Note: Current 

WPDES permit 

authorizes discharges.)

Issued: 11/26/85

Expires: Not Listed WDNR

Letter Approval (Note: Continued 

authorization via WPDES permit.)

(Ch. 283 Wisconsin Statutes)

N/A Issued: 08/05/92

Expires: Not Listed WDNR

Individual WPDES permit (Clean 

Water Act (33 USC Section 1251

et seq.), Ch. 283 Wisconsin 

Statutes)

WI-00001571-06

Issued: Not Listed

Expired: 06/30/10

(Authorization continues. 

Timely renewal 

application was 

submitted.)

WDNR

General WPDES Industrial Storm

Water Discharge Permit (Clean 

Water Act (33 USC Section 1251 et 

seq.), Ch. 283 Wisconsin Statutes)

WI-S049158-2

Issued: Not Listed

Expired: 03/31/06 

(Authorization continues.

Automatically reissued 

when new permit 

becomes available.)

WDNR

Air Pollution Control Operation 

Permit (Federal Clean Air Act (42 

USC 7401 et seq.), Ch. 285 

Wisconsin Statutes) 

431022790-F11 (Note: 

DEK is considering 

conversion of this 

permit to a “Type A 

Registration

Operation Permit,” Air

Pollution Control Permit

Number ROP-A01, 

issued by the WDNR.)

Issued: Not Listed

Expired: 06/19/07 

(Timely renewal 

application was 

submitted. Authorization 

continues under clause 

285.62(8) of the 

Wisconsin statutes.)

WDNR

Registration (Ch. 280 and 281

Wisconsin Statutes) 43104061 Issued: Not Listed

Expires: Not Listed WDNR
Purpose and Need for Action

NUREG-1437, Supplement 40 1-10 August 2010

Permit and Applicable Statute Number Dates Responsible 

Agency

High Capacity Well Approval (Ch. 

281 Wisconsin Statutes) 52802, 52803 Issued 01/26/68Expires: Not Listed WDNR

Aboveground Storage Tank 

Registration (Ch. 101.09 Wisconsin 

Statutes

Owner ID: 83035, Site 

ID: 679179, Tank ID: 

463455

Issued: Not Listed

Expires: Not Listed

Wisconsin 

Department of 

Commerce

Underground Storage Tank 

Registration (Federal Resource

Conservation and Recovery Act (42 

USC 6901 et seq.), Ch. 101.09 

Wisconsin Statutes)

Owner ID: 383035 ,Site 

ID: 679179, Tank IDs:

285236, 2852239,

406492, 771175,

978062

Issued: Not Listed 

Expires: 10/28/10

(Only 406492 and 

771175 require permits.)

Wisconsin 

Department of 

Commerce

License to ship radioactive material 

(Tennessee Code Annotated 

68-202-206)

T-WI003-L10 Issued: Not Listed

Expires: 12/31/10

Tennessee 

Department of 

Environment and 

Conservation

Site Access Permit (R313-26 of 

Utah Radiation Control Rules) 0704004220 Issued: 6/28/10

Expires: 6/28/11

Utah Department of 

Environmental 

Quality

1.10 REFERENCES 

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

Regulations for Domestic Licensing and Related Regulatory Functions.”

73 FR 57154, October 1, 2008, U.S. Nuclear Regulatory Commission, Washington, D.C., 

“Notice of Acceptance for Docketing of the Application and Notice of Opportunity for Hearing 

Regarding Renewal of Facility Operating License No. DPR-43 for an Additional 20-Year Period; 

Dominion Energy Kewaunee, Inc.; Kewaunee Power Station,” Federal Register, Volume 73, No. 

191, pp. 57154-57156, Washington, D.C.

73 FR 59678, October 9, 2008, U.S. Nuclear Regulatory Commission, Washington, D.C., 

“Dominion Energy Kewaunee, Inc., Kewaunee Power Station; Notice of Intent To Prepare an 

Environmental Impact Statement and Conduct Scoping Process,” Federal Register, Volume 73, 

No. 197, pp. 59678-59679, Washington, D.C.

Dominion Energy Kewaunee, Inc. (DEK). 2008. “Applicant’s Environmental Report – Operating 

License Renewal Stage. Appendix E of Application for Renewed Operating License, Kewaunee 

Power Station,” Docket No. 50-305, August 2008. Agency-wide Documents Access and 

Management System (ADAMS) Accession No. ML082341039.

Dominion Energy Kewaunee, Inc. (DEK). 2008a. “Application for Renewed Operating License, 

Kewaunee Power Station,” Docket No. 50-305, August 2008. ADAMS Accession Nos. 

ML082341020, ML082341038, ML082420854.

Dominion Energy Kewaunee, Inc. (DEK). 2010. “Dominion Energy Kewaunee, Inc. (DEK) 

Kewaunee Power Station Application for Renewed Operating License Comments on Draft 

Supplement 40 to the Generic Environmental Impact Statement,” Docket No. 50-305, April 12, 

2010. ADAMS Accession No. ML101060515.

Atomic Energy Act of 1954 (AEA), 42 USC 2011, et seq.

Endangered Species Act of 1973 (ESA), 16 USC 1531, et seq.

Magnuson-Stevens Fishery Conservation and Management Act, as amended by the 

Sustainable Fisheries Act of 1996, 16 USC 1855, et seq.
Purpose and Need for Action

August 2010 1-11 NUREG-1437, Supplement 40

National Environmental Policy Act of 1969 (NEPA), 42 USC 4321, et seq.

National Historic Preservation Act (NHPA), 16 USC 470, et seq.

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, D.C. 

ML040690705 and ML040690738.

U.S. Nuclear Regulatory Commission (NRC). 2009a. “Environmental Impact Statement Scoping 

Process Summary Report for Kewaunee Power Station,” April 6, 2009. ADAMS Accession No. 

ML090770880.

U.S. Nuclear Regulatory Commission (NRC). 2009b. “Kewaunee Power Station, October 21–

22, 2008, Site Audit Summary.” ADAMS Accession No. ML092180137.

U.S. Nuclear Regulatory Commission (NRC). 2009c. “Kewaunee Power Station, May 26–28, 

2009, Site Audit Summary.” ADAMS Accession No. ML092050144.

U.S. Nuclear Regulatory Commission (NRC). 2010a. E-mail between Jeremy Susco and Paul 

Aitken Regarding Kewaunee LRA Environmental Report. ADAMS Accession No. 

ML101270071.

U.S. Nuclear Regulatory Commission (NRC). 2010b. Updated Permit Info re Kewaunee LRA 

FSEIS. (ADAMS Accession No. ML101890676).
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August 2010 2-1 NUREG-1437, Supplement 40

2.0 AFFECTED ENVIRONMENT

Kewaunee Power Station (KPS) is an one-unit pressurized water reactor (PWR) power plant 

located on the west central shore of Lake Michigan in Kewaunee County, WI. KPS is 

approximately 30 miles (mi) east-southeast of Green Bay and 8 mi south of the city of 

Kewaunee. The KPS site boundary encompasses approximately 908 acres. Structures, 

facilities, and parking lots occupy approximately 60 acres, and approximately 450 acres are

used for agriculture. The balance remains in a mixture of woods, fields in various stages of 

succession, small wetlands and watercourses, and open areas. The site includes approximately 

2 mi of continuous frontage on the western shore of Lake Michigan. For purposes of the 

evaluation in this report, the “affected environment” is the environment that currently exists at 

and around KPS and its associated transmission lines’ rights–of–way (ROWs). Because existing 

conditions are at least partially the result of past construction and operation at the plant, the 

impacts of the past and ongoing actions and how they have shaped the environment are 

presented here. The facility and its operation are described in Section 2.1 and the affected 

environment is presented in Section 2.2.

2.1 FACILITY DESCRIPTION

This assessment of the affected environment begins with a description of KPS, which is the 

source of potential environmental effects. Figures 2-1 and 2-2 present the 50-mi and 

6-mi vicinity maps around KPS, respectively. With the exception of a highway traversing the site 

(State Route 42), town roads, and the Sandy Bay Cemetery, a 1.13-acre (ac) cemetery that is 

owned and maintained by the town of Carlton, all property within the site boundary is owned and 

operated by Dominion Energy Kewaunee, Inc. (DEK), as shown in Figure 2-3.
Affected Environment 

NUREG-1437, Supplement 40 2-2 August 2010

Figure 2-1. Kewaunee Power Station 50-Mile Radius
Affected Environment

August 2010 2-3 NUREG-1437, Supplement 40

Figure 2-2. Kewaunee Power Station 6-Mile Radius
Affected Environment 

NUREG-1437, Supplement 40 2-4 August 2010

Figure 2-3. Kewaunee Power Station Site Map
Affected Environment

August 2010 2-5 NUREG-1437, Supplement 40

2.1.1 Reactor and Containment Systems

KPS is a single unit, two-loop closed cycle PWR with a turbine generator. The reactor and 

turbine generator were furnished by Westinghouse Electric Corporation. Pioneer Services and 

Engineering supported the design and construction of the unit. The reactor is housed in a 

double containment consisting of a cylindrical steel shell surrounded by a reinforced concrete 

cylindrical shield building.

The KPS fuel is slightly enriched (less than 5 weight percent) uranium dioxide with an average 

burn up for the peak rod of 17,500 megawatt days per metric ton uranium. KPS was originally 

licensed for a thermal output of 1,650 megawatts-thermal (MWt) and gross electrical output of 

535 megawatts-electric (MWe). In 2004, the plant received a license amendment that increased 

the thermal output to 1,772 MWt and a gross electrical output of 590 MWe (DEK, 2008).

In a PWR power generation system, reactor heat is transferred from the primary coolant to a 

lower pressure secondary coolant loop, allowing steam to be generated in the steam supply 

system. Each of the primary coolant loops contain one steam generator, one reactor coolant 

pump, and interconnected piping. Reactor coolant is pumped from the reactor through the 

steam generators and back to the reactor. Each steam generator has a heat exchanger that 

produces superheated steam at a constant pressure over the reactor’s operating power range. 

Coolant flows through the tubes as steam is generated on the lower pressure shell side. The 

steam then flows from the steam generator to the turbine unit that turns the electrical generator.

2.1.2 Radioactive Waste Management

KPS’s radioactive waste system collects, treats, stores, and disposes of radioactive and 

potentially radioactive wastes that are byproducts of plant operations. The byproducts are 

activation products resulting from the irradiation of reactor water and impurities therein 

(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 the plant within the limits set forth in Title 10 of the Code of Federal 

Regulations (CFR) Part 20 (10 CFR 20), “Standards for Protection against Radiation” 

(DEK, 2008). 

Radioactive wastes resulting from plant operations are classified as liquid, gaseous, or solid. 

Radioactive liquid wastes are generated from liquids received directly from portions of the 

reactor coolant system or that were contaminated by contact with liquids from the reactor 

coolant system. Radioactive gaseous wastes are generated from gases or airborne particulates 

vented from reactor and turbine equipment containing radioactive material. Radioactive solid 

wastes are solids from the reactor coolant system, solids that contacted reactor coolant system 

liquids or gases, or solids used in the reactor coolant system or the power conversion system.

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. Spent fuel assemblies are stored in the two 

spent fuel pools located inside the plant and in dry casks located onsite, north of the plant

(DEK, 2008c).

The KPS offsite dose calculation manual (ODCM) contains the methodology and parameters 

used to calculate offsite doses resulting from radioactive gaseous and liquid effluents, and the 
Affected Environment 

NUREG-1437, Supplement 40 2-6 August 2010

gaseous and liquid effluent monitoring alarm and trip set points. The methodology is used to 

ensure that radioactive material discharged from the plant meets regulatory dose limits. The 

ODCM also contains the radioactive effluent controls and radiological environmental monitoring 

activities and descriptions of the information that is included in the annual environmental 

operating report and annual radioactive effluent release report (DEK, 2008c).

2.1.2.1 Radioactive Liquid Waste

The KPS liquid waste disposal system collects, holds, treats, processes, stores, and monitors all 

radioactive liquid wastes. The system is divided into subsystems so that liquid waste from 

various sources can be segregated and processed (DEK, 2008). Prior to discharge, the waste is 

sampled and analyzed to determine if it meets radiological release criteria. The waste is 

discharged under controlled conditions and monitored by a radiation detector. The release is 

terminated if the radiation level in the liquid waste exceeds a preset limit. Liquid releases to the 

environment are limited to the maximum extent possible to satisfy the dose objectives in 

Appendix I to 10 CFR Part 50, “Domestic Licensing of Production and Utilization Facilities,” and 

the dose limits in 10 CFR Part 20 (DEK, 2008).

The staff reviewed the KPS annual radioactive effluent release reports for liquid effluents from 

2004 through 2008 (DEK, 2005), (DEK, 2006), (DEK, 2007), (DEK, 2008a), (DEK, 2009). Based 

on the liquid waste processing system’s performance from 2004 through 2007, the liquid 

discharges for 2008 are typical of previous years. Variations on the amount of radioactive 

effluents released from year to year are expected based on the overall performance of the plant 

and the number and scope of outages and maintenance activities. The radioactive liquid wastes 

reported by KPS are reasonable, and no unusual trends were noted.

2.1.2.2 Radioactive Gaseous Waste

The KPS gaseous waste disposal system processes and disposes of radioactive gaseous 

effluent to the atmosphere. The system receives and processes gases from plant systems and 

components, which include the reactor coolant system, the chemical volume control system, 

cover gases in waste-holding tanks, and gases vented from plant components. The processed 

gases are routed to a vent that is monitored by a radiation monitor and released into the 

atmosphere (DEK, 2008).

KPS discharges gaseous waste in accordance with the procedures and methodology described 

in the ODCM. The radioactive gaseous waste system is used to reduce radioactive materials in 

gaseous effluents before discharge, per dose limits in 10 CFR Part 20 and dose design 

objectives in Appendix I to 10 CFR Part 50. The staff reviewed the KPS radioactive effluent 

release reports for gaseous effluents from 2004 through 2008 (DEK, 2005), (DEK, 2006), (DEK, 

2007), (DEK, 2008a), (DEK, 2009). Based on the gaseous waste processing system’s 

performance from 2004 through 2007, the gaseous discharges for 2008 are typical of previous 

years. Variations on the amount of radioactive effluents released from year to year are expected 

based on the overall performance of the plant and the number and scope of outages and 

maintenance activities. The radioactive gaseous wastes reported by KPS are reasonable, and 

no unusual trends were noted.

2.1.2.3 Radioactive Solid Waste

The radioactive solid waste management program at KPS is designed to safely collect, process, 

store, and prepare radioactive wet and dry solid waste materials for shipment to an offsite waste 

processor or for disposal.
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August 2010 2-7 NUREG-1437, Supplement 40

Solid wastes consist mainly of dry active waste, such as contaminated paper, plastic, wood, 

metals, and spent resin. Solid wastes are collected, analyzed, packaged, and shipped from the 

site according to the KPS solid radioactive waste process control program. The solid wastes are 

prepared in accordance with the requirements in 10 CFR Part 61, “Licensing Requirements for 

Land Disposal of Radioactive Waste,” for waste form and classification, as well as disposal 

site-specific regulations (DEK, 2008).

The State of South Carolina’s licensed low-level radioactive waste disposal facility, located in 

Barnwell, has limited the access from radioactive waste generators located in States that are 

not part of the Atlantic Low-level Waste Compact. Wisconsin is not a member of the Atlantic 

Low-level Waste Compact; however, this has had a minimal effect on KPS’s ability to handle its 

radioactive solid low-level waste. KPS uses an offsite vendor to perform volume reduction of its 

waste and based on the generation rate and volume reduction practices, KPS has adequate 

storage capacity for its radioactive waste during the license renewal term.

KPS also generates and stores very small quantities of low-level mixed waste (LLMW). LLMW is 

waste that exhibits hazardous characteristics and contains low levels of radioactivity.

The staff reviewed the 2004 through 2008 KPS low-level radioactive waste reports 

(DEK, 2005), (DEK, 2006), (DEK, 2007), (DEK, 2008a), (DEK, 2009). The solid waste volumes 

and radioactivity amounts generated in 2008 are typical of previous annual waste shipments 

made by KPS. Variations in the amount of radioactive solid waste generated and shipped from 

year to year are expected based on the overall performance of the plant and the number and 

scope of outages and maintenance activities. The volume and activity of radioactive solid 

wastes reported by KPS are reasonable, and no unusual trends were noted.

No plant refurbishment activities were identified by the applicant as necessary for the continued 

operation of KPS through the license renewal term. Routine plant operational and maintenance 

activities currently performed will continue during the license renewal term. Based on the past 

performance of the radioactive waste system and the lack of any planned refurbishment 

activities, similar amounts of radioactive solid waste are expected to be generated during the 

license renewal term.

2.1.3 Nonradioactive Waste Management

The Resource Conservation and Recovery Act (RCRA) governs the disposal of solid and 

hazardous waste. RCRA regulations are contained in 40 CFR, Protection of the Environment, 

Parts 239 through 299 (40 CFR 239, et seq.). Parts 239 through 259 of 40 CFR contain 

regulations for solid (nonhazardous) waste, and Parts 260 through 279 contain regulations for 

hazardous waste. RCRA Subtitle C establishes a system for controlling hazardous waste from 

“cradle to grave,” and Subtitle D encourages States to develop comprehensive plans to manage 

nonhazardous solid waste and mandates minimum technological standards for municipal solid 

waste landfills (EPA, 2007). 

In Wisconsin, RCRA regulations are administered by the Waste and Materials Management 

Program of the Wisconsin Department of Natural Resources (WDNR). The Waste and Materials 

Management Program has many administrative codes and State statutes that govern the 

regulation of solid and hazardous waste. Chapter 289 of the Wisconsin State statutes and 

chapters NR 500 and NR 502, among others, of the Wisconsin administrative code address 

general solid waste management requirements, including storage, transportation, transfer, and 

incineration. Chapter 291 of the Wisconsin State statutes and chapters NR 660 through NR 666, 
Affected Environment 

NUREG-1437, Supplement 40 2-8 August 2010

NR 668, and NR 670 of the Wisconsin administrative code address the identification, 

generation, minimization, transportation, and final treatment, storage, or disposal of hazardous 

wastes. 

Nonradiological waste streams generated at KPS include used oil, hazardous and 

nonhazardous solvents and degreasers, laboratory wastes, unused expired chemicals, 

asbestos wastes, paint strippers, universal wastes, antifreeze, one-time only (i.e., project 

specific wastes, point-source discharges) regulated under the Wisconsin Pollutant Discharge 

Elimination System (WPDES), sanitary waste, including sewage, and general plant trash 

(DEK, 2009e).

2.1.3.1 Hazardous Waste

Hazardous waste means solid waste, or a combination of solid wastes, which, because of its 

quantity, concentration, or physical, chemical, or infectious characteristics, may cause or 

contribute to an increase in mortality or serious illness. Such waste may also pose a significant 

present or potential hazard to human health or the environment if it is not properly treated, 

stored, transported, disposed of, or otherwise handled (40 CFR Part 261, “Identification and 

Listing of Hazardous Waste”). 

KPS generates a small amount of hazardous waste each year, primarily consisting of unused 

expired laboratory chemicals and hazardous solvents and degreasers (DEK, 2009e). KPS is 

classified as a “small quantity generator” of hazardous waste because the plant generates less 

than 2,205 pounds (lbs) (1,000 kilograms (kg)) of hazardous waste in one month; no more than 

13,228 lbs (6,000 kg) of hazardous waste may be accumulated on site at any one time; and 

accumulated hazardous waste is stored in aboveground tanks or containers for no more than 

180 or 270 days, depending on the distance the waste is transported for disposal (EPA, 2007). 

During the KPS site audit in May 2009, the staff toured the warehouse where hazardous and 

universal wastes are safely and properly collected, sorted, packaged, and temporarily stored 

until offsite disposal. The staff also reviewed the DEK hazardous waste procedures documented 

in the “Kewaunee Power Station Hazardous Waste Plan” (DEK, 2009e) and determined that 

they are consistent with applicable RCRA regulations.

2.1.3.2 General Plant Trash

As part of routine plant maintenance and operations, KPS generates solid waste, as defined by 

RCRA. General plant trash includes paper, garbage, and construction waste. In 2008, KPS 

generated approximately 256 tons (232 metric tons (MT)) of general plant trash, and over the 

past five years, it has generated approximately 1,000 tons (907 MT) of trash (DEK, 2009e). The 

majority of KPS trash is collected in a compactor dumpster to minimize volume and trips to the 

Kewaunee County landfill in West Kewaunee (DEK, 2008). The recycling program at KPS is 

discussed below in Section 2.1.3.6.

2.1.3.3 Universal Waste

Universal waste is hazardous waste that is generated in a variety of settings and by a vast 

community and poses collection and management problems. Universal waste is often not 

appropriately managed under existing hazardous waste regulations. The Environmental 

Protection Agency (EPA) classifies several hazardous wastes as universal wastes, including 

batteries, certain pesticides, mercury containing devices, and fluorescent lamps 

(40 CFR Part 273, “Standards for Universal Waste Management”). KPS is a small-quantity 

handler of universal waste (i.e., the facility cannot accumulate more than 11,000 lbs (5,000 kg) 

of universal waste at any one time). KPS generates common operational wastes, such as 
Affected Environment

August 2010 2-9 NUREG-1437, Supplement 40

lighting ballasts containing polychlorinated biphenyls (PCBs), lamps, and batteries. From 2006 

through 2008, KPS generated approximately 8 tons (16,000 lbs (7,257 kg)) of universal waste 

(DEK, 2009e). Common universal waste is packaged together and stored in the onsite 

warehouse until disposed of offsite by a licensed disposal company.

2.1.3.4 Low-level Mixed Waste

As previously discussed in Section 2.1.2.3, LLMW contains both low-level radioactive waste and 

RCRA hazardous waste (40 CFR Part 266, “Storage, Treatment, Transportation, and Disposal 

of Mixed Waste”). KPS generates very small quantities of LLMW. From 2006 through 2008, 

LLMW at KPS consisted of Agitene (a cleaning solvent), paint residue, and excess caustic from 

testing and repair of caustic standpipe pumps. KPS generated 23 lbs (10.4 kg) of mixed waste 

in 2006, 25 lbs (11.4 kg) in 2007, and 14 lbs (6.4 kg) in 2008. As permitted by WDNR 

regulations, Agitene was disposed of by diluting it in the used oil stream and sent to the boiler 

fuel oil tank, as approved by the WDNR air permit for KPS (DEK, 2009c).

2.1.3.5 Permitted Discharges

KPS generates two types of wastewater—industrial effluents and sanitary liquid wastes, both of 

which are discharged to Lake Michigan according to the KPS WPDES Permit No. 

WI-0001571-07-0, as enforced by WDNR (radioactive liquid waste is addressed in Section 

2.1.2.1 of this report). A hypochlorinating system intermittently injects sodium hypochlorite into 

the condenser inlet waterboxes to clean and defoul the condenser of biological organisms and 

prevent the build-up of zebra mussels (Dreissena polymorpha) within the cooling system 

(DEK, 2008). This normal operational process generates chemical and biocide liquid wastes 

that are combined with the plant cooling water discharge. KPS cooling water is discharged to 

Lake Michigan within the plant’s WPDES permit limitations. Section 2.1.7.3 of this report 

provides more information on KPS WPDES permit and effluent limitations.

KPS operates a permitted (WDNR Permit No. 3430) onsite sewage treatment facility to treat 

sanitary wastewater generated by the plant. The sewage treatment facility discharges through a 

WPDES-permitted outfall to an unnamed tributary that flows to Lake Michigan. The sewage 

treatment facility has a design capability of 20,000 gallons per day (gpd) (75,708 liters per day 

(Lpd)); however, routine sewage processing is approximately 11,000 gpd (41,640 Lpd). During 

outage periods when more workers are onsite, this number approaches the design capacity 

(DEK, 2009e). Digested sanitary sludge is periodically transferred to a sludge holding tank 

where it is concentrated and sent for disposal to a WDNR-approved sewage treatment facility in 

Green Bay (DEK, 2008). 

2.1.3.6 Pollution Prevention and Waste Minimization

Currently, KPS implements a waste minimization program that consists of steps such as 

segregating hazardous and nonhazardous wastes, choosing nonhazardous substitutes when 

possible, recycling or reclaiming appropriate waste materials, monitoring expired chemicals to 

determine minimum stocking requirements to reduce recurring excess, finding alternate uses for 

excess materials, or returning unused materials to the manufacturer. KPS also implements a 

recycling program for common waste materials, such as paper, plastic, and metal. From 2006 

through 2008, KPS recycled 289.4 tons (263 MT) of non-metal materials (i.e., paper, plastic, 

and cardboard) and 71.5 tons (65 MT) of metal. 

In support of nonradiological waste minimization efforts, the EPA Office of Pollution Prevention 

and Toxics established a clearinghouse that provides information regarding waste management 

and technical and operational approaches to pollution prevention. The EPA clearinghouse can 
Affected Environment 

NUREG-1437, Supplement 40 2-10 August 2010

be used as a source for additional opportunities for waste minimization and pollution prevention 

at KPS, as appropriate (EPA, 2008f).

The EPA also encourages the use of environmental management systems (EMSs) for 

organizations to assess and manage the environmental impact associated with their activities, 

products, and services in an efficient and cost-effective manner. The EPA defines an EMS as “a 

set of processes and practices that enable an organization to reduce its environmental impacts 

and increase its operating efficiency.” EMSs help organizations fully integrate a wide range of 

environmental initiatives, establish environmental goals, and create a continuous monitoring 

process to help meet those goals. The EPA Office of Solid Waste especially advocates the use 

of EMSs at RCRA-regulated facilities to improve environmental performance, compliance, and 

pollution prevention (EPA 2008f). 

2.1.4 Plant Operation and Maintenance

Maintenance activities conducted at KPS include inspection, testing, and surveillance to 

maintain the current licensing basis of the facility and to ensure compliance with environmental 

and safety requirements. Various programs and activities currently exist at KPS 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 

in-service inspection and testing, maintenance structures monitoring program, and maintenance 

of water chemistry.

Additional programs include those implemented to meet technical specification surveillance 

requirements, those implemented in response to NRC generic communications, and various 

periodic maintenance, testing, and inspection procedures. Certain program activities are 

performed during the operation of the unit, while others are performed during scheduled 

refueling outages. Nuclear power plants must periodically discontinue the production of 

electricity for refueling, periodic in-service inspection, and scheduled maintenance. KPS refuels 

at 18-month intervals.

2.1.5 Power Transmission Systems

As stated in the environmental report (ER) for the license renewal of KPS (DEK, 2008):

In 1999, the Wisconsin legislature passed Act 9, which encouraged utilities with 

service areas in Wisconsin to transfer ownership and operation of transmission 

assets to an independent transmission company. In response to the Act, WPSC 

[Wisconsin Public Service Corporation] and WP&L [Wisconsin Power and Light 

Company (owners of KPS at the time)] transferred ownership of their 

transmission lines to the American Transmission Company (ATC).

ATC, DEK, and Midwest Independent Transmission System Operator (MISO) 

have a three-party Generator to Transmission Interconnection Agreement for 

KPS filed with the Federal Energy Regulatory Commission (FERC), whereby 

ATC transferred operation of its facilities to the MISO. In doing so, ATC acts in 

the capacity of the transmission system operator and MISO is the independent 

system operator.

KPS is connected to the regional grid via two 138-kilovolt (kV) and two 345-kV transmission 

lines, which total 80.6 mi (129.7 kilometers (km)) in length. Transmission lines considered in 

scope for license renewal are those constructed to connect the facility to the transmission 
Affected Environment

August 2010 2-11 NUREG-1437, Supplement 40

system; therefore, the four lines (Line F-84, Line Y-51, Line R-304, and Line Q-303) are 

considered in scope and are discussed below in detail.

Four transmission lines originate at the KPS switchyard and are shown in Figure 2-4. 

Line F-84, which is a 138-kV transmission line, connects from the KPS site substation to the 

East Krok substation and travels a total distance of 8.2 mi (13.2 km). Line Y-51, which is also a 

138-kV transmission line, connects from the KPS site to the Shoto substation, which is 16.2 mi 

(26.1 km) in total length. Line R-304, a 345-kV transmission line, is the longest transmission line 

associated with the KPS site and connects from the KPS site to the North Appleton substation, 

traveling a total distance of 50.6 mi (81.4 km). Finally, line Q-303, also a 345-kV transmission 

line, travels a total distance of 5.6 mi (9.0 km), connecting from the KPS site substation to the 

Point Beach Nuclear Plant substation (DEK, 2008).

The transmission lines associated with the KPS site have ROWs with an average width of 

150 feet (ft) (45.7 meters (m)). Additionally, there is a 50-ft (15-m) minimum buffer between the 

ROWs and any waterways and wetlands, within which DEK states that selective hand-cutting is 

an acceptable means of vegetation management; however, buffers can vary up to 200 ft (61 m), 

based on agreements with the landowners or the State (DEK, 2010). These transmission line 

ROWs total 75 mi (121 km) of corridor, and account for an area of approximately 1,270 ac 

(514 hectares (ha)). The substation on the KPS site, the switchyards off site, and transmission 

towers (poles) occupy approximately 10 ac (4 ha). Land types along the transmission line 

ROWs are comprised of approximately 84 percent farmland, 7 percent woodland, 2 percent 

wetlands, and 7 percent scrubland (DEK, 2008).
Affected Environment 

NUREG-1437, Supplement 40 2-12 August 2010

Figure 2-4. Kewaunee Power Station Transmission Line System
Affected Environment

August 2010 2-13 NUREG-1437, Supplement 40

2.1.6 Cooling and Auxiliary Water Systems

KPS uses a once-through heat dissipation system that withdraws water from, and discharges it 

to, Lake Michigan. Unless otherwise noted, the discussion of the cooling-water system is 

adapted from the ER (DEK, 2008), or information gathered by the NRC at the site audit.

Water is withdrawn from Lake Michigan via an intake structure located approximately 1,600 ft 

(488 m) from the shore, east-northeast of KPS. The circulating water intake structure consists of 

a cluster of three inlets that are submerged at a depth of 15 ft (4.6 m). Each inlet is 22 ft (6.7 m) 

in diameter and contains 2- by 2-ft (0.6- by 0.6-m) trash grills to prevent the intake of debris. 

Surface water velocity at the intake inlets is less than 1 foot per second (fps) or 0.3 meters per 

second (m/s) when the plant is running at full power. The three intake inlets are each reduced to 

6-ft (1.8-m) diameter steel pipes, which join to one 10-ft (3-m) diameter steel pipe buried 

approximately 3 ft (0.9 m) below the lake bottom. The buried intake pipe brings water to a 56.5-

by 25-ft (17.2- by 7.6-m) onshore forebay, which contains a 38.5-ft (11.7-m) long weir for 

overflow. Water velocity within the forebay ranges from 0.72 to 2.9 fps (0.22 to 0.88 m/s) at 

maximum flow and from 0.33 to 1.6 fps (0.10 to 0.5 m/s) at minimum flow (NES, 1976b). From 

the forebay, water passes through four 10-ft (3-m) wide by 36-ft (11-m) long woven wire 

traveling screens with 3/8-inch (0.95-centimeter (cm)) mesh and automatic backwash that 

extend from the forebay bottom to 10 ft (3 m) above water level (NES, 1976b). During normal 

operation, the screens are automatically rotated every 4 hours for a 45-minute duration or for a 

10-minute duration during a 6-inch (15-cm) pressure drop (NES, 1976b). Any fish and debris 

that are automatically backwashed from the traveling screens are returned to the lake via the 

10-ft (3-m) diameter discharge tunnel.

Once taken in, water is pumped by two vertical dry-pit circulating water pumps; each designed 

to supply 210,000 gallons per minute (gpm) (468 cubic feet per second (cfs) or 13.2 cubic 

meters per second (m3

/s)). Normal flow rate throughout the cooling system is approximately 

400,000 gpm (891 cfs or 25.2 m3

/s) when both circulating pumps are running. In the winter 

months, the reduced temperature of the lake requires less water for cooling, such that the flow 

rate is reduced to approximately 287,000 gpm (639 cfs or 18.1 m3

/s) (AEC, 1972). Generally, 

higher flow rates are employed from May through November, and lower flow rates are employed 

from December through April (NES, 1976b).

Water is returned to Lake Michigan via a 10-ft (3-m) diameter concrete discharge tunnel after 

passing through the condenser. The discharge tunnel connects to a discharge structure located 

on the shoreline, just south of the forebay. During periods of sub-freezing weather, a 

recirculating pump routes water to the intake inlet grills and traveling screens to prevent icing.

In addition to the circulating water intake, two auxiliary water intake tees are located 50 and 

100 ft (15 and 30 m) shoreward of the circulating water intake. Each tee has a 30-inch (76-cm), 

screened opening approximately 1 ft (0.3 m) above the lake bottom. The screen cover plates on 

the openings prevent entrainment of debris and aquatic organisms. Each auxiliary water intake 

can supply water in excess of 24,000 gpm (53.5 cfs or 1.5 m3

/s).

Cooling water is intermittently treated with sodium hypochlorite to prevent micro- and 

macro-fouling within the cooling system in accordance with limits specified in the KPS WPDES 

permit (WDNR, 2005).
Affected Environment 

NUREG-1437, Supplement 40 2-14 August 2010

2.1.7 Facility Water Use and Quality

Both the KPS circulating water system and the service water system draw water from, and 

discharge to, Lake Michigan. Onsite groundwater wells (none are Ranney wells) also supply 

water for cooling water makeup and for the plant equipment water system. The following 

sections detail water use at KPS. 

2.1.7.1 Groundwater Use

Groundwater use at KPS is relatively minor compared to the total amount of water used for 

operations. Specifically, KPS uses groundwater for cooling, stand-by cooling, potable water, and 

for the plant equipment water system (DEK, 2008), (DEK, 2010). The plant draws onsite 

groundwater from two wells installed at depths of 310 ft (94 m) and 320 ft (98 m). WDNR 

permits groundwater withdrawals from these wells, which averaged a total annual pump rate of 

3,339,176 gallons per year (6.4 gpm or 4.0 x 10-4 m3

/s) from 1977 to 1989 (DEK, 2009a). In 

1995, this withdrawal rate increased to an average total pump rate of 25 gpm (1.6 x 10-3 m3

/s) 

to 61 gpm (3.9 x 10-3 m3

/s) (DEK, 2009a). An additional 14 wells were installed in 2007 for 

groundwater monitoring purposes (STS, 2007).

2.1.7.2 Surface Water Use

KPS withdraws approximately 400,000 gpm (891 cfs or 25.2 m3/s) from Lake Michigan when 

both pumps are operating. Because KPS uses a once-through cooling system, consumptive 

water losses are minimal, and the majority of the cooling water withdrawn is discharged directly 

back to Lake Michigan in a manner complying with the plant’s WPDES Wastewater Discharge 

Permit No. WI-00001571-06 issued by WDNR in 2005 (WDNR, 2005). 

The intake structure is designed to pump lake water into the system via a 10-ft diameter (3 m) 

pipe. Normal lake elevation at the intake is 577 ft (176 m). During summer operations, when two 

of the plant’s circulating water pumps are in service, the water level in the intake forebay is 

approximately 571 ft (174 m). During winter operations, when only one circulating water pump is 

in service, the water level is approximately 574 ft (175 m). Because the circulating water pump 

requires a level of at least 566 ft (172.5 m), low level procedures are activated for the plant if the 

water level decreases to 567.5 ft (173 m) (DEK, 2008d). 

2.1.7.3 Dredging

KPS does not conduct any maintenance dredging activities and does not plan to initiate any 

during the license renewal term (DEK, 2008).

2.2 AFFECTED ENVIRONMENT

KPS is located on approximately 908 ac of land owned and operated by DEK, on the 

west-central shore of Lake Michigan in Kewaunee County, WI, as shown in Figure 2-2. Of the 

908 ac, 450 ac are currently used for agriculture. The developed portion of the site consisting of 

the power plant structure, reactor containment, and associated buildings, maintenance facilities, 

parking lots, and roads occupies approximately 60 ac of the site. The balance of land remains in 

a mixture of woods, fields in various stages of succession, small wetlands and watercourses, 

and open areas (DEK, 2008).
Affected Environment

August 2010 2-15 NUREG-1437, Supplement 40

2.2.1 Land Use

The immediate area around KPS is completely enclosed by a security fence, with access to the 

station controlled at a security gate. The exclusion area, as defined by 10 CFR 100.3, surrounds 

the plant site as shown in Figure 2-3. The plant site can be accessed by road on the west side 

or from Lake Michigan on the east. Road access to the plant site is from State Highway 42 

(DEK, 2008). The Two Creeks Buried Forest State Natural Area, a unit of the Ice Age National 

Scientific Reserve, is located approximately 1 mile south of the KPS property. The Reserve is a 

separate affiliated area of the National Park Service.

2.2.2 Air Quality and Meteorology

KPS is located in Carlton, Kewaunee County, WI, approximately 27 mi (44 km) southeast of 

Green Bay on the western shore of Lake Michigan, in the eastern part of Wisconsin. Slightly 

rolling topography of the region was formed by continental glaciers that slowly moved across 

Wisconsin for lengthy periods of time, leaving behind ground moraine of till, sand, and gravel. 

The climate of Wisconsin is continental and belongs to “Dfb” type of the Köppen climate 

classification: hot summers with very cold winters and evenly distributed precipitation throughout 

the year. The growing season is significantly longer in the eastern part of Wisconsin (from late 

April–early May to late September–early October), due to the influence of Lake Michigan, than 

in central and northern parts of Wisconsin. The growing season in southwestern parts of the 

State has the same duration. The first fall freezes usually occur in mid-October. 

The dominant wind direction throughout the State of Wisconsin is from the west. However, wind 

direction near KPS is variable due to the close proximity to Lake Michigan, which also 

contributes to having both onshore and offshore winds. Onshore winds blow northeast from 

Lake Michigan toward land, while offshore winds blow southwest from the land to Lake 

Michigan. There are seasonal wind direction variations, such as northeast wind occurrences in 

the spring and northwestern winds in winter that comprise the majority of the winds at KPS. The 

average annual wind speed for the National Weather Service Station located in Green Bay, WI, 

(27 mi (44 km) northwest of KPS) is 9.9 miles per hour (mph) (8.9 knots).

Wisconsin belongs to the Midwestern Regional Climate Center of the National Oceanic and 

Atmospheric Administration (NOAA). Historical data compiled by NOAA National Climatic Data 

Center (NCDC) over a 30-year period from 1971 to 2000 indicates that the mean annual 

temperature in Kewaunee County is 44.1 °F (6.7 °C) and ranges from 68.6 °F (20.3 °C) in July 

to 18 °F (7.78 °C) in January (NCDC, 2009a). According to the Center’s historic climate data for 

the Kewaunee 3 NW, WI Station, which is located approximately 8 mi (13 km) from KPS, annual 

precipitation is approximately 30.30 inches (77 cm), with the June–September period being the 

wettest (NCDC, 2009). Precipitation is distributed according to the demands of the seasons with 

the majority of the precipitation occurring during the growing, freeze-free period; however, 

occasionally droughts do occur in the area. Severe weather is typical for Wisconsin. Floods 

have caused the most damage to the people and property in the State. According to the data 

recorded by NCDC, 935 floods occurred in the State of Wisconsin from 1950 to 2008 

(NCDC, 2009b). Two flood events were reported in Kewaunee County: the flood of June 1996, 

which affected several counties of Eastern Wisconsin and caused $56 million in property 

damages, and the flood of March 2007, caused by heavy snowfall, which did not cause any 

damages. Seven tornadoes hit Kewaunee County between 1950 and 2009 (NCDC, 2009c).
Affected Environment 

NUREG-1437, Supplement 40 2-16 August 2010

2.2.2.1 Regional Air Quality Impacts

Kewaunee County is part of the Lake Michigan Intrastate Air Quality Control Region (AQCR) 

designated by the EPA and codified in 40 CFR 81.67 and Chapter 404.03 of the Wisconsin 

Administrative Code. Three of the seventeen counties in Wisconsin that are a part of the Lake 

Michigan Intrastate AQCR (Door, Manitowoc, and Sheboygan) make up sub-region 1. These 

three sub-region 1 counties are located near Kewaunee County and currently are designated by 

the EPA as 8-hour ozone non-attainment areas (EPA, 2008). Kewaunee County is a 

maintenance county for 8-hour ozone and is in attainment for all other criteria pollutants (EPA, 

2009). 

WDNR implements the Air Management Program and coordinates the ambient air quality 

monitoring network in the State of Wisconsin. Kewaunee County is part of the Northeastern Air 

Region of the WDNR. The closest KPS WDNR ozone monitoring station within the Kewaunee 

County is located in the city of Kewaunee and has been in operation since 1994. In October 

2006, the EPA issued final amendments to the ambient air monitoring regulations for criteria 

pollutants (40 CFR Parts 53 and 58) containing the requirement to establish National Core 

(NCore) multi-pollutant higher-sensitivity monitoring stations throughout the country. The 

Mayville WDNR monitoring site, located approximately 78 mi (126 km) southwest of KPS, is 

proposed for this purpose. 

KPS stationary emission sources that do not require the facility to secure a Title V permit are: 

three standby emergency power supply diesel generators, one space heating boiler, and 

several insignificant emission units that are listed in the KPS Air Pollution Control Operation 

Permit. KPS is recognized as a Synthetic Minor facility, non-Part 70 by WDNR due to the 

quantities of emissions and restrictions on the hours of operation of its stationary sources of 

criteria pollutants (DEK, 2009d). The generators are tested periodically to ensure their continued 

ability to perform their intended function. There are procedures in place to ensure continuous 

monitoring, sampling, and filtering of the oil. 

KPS operates a meteorological system that consists of weather instruments mounted on a 

primary 197-ft (60-m) high tower and 33-ft (10-m) backup tower, which provides alternative 

measurements and serves as a secondary data source in the event of sensor failure on the 

primary tower. There are wind sensors mounted on the primary tower that allow for the 

calculation of horizontal wind direction standard deviation. The sensors are located at 10 and 

60 m height. Vertical temperature differentials are measured with redundant sensor pairs 

between both levels. Ambient temperature sensors are located at the 10-m level. Precipitation is 

measured at ground level. The backup tower measures ambient temperature, wind speed, 

direction, and standard deviation at the 33-ft (10-m) level in the event of primary tower failure.

There is an established real time review and data quality assurance program for meteorological 

data. The quality control process involves routine daily inspection of the meteorological data and 

biweekly review, comparison, and processing of the data by the meteorological staff of the 

Dominion Weather Center. The quality assured meteorological data is then incorporated into the 

Annual Radioactive Release Reports (DEK, 2009d).

Sections 101(b) (1), 110, 169(a) (2), and 301(a) of the Clean Air Act as amended (42 U.S.C.

7401 et seq.) established mandatory Class I Federal areas where visibility is important. There 

are no mandatory Class I Federal areas in the State of Wisconsin or in close proximity to KPS. 

The mandatory Class I Federal areas closest to KPS are Seney Wilderness Area, MI, located 

149 mi northeast from KPS, and Isle Royale National Park, MI, located 255 mi northwest from 

KPS. Therefore, no adverse impacts on Class I areas are anticipated from KPS operation.
Affected Environment

August 2010 2-17 NUREG-1437, Supplement 40

2.2.3 Groundwater Resources

The soil profile at the KPS site consists of glacial drift made up primarily of silty clay, ranging 

from 60 to 150 ft (18 to 46 m) thick. Underlying the glacial material is a 350-ft (107-m) to 600-ft 

(183-m) thick layer of sedimentary bedrock. The water table underneath the KPS site ranges 

from 10 to 30 ft (3 to 9 m) below land surface and slopes east toward Lake Michigan 

(STS, 2007). 

The three principal aquifers beneath the site are the Glacial Outwash Aquifer, the Niagara 

Dolomite Aquifer, and the Deep Sandstone Aquifer. An additional minor aquifer, the St. Peter 

Sandstone Aquifer, is of limited groundwater use. About half of the local wells are screened in 

the Glacial Outwash Aquifer, which is made up of sand and gravel layers, the largest of which is 

not continuous at the site (STS, 2007). Wells screened in this aquifer have a flow rate of 

approximately 17 gpm (1.1 x 10-3 m3

/s). The other half of the local wells is screened in the 

Niagara Dolomite Aquifer, the uppermost bedrock aquifer along the Lake Michigan coastline. 

Wells screened in this aquifer typically have a depth between 30 and 60 ft (9 to 18 m) and have 

a flow rate of approximately 13 gpm (8.2 x 10-4 m3

/s). Wells pumped within this aquifer have 

been known to affect the water levels of nearby wells, and those near the shoreline of Lake 

Michigan may induce water flow from the lake into the aquifer (DEK, 2007b). The two 

groundwater wells used by KPS draw water from the Niagara Dolomite Aquifer at depths of 

310 ft (94 m) and 320 ft (98 m) (DEK, 1968).

The third and deepest major aquifer, the Deep Sandstone Aquifer, is between 1,200 and 

1,700 ft (366 to 518 m) and includes the Dresbach, Franconia, and Trempealeu formations. This 

aquifer is separated from the Niagara Dolomite by 800 ft (244 m) of shale and dolomite strata. 

Water in the Deep Sandstone Aquifer is not potable because it is too saline (DEK, 2007b). 

Figure 2-5 illustrates the primary aquifers beneath KPS.
Affected Environment 

NUREG-1437, Supplement 40 2-18 August 2010

 Glacial 

 

 

Source: WDNR, 2009f

Figure 2-5. Primary Aquifers Beneath the Kewaunee Power Station Site

2.2.3.1 Kewaunee Power Station Water Supply Wells

KPS has two high capacity onsite wells screened in the Niagara Dolomite Aquifer (DEK, 1968). 

These wells are permitted for groundwater withdrawal by WDNR. The first well (BE601) is 310 ft 

(94 m) in depth and 10 inches (25.4 cm) in diameter. The second well (BE602) is 320 ft (98 m) 

in depth and 10 inches (25.4 cm) in diameter (DEK, 2007a).

Together, both wells yield an average total of 25 gpm (1.6 x 10-3 m3/s) to 61 gpm 

(3.9 x 10-3 m3

/s). The highest recorded monthly average yield occurred in January 2008 at 

52.6 gpm (3.3 x 10-3 m3

/s) (DEK, 2009a). The data in Table 2-1 from August 2008 to February 

2009 is incorrect due to equipment problems. DEK installed new flow totalizers in March 2009. 

From March 2009 to December 2009, KPS withdrew an average of 38 gpm from the wells, 

which is consistent with previous years (DEK, 2010).

Outwash Aquifer

Niagara Dolomite Aquifer

Deep Sandstone Aquifer
Affected Environment

August 2010 2-19 NUREG-1437, Supplement 40

Table 2-1. Potable Water Usage (Gallons) at Kewaunee Power Station

Month Well Well Total Usage Average 

Usage Average Usage Average Usage

1A 1B Per Day Per Hour Per Min

Sep-07 2,109,465 284 2,109,749 72,750 3,031 50.5

Oct-07 2,391,263 17,339 2,408,602 72,988 3,041 50.7

Nov-07 2,139,279 0 2,139,279 71,309 2,971 49.5

Dec-07 1,858,387 435 1,858,822 58,816 2,451 40.8

Jan-08 2,247,797 0 2,247,797 72,558 3,023 50.4

Feb-08 2,193,619 0 2,193,619 75,696 3,154 52.6

Aug-08 0 0 0 0 0 0.0

Sep-08 36,977 490,822 527,799 15,093 629 10.5

Oct-08 29,988 0 29,988 968 40 0.7

Nov-08 2 0 2 0 0 0.0

Dec-08 72,999 60,415 133,414 3,814 159 2.6

Jan-09 0 615 615 20 1 0.0

Feb-09 11 0 11 0 0 0.0

Mar-09 1,628,170 0 1,628,170 58,070 2,420 40.3

Apr-09 624,874 1,135,966 1,760,840 58,776 2,449 40.8

Source: DEK, 2009a

2.2.3.2 Kewaunee Power Station Groundwater Monitoring

KPS monitors groundwater for the possible infiltration of radionuclides, such as tritium. As 

tritium decays, it emits a low energy beta particle that cannot travel far into either tissue or air. 

Tritium is a product of man-made sources, as well as natural processes. 

The KPS groundwater monitoring program includes 14 monitoring wells, including the two high 

capacity wells onsite (DEK, 2009b). The groundwater monitoring wells were installed in 2007 for 

use in tritium assessment at the plant site. This assessment concluded that the most likely 

potential tritium release to groundwater is contained in the sand backfill beneath the site, and 

the migration of this potential release would likely follow the water table east toward Lake 

Michigan (STS, 2007).

2.2.4 Surface Water Resources

In accordance with the Federal Water Pollution Control Act (or the Clean Water Act (CWA)), 

KPS effluent discharges are regulated by WPDES Permit No. WI-00001571-06 issued and 

enforced by the WDNR. Section 402 of the CWA states that the National Pollutant Discharge 

Elimination System (NPDES) prohibits discharges of pollutants from any point source into the 

nation’s waters except as allowed under an NPDES permit. The purpose of this permit is to 

regulate wastewater discharge to preserve the water quality of the surrounding water bodies. As 

of the most recent permit issued, there have been no notices of violation for the KPS site. 

Information in this section is from the most recent KPS WPDES permit, a copy of which is 

included in the applicant’s license renewal ER. 
Affected Environment 

NUREG-1437, Supplement 40 2-20 August 2010

Table 2-2 shows the quantitative effluent limitations regulated under the WPDES permit or the 

residual concentrations of permitted chemical additives that may be discharged to Lake 

Michigan. In accordance with this permit, any new chemical additives introduced or current 

dosages increased must first be reviewed and approved by the WDNR. 

Table 2-2. Wisconsin Pollutant Discharge Elimination System Effluent Limitations for 

Kewaunee Power Station

Sample Total Suspended Solids

(mg/L)

Total Residual 

Chlorine

(lbs/day)

Oil and Grease

(Hexane or Freon) (mg/L)

Discharge Flow

(million gallons 

per day (MGD))

Point No. Monthly

Average

Daily

Max.

Weekly

Max.

Daily

Max.

Monthly

Average

Daily

Max.

Outfall 001 30 100 NLR 180 10 15 494*

Outfall 002 NLR NLR NLR NLR NLR NLR 3.96

Outfall 003 30 NLR 45 NLR NLR NLR 0.01

SP101 30 100 NLR NLR 15 20 0.01

SP201 30 100 NLR NLR 15 20 0.06

SP301 30 100 NLR NLR 15 20 0.03

SP501 30 100 NLR NLR 15 20 0.14

NLR: No Limit Required

*580 MGD (summer); 380 MGD (winter)

Source: WDNR, 2005

The permit outlines the effluent limitations and monitoring requirements of the three different 

discharge outfalls, as well as five additional sampling points. In addition to the effluent 

limitations shown in Table 2-2, the permit describes the minimum number of sampling events 

required for each outfall. Flow monitoring requirements are outlined for certain outfalls, as well 

as required pH monitoring, with pH levels expected to be between 6.0 and 9.0 year-round. 

Outfall 001 discharges condenser cooling water and process wastewater and is sampled prior to 

discharge to Lake Michigan. Daily temperature averages at this outfall are recorded. Outfall 002 

monitors recirculated water from Outfall 001 to prevent icing of the intake. Only flow rate is 

monitored at this outfall. Outfall 003 samples the sewage treatment plant effluent prior to its 

discharge to an unnamed tributary to Lake Michigan. Both Outfall 001 and 003 are required to 

undergo both acute and chronic Whole Effluent Toxicity (WET) testing two to three times during 

the duration of the permit. The permittee (DEK) is required to investigate any occurrences of 

serious or repeated toxicity found during these WET tests.

Five additional sampling points are regulated by the WPDES permit. SP101 samples the steam 

generator blowdown to Outfall 001. SP201 samples the floor drains to Outfall 101. SP301 

samples the service water treatment lagoon overflow to Outfall 101. SP501 samples the reverse 

osmosis discharge wastewater to Outfall 101. SP601 monitors the flow of Lake Michigan water 

or water pumped from the turbine building basement in case of circulating water system failure 

near the Outfall 101 discharge structure. 

KPS implements a Storm Water Pollution Prevention Plan onsite to reduce the amount of 

pollution discharged through storm water runoff. The purpose of this plan is to eliminate any 

contact discharged storm water that may have with potentially contaminating materials. There 
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August 2010 2-21 NUREG-1437, Supplement 40

are seven designated storm water outfalls onsite. Discharge monitoring of these outfalls is 

regulated by a “Tier 2” WPDES permit (Permit No. WI-S067857-2) (DEK, 2009f). 

Sanitary wastewater is treated at the site’s sewage treatment plant, which was installed in 1986. 

Typical plant operations require the plant to treat approximately 11,000 gpd (7.6 gpm; 

4.8 x 10-4 m3

/s); however, the plant is capable of treating up to 20,000 gallons (75.7 m3) of 

sewage per day. The system discharges approximately 7.6 gpm (4.8 x 10-4 m3

/s). Solids are 

disposed of at an offsite facility after onsite treatment (DEK, 2008).

2.2.5 Aquatic Resources

KPS is located on the west-central shore of Lake Michigan. Lake Michigan constitutes a total 

area of 67,900 square miles (mi2

) (175,800 square kilometers (km2)) and a total volume of 

1,180 cubic miles (mi3

) (4,920 cubic kilometers (km3)) and is the third largest of the Great Lakes 

by area and second largest by volume (EPA, 1992). The lake’s average depth is 279 ft (85 m) 

and maximum depth is 925 ft (282 m) (GLC, 2000). The lake surface lies at an average of 577 ft 

(176 m) above mean sea level (AEC, 1972). The Lake Michigan drainage basin encompasses 

over 45,000 mi2 (72,400 km2

) and major tributaries include the Fox-Wolf, Grand, and 

Kalamazoo rivers (DEK, 2008); (GLC, 2000). Lake Michigan flows through the Straits of 

Mackinac into Lake Huron at a recharge rate of once every 100 years (GLC, 2000). Lake 

Michigan has a low salinity level of less than 0.1 parts per thousand (ppt) (DEK, 2008).

Lake Michigan is used for a variety of purposes, including commercial and recreational boating, 

sport and commercial fishing, and tourism. The major changes and modifications that have had 

the greatest effect on aquatic resources of Lake Michigan include lakefront industrial, urban, 

and residential development; water quality impairment from industrial, municipal, agricultural, 

navigational, and recreational water uses; overfishing; and invasion of exotic species 

(EPA, 2008e). The Lake Michigan ecosystem continues to experience profound changes 

because of development, impacts of invasive species, and pollution. In its 2008 Lakewide 

Management Plan, the EPA (2008d) described Lake Michigan’s status as mixed with a slight, 

but continuing, decline in water quality.

There have been a series of milestones in the management of the Great Lakes. In 1955, the 

Canadian/U.S. Convention on Great Lakes Fisheries created the Great Lakes Fishery 

Commission (GLFC), which coordinates fisheries research and facilitates cooperative fishery 

management among the State, provincial, Tribal, and Federal agencies. The GLFC is 

responsible for implementing the Joint Strategic Plan for Management of Great Lakes Fisheries 

(GLFC, 1997). Eight States bordering the Great Lakes, the Province of Ontario, two intertribal 

agencies, and several Federal agencies are signatory to this management plan and work 

together to rehabilitate native lake species, control exotic species, prevent and manage fishery 

disease, coordinate law enforcement, produce new research, publish state-of-the-lake reports, 

and determine total allowable catch and allocation agreements and fish stocking levels 

(GLFC, 2009).

In 1972, the first Great Lakes Water Quality Agreement (GLWQA) was signed between the 

International Joint Commission (IJC) of Canada and the United States. Both countries pledged 

to address the deterioration of Great Lakes water quality from point source and non-point 

source pollution. A new GLWQA was signed in 1978 that outlined additional commitments to 

restore and maintain the “chemical, physical, and biological integrity” of the Great Lakes by 

seeking to eliminate persistent toxic substances (IJC, 2006). In 1987, the GLWQA established 

processes and basic commitments for developing and implementing remedial action programs 
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NUREG-1437, Supplement 40 2-22 August 2010

(RAPs) in geographic areas of concern (AOCs) and within the context of existing Lakewide 

Management Plans (LaMPs) (EPA and Environment Canada, 1997).

The EPA (2008d) identified 42 AOCs across the Great Lakes basin, 10 of which are in the Lake 

Michigan basin. The closest AOC in relation to KPS is the Lower Green Bay and Fox-Wolf River 

AOC, which suffers from eutrophication, degradation of phytoplankton and zooplankton 

populations, and has consumption advisories for mallard ducks and 12 species of fish 

(EPA, 2008e). Water contaminants of concern in this area include phosphorus, suspended 

solids, PCBs, ammonia, and various pesticides. Sediment contaminants include PCBs, 

cadmium, mercury, lead, and pesticides (EPA, 2008d). The Great Lakes Binational Toxics 

Strategy was created in 1997 for the purpose of reducing the environmental threats posed by 

persistent toxic substances such as those mentioned above (EPA and Environment Canada, 

1997). By 2006, as a result of this effort, deliberate mercury use and mercury releases were 

reduced by 50 percent in the United States, dioxin/furan releases were reduced by 75 percent in 

the United States, and less PCB-containing equipment use was documented (EPA and 

Environment Canada, 2007).

The EPA conducted a study from 1994 to 2000, called the Lake Michigan Mass Balance Study 

(LMMB), which focused on the pathways of four major chemicals: PCBs, representative of 

conservative organic compounds; atrazine, a widely used herbicide representative of reactive, 

biodegradable compounds; trans-nonachlor, a component of the pesticide chlordane, 

representative of persistent, bioaccumulative compounds; and mercury, also a persistent, 

bioaccumulative compound in the atmosphere, tributaries, lake water, sediments, and food 

webs of Lake Michigan and its basin. The Great Lakes Binational Toxics Strategy was 

implemented within the last three three years of the LMMB study. Because the Great Lakes 

Binational Toxics Strategy has reported successes at reducing levels of toxins in all categories 

the Strategy addresses, actual levels of toxins may now be further reduced than the LMMB 

indicates. Therefore, only general trends for toxin levels identified in the LMMB are discussed.

PCBs are organochlorines that were once widely used for industrial purposes until the EPA 

banned them from use in 1979 in all but completely enclosed systems due to their 

environmental and health effects. PCBs have been linked to reproductive problems and 

deformities in fish and wildlife. Trans-nonachlor is a component of the pesticide chlordane that 

can rapidly bioaccumulate. During the LMMB, PCB and trans-nonachlor trends indicated that 

levels are declining overall. Levels of dissolved and particulate PCBs in the atmosphere, Lake 

Michigan tributaries, the Lake Michigan Water column, and sediments were generally highest in 

the southern portion of the Lake Michigan basin and near urbanized and industrialized areas 

(McCarty et al., 2004). However, trans-nonachlor concentrations were higher in rural, 

agricultural areas with decreasing concentrations northward (McCarty et al., 2004). This trend 

may be a result of historical application, since this chemical is no longer produced in the United 

States (McCarty et al., 2004). The WDNR advises against eating lake trout (larger than 

27 inches (69 cm)) within Lake Michigan due to the risk of high PCB levels (WDNR, 2009). The 

WDNR also advises against eating brown trout (larger than 25 inches (64 cm)), Chinook salmon 

(larger than 36 inches (91 cm)), and lake trout (23 to 27 inches (58 to 69 cm)) more than once 

every two two months due to the potential for elevated PCB levels (WDNR, 2009).

Atrazine is one of the most widely used herbicides in the United States and is most commonly 

applied to corn crops in spring months within the Lake Michigan basin. The chemical does not 

bioaccumulate but persists in the water column due to its slow decay rate. Atrazine 

concentrations were found to be highly seasonal, corresponding to agricultural application 

during the spring months, and regionally, were elevated in areas of high agricultural production. 
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August 2010 2-23 NUREG-1437, Supplement 40

Tributaries were found to be the most prevalent source of atrazine, though levels in the Lake 

Michigan water column were generally persistent with a slow decay rate of one percent per 

year. Results suggested that lakewide levels of atrazine in Lake Michigan may be increasing 

under present loads (Brent et al., 2001).

Mercury is a persistent metal that can bioaccumulate and cause reproductive and growth effects 

in fish and wildlife. Vapor, particulate, and precipitate were all major contributors of mercury to 

Lake Michigan, with seasonal patterns—the highest concentrations were observed in summer 

months—and regional patterns, with Chicago having significantly higher concentration of 

mercury in both particulate and vapor phases. Mercury levels in Lake Michigan tributaries were 

comparable to previously recorded levels in other Midwestern rivers and well below the 

nationwide criteria for water quality. Levels were highest in the Fox River, which had 

concentrations averaging up to 2.7 times higher than other tributaries (McCarty et al., 2004a). 

Water column levels of mercury in Lake Michigan were lower than measured levels in tributaries 

and generally well mixed within the water column (McCarty et al., 2004a). Mercury levels in trout 

and coho salmon were found to exceed the EPA guidelines for unrestricted consumption and at 

levels that warrant consumption advisories for these species (McCarty et al., 2004a). As of 

2009, no consumption advisories exist for fish in Lake Michigan bordering Kewaunee or its 

neighboring counties (WDNR, 2009).

In the near vicinity of KPS, Lake Michigan is shallow with depths of 15 to 20 ft (4.6 to 6.1 m) 

1,600 ft (488 m) offshore of the intake structure (DEK, 2008). Near-shore substrate consists 

mainly of cobble and gravel, and bottom sediment consists mainly of hard red clay and fine to 

medium sand (AEC, 1972), (EA Engineering, 2007). The depth reaches over 600 ft (82 m) in the 

central part of the lake, referred to as the Chippewa Basin (EA Engineering, 2007).

The native fish community consists of deepwater species, including the bloater (Coregonus 

hoyi), lake herring (Coregonus artedii), and lake whitefish (Coregonus clupeaformis); predators, 

including lake trout (Salvelinus namaycush) and walleye (Stizostedion vitreum); and 

intermediate predators, such as white bass (Morone chrysops) and yellow perch (Perca 

flavescens). Demersal species, such as white sucker (Catostomus commersoni) and freshwater 

drum (Aplodinotus grunniens); small forage species, such as the emerald shiner (Notropis 

atherinoides); and sunfish family species, such as pumpkinseed (Lepomis gibbosus) and 

smallmouth bass (Micropterus dolomieui), are also characteristic of the native fish community 

near KPS (EA, Engineering 2007), (UWSGI, 2002b).

Preoperational monitoring indicated that the fish population in Lake Michigan near the KPS site 

was primarily composed of alewife (Alosa pseudoharengus), lake trout (Salvelinus namaycush), 

and rainbow smelt (Osmerus mordax) (AEC, 1972). Lake chub, yellow perch, white suckers, 

longnose dace, and slimy sculpin were also captured during 1971 fish collections (AEC, 1972). 

The most prevalent sport fish in the area was lake trout, most of which had been recently 

stocked in Wisconsin waters by Federal or State agencies (AEC, 1972).

Catch data for the period of 1971 through 1975 for the KPS CWA Section 316(a) Demonstration 

(NES, 1976a) included both preoperational and operational data. Alewife was the most 

prevalent species, constituting 65 percent of total catch. Other recorded species included 

rainbow smelt, yellow perch, lake trout, lake chub, white sucker, longnose dace, and longnose 

sucker. Sport fishing species included lake trout, rainbow trout, brown trout, brook trout, coho 

salmon, and Chinook salmon, the abundance of which was attributed to the activity of stocking 

in the KPS area. The 316(a) Demonstration did not identify any significant increases or 

decreases in fish densities (NES, 1976a).
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NUREG-1437, Supplement 40 2-24 August 2010

The Lake Michigan biological community has changed numerous times since the mid-19th 

century as a result of introduced fish and invertebrate species. Major introductions include the 

common carp (Cyprinus carpio) and brown trout (Salmo trutta) in the 1890s (EA Engineering, 

2007), the rainbow smelt in the early 1900s (Crowder, 1980), (UWSGI, 2002c), the sea lamprey 

(Petromyzon marinus) in the late 1930s (USGS, 2008), the alewife in the 1950s 

(EA Engineering, 2007), (Crowder, 1980), and the round goby in the 1990s (EA Engineering, 

2007). Two dreissenid mussels, the zebra mussel (Dreissena polymorpha) and the quagga 

mussel (Dreissena bugensis), have also invaded Lake Michigan beginning in the 1990s 

(Brandt, 2004), (EA Engineering, 2007).

Common carp were brought to North America as a farmed food source in the late 1800s and 

spread to the Great Lakes beginning in 1893 (UWSGI, 2002a). Carp are particularly abundant 

near the southeastern shore of Lake Michigan and lower Green Bay. Carp can reproduce 

quickly and out-compete native fish species due to their large size and voracious appetite 

(EPA, 2008c), (UWSGI, 2002a). Brown trout were introduced to North America in 1883 and

specifically to Wisconsin in 1887 (UWSGI, 2002). Brown trout have not negatively affected 

native species because brown trout adapt readily to degraded habitats and are regularly 

harvested as game fish (UWSGI, 2002). 

The sea lamprey entered the Great Lakes via ship canals and locks from the Atlantic Ocean in 

the 1930s (USGS, 2008). Sea lamprey is a primitive fish that feeds parasitically on the blood of 

host fish during part of its life cycle (USGS, 2008). Within Lake Michigan, common host fish 

include lake trout, whitefish, and other top predator species (EA Engineering, 2007). Prey 

species in the Great Lakes are smaller than natural prey species in the Atlantic Ocean, which 

makes Great Lakes prey species more likely to be killed from a sea lamprey attack or die of 

secondary infection from wounds (DEK, 2008), (USGS, 2008). Approximately 40 to 60 percent 

of lake trout attacked by sea lamprey die from loss of blood (USGS, 2008). A combination of 

overfishing and sea lamprey predation are attributed to the lake trout’s (Salvelinus namaycush) 

extirpation from lakes Michigan, Ontario, Erie, and Huron (USGS, 2008). Sea lamprey 

predation, in combination with overfishing and other factors, has led to the extinction of the 

longjaw cisco (Coregonus alpenae), the deepwater cisco (C. johannae), and the blackfin cisco 

(C. nigripinnis) (Fuller et al., 2007). Sea lamprey is also responsible for the whitefish and chub 

population collapses during the 1940s and 1950s (USGS, 2008). 

As a result of sea lamprey introductions, many top predator species’ populations were reduced, 

which allowed populations of their prey, rainbow smelt and alewife, to flourish. Rainbow smelt 

were initially released into Crystal River, MI, in 1912 as food for stocked salmon and soon after 

spread to the Great Lakes (Crowder, 1980) (UWSGI, 2002c). The alewife was first observed in 

Lake Michigan in 1949 and was able to outcompete and prey on the young of dwindling 

populations of several native fish species (Crowder, 1980). During the period of time rainbow 

smelt and alewife were introduced to Lake Michigan, the numbers of numerous native species 

declined and some became extremely rare. These species include emerald shiner (Notropis 

atherinoides), lake herring (Coregonus artedi), kiyi (C. kiyi), and five other species of cisco 

(Coregonus species) (Crowder, 1980). Numerous hypotheses may explain native fish 

population declines, but the effects of invasive species are the most commonly put forth. 

Alewives may contribute to a decline in native fish populations because alewives are able to 

outcompete native species for planktonic and other smaller organisms, and alewives may also 

prey on the eggs and larvae of native fish species (Crowder, 1980), (EA Engineering, 2007). 

Rainbow smelt are thought to prey on eggs and larvae of native fish, including lake trout, 

whitefish, walleye, and cisco, and have a negative impact on the native fish population 

(Crowder, 1980), (WDNR, 2004). Native fish that consume smelt and alewives may have a 
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August 2010 2-25 NUREG-1437, Supplement 40

decreased ability to successfully reproduce because smelt and alewives are rich in thiaminase, 

an enzyme that destroys thiamin, which is necessary for embryo development (WDNR, 2004) 

(Fitzsimmons et al., 2005). Rainbow smelt are harvested commercially and recreationally in 

Wisconsin, which serves as a controlling force on the population. In 2004, 155,000 lbs (70,300 

kg) of smelt were harvested by commercial trawlers in Lake Michigan and Green Bay alone 

(WDNR, 2004). 

Annual die-offs of alewives became common in the 1950s and 1960s due to overcrowding 

(Crawford, 2001). Alewives prey on zooplankton, which decreases the population of 

zooplankton available to graze on phytoplankton, thereby decreasing the clarity of water 

(Crawford, 2001). Evidence also suggests that selective predation on zooplankton caused a 

shift in the size structure of zooplankton in Lake Michigan. Larger cladocerans (including 

Leptodora kindtii, Daphnia galeata, and D. retrocurva), three species of larger calanoid 

copepods, and the cyclopoid copepod Mesocyclops edax sharply declined between the 

introduction of the alewife and 1966, while medium and small sized zooplankton species 

increased in numbers (Wells, 1970). Some populations, such as D. retrocurva, experienced a 

decrease in average size and size at onset of maturity (Wells, 1970). In 1965, WDNR initiated a 

stocking program that included pacific salmon and other salmonids to control alewife 

populations (EA Engineering, 2007). By the mid-to-late 1980s, alewife numbers were visibly 

reduced as a result of salmon stocking (Crawford, 2001). Stocking of salmonids continues, in 

reduced numbers, which has created a better balance between alewife and salmonid predator 

populations and provides for sport fishing (EA Engineering, 2007). Currently, the only objective 

for salmonid stocking is to maintain the recreational fishery base as stream temperatures are 

too high for natural spawning along the Wisconsin shoreline of Lake Michigan (Crawford, 2001).

Two dreissenid mussels, the zebra mussel and the quagga mussel, established populations in 

Lake Michigan in the 1990s as a result of ship ballast-water discharges (EA Engineering, 2007). 

Zebra mussels displace native clams and unionid mussels by interfering with their feeding, 

growth, and reproduction when they attach themselves to live clams and mussels (DEK, 2007a). 

The reduction of available phytoplankton mass as a result of these mussel species is attributed 

to the decline of Diporeia species, which were dominant amphipods, by 90 percent between 

1993 and 2002, though the exact mechanism is uncertain (Brandt, 2004). Community 

alterations by the dreissenid mussels are also thought to contribute to the population decline 

and poorer observed body condition of whitefish species and yellow perch because of the 

decline of Diporeia as their food source (Platt, 2009). Though the cause-and-effect relationship 

between the quagga mussel increase and the loss of Diporeia is not completely understood, the 

Great Lakes Coalition and the Natural Resources Defense Council, among others, are pushing 

for stronger regulations regarding ship ballast water to limit the additional spread of the mussel 

species (Platt, 2009). 

The Lake Michigan phytoplankton and zooplankton communities are highly variable and may be 

experiencing changes due to contaminant and nutrient levels, sedimentation, and invasive 

species (EPA, 2008d). Phytoplankton abundance and production in near shore waters of Lake 

Michigan have been decreasing since 1970 and has been suggested to be caused by a 

reduction in phosphorus loadings (Madenjian et al., 2002). Makarewicz et al. (1994) examined 

trends in phytoplankton abundance in Lake Michigan from 1983 to 1992 and related them to 

“top-down mediated changes” observed in the fish and zooplankton communities. 

Bacillariophyta (diatoms) dominated spring samples in all but one year and accounted for 69 to 

95 percent of total algal biomass. Summer phytoplankton samples were dominated by diatoms, 

Chlorophyta (green algae), Chrysophyta (yellow-green or yellow-brown algae), and Pyrrhophyta 

(dinoflagellates). The presence of large-bodied zooplankton (e.g., Daphnia species) resulted in 
Affected Environment 

NUREG-1437, Supplement 40 2-26 August 2010

increasing abundance of colonial and filamentous algae; low numbers of Daphnia species were 

associated with an increasing abundance of small, unicellular phytoplankton. Makarewicz et al. 

(1994) also noted that large zooplankton became more abundant from 1983 through 1985 after 

a sharp decline in the abundance of alewives in 1982 and 1983.

The introduction of the non-native spiny water flea (Bythotrephes cederstroemi), a cladoceran, 

caused a significant decline in three native species of Daphnia (Lehman, 1991). Another 

non-native cladoceran, the fishhook water flea (Cercopagis pengoi), has also invaded the Great 

Lakes (WDNR, 2004a). These species compete with planktivorous larval fish for food and have 

been implicated as a factor in the decline of alewives in Lake Erie, Lake Huron, Lake Michigan, 

and Lake Ontario (Liebig and Benson, 2007).

2.2.6 Terrestrial Resources

The KPS site and its associated transmission lines are located within the Lake Michigan 

watershed and drainage basin. The KPS site is located in the town of Carlton, Kewaunee 

County, WI, and is approximately 37 mi (59.5 km) southeast of Green Bay, WI. The KPS site is 

908 ac (367 ha), of which 450 ac (182 ha) are leased for farmland (DEK, 2008). These 

farmlands would be allowed to return to forested or wetland areas if the leases ran out or were 

terminated. The KPS reactor buildings, other building facilities, parking lots, and switchyard 

cover 60 ac (24 ha) of the overall site (DEK, 2008). The remaining 398 ac (161 ha) is mixed use 

and is comprised of forested plots, fields, wetlands, and watercourses (DEK, 2008). Site land 

use consists of about 53 percent agriculture, 16 percent open fields/early successional, 

18 percent forest communities, 1 percent shoreline, 7 percent plant site facilities, and 3 percent 

mowed fields (DEK, 2009c). Figure 2-3 shows the KPS site boundary. Some open fields may be 

due to ROW maintenance, which keeps the forested areas in stages of early succession.

Upland areas at the KPS site support a variety of trees, including quaking aspen (Populus 

tremuloides), northern white cedar (Thuja occidentalis), eastern cottonwood (Populus deltoides), 

black willow (Salix nigra), green ash (Fraxinus pennsylvanica), American beech (Fagus 

grandifolia), and paper birch (Betula papyrifera) (DEK, 2008). Low-story trees and shrubs 

include red osier dogwood (Cornus stolonifera), hazelnuts (Corylus species), blueberry 

(Vaccinium species), and brambles (Rubus species) (WDNR, 2009c). Open field and grassland 

species include Bird’s-foot violet (Viola pedata), rosinweed (Silphium integrifolium), rattlesnake 

master (Eryngium yuccifolium), and blazing star (Liatris pycnostachya) (WDNR, 2009d). The 

farmland that DEK leases out produces common Wisconsin crops, including soybeans.

The Lake Michigan shoreline on the KPS site is comprised mostly of narrow (0- to 100-ft wide 

(0- to 30.5-m wide)) beaches with sparse vegetation. The beaches are bordered by bluffs or 

cliffs, which have been created over years of erosion induced by the fluctuating lake levels. In 

the late 1980s, DEK placed riprap along the edges of the bluffs of the southern end of the site 

shoreline to combat cliff erosion. The beach is at its narrowest at the south of KPS. North of the 

plant, the beaches are slightly wider, ranging from 20 to 80 ft (6 to 24 m) and also contain the 

most vegetation comprised of low-lying growth, shrubs, and trees. The beaches are the widest 

(more than 80 ft (24 m)) where the slope to the lake is more gradual (DEK, 2008). 

The U.S. Fish and Wildlife Service (USFWS) National Wetlands Inventory database shows 

wetlands, some of which are classified as significant habitats, on the KPS site, as well as the 

neighboring shorelines of Lake Michigan surrounding the site (USFWS, 2009). Two wetland 

areas have been delineated by DEK. The first is an area referred to by DEK staff as the 

“Independent Spent Fuel Storage Installation wetland,” which was delineated in 2005–2006 for 
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August 2010 2-27 NUREG-1437, Supplement 40

purposes of pad construction and expansion. The second delineated wetland surrounds the 

KPS switchyard on three sides. Typical wetland species for the KPS site and surrounding area 

include tussock sedge (Carex stricta), northern white cedar (Thuja occidentalis), and wild rice 

(Zizania aquatica) (WDNR, 2009e).

Invasive plant species common to the KPS site and surrounding areas may include Amur 

honeysuckle (Lonicera maackii), European alder (Alnus glutinosa), bull thistle (Cirsium vulgare), 

butter and eggs (Linarea vulgaris), Canada bluegrass (Poa compressa), Canada thistle (Cirsium 

arvense), common buckthorn (Rhamnus cathartica), crown vetch (Coronilla varia), cottonwood 

(Populus deltoides), Kentucky bluegrass (Poa pratensis), kudzu (Pueraria lobata syn Pueraria 

montana var lobata), multiflora rose (Rosa multiflora), tree-of-heaven (Ailanthus altissima), big 

tooth (or large tooth) aspen (Populus grandidentata), quaking aspen (Populus tremuloides), 

black locust (Robinia pseudoacacia), willows (Salix species), white sweet clover (Melilotus 

alba), Queen Anne’s lace (Daucus carota), and box elder (Acer negundo) (WDNR, 2009b). 

Invasive animal species common to the KPS site and surrounding area may include Asian 

longhorned beetle (Anoplophora glabripennis), emerald ash borer (Agrilus planipennis), mute 

swan (Cygnus olor), European gypsy moth (Lymantria dispar), and eastern tent caterpillar 

(Malacosoma americanum) (WDNR, 2009a). DEK does not manage any invasive species on 

the KPS site and has not managed invasive species in the past. DEK is not required to keep 

records of known invasive species and does not have programs or procedures in place to 

control terrestrial plant or animal invasive populations on the KPS site.

A variety of wildlife exists on and in the vicinity of the KPS site. Mammals common to the KPS 

site include the white-tailed deer (Odocileus virginianus), eastern cottontail (Sylvilagus 

floridanus), raccoon (Procyon lotor), coyote (Canis latrans), fox squirrel (Sciurus niger), eastern 

chipmunk (Tamias striatus), and short-tailed shrew (Blarina brevicauda) (DEK, 2008). Reptiles 

and amphibians common to the KPS site include spring peepers (Pseudacris crucifer), green 

frogs (Rana clamitans), wood frogs (Rana sylvatica), American toads (Bufo americanus), chorus 

frogs (Pseudacris triserata), as well as numerous species of snakes, turtles, lizards, and 

salamanders (DEK, 2008). Additionally, several common amphibian species, including spring 

peepers (Pseudacris crucifer), green frogs (Rana clamitans), wood frogs (Rana sylvatica), 

American toads (Bufo americanus), and chorus frogs (Pseudacris triserata) were recorded 

during a recent KPS terrestrial survey (DEK, 2008a).

The KPS site provides habitat to a variety of songbirds, upland game birds, waterfowl, and 

raptors. Birds common to the KPS site include the red-winged blackbird (Agelaius phoeniceus), 

European starling (Sturnus vulgaris), American goldfinch (Carduelis tristis), clay-colored 

sparrow (Spizella pallida), American robin (Turdus migratorius), ring-billed gull (Larus 

delawarensis), Canada goose (Branta canadensis), and mallard (Anas platyrhynchos) 

(DEK, 2008). Bank swallows (Riparia riparia) nest in the cliffs along the Lake Michigan shore 

(DEK, 2008). A registered peregrine falcon (Falco peregrinus) breeding pair has nested on the 

KPS reactor building since 2001. An osprey (Pandion haliaetus) was seen flying over the KPS 

site in 2006; however, there have been no recorded sightings since.

DEK has several procedures for protecting the environment, including vegetation and wildlife, 

from impacts that could result from activities at KPS. Generally, procedures require KPS activity 

planners to complete an environmental review checklist to determine if a proposed activity 

requires further evaluation for environmental impacts and risk. If the environmental review 

checklist reveals that a planned activity could disturb vegetation or wildlife habitat, then an 

environmental evaluation must also be completed and a qualified subject matter expert must 

evaluate the potential for adverse impacts on endangered or threatened wildlife and plant 
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NUREG-1437, Supplement 40 2-28 August 2010

species or critical habitat. If the evaluation concludes that the proposed activity would result in 

an environmental impact, then the activity may not proceed until the impact has been resolved 

through avoidance, mitigation, or a compliance plan, when allowed by regulation.

DEK manages the Joe Krofta Memorial Forest, named for a previous landowner. The forest is a 

15-ac (6-ha) site with various planted trees and is located within the southern half of the KPS 

site. It was previously used as an outdoor classroom by local schools, but since September 11, 

2001, access to this site has been restricted for security reasons (DEK, 2008). 

2.2.7 Threatened and Endangered Species

2.2.7.1 Aquatic Threatened and Endangered Species

Table 2-3 lists threatened, endangered, or candidate species known to occur in Kewaunee 

County, in which KPS is located, or Brown, Manitowoc, or Outagamie counties, where 

transmission line ROWs associated with KPS traverse.

No Federally-listed aquatic species are known to occur on or in the vicinity of KPS or its 

associated transmission line ROWs. Three fish species and six mussel species are State-listed 

as threatened or endangered and have the potential to occur in the vicinity of KPS. None of 

these species were identified during the February 2006 to February 2007 impingement and 

entrainment study conducted by EA Engineering, Science, and Technology, Inc. 

(EA Engineering, 2007).
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August 2010 2-29 NUREG-1437, Supplement 40

Table 2-3. Listed Aquatic Species. The species below are Federally-listed or Wisconsin-listed 

as threatened, endangered, or candidate species. These species may occur on the KPS site, 

within Lake Michigan, or within the transmission line ROWs.

Scientific Name Common Name Federal 

Status(a)

State 

Status(a)

County of Occurrence(b)

Fish

Acipenser fulvescens lake sturgeon - SSC Brown, Outagamie

Anguilla rostrata American eel - SSC Brown

Clinostomus elongates redside dace - SSC Brown, Manitowoc

Erimyzon sucetta lake chubsucker - SSC Manitowoc

Etheostoma clarum western sand 

darter - SSC Outagamie

Fundulus diaphanous banded killifish - SSC Kewaunee, Manitowoc

Lepomis megalotis longear sunfish - T Brown

Moxostoma valenciennesi greater redhorse - T Brown, Kewaunee, 

Manitowoc

Notropis anogenus pugnose shiner - T Kewaunee

Notropis texanus weed shiner - SSC Outagamie

Opsopoeodus emiliae pugnose 

minnow - SSC Outagamie

Mussels

Tritogonia verrucosa buckhorn - T Outagamie

Alasmidonta marginata elktoe - SSC Manitowoc, Outagamie

Alasmidonta viridis slippershell 

mussel - T Manitowoc

Epioblasma triquetra snuffbox - E Outagamie

Pleurobema sintoxia round pigtoe - SSC Outagamie

Quadrula metanevra monkeyface - T Manitowoc

Simpsonaias ambigua salamander 

mussel - T Outagamie

Venustaconcha 

ellipsiformis ellipse - T Manitowoc

(a) C = Candidate; E = Federally endangered; SSC = species of special concern; T = Federally threatened; 

- = No listing

(b) Species has recorded occurrence in the listed counties within the past 50 years according to the WDNR

Sources: DEK, 2008; USFWS, 2008; WDNR, 2004a; WDNR, 2008; WDNR, 2008a; WDNR, 2008b; WDNR,

2008c; WNHP, 2006

2.2.7.2 Terrestrial Threatened and Endangered Species

There are five Federally-listed threatened or endangered terrestrial species that have potential 

habitat on the KPS site: the piping plover (Charadrius melodus), the Hine’s emerald dragonfly 

(Somatochlora hineana), the Karner blue butterfly (Lycaeides melissa samuelis), the dune or 

Pitcher’s thistle (Cirsium pitcheri), and the dwarf lake iris (Iris lacustris). The bald eagle 

(Haliaeetus leucocephalus) and the peregrine falcon (Falco peregrinus) were formerly listed as 

Federally threatened and may also be found in the vicinity of the KPS site. A peregrine falcon 
Affected Environment 

NUREG-1437, Supplement 40 2-30 August 2010

(Falco peregrinus) breeding pair has nested on the KPS reactor building since 2001. Four 

State-listed species were identified as species for consideration of the proposed license renewal 

of KPS, including the Caspian tern (Sterna caspia), the osprey (Pandion haliaetus), and the 

formerly listed bald eagle and peregrine falcon (USFWS, 2008), (DEK, 2008). 

The piping plover, a Federally- and State-listed endangered bird, is known to live on the 

shorelines in the vicinity of KPS. The USFWS has stated in a letter to the NRC that the habitat is 

not suitable for piping plovers on the KPS site (USFWS, 2008). The minimum piping plover 

nesting habitat requirements, as stated by the USFWS and outlined in the ER (DEK, 2008) 

include: 

Federally Protected and Formerly Protected Terrestrial Species

Total shoreline length of at least 200 meters (660 feet) of gently sloping, sparsely 

vegetated (<50 percent herbaceous and low woody cover) sand beach with a total 

beach area of at least 2 hectares (5 acres); appropriately sized sites must have an area 

50 meters (160 feet) in length where the beach width is at least 7 meters (23 feet).

The shoreline from the northern boundary of the KPS site to just below the reactor buildings are 

deemed to have “marginal” potential as plover nesting habitat while the southern end of the KPS 

site have no potential piping plover habitat (DEK, 2008). Recent surveys of KPS for piping 

plovers have not documented the species onsite (DEK, 2008). The piping plover is a small 

shorebird with long legs, brown feathered wings, and a white body (USFWS, 2009a). Piping 

plovers nest in the sand along the coastline. High human traffic to the beaches of the Atlantic 

coast and Great Lakes is considered to be the main reason for the decline of the species 

populations (USFWS, 2009a). Activity on beaches can destroy nests, eggs, and the young of 

the piping plover.

The Hine’s emerald dragonfly, a Federally- and State-listed endangered species, has been 

listed by the USFWS mostly due to loss and fragmentation of habitat (DEK, 2008), (USFWS, 

2009). The dragonfly inhabits calcareous, spring-fed marshes and sedge meadows (DEK, 

2008), (USFWS, 2009). The dragonfly has bright emerald green eyes and yellow stripes on its 

side, and grows to about 2.5 inches (6.4 cm) in length and has a wingspan of about 3.3 inches 

(8.4 cm) (USFWS, 2009). The dragonfly has been reported in Kewaunee County, and the 

closest location to the KPS site was a small population of the dragonflies from the Black Ash 

swamp in northern Kewaunee County in 2001 (DEK, 2009b). Recent wildlife surveys on KPS 

lands did not detect the presence of Hine’s emerald dragonflies (DEK, 2008).

The Karner blue butterfly is Federally-listed by the USFWS as endangered; however, the State 

of Wisconsin does not list the species as either threatened or endangered (DEK, 2008), 

(USFWS, 2009c). Of the counties that contain the KPS site and its associated transmission 

lines, Outagamie County is the only one with known populations of the butterfly (DEK, 2008). 

The butterfly has about a 1 inch (2.5 cm) wingspan and the males and females are different in 

appearance (USFWS, 2009c). The upper side of the male has shades of bright silver or dark 

blue with narrow black margins (USFWS, 2009c). Females are grayish brown, with very dark 

brown nodes on the outer portions of the wings, and the upper sides of the females are blue, 

with irregular bands of orange crescents inside the narrow black border. The underside of both 

the males and females are gray, and have a continuous band of orange crescents traveling the 

edges of both wings and the underside have scattered black spots circled with white (USFWS, 

2009c). For habitat, the butterfly prefers pine and oak trees, as well as savannas and barrens, 

which contain wild lupine (Lupinus perennis) and other flowering plants (DEK, 2008). After the 

species hatches, the caterpillars will only feed on the wild lupine species leaves and are, 
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August 2010 2-31 NUREG-1437, Supplement 40

therefore, limited to breed in habitats containing that plant species (DEK, 2008). Habitat 

fragmentation, development in Wisconsin, and protection against forest fires (wild lupine 

requires early stages of forest succession for maximum growth), have all reduced the 

populations of wild lupine and its ability to reproduce (DEK, 2008). Surveys of the KPS site and 

its associated transmission line ROWs did not show any presence of the Karner blue butterfly 

(DEK, 2008).

The dune or Pitcher’s thistle, a Federally- and State-listed threatened species, is known to live 

in Manitowoc County, a county crossed by KPS-associated transmission lines (WDNR, 2008b). 

The thistle is native to Wisconsin and grows on the beaches and dunes associated with the 

Great Lakes (WDNR, 2008b). The thistle can grow to heights of up to 3 ft (1 m) tall, and is 

covered with hairs along the stem (USFWS, 2009d). Leaves of the thistle can be 1 ft (0.3 m) 

long each, and usually have deep lobes (USFWS, 2009d). The Pitcher’s thistle takes five to 

eight years of growing before it begins to flower (USFWS, 2009d). Its non-flowering form is a 

grouping or cluster of bright silvery leaves, while the flowering form of the thistle typically has a 

single stem with many branches that have cream or pink flowers at the ends (USFWS, 2009d). 

Pitcher’s thistle is most often found along the shoreline of the Great Lakes or in unforested 

fields, and always near other plant communities. Surveys performed by DEK for Pitcher’s thistle 

on the KPS site or in associated transmission lines have no documented occurrences 

(DEK, 2008). 

The dwarf lake iris is Federally- and State-listed as threatened, and has been known to occur in 

Brown County, a county crossed by KPS-associated transmission lines (WDNR, 2008). Dwarf 

lake iris is a very small iris with dark, deep blue flowers, although sometimes flowers can be lilac 

or white (USFWS, 2009b). The flowers are about 1 to 1.5 inches (2.5 to 3.8 cm) wide and 1.5 to 

2.5 inches (3.8 to 6.4 cm) tall (USFWS, 2009b). The iris’s leaves can grow to 6 inches (15 cm) 

long and are sword-like in shape, and grow in clusters (USFWS, 2009b). The iris prefers 

habitats of shoreline, dunes, or cedar forest edge ecosystems, and grows in sandy soils or on 

beaches with little to no other vegetation present (USFWS, 2009b). Surveys for dwarf lake iris 

on the KPS site or its associated transmission lines did not document any occurrences of the 

plant species (DEK, 2008).

On July 9, 2007, the USFWS issued a Federal Register notice announcing the delisting of the 

bald eagle from the Federal List of Endangered and Threatened Wildlife (72 FR 37346). Eagles 

continue to be protected at the national level by the Bald and Golden Eagle Protection Act, as 

well as the Migratory Bird Treaty Act, and at the State level as a Wisconsin-listed threatened 

species. The bald eagle is a large bird, even among raptor species, and can reach a weight of 

more than 13 lbs (6 kg). The eagle has a white head and tail, with brown body feathers. Bald 

eagles eat fish, small mammals, birds, and occasionally carrion. Bald eagles are known to occur 

throughout Wisconsin and in every county associated with the KPS site or its associated 

transmission lines. They are seen regularly along the Lake Michigan shoreline. Eagles have 

been seen on the KPS site by employees and during the staff audit; however, the KPS site does 

not have any eagle nests (DEK, 2008).

The peregrine falcon was removed from the Federal listing in August 1999, but continues to be 

listed as endangered at the State level in Wisconsin. Adult birds have a bluish black head and 

wings, are 14 to 19 inches (36 to 48 cm) tall, and have a 39- to 43-inch (99- to 109-cm) 

wingspan (Cornell, 2003). Peregrine falcons nest on high cliffs near river systems and in some 

cases, especially associated with breeding attempts, the falcon can nest on bridges and tall 

buildings. The KPS site has had a breeding pair nesting on its reactor building since 2001, and 
Affected Environment 

NUREG-1437, Supplement 40 2-32 August 2010

the pair has produced at least 14 fledglings (DEK, 2008). In an effort to protect the nesting pair 

and their young, DEK regularly communicates with USFWS and WDNR (DEK, 2008).

The Caspian tern, a State-listed endangered species, is potentially occurring on the KPS site 

and its associated transmission lines (WDNR, 2004a), (WNHP, 2006). The Caspian tern is the 

largest known tern species in the world and is easily recognized by its red bill. The tern has grey 

feathers on its wings, an all white underbelly, and black feathers on its head. In the spring of 

2006, approximately 24 Caspian terns lived and were observed on the shoreline adjacent to the 

KPS site (DEK, 2008). 

State Protected Terrestrial Species

The Wisconsin State-listed threatened osprey may potentially occur on the KPS site or its 

associated transmission lines. The osprey is a fairly large bird of prey with a body length of 

about 21 to 24 inches (53 to 61 cm) and a wingspan of 4.5 to 5.5 ft (1.4 to 1.7 m). Osprey feed 

exclusively on live fish (USFWS, 2008b). Individuals are brown with a white belly and have 

distinctive patches on their wings. The osprey has long, sharp talons, which are used for 

gripping fish. Females are larger than males, which is true for most birds of prey. The osprey’s 

habitat includes rivers, lakes, and shallow water estuaries. Nesting often occurs on artificial 

structures such as flat-topped wooden platforms, meteorological towers, channel markers, and 

radio towers, where such structures are near shallow waters that support plentiful fish. Osprey 

pairs tend to be solitary nesters and may colonize secure areas such as islands 

(USGS, undated). In May of 2006, one osprey was sighted on the KPS site; however, no other 

ospreys have been seen on the KPS site, or its associated transmission lines since.

2.2.8 Socioeconomic Factors 

This section describes current socioeconomic factors that have the potential to be directly or 

indirectly affected by changes in operations at KPS. KPS and the people and communities 

surrounding it can be described as a dynamic socioeconomic system. The nuclear power plant 

requires people, goods, and services from local communities to operate the plant. The 

communities, in turn, provide the people, goods, and services to run the plant. KPS employees 

residing in the community receive income from the plant in the form of wages, salaries, and 

benefits and spend this income on goods and services within the community, thereby creating 

additional opportunities for employment and income. People and businesses in the community 

also receive income for the goods and services sold to KPS. Payments for these goods and 

services create additional employment and income opportunities in the community. The 

measure of a communities’ ability to support the operational demands of KPS depends on the 

ability of the community to respond to changing socioeconomic conditions.

The socioeconomics region of influence (ROI) is defined by the areas where KPS employees 

and their families reside, spend their income, and use their benefits, thereby affecting the 

economic conditions of the region. The KPS ROI consists of a three-county area (Kewaunee, 

Manitowoc, and Brown counties in Wisconsin). The following sections describe the housing, 

public services, offsite land use, visual aesthetics and noise, population demography, and the 

economy in the ROI surrounding KPS.

DEK employs a permanent workforce of approximately 705 workers (DEK, 2008). 

Approximately 95 percent live in Kewaunee County, Manitowoc County, and Brown County, in 

Wisconsin (Table 2-4). Most of the remaining 5 percent of the workforce are divided among 9 

other counties in Wisconsin and a few employees living out of State with numbers ranging from 

1 to 11 employees per county. Given the residential locations of KPS employees, the most 
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August 2010 2-33 NUREG-1437, Supplement 40

significant impacts of plant operations are likely to occur in Kewaunee, Manitowoc, and Brown 

counties. The focus of the socioeconomic impact analysis in this SEIS is based on the impacts 

of KPS on these three counties.

Table 2-4. Kewaunee Power Station Employee Residence by County (Wisconsin)

County Number of Employees Percentage (%) 

of Total

Manitowoc 280 39.7

Brown 228 32.3

Kewaunee 159 22.6

Door 11 1.6

Outagamie 4 0.6

Sheboygan 4 0.6

Other 19 2.6

Total 705 100

Source: DEK, 2008

Refueling outages at KPS normally occur at 18-month intervals. During refueling outages, site 

employment increases by as many as 600 to 700 workers for approximately 30 days 

(DEK, 2008). Most of these workers are assumed to be located in the same geographic areas 

as KPS employees.

2.2.8.1 Housing

Table 2-5 lists the total number of occupied and vacant housing units, vacancy rates, and 

median value in the three-county ROI. According to the 2000 Census, there were approximately 

133,000 housing units in the socioeconomic region, of which approximately 127,600 were 

occupied. The median value of owner-occupied housing units in the three Wisconsin counties 

ranged from $90,900 in Manitowoc County to $116,100 in Brown County. The vacancy rate was 

the lowest in Brown County (3.2 percent) and highest in Kewaunee County (7.3 percent). 

Kewaunee County has the smallest number of total and vacant housing units amongst the three 

counties (USCB, 2009a).

By 2007, the estimated number of housing units grew in all three counties by approximately 

10 percent of their combined total inventories. In Kewaunee County, the number of housing 

units grew to an estimated total of 9,013 units in 2007, an increase of approximately 800 units. 

In Manitowoc County, the number of housing units grew by more than 2,000 units to an 

estimated total of 36,661 units or approximately 6 percent (USCB, 2009a).
Affected Environment 

NUREG-1437, Supplement 40 2-34 August 2010

Table 2-5. Housing in Kewaunee, Manitowoc, and Brown Counties in Wisconsin

Kewaunee Manitowoc Brown ROI

2000

Total 8,221 34,651 90,199 133,071

Occupied housing units 7,623 32,721 87,295 127,639

Vacant units 598 1,930 2,904 5,432

Vacancy rate (percent) 7.3 5.6 3.2 4.1

Median value (dollars) 92,100 90,900 116,100 99,700

2005–2007, 3-Year Es timate

Total 9,013 36,661 101,256 146,930

Occupied housing units 8,272 33,704 95,165 137,141

Vacant units 741 2,957 6,091 9,789

Vacancy rate (percent) 8.2 8.1 6.0 6.7

Median value (dollars) 134,100 118,300 155,400 135,933

Source: USCB, 2009a

2.2.8.2 Public Services 

Since 95 percent of workers at KPS reside in Kewaunee, Manitowoc, and Brown counties, in 

Wisconsin, the discussion of public water supply systems is limited to these counties. In 

Table 2-6, information about municipal water suppliers in these counties, their permitted 

capacities and maximum design yields, reported annual peak usage, and population served are 

presented.

Water Supply

Lake Michigan is the source of potable water for the cities of Two Rivers, Manitowoc, and Green 

Bay, and groundwater provides potable water for smaller towns and rural residences in the 

vicinity of the KPS site. Two groundwater wells at KPS are used for cooling, stand-by cooling, 

the plant equipment water system, and potable water. KPS pumps groundwater for use as 

potable water and is not connected to a municipal system. At the present time, the water supply 

systems in Kewaunee, Manitowoc, and Brown counties are operating below their maximum 

capacities. The following are brief descriptions of the water supply systems in the three 

counties.

Kewaunee County’s major public water systems serve the majority of residential, commercial, 

and industrial users and are located in the cities of Kewaunee and Algoma and in the village of 

Luxemburg. These three municipal water systems are supplied from groundwater through 

community wells. County planners state that these systems are considered adequate for the 

cities’ and village’s present and future growth. The village of Casco and 10 towns within the 

county that are not serviced by public systems have individual or shared wells that are owned 

and maintained by the property owner(s). The city of Green Bay obtains drinking water supplies 

from Lake Michigan by means of the Green Bay water pipeline. Two raw water pipelines cross 

through the central portion of Kewaunee County to supply potable water to the city of Green Bay 
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August 2010 2-35 NUREG-1437, Supplement 40

and several of its suburbs. At this time, none of the communities in Kewaunee County has any 

plans of using this utility for their water needs (Bay-Lake Regional Planning Commission, 2007).

The cities of Manitowoc and Two Rivers are the two largest municipal water suppliers in 

Manitowoc County (Table 2-6). Both cities obtain their municipal water from Lake Michigan. All 

other water systems in the county rely on groundwater as their source (Bay-Lake Regional 

Planning Commission, 2005).

Local community infrastructures continue to be used and existing wells are used for backup 

purposes. Groundwater is the source of all drinking water and other water uses within the 

remainder of Brown County (DEK, 2008).

Table 2-6. Public Water Supply Systems (thousand gallons per day)

Water Supplier Water Source Average Daily 

Demand System Capacity Population Served

Kewaunee County 

Algoma Waterworks GW 261 1,584 3,357

Kewaunee Waterworks GW 362 2,592 2,887

Luxemburg Waterworks GW 257 590 2,292

Manitowoc County 

Cleveland Waterworks GW 75 1,500 1,410

Kiel Waterworks GW 500 4,532 3,630

Manitowoc Waterworks SW 8,000 31,000 34,500

Mishicot Waterworks GW 1,404 1,440 1,422

Reedsville Waterworks GW 100 500 1,200

Two Rivers Waterworks SW 1,500 4,000 13,354

Brown County

Allouez Waterworks SW 1,100 4,000 14,443

Ashwaubenon Waterworks SW 3,449 6,000 17,625

Bellevue Waterworks SW 1,000 4,000 14,500

De Pere Water Department SW 2,600 6,000 22,310

Green Bay Waterworks SW 20,000 42,000 103,018

Hobart Waterworks Service Area #1 GW 864 1,400 1,600

Howard Waterworks SW 1,860 4,200 14,543

Lawrence Utility District SW 1,050 4,320 1,200

Wrightstown Waterworks GW 220 1,000 2,578

GW = groundwater; SW = surface water

Source: DEK, 2008
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NUREG-1437, Supplement 40 2-36 August 2010

KPS is located in the Kewaunee School District, Kewaunee County, which had an enrollment of 

approximately 1,000 students in the 2008–2009 school year (DPI, 2009). Kewaunee County has 

three public school districts with over 1,900 enrolled students (DPI, 2009). Manitowoc and 

Brown counties have six and eight public school districts, respectively (DPI, 2009). Total 

enrollment in Manitowoc and Brown counties’ schools in the 2008–2009 school year was 

approximately 12,000 and 42,000 students, respectively (DPI, 2009), (IES, 2009).

Education

Employees enter the KPS site gate after exiting State Highway 42 to the west. State Highway 

42 has a north-south orientation and runs near the Lake Michigan shoreline in Kewaunee 

County. KPS workers from Ahnapee and Pierce would likely travel south on State Highway 42; 

employees from Red River, Lincoln, Luxemburg, and Casco could travel along County Highway 

C to the intersection with State Highway 42 and then continue south; those in Montpelier and 

West Kewaunee, Franklin, and Carlton would likely choose one of the east-west roads, travel 

east to the State Highway 42 intersection and then continue south. KPS workers commuting 

from Manitowoc County would also travel north on State Highway 42. County Highway BB is 

just south of the station, and the State-maintained Nuclear Road terminates on State Highway 

42 near the plant entrance. State and county roads in this part of Wisconsin were laid out in 

grids on true north-south axes with accommodations for naturally occurring geographical 

boundaries. Thus, Nuclear Road, County Highway BB, and many other east-west roads leading 

to KPS are perpendicular to State Highway 42.

Transportation

The average annual daily traffic (AADT) volume along State Highway 42 in Kewaunee County, 

in 2006, ranged from 2,400 vehicles to 6,800 vehicles at the various intersections. The AADT 

sampling location nearest the intersection of Nuclear Road and State Highway 42 was 2,600 

vehicles. In 2005, the AADT volume along the State Highway 42 in Manitowoc County ranged 

from 1,900 vehicles to 21,500 vehicles at the various intersections. The section of State 

Highway 42 where the 21,500 vehicles were recorded is the section where State Highway 42 

and Interstate Highway 43 share the same road (just west of Manitowoc) (WDOT, 2009).

Table 2-7 lists commuting routes to KPS and AADT volume values. The AADT values represent 

traffic volumes for a 24-hour period factored by both day of week and month of year.
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August 2010 2-37 NUREG-1437, Supplement 40

Table 2-7. Major Commuting Routes in the Vicinity of the Kewaunee Power Station in 

2006 Average Annual Daily Traffic Counts

Roadway and Location AADT (a)

State Highway 42 

(between County Highway BB and Cherneyville Road) 2,600

State Highway 42 

(between Cherneyville Road and Lakeshore Drive) 2,400

State Highway 42 

(between State Highway 29 and Lakeshore Drive) 2,500

State Highway 42 

(between Miller Street and State Highway 29) 5,400

State Highway 42 north of Miller Street 3,700–4,800

State Highway 29 west of Kewaunee 3,100–3,800

State Highway 42 

(between Two Rivers and County Highway BB) 3,200

Source: WDOT, 2009

(a) All AADTs represent traffic volume during the average 24-hour day during 2005 and 2006.

2.2.8.3 Offsite Land Use

Offsite land use conditions in Kewaunee and Manitowoc counties are described in this section 

because Kewaunee and Manitowoc are the only counties in which KPS employees represent 

more than 0.1 percent of the county population. Kewaunee County also receives Wisconsin 

Shared Revenues Utility Program payments from the State of Wisconsin because of KPS’s 

presence in the county. In addition to shared revenue, Kewaunee and other counties in the 

vicinity of KPS receive revenue from sales taxes and fees paid by DEK and its employees 

residing in the region. Changes in the number of workers at KPS and tax payments could affect 

land use conditions in these counties.

KPS is located in southeastern Kewaunee County. Manitowoc and Brown counties are located 

south and west of Kewaunee County, respectively. Kewaunee County has experienced small 

increases in population and housing over the last 16 years (1990 to 2006). However, the 

number of housing units in Kewaunee County grew faster than the population.

Kewaunee County occupies approximately 340 mi2 (217,600 ac) (USCB, 2009c). Almost 

93 percent of the county’s land is undeveloped. The majority (84 percent) of the undeveloped 

acreage consists of croplands or pastures and woodlands. Croplands or pastures comprise 

nearly 63 percent of the county’s total land area, while woodlands cover 21 percent of the total 

land area. Some of the larger woodland areas in the county include the Black Ash Swamp in the 

town of Lincoln, Duvall Swamp in Red River, and Lipsky Swamp in West Kewaunee (Bay-Lake 

Regional Planning Commission, 2007).

Almost 80 percent of the county’s land is agricultural (USDA, 2009). Residential uses account 

for the largest developed land use, covering 2.6 percent of the county’s total land area, while 

transportation and agricultural structures each account for approximately 1.6 percent. The 

largest concentrations of residential, commercial, and industrial land are found in and around 

the cities of Algoma and Kewaunee, the village of Casco, and the town and village of 

Luxemburg (Bay-Lake Regional Planning Commission, 2007).

KPS is located in the town of Carlton in Kewaunee County. The town limits of Carlton 

encompass an area of 35.6 mi2

. Carlton has experienced relatively little land use change since 
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NUREG-1437, Supplement 40 2-38 August 2010

KPS began operations. Approximately 97 percent of the land is agricultural or woodland, and 

3 percent is developed. Dairy farming is the primary economic activity.

Manitowoc County occupies approximately 592 mi2 (378,900 ac) (USCB, 2009c). Almost 

66 percent of the county’s land is farmed (USDA, 2009). Manitowoc County experienced small 

increases in population and housing over the 16 years from 1990 to 2006, with the number of 

housing units growing faster than the population. However, from 2000 to 2006, the population in 

Manitowoc County declined by a small amount while the number of housing units increased.

2.2.8.4 Visual Aesthetics and Noise

KPS can be seen from the lake but is partly shielded by vegetation along the lake. The 

predominant feature of the KPS site is the reactor building, which is approximately 180-feet tall 

(AEC, 1972). On the lake side of the reactor building is the turbine building, which is 

approximately 100-ft tall (AEC, 1972). Other features include the auxiliary building (adjoining the 

reactor building), administration building, and meteorological tower. The turbine building and 

reactor containment structures dominate the landscape of the site.

Noise from nuclear plant operations can be detected offsite. Sources of noise at KPS include 

the turbines and large pump motors. Given the industrial nature of the station, noise emissions 

from the station are generally nothing more than an intermittent minor nuisance. However, noise 

levels may sometimes exceed the 55 decibels adjusted (dBA) level that the EPA uses as a 

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. (EPA, 

1974)

2.2.8.5 Demography

According to the 2000 Census, approximately 86,224 people lived within 20 mi of KPS, which 

equates to a population density of 132 persons per mi2 (DEK, 2008). This density translates to 

GEIS Category 4, least sparse (greater than or equal to 120 persons per mi2 within 20 mi). 

Approximately 723,900 people live within 50 mi of KPS (DEK, 2008). This equates to a 

population density of 202 persons per mi2

. Applying the GEIS proximity measures, KPS is 

classified as proximity Category 4 (greater than or equal to 190 persons per mi2 within 50 mi). 

Therefore, according to the sparseness and proximity matrix presented in the GEIS, rankings of 

sparseness Category 4 and proximity Category 4 result in the conclusion that KPS is located in 

a high population area.

Table 2-8 shows population projections and growth rates from 1970 to 2050 in Kewaunee, 

Manitowoc, and Brown counties. The growth rate in Kewaunee County showed an increase of 

6.9 percent for the period of 1990 to 2000. County populations are expected to continue to grow 

in Kewaunee, Manitowoc, and Brown counties through 2050.
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August 2010 2-39 NUREG-1437, Supplement 40

Table 2-8. Population and Percent Growth in Kewaunee, Manitowoc, and Brown Counties, 

Wisconsin, from 1970 to 2000 and Projected for 2008 to 2050

Year

Kewaunee Manitowoc Brown

Population Percent Growth(a) Population

Percent 

Growth(a) Population

Percent 

Growth(a)

1970 18,961 — 82,294 — 158,244 —

1980 19,539 3.0 82,918 0.8 175,280 10.8

1990 18,878 -3.4 80,421 -3.0 194,594 11.0

2000 20,187 6.9 82,887 3.1 226,778 16.5

2008 20,388 1.0 80,641 -2.7 245,018 8.0

2010 21,841 8.2 85,834 3.6 254,040 12.0

2020 23,587 8.0 89,035 3.7 282,409 11.2

2030 25,085 6.4 91,622 2.9 306,931 8.7

2040 26,748 6.6 94,618 3.3 334,018 8.8

2050 28,370 6.1 97,512 3.1 360,463 7.9

— = No data available.

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

Sources: Population data for 1970 through estimated population data for 2008 (USCB, 2009b); population projections 

for 2010– 2030 by State of Wisconsin Demographics Services Center, Division of Intergovernmental Relations, 

Department of Administration (5/30/2008); population projections for 2040 and 2050 (calculated).

The 2000 and 2005–2007 American Community Survey 3-Year Estimates demographic profiles 

of the three-county ROI population are presented in Table 2-9 and Table 2-10. In 2000, minority 

individuals (both race and ethnicity) comprised 8.5 percent of the total three-county population. 

The minority population was composed largely of Hispanic or Latino and Asian residents.

Demographic Profile
Affected Environment 

NUREG-1437, Supplement 40 2-40 August 2010

Table 2-9. Demographic Profile of the Population in the Kewaunee Power Station 

Three-County Socioeconomic Region of Influence in 2000

Kewaunee Manitowoc Brown ROI

Total Population 20,187 82,887 226,778 329,852

Race (percent of total population, not Hispanic or Latino)

White 98.2 95.0 89.6 91.5

Black or African American 0.1 0.3 1.1 0.9

American Indian and Alaska Native 0.3 0.4 2.1 1.6

Asian 0.1 2.0 2.2 2.0

Native Hawaiian and Other Pacific Islander 0.0 0.0 0.0 0.0

Some other race 0.0 0.0 0.0 0.0

Two or more races 0.5 0.7 1.0 0.9

Ethnicity

Hispanic or Latino 153 1,343 8,698 10,194

Percent of total population 0.8 1.6 3.8 3.1

Minority Population (including Hispanic or Latino ethnicity)

Total minority population 365 4,131 23,535 28,031

Percent minority 1.8 5.0 10.4 8.5

Source: USCB, 2009b

According to the U.S. Census Bureau’s (USCB’s) 2005–2007 American Community Survey 

3-Year Estimates, minority populations in the three-county region were estimated to have 

increased by over 8,300 persons and comprised 10.6 percent of the total three county 

population (see Table 2-10). Most of this increase was due to an estimated increase in the 

Hispanic or Latino population (over 5,000 persons) of over 52 percent from 2000. This was the 

largest percentage increase of any minority population and a 1.4 percent increase in the 

Hispanic or Latino population when compared to the total increase in the three-county 

population. The next largest increase in minority population was in the Black or African 

American population, an increase of over 1,600 persons from 2000. However, this resulted in a 

0.5 increase in population as a percentage of the total increase in the three-county population.
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August 2010 2-41 NUREG-1437, Supplement 40

Table 2-10. Demographic Profile of the Population in the Kewaunee Power Station 

Three-County Socioeconomic Region of Influence in 2005–2007, 3-Year Estimate

Kewaunee Manitowoc Brown ROI

Total Population 20,532 81,009 240,801 342,342

Race (percent of total population, not Hispanic or Latino)

White 97.0 94.0 87.2 89.4

Black or African American 0.0 0.6 1.7 1.3

American Indian and Alaska Native 0.2 0.3 1.9 1.4

Asian 0.2 1.9 2.3 2.1

Native Hawaiian and Other Pacific Islander 0.2 0.0 0.1 0.1

Other 0.0 0.0 0.1 0.1

Two or more races 0.8 0.9 1.2 1.1

Ethnicity

Hispanic or Latino 314 1,880 13,347 15,541

Percent of total population 1.5 2.3 5.5 4.5

Minority Population (including Hispanic or Latino ethnicity)

Total minority population 624 4,895 30,826 36,345

Percent minority 3.0 6.0 12.8 10.6

Source: USCB, 2009b

Within 50 mi (80 km) of KPS, colleges and recreational opportunities attract daily and seasonal 

visitors who create demand for temporary housing and services. In 2009, there were 

approximately 11,794 students attending colleges and universities within 50 mi (80 km) of KPS 

(IES, 2009).

Transient Population

In 2000 in Kewaunee County, 45.2 percent of all housing units were considered temporary 

housing for seasonal, recreational, or occasional use. By comparison, seasonal housing 

accounted for 26.8 percent, 14.3 percent, and 60.1 percent of total housing units in Manitowoc 

and Brown counties and Wisconsin, respectively (USCB, 2009a). Table 2-11 provides 

information on seasonal housing for the 12 counties located all or partly within 50 mi of KPS.
Affected Environment 

NUREG-1437, Supplement 40 2-42 August 2010

Table 2-11. Seasonal Housing in Counties Located within 50 Miles of the Kewaunee 

Power Station

County(a) Housing units

Vacant housing units: For 

seasonal, recreational, or 

occasional use

Percent

Wisconsin 236,600 142,313 60.1

Brown 2,904 414 14.3

Calumet 848 287 33.8

Door 7,759 6,970 89.8

Fond du Lac 2,340 573 24.5

Kewaunee 598 270 45.2

Manitowoc 1,930 518 26.8

Marinette 8,675 7,586 87.4

Oconto 5,833 4,837 82.9

Outagamie 2,084 237 11.4

Shawano 2,502 1,793 71.7

Sheboygan 2,402 804 33.5

Winnebago 3,564 1,032 29.0

County Total 41,439 25,321 45.9 (avg.)

Source: USCB, 2009a

(a) Counties within 50 mi of KPS that are totally or partially located within the 50-mi radius.

avg. = percent average for counties within the KPS 50-mile radius and excludes State percentage.

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 harvesting of crops, particularly fruit, throughout rural areas of the United States. 

Others may be permanent residents near KPS who travel from farm to farm harvesting crops.

Migrant Farm Workers

Migrant workers may be members of minority or low-income populations. Because they travel 

and can 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.

Information on migrant farm and temporary labor was collected in the 2007 Census of 

Agriculture. Table 2-12 provides information on migrant farm workers and temporary farm labor 

(less than 150 days) within 50 mi of KPS. According to the 2007 Census of Agriculture, 

approximately 8,000 farm workers were hired to work for less than 150 days and were 

employed on 2,300 farms within 50 mi of KPS. The county with the largest number of temporary 

farm workers (1,108 workers on 298 farms) was Fond du Lac County in Wisconsin (USDA, 

2009).

In the 2002 Census of Agriculture, farm operators were asked for the first time whether or not 

any of them hired migrant workers, defined as a farm worker whose employment required travel 

that prevented the migrant worker from returning to their permanent place of residence the 

same day. A total of 131 farms in the 50-mi radius of KPS reported hiring migrant workers in the 
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August 2010 2-43 NUREG-1437, Supplement 40

2007 Census of Agriculture. Brown County reported the most farms (20 farms) with hired 

migrant workers, followed by Fond du Lac County and Outagamie County with 16 farms 

(USDA, 2009).

According to the 2007 Census of Agriculture estimates, 675 temporary farm laborers (those 

working fewer than 150 days per year) were employed on 148 farms in Kewaunee County, and 

976 and 823 temporary farm workers were employed on 256 and 213 farms in Manitowoc and 

Brown counties, respectively (USDA, 2009). 

Table 2-12. Migrant Farm Workers and Temporary Farm Labor in Counties Located within 

50 Miles of the Kewaunee Power Station

County(a)

Number of farms 

with hired farm 

labor(b)

Number of farms 

hiring workers for 

less than 150 days(b)

Number of farm 

workers working for 

less than 150 days(b)

Number of farms 

reporting migrant 

farm labor(b)

Wisconsin 17,889 13,169 45,921 636

Brown 318 213 823 20

Calumet 244 163 471 12

Door 201 167 564 6

Fond du Lac 451 298 1,108 16

Kewaunee 250 148 675 11

Manitowoc 353 256 976 12

Marinette 143 107 476 9

Oconto 251 171 606 7

Outagamie 350 230 755 16

Shawano 417 246 872 8

Sheboygan 290 201 664 5

Winnebago 214 144 404 9

County Total 3,482 2,344 8,394 131

Source: 2007 Census of Agriculture–County Data (USDA, 2009)

(a) Counties within 50 mi of KPS that are totally or partially located within the 50-mi radius.

(b) Table 7. Hired Farm Labor - Workers and Payroll: 2007

2.2.8.6 Economy

Between 2000 and the USCB’s 2005–2007 American Community Survey 3-Year Estimates, the 

civilian labor force in Kewaunee County increased 5.7 percent from 10,984 to 11,609. During 

the same time period, the civilian labor force in Manitowoc County grew by 1.6 percent. By 

2007, the civilian labor force in Brown County increased by 6.1 percent 

(USCB, 2009).

Employment and Income

According to the USCB’s 2005–2007 American Community Survey 3-Year Estimates, 

manufacturing represented the largest industrial sector of employment in the three-county 

region followed by educational services, health care and social assistance, and retail trade 

industry. A list of some of the major employers in Kewaunee County is provided in Table 2-13.
Affected Environment 

NUREG-1437, Supplement 40 2-44 August 2010

Table 2-13. Major Employers in Kewaunee County in 2005

Employer Service or Product Number of 

Employees

Aurora Medical Center of Oshkosh General medical & surgical hospitals 500–999

Wisconsin Label Corp. Commercial flexographic printing 500–999

Algoma Hardwoods Inc. Wood window & door manufacturing 250–499

Kewaunee Nuclear Power Plant Nuclear electric power generation 250–499

Luxemburg-Casco Public Schools Elementary & secondary schools 250–499

Kewaunee Fabrications LLC Miscellaneous gen. purpose machinery mfg. 250–499

Kewaunee School District Elementary & secondary schools 100–249

County of Kewaunee Highway, street, & bridge construction 100–249

N E W Plastics Corp. Plastics bottle manufacturing 100–249

The Vollrath Co. LLC Kitchen utensil, pot, & pan manufacturing 100–249

Source: DWD, 2006

Estimated income information for the KPS ROI is presented in Table 2-14. According to the 

USCB’s 2005–2007 American Community Survey 3-Year Estimates, Kewaunee and Brown 

counties each had median household incomes above the State average. Brown County had the 

highest median household income among the three counties. Per capita incomes in Kewaunee 

County and Manitowoc County were both below per capita income estimates for Brown County 

and the State. In Kewaunee and Manitowoc counties, an estimated 5.8 and 8.6 percent of the 

population were living below the official poverty level, respectively, while the percentage for 

Brown County and the State of Wisconsin as a whole was over 10 percent. The percentage of 

families living below the poverty level in Kewaunee County and Manitowoc County (4.6 and 

5.5 percent, respectively) was lower than the percentage of families in Brown County and the 

State of Wisconsin as a whole (both over 7 percent) (USCB, 2009).

Table 2-14. Estimated Income Information for the Kewaunee Power Station Region of 

Influence, 2005–2007 3-Year Estimates

Kewaunee Manitowoc Brown Wisconsin

Median household income (dollars) 51,734 47,075 51,624 50,309

Per capita income (dollars) 23,771 23,592 25,741 25,742

Percent of families living below the poverty level 4.6 5.5 7.6 7.1

Percent of individuals living below the poverty level 5.8 8.6 10.4 10.8

Source: USCB, 2009

According to the USCB’s 2005–2007 American Community Survey 3-Year Estimates, the 

unemployment rate in Kewaunee and Manitowoc counties was 4.5 and 5.5 percent, 

respectively, which was lower than the unemployment rate of 5.8 percent for the State of 

Wisconsin (USCB, 2009). The unemployment rate in Brown County was 6.2 percent, which was 

higher than the State average (USCB, 2009).

Unemployment
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August 2010 2-45 NUREG-1437, Supplement 40

Utilities and large electricity generators in Wisconsin are generally exempt from paying local 

property taxes. Instead, “gross revenue” taxes are collected from the utilities, which are then 

combined with other revenue, collected Statewide to become part of the State’s general 

purpose revenue fund. The general purpose revenue fund is disbursed in the form of aid 

payments to local governments. In general, utility aid payments are distributed to the county and 

municipality based on utility valuation or location.

Taxes

Utility aid payments consist of the following components: ad valorem payment, spent nuclear 

fuel storage payment, minimum payment, per capita limit, megawatt-based payment, special 

minimum payment, and incentive payments. Descriptions of the components applicable to KPS 

are provided below, which have been adapted from the applicant’s environmental report (DEK, 

2008) and the Wisconsin Department of Revenue website (WDOR, 2009a) unless otherwise 

noted.

This component is based on the “net book value” of “qualifying property” for “eligible utilities.” 

The total value of “qualifying property” in a municipality may not exceed $125 million per utility 

company or, if the property is owned by two or more utilities, $125 million for that specific 

property.

Ad Valorem Payment

● “Net book value” is the original cost of the property minus depreciation. For 

deregulated companies, depreciation is generally reported on a straight-line

basis.

● “Qualifying property” includes: (a) production plants that were in operation on 

January 1, 2004, and not subsequently rebuilt or “repowered,” (b) substations,

and (c) general structures. The land on which such property is located is 

excluded. Electric utility production plant consists of generating station 

structures and improvements and associated boilers, reactors, reservoirs, dams, 

waterways, fuel holders, engines, prime movers, and generators. Electric utility 

substations are facilities that connect the local distribution lines to the interstate 

electric transmission system. Gas utility substations are facilities that connect 

the local distribution lines to interstate gas transmission pipelines. For any utility, 

general structures included office buildings, garages, maintenance facilities, and 

related structures.

● “Eligible utilities” include: (1) private companies that produce, transmit, or 

distribute electricity or gas in more than one municipality; (2) electric 

cooperatives; (3) municipal utilities (for the portion of their property located 

outside the municipality that owns the utility); (4) municipal electric association 

projects (multi-municipal entities that own electric plants and/or purchase and 

transmit electricity to their members); and (5) qualified wholesale electric 

companies (entities that sell 95 percent or more of their power at wholesale and 

have a total generating capacity of 50 megawatts (MW) or more).

When calculating payments, the net book value in a municipality may not be less than the net 

book value as of December 31, 1989, minus the value of property removed since that date. This 

is called the “value guarantee.”
Affected Environment 

NUREG-1437, Supplement 40 2-46 August 2010

A payment of $50,000 is made to any municipality and county in which spent nuclear fuel is 

stored on December 31st of the prior year. If the nuclear fuel storage facility is located within 

1 mile of another municipality or county, the municipality or county where the fuel is stored is 

paid $40,000 and the nearby municipality or county is paid $10,000.

Spent Nuclear Fuel Storage Payment

This component applies only to electric generating plants with a rated capacity of 200 MW or 

more that were in operation on January 1, 2004, and not subsequently rebuilt or “repowered.” 

The minimum payment to a municipality or county with such a plant may not be less than 

$75,000.

Minimum Payment

The total payment from the ad valorem and minimum payments may not exceed $425 per 

capita for municipalities ($300 before 2009) and $125 per capita for counties ($100 before 2009)

(NRC, 2010). Payments under the spent nuclear fuel storage component are exempt from this 

limit.

Per Capita Limit

Through 2008, this component only applies to electric generating plants that began operation or 

were “repowered” after December 31, 2003. Starting in 2009, this component applies to KPS in 

lieu of the ad valorem payment (NRC, 2010). The payment is $2,000 per MW of name-plate 

generating capacity. For a plant in a town, one-third ($666.67) is paid to the town and two-thirds 

($1,333.33) is paid to the county. For a plant in a village or city, two-thirds ($1,333.33) is paid to 

the village or city and one-third ($666.67) is paid to the county.

Megawatt-based Payment

Beginning with payments in 2009, for electric generating facilities that began operating before 

January 1, 2004 and that have not been not subsequently rebuilt or "repowered," the payment 

will be the greater of (a) the amount calculated under the net book value based payment, using 

the current net book value, or (b) the amount calculated under the $2,000 per MW payment 

plus, for plants using an "alternative fuel source," any applicable incentive payments. Once 

payments are made under alternative (b), all future payments will be based on alternative (b). 

However, if the amount calculated under the net book value payment using the guaranteed 

value (net book value as of December 31, 1989, minus the value of property removed since that 

date) is greater than the amounts calculated under alternatives (a) or (b), then the payment is 

based on the guaranteed net book value. (NRC, 2010).

Special Minimum Payment

In lieu of property tax on its electrical generating plant and other facilities, DEK pays the State of 

Wisconsin a lump sum gross revenue tax. There is no direct correlation between the amount of 

taxes paid to the State of Wisconsin and the distribution of funds to local taxing jurisdictions.

The allocation of tax revenue attributable to KPS to local taxing jurisdictions is not recorded.

Taxes Paid by DEK

Wisconsin State law requires that utility aid funds be paid to the municipalities and counties 

where utility property is located. The utility aid payments to the town of Carlton and Kewaunee 

County from the State can be attributed to the presence of KPS in these jurisdictions. 

Tables 2-15 through 2-19 present information about the town of Carlton’s and Kewaunee 
Affected Environment

August 2010 2-47 NUREG-1437, Supplement 40

County’s total tax revenues and the utility aid payments to the town of Carlton and Kewaunee 

County from the State of Wisconsin (for all utility property located in the town of Carlton).

As presented in Table 2-18, the utility aid payments represent approximately 58.0 to 

69.2 percent of the town of Carlton’s total tax revenues. The vast majority of the payments are 

attributed to KPS. In 2004 and 2005, the town of Carlton collected no general property tax from 

its residents (DEK, 2008). Additionally, as shown in Table 2-19, the utility aid payments to 

Kewaunee County represent approximately 2.3 to 3.8 percent of Kewaunee County’s total tax 

revenue.

Table 2-15. Wisconsin Shared Revenue Utility Payments to the Town of Carlton for Utility 

Property in the Town of Carlton, 2004 to 2008

Item 2004 2005 2006 2007 2008

Utility Property: Net Book Value:

Wisconsin Power & Light 48,276,451 44,689,234 6 6 6

Wisconsin Public Service 70,717,380 73,240,209 0 240,250 154,309

Dominion Energy 

Kewaunee

0 0 75,773,083 36,556,659 37,503,448

American Transmission 1,310,499 1,281,173 1,872,469 2,209,085 2,043,656

Total 120,304,330 119,210,61

6

77,643,558 39,006,000 39,701,413

Value Guarantee 1,093,714 0 17,062,594 55,702,152 55,006,739

Total Value 121,398,044 119,210,616 94,708,152 94,708,152 94,708,152

Payment:

Payment Rate 0.003 0.003 0.003 0.003 0.003

Payment – Rate X Total 

Value

364,194.13 357,631.85 284,124.46 284,124.46 284,124.46

Population 1,032 1,037 1,031 1,034 1,061

Payment Limit – Per 

Capita

300.00 300.00 300.00 300.00 300.00

Maximum Payment 309,600.00 311,100.00 309,300.00 310,200.00 318,300.00

Value-Based Payment 309,600.00 311,100.00 284,124.46 284,124.46 284,124.46

Spent Nuclear Fuel 

Payment

50,000.00 50,000.00 50,000.00 50,000.00 50,000.00

Total Utility Payment 359,600.00 361,100.00 334,124.46 334,124.46 334,124.46

Source: DEK, 2008

Note: The shared revenue payment is funded from general State revenues; it is not paid by the utilities in the town. It 

is a payment for the presence of the utilities in the town and county.
Affected Environment 

NUREG-1437, Supplement 40 2-48 August 2010

Table 2-16. Wisconsin Shared Revenue Utility Payments to Kewaunee County for Utility 

Property in the Town of Carlton, 2004 to 2008

Item 2004 2005 2006 2007 2008

Utility Property: Net Book Value:

Wisconsin Power & 

Light

48,276,451 44,689,234 6 6 6

Wisconsin Public 

Service

70,717,380 73,240,209 0 240,250 154,309

Dominion Energy 

Kewaunee

0 0 75,773,083 36,556,659 37,503,448

American Transmission 1,310,499 1,281,173 1,872,469 2,209,085 2,043,656

Total 120,304,330 119,210,616 77,643,558 39,006,000 39,701,413

Value Guarantee 1,093,714 0 17,062,594 55,702,152 55,006,739

Total Value 121,398,044 119,210,616 94,708,152 94,708,152 94,708,152

Payment:

Payment Rate 0.006 0.006 0.006 0.006 0.006

Payment – Rate X 

Total Value

728,388.26 715,263.70 568,248.91 568,248.91 568,248.91

Population 20,648 21,082 12,157 21,198 21,358

Payment Limit – Per 

Capita

100.00 100.00 100.00 100.00 100.00

Maximum Payment 2,064,800.00 2,108,200.00 2,115,700.00 2,119,800.00 2,135,800.00

Value-Based Payment 728,388.26 715,263.70 568,248.91 568,248.91 568,248.91

Spent Nuclear Fuel 

Payment

50,000.00 50,000.00 50,000.00 50,000.00 50,000.00

Total Utility Payment 778,388.26 765,263.70 618,248.91 618,248.91 618,248.91

Source: DEK, 2008; NRC, 2010

Note: The shared revenue payment is funded from general State revenues; it is not paid by the utilities in the town. It 

is a payment for the presence of the utilities in the town and county.
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August 2010 2-49 NUREG-1437, Supplement 40

Table 2-17. Wisconsin Shared Revenue Utility Payments to the Town of Carlton and 

Kewaunee County for Utility Property in the Town of Carlton for 2009

Item Town of Carlton Kewaunee County Combined Total

Utility Property: Net Book Value: 2,145,830.00 2,145,830.00 2,145,830.00

Payment Rate 0.003 0.006

Value-Based Payment 6,437.49 12,874.98 19,312.47

Megawatt-Based Payment:

$ per MW of Capacity 666.67 1,333.33 2,000.00

MW Capacity 535 535 535

Megawatt – Based Payment 356,666.67 713,333.32 1,070,000.00

Maximum Payment:

Population 1,064 21,488

Payment Limit – Per capita 425.00 125.00

Maximum Payment 452,200.00 2,686,000.00 3,138,200.00

Utility Property – Value-Based 

Payment

6,437.49 12,874.98 19,312.47

Utility Property – Megawatt-Based 

Payment

356,666.67 713,333.32 1,070,000.00

Spent Nuclear Fuel Payment 50,000.00 50,000.00 100,000.00

Total Utility Payment 413,104.66 776,208.30 1,189,312.47

Source: DEK, 2008; NRC, 2010

Note: The shared revenue payment is funded from general State revenues; it is not paid by the utilities in the town. 

It is a payment for the presence of the utilities in the town and county.

Table 2-18. Town of Carlton – Wisconsin Shared Revenue Utility Payments and Total 

Town Revenues, 2004 to 2008

Year 2004 2005 2006 2007 2008

Total Revenues 522,200 522,100 515,200 576,400 514,700

Wisconsin Shared Revenue Utility Payments 359,600 361,100 334,124 334,124 334,124

Percent of Total Revenues 68.9 69.2 64.9 58.0 64.9

Source: DEK, 2008; WDOR, 2009a; WDOR, 2009b
Affected Environment 

NUREG-1437, Supplement 40 2-50 August 2010

Table 2-19. Kewaunee County – Wisconsin Shared Revenue Utility Payments and Total 

Town Revenues, 2004 to 2008

Year 2004 2005 2006 2007 2008

Total Revenues 20,376,900 22,597,300 21,683,600 26,351,500 26,185,200

Wisconsin Shared Revenue 

Utility Payments

778,388 765,264 618,249 618,249 618,249

Percent of Total Revenues 3.8 3.4 2.9 2.3 2.4

Source: DEK, 2008; WDOR, 2009a; WDOR, 2009b

2.2.9 Historic and Archaeological Resources

This section discusses the cultural background and the known historic and archaeological 

resources at the KPS site and in the surrounding area.

2.2.9.1 Cultural Background

The landscape of Wisconsin is dominated by glacial and postglacial geological deposits. The 

Pleistocene Age glaciers reached their greatest extent 14,000 to 16,000 years ago, and the last 

glacial advance (the Two Rivers or Valderan) dates to about 12,400 years ago. Approximately 

12,000 years ago the glaciers retreated and exposed most of the current area of Wisconsin.

The region around the KPS site contains prehistoric and historic Native American and 

Euro-American cultural resources. Twenty properties in Manitowoc County and eleven 

properties in Kewaunee County are listed in the National Register of Historic Places (NRHP). 

None of these properties fall within a 6-mi radius of KPS (NPS, 2009a), (NPS, 2009b).

The climate during the Paleo-Indian Period was much cooler and wetter than today. The 

distribution of Paleo-Indian artifacts in Wisconsin correlates with the last stages of glacial activity 

and fluctuating lake levels. Paleo-lndians exploited postglacial environments and organized in 

small mobile hunting groups and appear to have been more numerous in southern Wisconsin 

than in the north where glacial conditions persisted longer (R. Mason, 1997). 

Paleo-Indian populations were highly mobile. Most sites would have been short-term 

occupations (campsites). Paleo-Indian peoples hunted large, now extinct game, such as 

mastodon, mammoth, and caribou that lived on the lush vegetation that colonized postglacial 

soils (R. Mason, 1997). By the late Paleo-lndian Period, the levels of the Great Lakes may have 

been significantly lower than present. Paleo-lndian sites of this period could be submerged 

several hundred feet below the current surface (R. Mason, 1997). Later Paleo-lndian sites show 

evidence of woodworking tools reflecting the increasing forestation of the previously glaciated 

land. Late Paleo-lndian sites are widespread and continue to reflect small mobile populations. 

Instead of large game, species hunted during the later period included deer, caribou, bison, 

turtle, beaver, and other small mammals (R. Mason, 1997).

Prehistoric Periods

During the Archaic Period, subsistence hunting and gathering underwent changes to adapt to 

resource availability. As glaciers retreated northward and larger animals disappeared from the 

region, humans adapted to modern plants and smaller game animals. Between 10,000 and 

7,500 years ago, Archaic populations consisting of small groups of hunters and gatherers living 
Affected Environment

August 2010 2-51 NUREG-1437, Supplement 40

in caves and rock shelters along rivers, around lakes and wetlands, replaced the older 

Paleo-lndian culture. 

Archaic peoples may have been direct descendants of Paleo-lndians or may represent a 

migration of people from the south. These hunter-gatherers subsisted on fish, wild plants, nuts, 

acorns, and modern game animals such as elk and deer. Archaeological evidence indicates that 

settlement was sparse with small, mobile groups relying on diverse hunting and gathering 

strategies. At least one extensive Archaic local Wisconsin quarry site is known; however, stone 

tool materials from neighboring Illinois are also found at Archaic sites (Stoltman, 1997). By 

about 4,000 to 6,000 B.C., Archaic sites were more widely distributed throughout Wisconsin. 

Drier, warmer conditions with a rise in herbaceous species characterized this period. Archaic 

tool assemblages expanded to include fishing gear, ground stone plant processing tools, axes, 

and copper tools (Stoltman, 1997). Copper artifacts (such as harpoons, axes, adzes, chisels, 

knives, and drills) are widely found in eastern Wisconsin and in Manitowoc County (Stoltman, 

1997).

The Red Ochre Complex, an elaborate ceremonial burial complex distributed widely across the 

Midwest and the Great Lakes areas, serves to mark the transition between the Archaic and the 

Woodland periods. Information about the complex is largely limited to burial sites, therefore, the 

connections to the Archaic and Woodland Period remains uncertain (Stevenson et al., 1997). 

Use of copper for ornaments increased; evidence of fishing and wild rice harvesting exists. 

Toward the end of this period, mounds and Woodland pottery are found at these sites.

Approximately 2,500 years ago, the presence of pottery marks the beginning of the Woodland 

Period in Wisconsin. In Wisconsin, the Archaic culture persists throughout the early Woodland 

Period. The Woodland Period is also defined by the introduction of horticulture to augment 

subsistence hunting and gathering. In the Great Lakes region, evidence of domestication of 

local plants appears, as well as the introduction of exotic species. Squash is the earliest known 

agricultural crop (R. Mason, 1981). A reliance on agriculture led to the establishment of more 

permanent settlements during this period. Use of bows and arrows and pottery and construction 

of effigy mounds all began during of the Woodland Period.

The middle Woodland occupation (roughly 1,500 to 2,200 years ago) has distinctive 

characteristics that include construction of conical burial mounds and evidence of widespread 

interaction throughout central and eastern North America. The characteristics of this network, 

called the Hopewell Interaction Sphere, include elaborate ceremonialism, extensive trade of 

exotic manufactured items and raw materials, and large mound construction.

Late Woodland sites (occupied 700 to 1,600 years ago) show a decline in Hopewellian 

ceremonialism but continue the tradition of mound construction, primarily in the form of animal 

and human shapes, in the southern half of Wisconsin. Burials are associated with some, but not 

all, mounds (Stevenson et al., 1997). Cultivation of corn became increasingly prominent, and 

villages became more permanent (Stevenson et al., 1997). Late Woodland populations 

continued to increase and archaeological evidence from settlements shows a greater 

dependence on agriculture (R. Mason, 1981). 

An exception to the typical Woodland occupation is the intrusion of a few Middle Mississippian 

sites in Wisconsin about 1,000 years ago. These sites consist of permanent towns and 

ceremonial sites in Iowa, Minnesota, Missouri, and Illinois, particularly the site of Cahokia. 

Hierarchical structure, extensive trade networks, a focus on larger centralized villages, and 

intensive agriculture characterized these societies. Several sites in south-central Wisconsin 
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NUREG-1437, Supplement 40 2-52 August 2010

represent a northern extension of Mississippian culture. Aztalan, a palisade village containing 

four platform mounds and a series of dwellings, is the best known of these sites in Wisconsin 

(Goldstein and Freeman, 1997). The relationship of such sites with the surrounding Woodland 

sites is unclear, and the influence of the Mississippian culture on Woodland culture in Wisconsin 

appears to have been transitory (Green, 1997).

The transition from Woodland to later cultures is poorly understood. About 1,000 years ago, 

overlapping the late Woodland and Mississippian Period, sites referred to as the Oneota culture, 

recognized by distinctive pottery styles, appear in the archaeological record. Permanent 

villages, some fortified, were established; subsistence was based on corn, beans, squash, 

aquatic resources, and a variety of wild plants and game. Hunting and gathering, probably on a 

seasonal basis, supplemented the basic agricultural economy (Overstreet, 1997). Following the 

collapse of Mississippian influence, Oneota communities returned to the abandoned areas, and 

by about 700 years ago, they were the predominant culture in most of southern Wisconsin 

(Overstreet, 1997).

During the late Oneota culture, villages were concentrated in several areas, such as the Fox 

River valley in eastern Wisconsin. Subsistence patterns remained relatively constant throughout 

Oneota history until the arrival of Europeans (circa 1600 to 1650). Oneota settlements in 

eastern Wisconsin were abandoned by the time of French contact. Causes for this rapid 

depopulation could include disease, warfare, or out-migration (Overstreet, 1997). The Ho-Chunk 

(formerly Winnebago) Indians are commonly believed to be descendants of Oneota populations, 

but the archaeological evidence is inconclusive.

At the time of the first European contact (1600 to 1650), eastern Wisconsin was occupied by 

several American Indian groups (Ho-Chunk (Winnebago), Potawatomi, Menominee, and 

Chippewa). American Indian communities in the east were forced west due to ecological shifts 

(Cronon, 1983), societal collapse, and disease. Encroaching European settlement created 

waves of population shifts as these tribal groups pushed north and westward (Bragdon, 2001). 

Wisconsin tribal groups, responding to these pressures, shifted their areas of use to around 

Wisconsin, Michigan, and other areas of the Midwest.

Historic Period

The first European known to have visited the area was Jean Nicolet, a French explorer, who 

reached the Green Bay region in 1634 (AEC, 1972). Green Bay was subsequently established 

as the first French fur trading settlement, and a number of other trading posts were established 

throughout the late 1600s and 1700s. Father Marquette said his First Mass on All Saints Day, 

November 1, 1674, in Kewaunee County (Kewaunee County, 2009). French influence continued 

until the end of the French and Indian War. As the French withdrew from the western Great 

Lakes, items of British manufacture replaced French trade goods in Native American 

communities (C. Mason, 1997). Throughout the historic period, American Indian economies 

were supplanted or supplemented by an emphasis on hunting for the fur trade. European trade 

goods increasingly replaced traditional tools and utensils.

The United States acquired ownership of the northern Midwest at the close of the American 

Revolution, but de facto control remained with the British until the War of 1812 (AEC, 1972). 

Wisconsin was sparsely settled by Europeans prior to becoming a U.S. territory. Lead mining 

drew the first wave of Euro-American immigrants to southwestern Wisconsin in the 1820s. In 

1834, Wisconsin was surveyed and opened to Euro-American settlers. The fur trade, which had 

been a lucrative enterprise for the French, declined rapidly in the 1830s. During this time, the 

region was heavily forested. Settlement began in earnest when the lumber industry was started, 
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August 2010 2-53 NUREG-1437, Supplement 40

and the streams were dammed for water power. The vast forests of pine and larchwood led to 

shipbuilding. In 1848, Wisconsin became a State. Toward the end of the 19th century, farm 

settlement in the region followed the lumber industry (AEC, 1972).

The Potawatomi tribe lived in the area that is presently Door, Kewaunee, and Manitowoc 

counties for hundreds of years before Europeans began settling in Wisconsin. The Potawatomi 

are Algonquin speakers and are Neshnabek, a Potawatomi word that refers to “original people” 

(Forest County Potawatomi, 2009). A major village, Ma-kah-da-we-kah-mich- (cock), also 

known as Black Earth, was located 3.5 miles west of the plant site; on what is now the East 

Twin River (DEK, 2008). It was there that members of the tribe would plant crops of corn, 

beans, pumpkins, and squash. Each spring, the Potawatomi would establish a camp in Sandy 

Bay Creek, located on the northern edge of the KPS property (DEK, 2008). It was at this camp 

where the Potawatomi would fish during the annual spawning runs, primarily for suckers (Bach, 

1933). This area was used for hunting and gathering purposes until 1862 when the tribe was 

forced from their land by the U.S. government for non-payment of taxes (AVD, 2007). The burial 

ground for the tribe was also located here. (KCHS, 2002)

Kewaunee County was created in 1850s from Manitowoc County and was divided into three 

towns, Sandy Bay, Wolf River, and Kewaunee (Kewaunee County, undated). The southernmost 

town, Sandy Bay, was named for the little indenture in the shore of Lake Michigan. The town 

originally consisted of the present-day limits of Carlton and Franklin (Kewaunee County, 

undated). During the mid to late 1800s, Sandy Bay was a thriving village, with a productive 

sawmill (using a dam erected on Fischer Creek), a general store, cheese factory, post office, 

and hotel (KCHS, 2002). The large pier at Sandy Bay served as the center for shipping in the 

area, where lumber, bark (for tanning), and farmers’ crops were shipped to Milwaukee and 

Chicago. St. John’s Lutheran Church and cemetery and the Sandy Bay School were also part of 

the Sandy Bay Community. St. John’s was founded in 1869 and disbanded in 1947. The church 

was located on Route 42 but no longer exists. The cemetery is a Wisconsin Historical Resource 

and is currently owned and maintained by the town of Carlton. Sandy Bay School was located 

across Route 42 from the church and was in use until the 1960s. The schoolhouse was torn 

down in the 1960s to make way for the construction of KPS. By 1891, the settlement had all but 

disappeared. The only remnants from the community are the cemetery and a number of rotting 

pilings from the pier, which are visible from the shore by the mouth of Sandy Bay Creek 

(DEK, 2008).

2.2.9.2 Historic and Archaeological Resources at the Kewaunee Power Station Site

Most of the land at KPS was used for agricultural purposes. During the 1960s, land was 

acquired from 12 families to build KPS. The only remnants onsite from the farms are stretches 

of old barbed wire scattered around the site, part of the back end of an old threshing machine, a 

farm bridge north of the plant, and a bridge of unknown origin southwest of the plant (DEK, 

2008). As noted earlier, the Sandy Bay school house was also located onsite but was torn down 

due to the construction of KPS.

During the early to mid-1900s, Joe Krofta owned land approximately one-quarter mile south of 

the KPS plant. He planted a grove of trees in the area, and in 1931, built a small cabin. When 

KPS went into operation, the previous owners established the Kewaunee School Forest, which 

was used as an outdoor classroom for the county’s schools (DEK, 2008). During the 1980s, the 

lake level rose to historic high levels resulting in severe erosion. The cabin was about to 

collapse into Lake Michigan, and the plant’s owner at the time salvaged the front facade of the 
Affected Environment 

NUREG-1437, Supplement 40 2-54 August 2010

cabin and moved it to its current location. In 1987, the forest was renamed Joe Krofta Memorial 

Forest (DEK, 2008).

In 2007, DEK contracted with AVD Archaeological Services, Inc. (AVD) to conduct a Phase 1 

Archaeological Survey and literature review for the KPS site. Land disturbed during construction 

of KPS was not surveyed. A majority of the remaining land is leased agricultural cropland. A 

search of the Wisconsin records found only 141 historic and archaeological sites in Kewaunee 

County compared with more than 500 sites each for bordering Manitowoc, Brown, and Door 

counties (AVD, 2007). In addition, there are no eligible or listed NRHP properties located on the 

KPS site.

2.3 RELATED FEDERAL AND STATE ACTIVITIES

The staff reviewed the possibility that activities of other Federal agencies might impact the 

renewal of the operating license for KPS. Any such activity could result in cumulative 

environmental impacts and the possible need for a Federal agency to become a cooperating 

agency in the preparation of the KPS SEIS.

The NRC has determined that there are no Federal projects that would make it desirable for 

another Federal agency to become a cooperating agency in the preparation of the SEIS. There 

are no Federal lands, facilities, national wildlife refuges, forests, or parks within 50 mi of KPS. 

However, Two Creeks Buried Forest State Natural Area, a unit of the Ice Age National Scientific 

Reserve, is located approximately 1 mi south of the KPS property. The Reserve is a separate 

affiliated area of the National Park Service.

The NRC is required under Section 102(2) (c) of the National Environmental Policy Act of 1969 

to consult with and obtain the comments of any Federal agency that has jurisdiction by law or 

special expertise with respect to any environmental impact involved. The NRC has consulted 

with the USFWS, Advisory Council on Historic Preservation, Wisconsin Historical Society, 

Wisconsin Coastal Management Program, WDNR, Menominee Indian Tribe of Wisconsin, and 

23 other Native American Tribes listed in Section 1.8. Federal Agency consultation 

correspondence and comments on the SEIS are 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 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

10 CFR Part 61. Code of Federal Regulations, Title 10, Energy, Part 61, “Licensing 

Requirements for Land Disposal of Radioactive Waste.”

40 CFR Part 53. Code of Federal Regulations, Title 40, Protection of the Environment, Part 53, 

“Ambient Air Monitoring Reference and Equivalent Methods.”

40 CFR Part 58. Code of Federal Regulations, Title 40, Protection of the Environment, Part 58, 

“Ambient Air Quality Surveillance.”
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August 2010 2-55 NUREG-1437, Supplement 40

40 CFR Part 239, et seq. Code of Federal Regulations, Title 40, Protection of the Environment, 

Part 239, “Requirements for State Permit Program Determination of Adequacy.”

72 FR 37346. U.S. Department of the Interior, U.S. Fish and Wildlife Service, Washington, D.C, 

“Endangered and Threatened Wildlife and Plants; Removing the Bald Eagle in the Lower 48 

States From the List of Endangered and Threatened Wildlife.” Federal Register, Vol. 72, No. 

130, pp. 37345-37372, July 9, 2007.

AVD Archaeological Services, Inc (AVD). 2007. “Phase I Archaeological Survey at the 

Kewaunee Power Station in Kewaunee County, Wisconsin,” Prepared for Dominion Energy 

Kewaunee, Kewaunee, Wisconsin. [Non-public document, withheld per 36 CFR 800.11(c)]

Bach, W.H. 1933. “60 Years ago – Some Reminiscences by W.H. Bach, and Old Time 

Resident.” Available URL: 

http://www.wisconsinhistory.org/wlhba/articleView.asp?pg=1&id=7853&hdl=&np=Kewaunee+En

terprise&adv=yes&In=&fn=&q=&y1=&y2=&ci=&co=&mhd=&shd=

Bay-Lake Regional Planning Commission. 2005. “Bay-Lake Regional 2030 Regional 

Comprehensive Plan,” November 2005. Available URL: 

(accessed July 2009). 

[Copyright protected]

http://www.baylakerpc.org/REGIONALPLAN/Final/Bay-Lake%20Regional%202030%20Compre

hensive%20Plan.pdf (accessed July 2009). Agencywide Documents Access and Management 

System (ADAMS) Accession No. ML093250004.

Bay-Lake Regional Planning Commission. 2007. “Kewaunee County 20-Year Comprehensive 

Plan,” November 2005. Available URL: 

http://www.baylakerpc.org/Documents/Kewaunee_County/Kewaunee_County_Comp_Plan_Nov

ember_2007.pdf (accessed July 2009). ADAMS Accession No. ML093250005.

Bragdon, K. J. 2001. The Columbia Guide to American Indians of the Northeast, New York: 

Columbia University Press. [Copyright protected]

Brandt, S. 2004. “Effects of Diporeia Declines on Fish Diet, Growth and Food Web Dynamics in 

Southeast Lake Michigan,” Great Lakes Environmental Research Laboratory, National Oceanic 

and Atmospheric Administration. Available URL: 

http://www.glerl.noaa.gov/res/Task_rpts/1998/edybrandt09-3.html (accessed November 4, 

2008). ADAMS Accession No. ML093250006

Brent, R., J. Schofield, and K. Miller. 2001. “Results of the Lake Michigan Mass Balance Study: 

Atrazine Data Report,” U.S. EPA Great Lakes National Program Office, EPA 905R-01-010, 

December 2001. Available URL: http://www.epa.gov/glnpo/lmmb/results/atra_final.pdf

(accessed May 18, 2009). ADAMS Accession No. ML093250007. 

Clean Air Act of 1963, as amended, 42 U.S.C. 7401, et seq.

Cornell Lab of Ornithology (Cornell). 2003. “Peregrine Falcon.” Available URL: 

http://www.birds.cornell.edu/AllAboutBirds/BirdGuide/PeregrineFalcondtl.html (accessed 

June 6, 2008). ADAMS Accession No. ML073300303.
Affected Environment 

NUREG-1437, Supplement 40 2-56 August 2010

Crawford, S. S. 2001. “Salmonine Introductions to the Laurentian Great Lakes: An Historical 

Review and Evaluation of Ecological Effects, Executive Summary,” Canadian Special 

Publication of Fisheries and Aquatic Sciences. Available URL: 

http://www.uoguelph.ca/~scrawfor/research/research_greatlakes/research_greatlakes_fisheries/

research_greatlakes_fisheries_issues/research_greatlakes_fisheries_issues_salmon_monogra

ph.shtml (accessed July 15, 2009). ADAMS Accession No. ML093250009.

Cronon, W. 1983. Changes in the Land: Indians, Colonists, and the Ecology of New England. 

New York: Hill and Wang. [Copyright protected]

Crowder, L.B. 1980. “Alewife, Rainbow Smelt, and Native Fishes in Lake Michigan: Competition 

or Predation?,” Environmental Biology of Fishes, 5(3): 225-233.

Dominion Energy Kewaunee, Inc. (DEK). 1968. WDNR Well Installation Forms, Wisconsin 

Department of Natural Resources. ADAMS Accession No. ML091970509.

Dominion Energy Kewaunee, Inc. (DEK). 2005. “2004 Annual Radioactive Effluent Release 

Report,” Kewaunee, WI. ADAMS Accession No. ML051230416.

Dominion Energy Kewaunee, Inc. (DEK). 2006. “2005 Annual Radioactive Effluent Release

Report,” Kewaunee, WI. ADAMS Accession No. ML061240156.

Dominion Energy Kewaunee, Inc. (DEK). 2007. “2006 Annual Radioactive Effluent Release 

Report,” Kewaunee, WI. ADAMS Accession No. ML071220274.

Dominion Energy Kewaunee, Inc. (DEK). 2007a. “DNR Drinking Water System: High Capacity 

Wells.” ADAMS Accession No. ML091970509.

Dominion Energy Kewaunee, Inc. (DEK). 2007b. “Kewaunee Power Station Updated Safety 

Analysis Report, Revision 20.” ADAMS Accession No. ML071150379.

Dominion Energy Kewaunee, Inc. (DEK). 2008. “Applicant’s Environmental Report – Operating 

License Renewal Stage, Appendix E of Application for Renewed Operating License, Kewaunee 

Power Station,” Docket No. 50-305, August 2008. ADAMS Accession No. ML082341039.

Dominion Energy Kewaunee, Inc. (DEK). 2008a. “2007 Annual Radioactive Effluent Release 

Report,” Kewaunee, WI. ADAMS Accession No. ML081230068.

Dominion Energy Kewaunee, Inc. (DEK). 2008b. “2007 Annual Radioactive Effluent Release 

Report Offsite Dose Calculation Manual,” Kewaunee, WI. ADAMS Accession No. 

ML082190067.

Dominion Energy Kewaunee, Inc. (DEK). 2008c. “Application for Renewed Operating License, 

Kewaunee Power Station,” Docket No. 50-305, August 2008. ADAMS Accession Nos. 

ML082341020, ML082341038, ML082420854.

Dominion Energy Kewaunee, Inc. (DEK). 2008d. “KPS System Description: Circulating Water 

System (CW),” March 2008. ADAMS Accession No. ML091970509. 

Dominion Energy Kewaunee, Inc. (DEK). 2009. “2008 Annual Radioactive Effluent Release 

Report,” Kewaunee, WI. ADAMS Accession No. ML081230068.

Dominion Energy Kewaunee, Inc. (DEK). 2009a. “Kewaunee Power Station Potable Water Use 

Documentation.” ADAMS Accession No. ML091970509.

Dominion Energy Kewaunee, Inc. (DEK). 2009b. “Kewaunee Power Station Radiological 

Environmental Monitoring Manual (REMM),” May 2009. ADAMS Accession No. ML091970515.
Affected Environment

August 2010 2-57 NUREG-1437, Supplement 40

Dominion Energy Kewaunee, Inc. (DEK). 2009c. Response to Request to Docket Information 

Related to the Environmental Site Audit for Kewaunee Power Station, July 6, 2009. ADAMS 

Accession No. ML091970512.

Dominion Energy Kewaunee, Inc. (DEK). 2009d. Response to Request to Docket Information 

Related to the Environmental Site Audit for Kewaunee Power Station, Enclosure A –

Meteorology and Air Compliance. ADAMS Accession No. ML09190514.

Dominion Energy Kewaunee, Inc. (DEK). 2009e. Response to Request to Docket Information 

Related to the Environmental Site Audit for Kewaunee Power Station, Enclosure E –

Nonradiological Waste, Richmond, VA. ADAMS Accession No. ML091970529. 

Dominion Energy Kewaunee, Inc.(DEK). 2009f. “Stormwater Pollution Prevention Plan 

(SWPPP) for the Kewaunee Power Station,” April 2009. ADAMS Accession No. ML091970509.

Dominion Energy Kewaunee, Inc. (DEK). 2010. “Dominion Energy Kewaunee, Inc. (DEK) 

Kewaunee Power Station Application for Renewed Operating License Comments on Draft 

Supplement 40 to the Generic Environmental Impact Statement,” Docket No. 50-305,

April 12, 2010. ADAMS Accession No. ML101060515.

EA Engineering, Science, and Technology, Inc. (EA Engineering). 2007. “Impingement Mortality 

and Entrainment Characterization Report, Kewaunee Power Station, March 2006 – February 

2007,” Prepared for Dominion Resources Services, Inc., Glen Allen, VA. ADAMS Accession No. 

ML083520612.

Environmental Protection Agency (EPA). 1974. “Information on Levels of Environmental Noise 

Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety,” 

Report 550/9-74-004, Washington, D.C., March 1974. Available URL: 

http://www.nonoise.org/library/levels74/levels74.htm (accessed March 2, 2009). (See also “EPA 

Identifies Noise Levels Affecting Health and Welfare,” September 21, 2007. Available URL: 

http://www.epa.gov/history/topics/noise/01.htm). ADAMS Accession No. ML093250012.

Environmental Protection Agency (EPA). 1992. “Great Lakes Fact Sheet No. 1: Physical 

Features and Population.” Available URL: http://www.epa.gov/glnpo/atlas/gl-fact1.html

(accessed October 1, 2008). ADAMS Accession No. ML093250013.

Environmental Protection Agency (EPA). 2007. “Hazardous Waste Generator Regulations,” May 

2007. Available URL: http://www.epa.gov/osw/hazard/downloads/tool.pdf (accessed October 14, 

2008). ADAMS Accession No. ML082880301. 

Environmental Protection Agency (EPA). 2008. Approval and Promulgation of Implementation 

Plans and Designation of Areas for Air Quality Planning Purposes; Wisconsin; Redesignation of 

Kewaunee County to Attainment of Ozone; Final Rule. Federal Register, Vol. 73, No. 99, pp. 

29436-29444. 

Environmental Protection Agency (EPA). 2008c. “Invasive Species: Asian Carp and the Great 

Lakes.” Available URL: http://www.epa.gov/glnpo/invasive/asiancarp/ (accessed November 4, 

2008). ADAMS Accession No. ML093250016.

Environmental Protection Agency (EPA). 2008d. “Lake Michigan Lakewide Management Plan 

(LaMP) 2008.” Available URL: http://www.epa.gov/greatlakes/lamp/lm_2008/lm_2008.pdf

(accessed May 18, 2009). ADAMS Accession No. ML093250017.

Environmental Protection Agency (EPA). 2008e. “Lower Fox River and Green Bay Area of 

Concern.” Available URL: http://www.epa.gov/glnpo/aoc/greenbay.html (accessed May 18, 

2009). ADAMS Accession No. ML093250018.
Affected Environment 

NUREG-1437, Supplement 40 2-58 August 2010

Environmental Protection Agency (EPA). 2008f. “Pollution Prevention Information 

Clearinghouse (PPIC).” Available URL: http://www.epa.gov./oppt/ppic/

Environmental Protection Agency (EPA). 2009. “The Green Book Nonattainment Areas for 

Criteria Pollutants.” Available URL: 

(accessed 

August 20, 2009). ADAMS Accession No. ML082880301. 

http://www.epa.gov/air/oaqps/greenbk/index.html (accessed 

May, 2009). ADAMS Accession No. ML093250019.

Environmental Protection Agency and Environment Canada (EPA and Environment Canada). 

1997. “The Great Lakes Binational Toxics Strategy.” Available URL: 

http://binational.net/bns/strategy_en.pdf (accessed July 20, 2009). ADAMS Accession No. 

ML093250020.

Environmental Protection Agency and Environment Canada (EPA and Environment Canada). 

2007. “Great Lakes Binational Toxics Strategy: 2007 Annual Progress Report.” Available URL: 

http://binational.net/bns/2007/2007GLBTS_en.pdf (accessed July 20, 2009). ADAMS Accession 

No. ML093250021.

Fitzsimmons et al. 2005. “Thiamine Content and Thiaminase Activity of Ten Freshwater Stocks 

and One Marine Stock of Alewives,” Journal of Aquatic Animal Health, Vol. 17, pp. 26-35. 

Forest County Potawatomi. 2009. “Forest County Potawatomi History,” Forest County 

Potawatomi, Crandon, WI. Available URL: 

http://www.fcpotawatomi.com/index.php/Treaties/history-overview.html [Copyright protected]

Fuller, P., E. Maynard, and D. Raikow. 2007. “Alosa pseudoharengus,” USGS Nonindigenous 

Aquatic Species Database. Available URL: 

http://nas.er.usgs.gov/queries/FactSheet.asp?speciesID=490 (accessed January 6, 2009). 

ADAMS Accession No. ML093250022.

Great Lakes Commission (GLC). 2000. “Assessment of the Lake Michigan Monitoring Inventory: 

A Report on the Lake Michigan Tributary Monitoring Project.” Available URL: 

http://www.glc.org/monitoring/lakemich/pdf/full_report.PDF (accessed October 1, 2008). ADAMS 

Accession No. ML093250029.

Great Lakes Fishery Commission (GLFC). 1997. “A Joint Strategic Plan for Management of 

Great Lakes Fisheries,” Miscellaneous Publication 2007-01. GLFC: Ann Arbor, MI, June 10, 

1997. Available URL: http://www.glfc.org/fishmgmt/jsp97.pdf (accessed July 13, 2009). ADAMS 

Accession No. ML093250030.

Great Lakes Fishery Commission (GLFC). 2009. Great Lakes Fishery Commission Web page. 

Available URL: http://www.glfc.org/ (accessed July 13, 2009). ADAMS Accession No. 

ML093250031.

Goldstein, L., and J. Freeman. 1997. “Aztalan - A Middle Mississippian Village,” The Wisconsin 

Archaeologist, Vol. 78, Numbers 1 and 2, pp. 223-248. [Copyright protected]

Green, W. 1997. “The Middle Mississippian Peoples.” Wisconsin Archaeology, Chapter 8, The 

Wisconsin Archaeologist, Vol.78, Numbers 1 and 2, pp. 202-222, The Wisconsin Archaeological 

Society. [Copyright protected]

Institute of Educational Science (IES). 2009. “College Opportunities Online Locator,” Zip Code 

54216, U.S. Department of Education, National Center for Educational Statistics, Data release 

date March 6, 2009. Available URL: http://nces.ed.gov/ipeds/cool/RefineSearch.aspx (accessed 

July 2009). ADAMS Accession No. ML093250032.
Affected Environment

August 2010 2-59 NUREG-1437, Supplement 40

International Joint Commission (IJC). 2006. “Thirteenth Biennial Report on Great Lakes Water 

Quality.” Available URL: 

http://ijc.org:8080/glro/glro-web/resources/biennial-reports/BRGLWQ_13.pdf (accessed July 13, 

2009). ADAMS Accession No. ML093250033.

Kewaunee County Historical Society (KCHS). 2002. “Background for Historical Markers,” 

Compiled information by Donna Urban, March 2002. [Copyright protected]

Kewaunee County 2009. “Kewaunee County Genealogy and History.” Available URL: 

http://www.rootsweb.ancestry.com/~wikewaun/ (accessed July 2009). [Copyright protected]

Lehman, J.T. 1991. “Causes and Consequences of Cladoceran Dynamics in Lake Michigan: 

Implications of Species Invasion by Bythotrephes,” J. Great Lakes Res., Vol. 17, pp. 437-445.

Liebig, J., and A. Benson. 2007. “Bythotrephes longimanus,” Nonindigenous Aquatic Species 

Database, Gainesville, FL. Available URL: 

http://nas.er.usgs.gov/queries/FactSheet.asp?speciesID=162 (accessed July 13, 2009). 

ADAMS Accession No. ML093250034.

Madenjian, et al. 2002. “Dynamics of the Lake Michigan Food Web, 1970-2000,” Canadian 

Journal of Fisheries and Aquatic Sciences, Vol. 59, pp. 736-753.

Makarewicz, J.C., T. Lewis, and P. Bertram. 1994. “Epilimnetic Phytoplankton and Zooplankton 

Biomass and Species Composition in Lake Michigan, 1983 to 1992.” U.S. Environmental 

Protection Agency, Great Lakes National Program, Chicago, IL. Available URL: 

http://www.epa.gov/glnpo/monitoring/plankton/mich83-92/index.html (accessed July 13, 2009). 

ADAMS Accession No. ML093250035.

Mason, C. l. 1997. “The Historic Period in Wisconsin Archaeology, Native Peoples,” The 

Wisconsin Archaeologist, Vol. 78, Numbers 1 and 2, pp. 293-319. [Copyright protected]

Mason, R. J. 1997. “The Paleo-lndian Tradition,” The Wisconsin Archaeologist, Vol. 78, 

Numbers 1 and 2, pp. 78-i 10. [Copyright protected]

Mason, R. J. 1981. Great Lakes Archaeology, New York: Academic Press, Inc. [Copyright 

protected]

McCarty, et al. 2004. “Results of the Lake Michigan Mass Balance Study: Mercury Data Report,” 

U.S. EPA Great Lakes National Program Office, EPA 905 R-01-012, February 2004.

McCarty, et al. 2004a. “Results of the Lake Michigan Mass Balance Study: Polychlorinated 

Biphenyls and trans-Nonachlor Data Report,” U.S. EPA Great Lakes National Program Office, 

EPA 905 R-01-011, April 2004. Available URL: 

http://www.epa.gov/glnpo/lmmb/results/pcb/lmmbpcb.pdf (accessed May 18, 2009). ADAMS 

Accession No. ML093250036.

National Climatic Data Center (NCDC). 2009. Historical climate data, 1971–2000 NCDC 

normals, Precipitation Summary, 474195 Kewaunee Station, WI. ADAMS Accession No. 

ML091960148.

National Climatic Data Center (NCDC). 2009a. Historical climate data, 1971–2000 NCDC 

normals, Temperature Summary, 474195 Kewaunee Station, WI. ADAMS Accession No. 

ML091960128.

National Climatic Data Center (NCDC). 2009b. Flood events in Wisconsin, 1950–2009. 

Available URL: http://www4.ncdc.noaa.gov/cgi-win/wwcgi.dll?wwevent~storms (accessed July, 

2009). ADAMS Accession No. ML091960114.
Affected Environment 

NUREG-1437, Supplement 40 2-60 August 2010

National Climatic Data Center (NCDC). 2009c. Tornado activities in Kewaunee County, WI.

Available URL: http://www4.ncdc.noaa.gov/cgi-win/wwcgi.dll?wwevent~storms (accessed July, 

2009). ADAMS Accession No. ML091960104

Nalco Environmental Sciences (NES). 1976a. Kewaunee Nuclear Power Plant 316(a) 

Demonstration, Type 1: Absence of Prior Appreciable Harm. ADAMS Accession No. 

ML08520612.

Nalco Environmental Sciences (NES). 1976b. Kewaunee Nuclear Power Plant 316(b) 

Demonstration: Environmental Effects of Existing Cooling Water Intake Structures. ADAMS 

Accession No. ML083520612.

National Park Service (NPS). 2009a. “National Register of Historic Places Information System, 

Kewaunee County, Wisconsin.” Available URL: www.nr.nps.gov

National Park Service (NPS). 2009b. “National Register of Historic Places Information System, 

Manitowoc County, Wisconsin.” Available URL: 

(accessed August 3, 2009).

www.nr.nps.gov

Overstreet, D. F. 1997. “Oneota Prehistory and History,” The Wisconsin Archaeologist, Vol. 78, 

Numbers 1 and 2, pp. 250–296. [Copyright protected]

(accessed August 5, 2009). 

Platt, J. 2009. “Quagga Terror: Alien Mussels in U.S. Waters Cause Problems for Other 

Species,” Scientific American Online, March 16, 2009. Available URL: 

http://www.scientificamerican.com/blog/60-second-science/post.cfm?id=quagga-terror-alien-mu

ssels-in-us-w-2009-03-16 (accessed July 15, 2009). ADAMS Accession No. ML093250037.

State of Wisconsin, Department of Workforce Development (DWD). 2006. “Kewaunee County 

Workforce Profile,” December 2006. Available URL: 

http://www.dwd.state.wi.us/oea/county_profiles/archived/2006/kewaunee_profile_2006.pdf

Stevenson, et al. 1997. “The Woodland Tradition,” The Wisconsin Archaeologist, Vol. 78, 

Numbers 1 and 2, pp. 140-201. [Copyright protected]

(accessed July 2009). ADAMS Accession No. ML093250011.

Stoltman, J. B. 1997. “The Archaic Tradition,” The Wisconsin Archaeologist, Vol. 78, Numbers 1 

and 2, pp. 112-139. [Copyright protected]

STS Consultants, Ltd (STS). 2007. “Report of Well Installation Services,” Dominion Energy 

Kewaunee Power Station, August 2007. ADAMS Accession No. ML091970515. 

U.S. Atomic Energy Commission (AEC). 1972. “Final Environmental Statement Related to the 

Operation of Kewaunee Nuclear Power Plant,” Wisconsin Public Service Corporation, Docket 

No. 50-305, Directorate of Licensing, Washington, D.C., December 1972. ADAMS Accession 

No. ML082820122.

U.S. Census Bureau (USCB). 2009. “American Community Survey of Kewaunee County, 

Manitowoc County, and Brown County, Wisconsin, Data Profile Highlights. 2005–2007 

American Community Survey 3-Year Estimates.” Available URL: http://factfinder.census.gov

(accessed July 2009). 

U.S. Census Bureau (USCB). 2009a. “American FactFinder, Census 2000 and 2005–2007, 

3-Year Estimate, American Community Survey, QuickFacts on Kewaunee, Manitowoc, and 

Brown Counties. Housing Characteristics for 2000 and 2005–2007, 3-Year Estimate.” Available 

URLs: http://factfinder.census.gov and http://quickfacts.census.gov (accessed July 2009). 

U.S. Census Bureau (USCB). 2009b. “Decennial Census 1900 to 1990 and 2000 Data and 

American FactFinder, American Community Survey of Kewaunee County, Manitowoc County, 
Affected Environment

August 2010 2-61 NUREG-1437, Supplement 40

and Brown County, Wisconsin, Data Profile Highlights. 2005–2007 American Community 

Survey 3-Year Estimates.” Available URL: http://factfinder.census.gov (accessed July 2009). 

U.S. Census Bureau (USCB). 2009c. “State and County QuickFacts for Kewaunee County and 

Manitowoc County, Wisconsin.” Available URL: http://quickfacts.census.gov (accessed July 

2009). 

U.S. Department of Agriculture (USDA). 2009. “2007 Census of Agriculture. Iowa, Kansas, 

Missouri, Nebraska.” Released February 4, 2009. Available URL: 

http://www.agcensus.usda.gov/Publications/2007/Online_Highlights/County_Profiles/index.asp

U.S. Fish and Wildlife Service (USFWS). 2008. “County Distribution of Wisconsin’s Federally 

Threatened, Endangered, Proposed, and Candidate Species,” November 2008. Available URL: 

(accessed April 17, 2009). ADAMS Accession No. ML093250038.

http://www.fws.gov/Midwest/Endangered/lists/wisc08cty.pdf (accessed January 6, 2009). 

ADAMS Accession No. ML093250023.

US Fish and Wildlife Service (USFWS). 2008a. Letter to the NRC regarding the Renewal 

Application Review of Kewaunee Power Station, Kewaunee County, WI. October 28, 2008. 

ADAMS Accession No. ML 083390643.

U.S. Fish and Wildlife Service (USFWS). 2008b. “Osprey: Pandion haliaetus,” Available URL: 

http://www.fws.gov/chesapeakebav/osprey.html (accessed May 15, 2009). ADAMS Accession 

No. ML082880486.

U.S. Fish and Wildlife Service (USFWS). 2009. “Hine’s Emerald Dragonfly (Somatochlora 

hineana). Fact Sheet.” Available URL: 

http://www.fws.gov/Midwest/endangered/insects/hed/hins_fct.html (accessed August 9, 2009). 

ADAMS Accession No. ML093250024.

U.S. Fish and Wildlife Service (USFWS). 2009a. “Piping Plover, Atlantic Coast Population.” 

Available URL: http://www.fws.gov/northeast/pipingplover/ (accessed August 9, 2009). ADAMS 

Accession No. ML093250025.

U.S. Fish and Wildlife Service (USFWS). 2009b. “U.S. Fish and Wildlife Service. Threatened 

and Endangered Species. Dwarf lake iris. Factsheet.” Available URL: 

http://www.fws.gov/Midwest/Endangered/plants/pdf/dwarf-lake-iris.pdf (accessed August 9, 

2009). ADAMS Accession No. ML093250026.

U.S. Fish and Wildlife Service (USFWS). 2009c. “Threatened and Endangered Species, Karner 

Blue Butterfly, Lycaeides melissa samuelis Factsheet.” Available URL: 

http://www.fws.gov/Midwest/endangered/insects/kbb/kbbFactSheet.pdf (accessed August 9, 

2009). ADAMS Accession No. ML093250027.

U.S. Fish and Wildlife Service (USFWS). 2009d. “Threatened and Endangered Species. 

Pitcher’s Thistle Factsheet.” Available URL: 

http://www.fws.gov/Midwest/Endangered/plants/pdf/Pitchersthistle.pdf

U.S. Geological Survey (USGS). Undated. “Biological and Ecotoxicological Characteristics of 

Terrestrial Vertebrate Species Residing in Estuaries – Osprey.” ADAMS Accession No. 

ML091350285.

(accessed August 9, 

2009). ADAMS Accession No. ML093250028.

U.S. Geological Survey (USGS). 2008. “Sea Lamprey.” Available URL: 

http://www.glsc.usgs.gov/main.php?content=research_lamprey&title=Invasive%20Fish0&menu=

research_invasive_fish (accessed November 4, 2008). ADAMS Accession No. ML093250040.
Affected Environment 

NUREG-1437, Supplement 40 2-62 August 2010

U.S. Nuclear Regulatory Commission (NRC). 2010. E-Mail re NRC Follow-Up Request for Tax 

Info on Kewaunee License Renewal. ADAMS Accession No. ML101550354.

University of Wisconsin Sea Grant Institute (UWSGI). 2002. “Fish of the Great Lakes: Brown 

Trout” Available URL: http://www.seagrant.wisc.edu/greatlakesfish/browntrout.html (accessed 

November 4, 2008). ADAMS Accession No. ML093250041.

University of Wisconsin Sea Grant Institute (UWSGI). 2002a. “Fish of the Great Lakes: Carp.” 

Available URL: http://www.seagrant.wisc.edu/greatlakesfish/carp.html (accessed November 4, 

2008). ADAMS Accession No. ML093250042.

University of Wisconsin Sea Grant Institute (UWSGI). 2002b. “Fish of the Great Lakes: Fish of 

Lake Michigan.” Available URL: 

http://www.seagrant.wisc.edu/greatlakesfish/LakeMichFishIndex.html (accessed November 4, 

2008). ADAMS Accession No. ML093250043.

University of Wisconsin Sea Grant Institute (UWSGI). 2002c. “Fish of the Great Lakes: Rainbow 

Smelt.” Available URL: http://www.seagrant.wisc.edu/greatlakesfish/rainbowsmelt.html

(accessed November 4, 2008). ADAMS Accession No. ML093250044. 

Wells, L. 1970. “Effects of Alewife Predation on Zooplankton Populations in Lake Michigan,” 

Limnology and Oceanography, Vol. 15, 4:565-574.

Wisconsin Department of Public Instruction (DPI). 2009. “Public School Enrollment Data 2009: 

Public Enrollment by District by School by Gender.” Available URL: 

http://dpi.wi.gov/lbstat/xls/pecog09.xls (accessed July 2009). ADAMS Accession No. 

ML093250010.

Wisconsin Department of Natural Resources (WDNR). 2004. “Rainbow Smelt (Osmerus 

mordax).” Available URL: http://dnr.wi.gov/invasives/fact/rainbow_smelt.htm (accessed 

November 7, 2008). ADAMS Accession No. ML093250045.

Wisconsin Department of Natural Resources (WDNR). 2004a. “Wisconsin Endangered and 

Threatened Species Laws & List,” February 2004. Available URL: 

http://dnr.wi.gov/ORG/LAND/ER/wlist/WI_ET_Laws_List.pdf (accessed January 6, 2009). 

ADAMS Accession No. ML093250046.

Wisconsin Department of Natural Resources (WDNR). 2005. State of Wisconsin Department of 

Natural Resources Permit to Discharge Under the Wisconsin Pollutant Discharge Elimination 

System, Permit No. WI-0001571-07-0, Kewaunee Power Station, July 2005. ADAMS Accession 

No. ML083520612.

Wisconsin Department of Natural Resources (WDNR). 2008. “Natural Heritage Inventory 

County Maps: Brown County.” Available URL: 

http://dnr.wi.gov/org/land/er/nhi/CountyMaps/pdfs/Brown_County.pdf (accessed January 6, 

2009). ADAMS Accession No. ML093250047.

Wisconsin Department of Natural Resources (WDNR). 2008a. “Natural Heritage Inventory 

County Maps: Kewaunee County.” Available URL: 

http://dnr.wi.gov/org/land/er/nhi/CountyMaps/pdfs/Kewaunee_County.pdf (accessed January 6, 

2009). ADAMS Accession No. ML093250048.

Wisconsin Department of Natural Resources (WDNR). 2008b. “Natural Heritage Inventory 

County Maps: Manitowoc County.” Available URL: 

http://dnr.wi.gov/org/land/er/nhi/CountyMaps/pdfs/Manitowoc_County.pdf (accessed January 6, 

2009). ADAMS Accession No. ML093250049.
Affected Environment

August 2010 2-63 NUREG-1437, Supplement 40

Wisconsin Department of Natural Resources (WDNR). 2008c. “Natural Heritage Inventory 

County Maps: Outagamie County.” Available URL: 

http://dnr.wi.gov/org/land/er/nhi/CountyMaps/pdfs/Outagamie_County.pdf

Wisconsin Department of Natural Resources (WDNR). 2009. “Choose Wisely: A Health Guide 

for Eating Fish in Wisconsin.” Available URL: 

(accessed January 6, 

2009). ADAMS Accession No. ML09325050.

http://dnr.wi.gov/fish/consumption/FishAdvweb09lo.pdf (accessed July 13, 2009). ADAMS 

Accession No. ML093250051.

Wisconsin Department of Natural Resources (WDNR). 2009a. “Invasive Species: Animals.” 

Available URL: http://dnr.wi.gov/invasives/animals.asp (accessed August 9, 2009). ADAMS 

Accession No. ML093250052.

Wisconsin Department of Natural Resources (WDNR). 2009b. “Invasive Species: Plants.” 

Available URL: http://dnr.wi.gov/invasives/plants.asp (accessed August 9, 2009). ADAMS 

Accession No. ML093250053.

Wisconsin Department of Natural Resources (WDNR). 2009c. “Natural Communities of 

Wisconsin.” Available URL: http://www.dnr.wi.gov/org/land/er/communities/ (accessed August 9, 

2009). ADAMS Accession No. ML093250054.

Wisconsin Department of Natural Resources (WDNR). 2009d. “Wisconsin Ecological 

Landscapes Handbook, Grassland Communities.” Available URL: 

http://www.dnr.wi.gov/landscapes/pdfs/Grass.pdf (accessed August 9, 2009). ADAMS 

Accession No. ML093250055.

Wisconsin Department of Natural Resources (WDNR). 2009e. “Wisconsin Ecological 

Landscapes Handbook, Wetland Communities.” Available URL: 

http://www.dnr.wi.gov/landscapes/pdfs/Wet.pdf (accessed August 9, 2009). ADAMS Accession 

No. ML093250056.

Wisconsin Department of Natural Resources (WDNR). 2009f. “Wisconsin’s Major Aquifers.” 

Available URL: http://www.dnr.state.wi.us/org/caer/ce/eek/teacher/groundwaterguide/P1213.pdf

(accessed August 2009). ADAMS Accession No. ML093250057.

Wisconsin Department of Revenue (WDOR). 2009a. “Shared Revenue Utility Payments.” 

Available URL: http://www.revenue.wi.gov/ (accessed on July 2010). 

Wisconsin Department of Revenue (WDOR). 2009b. “County and Municipal Revenues and 

Expenditures – 2004 through 2007.” Available URL: http://www.revenue.wi.gov/report/r.html

(accessed July 2009). ADAMS Accession No. ML093250058.

Wisconsin Department of Transportation (WDOT). 2009. “Travel Information – Traffic Count 

Maps by County.” Available URL: http://www.dot.wisconsin.gov/travel/counts/index.htm

(accessed July 2009). ADAMS Accession No. ML093250059.

Wisconsin Natural Heritage Program (WNHP). 2006. “Wisconsin Natural Heritage Working List.” 

December 2006. Available URL: http://dnr.wi.gov/ORG/LAND/ER/wlist/Working_List_2006.pdf

(accessed January 6, 2009).
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August 2010 3-1 NUREG-1437, Supplement 40

3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT

Facility owners or operators may need to undertake or, for economic or safety reasons, may 

choose to perform refurbishment activities in anticipation of license renewal or during the license 

renewal term. The major refurbishment class of activities characterized in the Generic 

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437 

(NRC, 1996), (NRC, 1999) is intended to encompass actions which typically take place only 

once in the life of a nuclear plant, if at all. Examples of these activities include, but are not 

limited to, replacement of boiling water reactor recirculation piping and pressurized-water 

reactor steam generators. As noted in the GEIS, refurbishment activities could result in 

environmental impacts beyond those that occur during normal plant operations. Refurbishment 

activities may affect a variety of environmental issues as listed in 

Table 3-1.

Table 3-1. Issues Related to Refurbishment. Kewaunee Power Station does not have any 

plans for refurbishment activities.

Issues Category

Surface Water Quality, Hyd rolog y, and Us e 

Impacts of refurbishment on surface water quality 1

Impacts of refurbishment on surface water use 1

Aquatic Ecology 

Refurbishment 1

Terrestrial Resources

Refurbishment impacts 2

Threatened or Endangered Species 

Threatened or endangered species 2

Groundwater Use and Quality

Impacts of refurbishment on groundwater use and quality 1

Air Quality

Air quality during refurbishment (nonattainment and maintenance areas) 2

Land Use

Onsite land use 1

Human Health

Radiation exposures to the public during refurbishment 1

Occupational radiation exposures during refurbishment 1

Socioeconomics 

Public services: public safety, social services, and tourism and recreation 1

Aesthetic impacts (refurbishment) 1

Housing impacts 2

Public services: education (refurbishment) 2

Public services: public utilities 2

Public services: transportation 2

Offsite land use (refurbishment) 2

Historic and Archaeological resources 2

Environmental Justice

Environmental justice Uncategorized
Environmental Impacts of Refurbishment

NUREG-1437, Supplement 40 3-2 August 2010

Dominium Energy Kewaunee, Inc. (DEK) submitted to the U.S. Nuclear Regulatory Commission 

(NRC) an environmental report (ER) as part of its license renewal application for Kewaunee 

Power Station (KPS) in August 2008. DEK addressed refurbishment activities in the ER (DEK, 

2008a), which is Attachment E of the license renewal application (DEK, 2008b). DEK states in 

the ER that the refurbishing assessment for KPS was done according to the regulations in 

10 CFR Parts 51 and 54 and complementary information in the GEIS. 

The requirements for the assessment of refurbishing in a license renewal of operating nuclear 

power plants include the preparation of an integrated plant assessment (IPA) under 

10 CFR 54.21. The IPA must identify and list systems, structures, and components subject to an 

aging management review. Items that are subject to aging and might require refurbishment 

include, for example, the reactor vessel, piping, supports, and pump casings, as well as those 

that are not subject to periodic replacement. 

In the case of KPS, the IPA did not identify the need for major refurbishment or replacement 

actions to maintain the functionality of important systems, structures, and components during 

the KPS license renewal period. Also, the IPA did not identify the need for modifications to any 

of the KPS facilities associated with the license renewal.

The staff reviewed the information presented in the KPS ER, support documentation, and 

gathered during the site audits and interviews. During the review, the staff did not identify any 

new and significant information that would affect the conclusion presented in the ER. Therefore, 

based on the review, the staff concluded that no refurbishing activities are necessary in 

anticipation of the license renewal or during the license renewal term. The staff does not expect 

that the environmental impacts caused by KPS during the renewal term will be beyond those 

that occur during the normal plant operations. 

3.1 REFERENCES

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

Regulations for Domestic Licensing and Related Regulatory Functions.”

10 CFR 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for Renewal 

of Operating Licenses for Nuclear Power Plants.”

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2, Washington, D.C.

ML040690705 and ML040690738.

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1, 

Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final 

Report,” NUREG-1437, Volume 1, Addendum 1, Washington, D.C. ADAMS Accession No.

ML040690720.

Dominion Energy Kewaunee, Inc. (DEK). 2008a. “Applicant’s Environmental Report – Operating 

License Renewal Stage. Appendix E of Application for Renewed Operating License, Kewaunee 

Power Station,” Docket No. 50-305, August 2008. Agencywide Documents Access and 

Management System (ADAMS) Accession No. ML082341039.

Dominion Energy Kewaunee, Inc. (DEK) 2008b. “Application for Renewed Operating License, 

Kewaunee Power Station,” Docket No. 50-305, August 2008. ADAMS Accession Nos. 

ML082341020, ML082341038, ML082420854.
August 2010 4-1 NUREG-1437, Supplement 40

4.0 ENVIRONMENTAL IMPACTS OF OPERATION

This chapter addresses potential environmental impacts related to the period of extended 

operation of Kewaunee Power Station (KPS). These impacts are grouped and presented 

according to resource. Generic issues (Category 1) rely on the analysis provided in the Generic 

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437 

(NRC, 1996), (NRC, 1999) and are discussed briefly. Site-specific issues (Category 2) have 

been analyzed for KPS and assigned a significance level of SMALL, MODERATE, or LARGE, 

accordingly. Some remaining issues are not applicable to KPS because of site characteristics or 

plant features. Section 1.4 of this report explains the criteria for Category 1 and Category 2 

issues and defines the impact designations of SMALL, MODERATE, and LARGE.

4.1 GENERIC LAND USE ISSUES

Table 4-1 lists the Category 1 issues (from Title 10 of the Code of Federal Regulations (10 CFR) 

Part 51, Subpart A, Appendix B, Table B-1) which are applicable to onsite land use and power 

line right-of-way (ROW) impacts during the renewal term. As stated in the GEIS, the impacts 

associated with these Category 1 issues were determined to be SMALL, and plant-specific 

mitigation measures would not be sufficiently beneficial to be warranted.

NRC reviewed and evaluated the Dominion Energy Kewaunee’s (DEK) environmental report 

(ER) (DEK, 2008), scoping comments, other available information, and visited KPS in search of 

new and significant information that would change the conclusions presented in the GEIS. No 

new and significant information was identified during this review and evaluation. Therefore, it is 

expected that there would be no impacts related to these Category 1 issues during the renewal 

term beyond those discussed in the GEIS.

Table 4-1. Land Use Issues. Section 2.2.1 of this supplemental environmental impact 

statement (SEIS) describes the land use around KPS.

Issues GEIS Section Category

Onsite land use 4.5.3 1

Power line ROW 4.5.3 1

4.2 GENERIC AIR QUALITY ISSUES

The air quality issue applicable to KPS is listed in Table 4-2. No Category 2 issues have been 

identified for air quality. The staff did not identify any new and significant information during the 

review of the applicant’s ER (DEK, 2008), the site audit, or during the scoping process. No 

major facility construction or refurbishments are planned to occur during the license renewal 

period. Therefore, there are no impacts related to this issue beyond those discussed in the 

GEIS. For these issues, the GEIS concluded that the impacts are SMALL.

Table 4-2. Air Quality Issues. Section 2.2.2 of this document provides a description of air 

quality at KPS.

Issue GEIS Section Category

Air quality effects of transmission lines 4.5.2 1
Environmental Impacts of Operation

NUREG-1437, Supplement 40 4-2 August 2010

4.3 GENERIC GROUNDWATER ISSUES

There were no Category 1 groundwater impacts identified for the KPS license renewal term, and 

no Category 2 issues were found applicable to the continued operation of the facility. KPS 

withdraws less than 100 gallons per minute of groundwater, and its once-through cooling 

system does not use cooling towers or cooling ponds, therefore, none of the NRC specified 

Category 2 issues for groundwater issues are applicable to KPS.

4.4 GENERIC SURFACE WATER ISSUES 

Table 4-3 lists the surface water quality issues applicable to KPS. NRC did not identify any new 

and significant information during the environmental review for the KPS license renewal, the site 

visit, or the scoping process. Therefore, no impacts are related to these issues beyond those 

discussed in the GEIS. For these issues, the GEIS concludes that the impacts are SMALL and 

additional site-specific mitigation measures are not likely to be warranted.

Table 4-3. Surface Water Issues. Sections 2.1.7.2 and 2.2.4 of this document provides a 

description of surface water at KPS.

Issue GEIS Section Catergory

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

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 once-through cooling systems 4.2.1.3 1

4.4.1 Water Use Conflicts

There were no Category 2 surface water issues identified for the KPS license renewal term.

4.5 AQUATIC RESOURCES

The generic (Category 1) and site-specific (Category 2) issues related to aquatic resources 

applicable to KPS are discussed below and listed in Table 4-4.
Environmental Impacts of Operation

August 2010 4-3 NUREG-1437, Supplement 40

Table 4-4. Aquatic Resources Issues. Section 2.1.6 of this document describes KPS’s cooling 

water system, and Section 2.2.5 of this document describes the aquatic resources.

Issue 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 super saturation (gas bubble disease) 4.2.2.1.8 1

Low dissolved oxygen in the discharge 4.2.2.1.9 1

Losses from predation, parasitism, and disease among organisms 

exposed to sublethal stresses 4.2.2.1.10 1

Stimulation of nuisance organisms 4.2.2.1.11 1

For Plants with Once-Through Cooling Pond Heat Dissipation Systems

Entrainment of fish and shellfish in early life stages 4.1.2 2

Impingement of fish and shellfish 4.1.3 2

Heat shock 4.1.4 2

4.5.1 Generic Aquatic Ecology Issues

The staff did not identify any new or significant information during the review of the applicant’s 

ER (DEK, 2008), the staff’s site audit, the scoping process, or the evaluation of other available 

information. Therefore, the staff found no impacts related to the generic, Category 1 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 be warranted.

4.5.2 Entrainment of Fish and Shellfish in Early Life Stages 

Entrainment occurs when aquatic organisms (usually eggs, larvae, and other small organisms) 

are drawn into the cooling water system and are subjected to thermal, physical, and chemical 

stress. For nuclear power plants with once-through cooling systems, the NRC considers the 

entrainment of fish and shellfish in early life stages into cooling water systems to be a Category 

2 issue, which requires a site-specific assessment during the license renewal application review 

process. KPS operates a once-through heat dissipation system that withdraws water from and 

discharges it back to Lake Michigan. A detailed description of the KPS cooling system is 

presented in Section 2.1.6 of this SEIS.

For the site-specific assessment of the KPS cooling system, the staff reviewed the applicant’s 

ER (DEK, 2008) and related documents, including the Clean Water Act (CWA) Section 316(a) 

Demonstration (NES, 1976), CWA Section 316(b) Demonstration (NES, 1976), and the KPS 

Impingement Mortality and Entrainment Characterization Report (EAE, 2007). The staff also 

reviewed the applicant’s Wisconsin Pollutant Discharge Elimination System (WPDES) Permit 
Environmental Impacts of Operation

NUREG-1437, Supplement 40 4-4 August 2010

No. WI-0001571-07-0, “Cooling Water Intake Structure Information Submittal” (Dominion, 2008), 

(WDNR, 2005), (WDNR, 2005a) and visited the KPS site.

Section 316(b) of the CWA requires that the location, design, construction, and capacity of the 

cooling water intake structures reflect the best technology available (BTA) in order to minimize 

adverse environmental impacts, specifically impingement and entrainment, to protect fish, 

shellfish, and other forms of aquatic life (33 USC 1326). Phase II of Section 316(b)’s 

implementing regulations applies to large existing electric generating plants, such as KPS, that 

withdraw more than 50 million gallons of water per day (gpd) (6.7 million cubic feet per day 

(cfd)). The Environmental Protection Agency (EPA) implemented Phase II on July 9, 2004 

(69 FR 41575). The new Phase II performance standards were designed to significantly reduce 

impingement mortality due to water withdrawals associated with cooling water intake structures 

used for power production and were to be implemented through the National Pollutant 

Discharge Elimination System (NPDES) permitting process. The rule would require licensees to 

demonstrate compliance with Phase II performance standards upon renewal of their NPDES 

permit. 

However, the EPA suspended the Phase II rule on July 9, 2007 (72 FR 37107), in response to 

the Second Circuit Court of Appeals decision in Riverkeeper, Inc. v. EPA, 475 F.3d 83 (2d Cir. 

2007). As a result, the EPA directed NPDES permit writers for Phase II facilities to develop 

technology-based permit conditions on a case-by-case basis using all reasonably available and 

relevant data and best professional judgment (BPJ) regarding the BTA. Some of the changes 

that the licensees may be required to implement by the EPA could include altering their intake 

structure, redesigning the cooling system, modifying station operation, or taking other mitigative 

measures.

Before suspension of the Phase II rule, DEK submitted a Proposal for Information Collection 

(PIC) to the Wisconsin Department of Natural Resources (WDNR) in October 2005 to 

demonstrate KPS’s compliance with the Phase II requirements. The PIC included options for 

achieving compliance with the rule and proposals for biological studies. The WDNR provided 

comments modifying the PIC, and DEK began collecting data in accordance with the modified 

PIC in March 2006. As a result of the July 9, 2007, suspension of the Phase II rule, KPS was no 

longer required to comply with the modified PIC; however, the WDNR modified the requirements 

contained in the KPS WPDES permit so that the one-year impingement and entrainment field 

study detailed in the modified PIC remained a requirement (WDNR, 2007). On January 4, 2008, 

DEK submitted a letter to the WDNR (Dominion, 2008) containing the one-year impingement 

and entrainment field study from March 2006 through February 2007 prepared by EA 

Engineering, Science, and Technology, Inc. (EA Engineering) (EAE, 2007).

Prior to this study, as a condition of the original WPDES permit for KPS, Nalco Environmental 

Sciences (NES) performed a one-year entrainment and impingement study (NES, 1976) for 

Wisconsin Public Service Corporation (WPSC) from April 1, 1975, through March 31, 1976. The 

results of this study were summarized in a 316(b) Demonstration. At that time, WDNR did not 

require any additional modifications of the cooling system or mitigation for compliance with the 

KPS WPDES permit as a result of the study.

4.5.2.1 Nalco Environmental Sciences, 1975–1976

The original KPS WPDES Permit required a one-year study on the environmental impacts of the 

cooling water intake structure, which NES (1976) conducted from April 1, 1975, through 

March 31, 1976; the results were summarized in a 316(b) Demonstration. NES gathered 

entrainment samples from the forebay once per week from April through August 1975 and twice 
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August 2010 4-5 NUREG-1437, Supplement 40

per month from September 1975 through March 1976. Two zero-mesh (335 μm) plankton nets 

with digital flow monitors were used to gather entrainment samples three times (12 a.m., 8 a.m., 

and 4 p.m.) during each 24-hour period of sampling. Two replicates were collected for each net 

at each time period. Collected fish eggs, larvae, and debris were then sorted, counted, and 

recorded. Larvae were measured to the nearest 0.1 mm (0.004 in.) and identified by species, as 

possible. Some juveniles were collected, though NES combined juveniles and larvae for 

purposes of analysis. Intake and discharge temperatures, water flow, and turbidity were also 

collected at the time of each sample. Impingement sampling methods for this study are 

discussed in Section 4.5.3 (NES, 1976).

Alewife was the most prevalent species of eggs collected from entrainment sampling, followed 

by rainbow smelt and white or longnose sucker (the study groups these together by family, 

Catostomidae) (See Table 4-5). Alewife eggs were collected in June, July, and August, while 

catostomid and rainbow smelt eggs were only collected in April and May. A total of 3,224 fish 

eggs were collected during the study with a peak collection of 1,777 eggs in July. NES (1976) 

estimated that a total of 52.6 million eggs were entrained through the KPS cooling system 

during the study year with peak numbers in July and August and a combined estimated total of 

43.9 million eggs (NES, 1976).

Table 4-5. Entrainment by Species, April 1975 through March 1976

Common Name Taxa Total Number 

Collected

Percentage of 

Total

Eggs

Alewife Alosa pseudoharengus 2208 68.5

Rainbow smelt Osmerus mordax 976 30.3

White or longnose sucker Catostomidae species 26 0.8

Unidentified taxa 14 0.4

Total 3224 100

Larvae and Juveniles

Rainbow smelt Osmerus mordax 411 89.7

Alewife Alosa pseudoharengus 20 4.4

Carp Cyprinus carpio 12 2.6

Burbot Lota lota 6 1.3

Whitefish Coregonidae species 5 1.1

Slimy sculpin Cottus cognatus 3 0.7

White or longnose sucker Catostomidae species 1 0.2

Total 458 100

Source: adapted from NES, 1976

Rainbow smelt was the most prevalent species of larvae and juveniles collected from 

entrainment sampling and accounted for almost 90 percent of the total collected. Alewife and 

catostomid larvae and juveniles were also identified in the samples. Additionally, carp (Cyprinus 

carpio), burbot (Lota lota), whitefish (Coregonidae species), and slimy sculpin (Cottus cognatus) 

were present, none of which were identified in egg samples. NES (1976) estimated that KPS 

entrained a total of 13.6 million larvae and juveniles through the KPS cooling system during the 
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NUREG-1437, Supplement 40 4-6 August 2010

study year with the majority entrained during summer months (6.4 million), followed by autumn 

(5.2 million), and then spring (2.0 million).

When all life stages are considered (eggs, larvae, and juveniles), alewife accounted for 

61 percent and rainbow smelt accounted for 38 percent of the total entrained. The study 

estimates that the number of alewife and rainbow smelt eggs lost to entrainment over the study 

year would be comparable to the potential production of 4,286 alewife females and 200 smelt 

females (NES 1976). The estimated loss of larval and juvenile individuals for each species 

would be equivalent to the larval production of 105,400 alewife, 4,630 smelt, 323 slimy sculpin, 

1 burbot, 10 whitefish, and 1 catostomid female (NES, 1976). The loss of carp juveniles was 

noted to be small compared to the large number of larvae produced by an average carp female, 

though no equivalent was provided. Froese and Pauly (2009) estimate that a 19-inch (47-cm) 

carp female can produce 300,000 eggs; therefore, the loss of carp larvae and juveniles due to 

entrainment is equivalent to the egg production of less than one adult female. NES (1976) 

considered these losses to be small for all species.

The NES (1976) study shows that the alewife population is adversely affected the most from 

entrainment. As discussed in Section 2.2.5 of this SEIS, the alewife is invasive to the Great 

Lakes and was first introduced to Lake Michigan in 1949. From the mid-1950s through 1960s, 

the rapid decrease in abundance of certain native fish that the alewife preyed on led to 

large-scale die-offs of alewives in the 1950s and 1960s (Crawford, 2001). The WDNR began a 

salmonid stocking program in 1965 to control the still overabundant alewife population and to 

help restore the native fish population (Madenjian et al., 2005). Though the number of entrained 

alewife seems high, this study took place within the time period that the previously 

overabundant population of alewife was showing decline due to salmonid predation. Therefore, 

the effect of entrainment on the total population of alewife may not have been significant. The 

National Marine Fisheries Service does not have annual commercial landing statistics available 

for 1976, the year that the impingement and entrainment study took place (NOAA, 2007). The 

closest years available for the State of Wisconsin are 1961 (2,113,200 pounds (lbs) or 

958,531 kilograms (kg)) and 1985 (23,366,000 lbs or 10,598,639 kg) (NOAA, 2007). Because 

the decline of alewife in Lake Michigan occurred between the 1960s and 1980s, the NRC will 

assume the average between 1961 and 1985 as an estimate for 1976, which is 12,739,600 lbs 

(5,778,585 kg). Adult alewives might typically weigh 8 to 9 ounces (227 to 255 grams (g)) on 

average (Bigelow and Schroeder, 1953). Therefore, the 1976 estimated landings would account 

for an estimated 23,980,423 adult alewives. In comparison, the equivalent production loss of 

109,686 females (under 0.5 percent) from entrainment of eggs, larvae, and juveniles is small.

4.5.2.2 EA Engineering, Science, and Technology, Inc., 2006–2007

After the EPA suspended the CWA 316(b) Phase II rule (discussed above), the WDNR modified 

the requirements of the KPS WPDES permit to include a one-year impingement and 

entrainment study. EA Engineering performed this study from March 2006 through February 

2007. EA Engineering gathered entrainment samples from the discharge canal once per week 

from March through August 2006, once in September 2006 due to a planned plant outage, and 

twice per month from October 2006 through February 2007. One zero-mesh (335 μm) plankton 

net equipped with a mechanical flow meter was used to gather entrainment samples four times 

(generally at 4 a.m., 10 a.m., 4 p.m., and 10 p.m.) during each 24-hour period of sampling. Two 

replicates were collected for each sampling time. Collected fish eggs, larvae, and debris were 

then sorted, counted, and recorded. Unlike the NES (1976) study, EA Engineering (2007) based 

their findings on density of entrainment rather than total number of organisms of each taxon 

collected. Additionally, eggs were only counted and identified as fertilized or unfertilized but 
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August 2010 4-7 NUREG-1437, Supplement 40

were not identified by species. Up to 20 larvae of each taxon and life-stage were measured to 

the nearest 0.004 inches (0.1mm). Impingement sampling methods for this study are discussed 

in Section 4.5.3 (EAE, 2007).

The amphipod crustacean genus Gammarus accounted for the vast majority (93 percent) of 

entrained organisms based on annual density. Burbot, alewife, and common carp were the most 

abundant fish species; however, these three species collectively accounted for only 

1.08 percent of the estimated total number of organisms entrained. A total of 15 fish species 

were identified in the entrainment samples. Density data as well as station cooling water flow 

data were used to estimate the total number of organisms entrained during the study year for 

each species (see Table 4-6) (EAE, 2007).

Table 4-6. Estimated Entrainment by Species, March 2006 through February 2007

Common Name Taxa Total Estimated Number 

(x 106)

Percentage of

Total

Eggs

Unidentified taxa 25.28 1.63

Total 25.28 1.63

Larvae

Burbot Lota lota 7.82 0.50

Carp Cyprinus carpio 5.40 0.35

Alewife Alosa pseudoharengus 3.52 0.23

Carp and minnow family Cyprinidae species 2.80 0.18

Clupeid family Clupeidae species 1.96 0.13

Rainbow smelt Osmerus mordax 1.25 0.08

Whitefish family Coregoninae species 0.80 0.05

Sickleback family Gasterosteidae species 0.66 0.04

Perch family Percidae species 0.55 0.03

Unidentified taxa 0.39 0.02

Round goby Neogobius melanostomus 0.14 0.01

Sucker species Catostomus species 0.12 <0.01

Ninespine Stickleback Pungitius pungitius 0.07 <0.01

White sucker Catostomus commersoni 0.05 <0.01

Deepwater sculpin Myoxocephalus thompsoni 0.04 <0.01

Juveniles

Rainbow smelt Osmerus mordax 3.22 0.21

Alewife Alosa pseudoharengus 0.29 0.02

Ninespine Stickleback Pungitius pungitius 0.20 0.01

Deepwater sculpin Myoxocephalus thompsoni 0.07 <0.01

Total 29.35 1.88

Invertebrates

Scud species Gammarus species 1494.22 96.23

Opossum shrimp Mysis relicta 3.22 0.21

Bloody-red mysid Hemimysis anomala 0.74 0.05

Total 1498.18 96.49

Source: adapted from EAE, 2007
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Total estimated numbers entrained for each species of fish were generally small when 

compared to the potential production of reproducing females. Female burbot can produce 

between 500,000 and 1,500,000 eggs (USFWS, 2003). Using the average egg production of 

1,000,000 eggs per female, the total estimated number of entrained burbot larvae is equivalent 

to the egg production of about eight females. Female carp can produce up to 300,000 eggs 

(Froese and Pauly, 2009). Therefore, the total estimated number of entrained carp larvae is 

equivalent to the egg production of 18 females. Female alewife can produce 60,000 to 100,000 

eggs (Fay et al., 1983). Using the average egg production of 80,000 eggs per female, the total 

estimated number of entrained alewife larvae is equivalent to the production of 44 females.

Because not all eggs are spawned, not all spawned eggs are fertilized, few fertilized eggs 

survive to become larvae in the wild, and mortality rates can be high within the larval stages, the 

estimated equivalent number of reproducing females for each species will likely be greater than 

the numbers calculated above. Though the specific mortality rate of alewives from egg to larval 

stage is unavailable, Edsall in 1970 (Fay et al., 1983) reported an alewife egg hatching rate of 

38 percent at an optimal incubation temperature of 64 °F (18 °C) in Lake Michigan. Using this 

hatching rate and the average production of 80,000 eggs per female (Fay et al., 1983), the total 

estimated number of entrained alewife larvae is equivalent to the production of 116 females. 

The staff calculated the percent of the Lake Michigan alewife population that 116 females 

represents by using a 2007 estimate (Madenjian et al., 2008) of a lakewide biomass of alewives 

(11,674 metric tons; 25,736,764.5 lbs) and the average weight of an adult alewife, which might 

typically be 8 to 9 ounces (227 to 255 g) (Bigelow and Schroeder, 1953). The staff found that 

alewife larval entrainment, calculated to be equivalent to the egg production of 116 females, 

would represent only 0.0002 percent of the Lake Michigan population. Specific mortality rates 

for burbot and carp were unavailable; however, the equivalent loss of reproducing females from 

larval entrainment would likely remain small in comparison to the lakewide population of each 

species.

When results of the 1975–1976 NES (1976) study are compared to the 2006–2007 EA

Engineering (2007) study, some notable differences appear. Rainbow smelt were more 

abundant in 1975–1976 samples than in 2006–2007 samples. Table 4-7 contains the total 

estimated numbers of entrained individuals for those species that appear in both studies. The 

total estimated number of eggs entrained was also much higher in the 1975–1976 study. 

Alewife, carp, burbot, and whitefish were more abundant in the 2006–2007 samples. EA

Engineering (2007) notes that these differences primarily reflect the changing population 

dynamics and species’ abundances in Lake Michigan during the 30-year interval between 

studies. Section 2.2.5 of this SEIS describes the changing aquatic communities within Lake 

Michigan as a result of numerous invasive species introductions, which supports this 

conclusion. 

Sampling differences may have occurred due to location of sampling: NES (1976) sampled in 

the forebay at the intake, while EA Engineering (2007) sampled in the discharge canal. 

However, the total absence of certain species from the 1975–1976 study is unlikely if these 

species were within the vicinity of KPS at the time of the study. Burbot, ninespine stickleback, 

round goby, and white sucker, all of which appeared in the 2006–2007 study but not in the 

1975–1976 study, spawn in relatively shallow water, which means that their larvae would have a 

greater likelihood of being entrained if these species were in the vicinity of KPS. Bunnell et al., 

(2007) reports a recovery of burbot numbers beginning in the 1980s after the species had 

suffered a decline in the 1970s following the introduction of alewife. This may account for the 

appearance of this species in the 2006–2007 study but not the 1975–1976 study. The ninespine 

stickleback population density in Lake Michigan was low from 1973–1995, increased 
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August 2010 4-9 NUREG-1437, Supplement 40

dramatically in 1996–1997, and has remained variable since this time, which may account for 

the increased number of individuals recorded in the 2006–2007 study (Bunnel et al., 2007), 

(EAE, 2007). Though species composition differs between the studies, both studies collected 

species representing the major trophic levels of fish: predator species, forage species, and 

bottom-dwellers; therefore, the results of these studies do not indicate that the aquatic 

community within the vicinity of KPS has become destabilized. Additionally, neither study 

indicates that any one species is being affected enough to cause decline or destabilization of 

the species population in Lake Michigan. 

Table 4-7. Estimated Total Numbers of Entrained Fish. Total estimated numbers are 

compared between the 1975–1976 study (NES, 1976) and 2006–2007 (EAE, 2007) study for 

those species that appeared in both studies.

Species and/or Life Stage

Total Estimated Number 

(x 106)

1975–1976

Total Estimated Number 

(x 106)

2006–2007

Fish eggs 52.672 25.28

Rainbow smelt juveniles 9.715 3.22

Rainbow smelt larvae 2.764 1.32

Alewife juveniles 0.393 0.29

Alewife larvae 0.271 3.52

Carp larvae 0.237 5.40

Burbot larvae 0.076 7.82

Slimy sculpin larvae 0.085 0.00

Whitefish larvae 0.076 0.80

Source: adapted from EAE, 2007

Based on the information presented in this section, the staff determined that the potential 

impacts of entrainment of fish and shellfish by the KPS cooling system during the 20-year 

renewal period would be SMALL. The staff identified potential mitigation measures, including 

use of finer mesh screens, operating under reduced intake flow, and scheduling outages during 

historic periods of high fish density. However, the staff concludes that none of the mitigation 

measures considered would eliminate adverse entrainment impacts and would not reduce the 

significance level below SMALL. The NRC does not have the authority to mandate these 

measures; it is the responsibility of the WDNR to impose any restrictions or modifications to the

cooling system to reduce the impact of entrainment under the WPDES permitting process. The 

staff did not identify any cost benefit studies applicable to these mitigation measures.

4.5.3 Impingement

Impingement occurs when aquatic organisms are pinned against intake screens or other parts 

of the cooling water system intake structure. For plants with once-through cooling systems, the 

impingement of fish and shellfish on screens associated with plant cooling systems is 

considered a Category 2 issue, which requires a site-specific assessment during the license 

renewal application review process. The staff considered the information and documents 

described previously in Section 4.5.2 to perform a site-specific assessment of impingement 

resulting from the KPS cooling system. Impacts of existing cooling water systems, including 

impacts of impingement, are regulated under the provisions of the CWA as described in Section 

4.5.2. Section 4.5.2 also includes a discussion of Section 316(b) requirements, which are 
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NUREG-1437, Supplement 40 4-10 August 2010

relevant to impingement. A detailed description of the KPS cooling system is presented in 

Section 2.1.6.

4.5.3.1 Nalco Environmental Sciences, 1975–1976

As previously described in Section 4.5.2, NES (1976) conducted a one-year impingement and 

entrainment study from April 1, 1975, through March 31, 1976. NES sampled adult and juvenile 

fish impinged on the traveling screens from 2 to 7 days per week during the study period. 

Impinged fish were washed into a discharge sluice and collected in a basket to be identified, 

measured, and weighed. Once the total number of alewives or smelt exceeded 50, only 

10 percent of the remaining alewives or smelt were removed to be weighed and measured, and 

these individuals served as a subsample from which to estimate the total number of alewives or 

rainbow smelt impinged (NES, 1976).

A total of 30 species of fish were collected in impingement samples during the study year (See 

Table 4-8). No Federally- or State-listed species were collected. Alewife accounted for the vast 

majority (83.2 percent) of the total individual fish impinged. Rainbow smelt, slimy sculpin, and 

longnose dace were also prevalent. A total of 215,108 fish were impinged with June having the 

highest number of fish (57,871), and March having the lowest number of fish (931). Alewives 

were collected in greatest numbers in the spring and summer, and few alewives were collected 

in winter, which corresponds to their seasonal patterns of migrating into shallower waters in the 

spring and inhabiting deeper portions of the lake in winter. NES (1976) estimated that only 

0.0003 percent of the total estimated biomass of alewife in Lake Michigan was impinged at KPS 

during the study year, which represents 0.02 percent of the total commercial catch in Wisconsin. 

Also, alewife die-offs were common during the late-1970s, which may account for the large 

number of alewives collected in impingement samples. The final SEIS for Point Beach Nuclear 

Station (NRC, 2005), which is located about 5 miles (mi) (8 kilometers (km)) south of KPS, 

notes that a majority of “impinged alewives were assumed to be dead or dying individuals 

associated with the annual spring die-off.” Rainbow smelt was the second most abundant 

species collected in impingement samples and was most common in October and November. 

Impinged smelt only accounted for 0.003 percent of the total estimated biomass of smelt in Lake 

Michigan and 0.3 percent of the total commercial catch in Wisconsin. Similarly, impinged slimy 

sculpin accounted for only 0.002 percent of the total estimated biomass of the species in Lake 

Michigan. All other species of fish impinged during the study year accounted for less than 

0.002 percent of the total estimated biomass of that species (NES, 1976).
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August 2010 4-11 NUREG-1437, Supplement 40

Table 4-8. Impinged Fish by Species, April 1975 through March 1976

Common Name Taxa Total 

Number

Percentage of 

Total

Alewife Alosa pseudoharengus 178,883 83.2

Rainbow smelt Osmerus mordax 19,206 8.9

Slimy sculpin Cottus cognatus 8,640 4.0

Longnose dace Rhinichthys cataractae 4,389 2.0

Lake chub Couesius plumbeus 1,584 0.7

Sucker group(a) Catostomus catostomus, C. commersonii, and 

Moxostoma macrolepidotum 1,000 0.5

Trout group(b) Oncorhynchus mykiss, Salmo trutta, Salvelinus 

fontinalis, and Salvelinus namaycush 344 0.2

Gizzard shad Dorosoma cepedianum 311 0.1

Carp Cyprinus carpio 259 0.1

Yellow perch Perca flavescens 245 0.1

Bullhead group(c) Ameiurus natalis and A. nebulosus 111 <0.1

Ninespine stickleback Pungitius pungitius 55 <0.1

Troutperch Percopsis omiscomaycus 39 <0.1

Whitefish group(d) Coregonus clupeaformis and Prosopium 

cylindraceum 13 <0.1

Pumpkinseed Lepomis gibbosus 9 <0.1

Burbot Lota lota 7 <0.1

Common shiner Notropis cornutus 4 <0.1

Salmon group(e) Oncorhynchus tshawytscha and O. kisutch 3 <0.1

Lamprey Petromyzontidae species 2 <0.1

Northern pike Esox lucius 2 <0.1

Bloater Coregonus hoyi 1 <0.1

Blacknose dace Rhinichthys atratulus 1 <0.1

Total 215,108 100

(a) Sucker group consists of white sucker, longnose sucker, and shorthead redhorse.

(b) Trout group consists of rainbow trout, brown trout, brook trout, and lake trout.

(c) Bullhead group consists of yellow bullhead and brown bullhead.

(d) Whitefish group consists of lake whitefish and round whitefish.

(e) Salmon group consists of Chinook salmon and coho salmon.

Source: adapted from NES, 1976

4.5.3.2 EA Engineering, Science and Technology, Inc., 2006–2007

As previously described in Section 4.5.2, EA Engineering (2007) conducted a one-year 

impingement and entrainment study from March 2006 through February 2007. Impingement 

samples were collected once per week from March through August 2006 and twice per month 

October 2006 through February 2007. No samples were collected in September 2006 due to a 

planned plant outage. Impingement samples were gathered in a collection basket downstream 

of the traveling screens over 24-hour periods from 9 a.m. to 9 a.m. As in the 1975–1976 NES 
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NUREG-1437, Supplement 40 4-12 August 2010

(1976) study, fish were then removed, identified, weighed, and counted. Up to 50 individual fish 

per species per 24-hour period were individually measured and weighed, and the excess 

individuals were counted and collectively weighed (EAE, 2007).

A total of 34 species of fish were collected in impingement samples during the study year. Over 

90 percent of all impinged fish were collected in June and July. No Federally- or State-listed 

species were collected. Alewife accounted for the vast majority (99.7 percent) of the total 

individuals impinged (EAE, 2007). Alewife collection peaked in June and July 2006 and again, 

to a lesser extent, in October and November 2006 (EAE, 2007). The staff estimated the percent 

of Lake Michigan alewives that were impinged in the KPS cooling system during the study year. 

EA Engineering (2007) recorded 690,402 individual alewives with a combined biomass of 

5,879 lbs (2,666,686.5 g) in impingement samples over the study year. Using the total number 

of collected alewife, the biomass of collected alewife, and the total estimated number of alewife 

impinged over the study year (5,592,692 individuals), the staff extrapolated the total estimated 

biomass of alewife impinged over the study year to be 47,624 lbs (21,601,844 g). Madenjian et 

al., (2008) estimates the 2007 lakewide biomass of alewife was 11,674 metric tons 

(25,736,764.5 lbs). Therefore, impinged alewife represented 0.002 percent of the total estimated 

alewife biomass in Lake Michigan in 2007.

Ninespine stickleback, rainbow smelt, yellow perch, mottled sculpin, and spottail shiner were 

collected in excess of 100 individual fish over the study year, and less than 100 individual fish of 

all other species were collected (See Table 4-9) (EAE, 2007). Similar to the estimates above, 

the staff used Madenjian et al.’s (2008) lakewide biomass estimates, EA Engineering (2007) 

total estimated number of individual fish impinged over the study year, and an extrapolated total 

estimated biomass based on the combined collected biomass during the study. The staff found 

that ninespine stickleback, rainbow smelt, yellow perch, mottled sculpin, and spottail shiner 

each accounted for less than 0.001 percent of the total estimated biomass of their species in 

Lake Michigan.
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Table 4-9. Impinged Fish by Species, February 2006 through January 2007

Common Name Taxa Total 

Collected

% of Total 

Collected

Total 

Estimated

% of Total 

Estimated

Alewife Alosa pseudoharengus 690,402 99.741 5,592,692 99.624

Ninespine stickleback Pungitius pungitius 572 0.083 4473 0.080

Rainbow smelt Osmerus mordax 300 0.043 3279 0.058

Yellow perch Perca flavescens 164 0.024 3080 0.055

Mottled sculpin Cottus bairdii 145 0.021 2148 0.038

Spottail shiner Notropis hudsonius 125 0.018 1615 0.029

Northern clearwater 

crayfish

Orconectes 

propinquus 123 0.018 1104 0.020

Longnose sucker Catostomus 

catostomus 62 0.009 590 0.011

Threespine 

stickleback

Gasterosteus 

aculeatus 55 0.008 525 0.009

White sucker Catostomus 

commersonii 52 0.008 597 0.011

Longnose dace Rhinichthys cataractae 50 0.007 714 0.013

Gizzard shad Dorosoma 

cepedianum 41 0.006 1216 0.022

Burbot Lota lota 27 0.004 384 0.007

Slimy sculpin Cottus cognatus 18 0.003 277 0.005

Round goby Neogobius 

melanostomus 12 0.002 117 0.002

Channel catfish Ictalurus punctatus 8 0.001 219 0.004

Lake trout Salvelinus namaycush 7 0.001 49 <0.001

Round whitefish Prosopium 

cylindraceum 7 0.001 169 0.003

Black bullhead Ameiurus melas 3 <0.001 90 0.002

Carp Cyprinus carpio 3 <0.001 70 0.001

Smallmouth bass Micropterus dolomieui 3 <0.001 43 <0.001

Brown trout Salmo trutta 2 <0.001 35 <0.001

Chinook salmon Oncorhynchus 

tshawytscha 2 <0.001 36 <0.001

Lake whitefish Coregonus 

clupeaformis 2 <0.001 38 <0.001

Bloater Coregonus hoyi 1 <0.001 28 <0.001

Bluegill Lepomis macrochirus 1 <0.001 28 <0.001

Sucker group Catostominae species 1 <0.001 22 <0.001

Sculpin group Cottidae species 1 <0.001 38 <0.001

Creek chub Semotilus 

atromaculatus 1 <0.001 29 <0.001

Pumpkinseed Lepomis gibbosus 1 <0.001 29 <0.001
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NUREG-1437, Supplement 40 4-14 August 2010

Common Name Taxa Total 

Collected

% of Total 

Collected

Total 

Estimated

% of Total 

Estimated

Rock bass Ambloplites rupestris 1 <0.001 26 <0.001

Shorthead redhorse Moxostoma 

macrolepidotum 1 <0.001 7 <0.001

Silver lamprey Ichthyomyzon 

unicuspis 1 <0.001 10 <0.001

White perch Morone americana 1 <0.001 22 <0.001

Total 692,195 100 5,613,799 100

Source: adapted from EAE, 2007

When results of the 1975–1976 NES (1976) study are compared to the 2006–2007 EA 

Engineering (2007) study, some notable differences appear. Alewife and rainbow smelt were 

among the most prevalent species impinged during both study years though the total number of 

alewife collected in the 2006–2007 study (690,402 individuals) was significantly higher than the 

total number collected in the 1975–1976 study (178,883 individuals). Impinged alewives in 

2006–2007 accounted for a slightly higher percentage of the total estimated biomass in Lake 

Michigan. However, both study years collected only a very small percentage of the total 

estimated biomass of alewives.

Generally, the same family groups were present in both studies, though species composition 

and abundance vary. Lake chub, rainbow trout, brook trout, yellow bullhead, brown bullhead, 

troutperch, common shiner, coho salmon, lamprey, northern pike, and blacknose dace were 

present in the NES (1976) study but did not appear in EA Engineering (2007) impingement 

samples. Conversely, mottled sculpin, spottail shiner, northern Clearwater crayfish, threespine 

stickleback, round goby, channel catfish, black bullhead, smallmouth bass, bluegill, 

Catostominae species, Cottidae species, creek chub, rock bass, silver lamprey, and white perch 

were present in the EA Engineering 2007 study but did not appear in NES (1976) impingement 

samples. Slimy sculpin and longnose dace were the third (4.0 percent) and fourth (2.0 percent) 

most prevalent species, respectively, in the NES (1976) study, while the two species only 

accounted for 0.003 and 0.007 percent, respectively, of total collected individuals in EA

Engineering (2007) impingement samples. EA Engineering (2007) attributes the majority of 

these differences to the changes in the Lake Michigan aquatic community between study years.

Bunnell et al. (2007) report a record class of yellow perch in 2005, which may explain the 

increase in this species numbers between the 1975–1976 study and the 2006–2007 study. As 

discussed in Section 4.5.2, Bunnell et al. (2007) also report a recovery of burbot numbers 

beginning in the 1980s, after the species had suffered a decline in the 1970s following the 

introduction of alewife. Though ninespine stickleback accounted for less than 0.01 percent in 

both studies, about 10 times as many individuals were collected in the 2006–2007 study. 

Threespine stickleback was not present in the 1975–1976 study but appeared in the 2006–2007 

study. These two species’ densities were low from 1973–1995, increased dramatically in 

1996–1997, and have remained variable since that time, which may account for the increased 

number of individuals recorded in the 2006–2007 study (Bunnell et al., 2007), (EAE, 2007). 

Rainbow smelt, which represented 8.9 percent of impinged individuals in the 1975–1976 study, 

has shown decline since 1994, though the cause for this decline is unclear (Bunnell et al., 

2007), (EAE, 2007). Rainbow smelt were present but in much reduced numbers in the 

2006–2007 study. 
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August 2010 4-15 NUREG-1437, Supplement 40

Section 2.2.5 of this SEIS describes the changing aquatic communities within Lake Michigan as 

a result of numerous invasive species introductions, which supports these conclusions. Because 

impinged fish represented such a small percentage of total estimated numbers in Lake 

Michigan, results of neither the NES (1976) study nor the EA Engineering (2007) study suggest 

that the impacts of the KPS cooling system on the aquatic community in the vicinity of KPS is 

negatively affecting any fish species or destabilizing the aquatic community as a whole.

Based on the information presented in this section, the staff determined that the potential 

impacts of impingement of fish and shellfish by the KPS cooling system during the 20-year 

renewal period would be SMALL. The staff identified potential mitigation measures, including 

closed-cycle cooling and derating the facility and scheduling plant outages during historic peak 

impingement periods. However, the staff concludes that none of the mitigation measures 

considered would eliminate adverse impingement impacts and would not reduce the 

significance level below SMALL. The NRC does not have the authority to mandate these 

measures. It is the WDNR’s jurisdiction to impose any restrictions or modifications to the cooling 

system to reduce the impact of impingement under the WPDES permitting process. The staff 

did not identify any cost benefit studies applicable to these mitigation measures.

4.5.4 Heat Shock

The NRC defines heat shock as acute thermal stress caused by exposure to a sudden elevation 

of water temperature that adversely affects the metabolism and behavior of fish and can lead to 

death. Heat shock is most likely to occur when an offline unit returns to service or when a 

station has a discharge canal effectively trapping fish in the flow of heated discharge from the 

plant. For plants with once-through cooling systems, the GEIS lists the effects of heat shock as 

a site-specific (Category 2) issue that requires a plant-specific assessment before license 

renewal. The staff considered the information and documents described previously in Section 

4.5.2 to perform a site-specific assessment of heat shock resulting from the KPS cooling 

system. The KPS cooling system is described in Section 2.1.6.

Section 316(a) of the CWA establishes a process by which a discharger can demonstrate that 

the established thermal discharge limitations are more stringent than necessary to protect 

balanced, indigenous populations of fish and wildlife and obtain facility-specific thermal 

discharge limits (33 USC 1326). In May 1976, NES (1976) provided WDNR with a Section 

316(a) demonstration that addressed compliance with the thermal effluent limitations in the 

WPDES permit and environmental impacts of KPS’s thermal discharge. This demonstration 

supported a petition for relief from Wisconsin Administrative Code thermal standards and a 

State statute that required all plants on Lake Michigan with cooling water-related thermal 

discharges to transition to a recirculating system by 1981 (DEK, 2008).

For the demonstration, NES reviewed monthly reports of temperature, flow, chemical, and 

biological data for the KPS thermal plume under average, ideal, and worst case conditions. NES 

(1976) used thermal plume surveys conducted by Industrial BIO-TEST Laboratories, Inc. 

between June 1974 and July 1975 to assess thermal plume characteristics at KPS. NES 

determined that the data was highly variable and could not be used to adequately characterize 

ambient conditions to yield a reliable plume model. However, NES used the thermal plume data 

to determine a discharge zone for KPS. The discharge zone was based on the EPA’s 

September 1974 Draft Guidelines for a 316(a) Demonstration and included the maximum 

surface area and maximum bottom area of the 2 °C (3.6 °F) isotherm. The discharge zone was 

determined to have an area of 985.3 acres (ac) (398.7 hectare (ha)) at the surface and 94.5 ac 

(38.2 ha) at the bottom. NES (1976a) estimated the extent of the thermally affected zones for 
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NUREG-1437, Supplement 40 4-16 August 2010

extreme conditions in summer and winter. In the summer, an ambient lake temperature of 

21.1 °C (70 °F) and a plant discharge temperature of 30 °C (86 °F) were used to predict the 

area of the thermal plume with zero lake current and with a lake current of 0.8 feet per second 

(fps) (0.2 meters per second (m/s)). In the winter, an ambient lake temperature of 0 °C (32 °F) 

and a plant discharge temperature of 15.5 °C (59.9 °F) were used to predict the area of the 

thermal plume with zero lake current and a lake current of 1.2 fps (0.37 m/s). Tables 4-10 and 

4-11 summarize these thermal plume estimates.

Lake Michigan has a surface area of 22,300 square miles (mi2) (14.27 million ac; 5.78 million 

ha) (WDNR, 2009b), and so, based on these thermal plume estimates, any thermal effects on 

aquatic species originating from the KPS cooling system would be very localized for those 

species with a lakewide distribution. Additionally, KPS’s discharge is located on the shoreline, 

just south of the forebay. Because water is discharged directly to Lake Michigan rather than 

returning to the lake via a discharge canal, fish are less likely to become entrapped in areas of 

elevated temperatures. The final SEIS for Point Beach Nuclear Station (NRC, 2005), which is 

located about 5 mi (8 km) south of KPS, also concluded that thermal effects on aquatic species 

would be localized because the plant is located on a relatively featureless portion of Lake 

Michigan with sandy substrate and rapid plume dissipation, no bays or points nearby to act as 

fish nurseries or other attracting features, and no substantial unique spawning grounds in the 

vicinity of the plant. 

Table 4-10. Kewaunee Power Station Thermal Plume Characteristics in Summer under 

Extreme Conditions

Isotherm Temperature(a) Distance in ft (m) Width in ft (m) Area in ac (ha)

No current

29.0 °C (84.2 °F) 111.4 (34.0) 79.5 (24.2) 0.17 (0.07)

28.0 °C (82.4 °F) 147.7 (45.0) 92.4 (28.2) 0.27 (0.11)

27.0 °C (80.6 °F) 204.9 (62.5) 112.7 (34.4) 0.46 (0.19)

26.0 °C (78.8 °F) 302.1 (92.1) 147.2 (44.9) 0.88 (0.36)

25.0 °C (77.0 °F) 486.9 (148.4) 212.7 (64.8) 2.04 (0.83)

24.0 °C (75.2 °F) 904.9 (275.8) 361.0 (110.0) 6.45 (2.61)

23.0 °C (73.4 °F) 2,194.1 (668.8) 818.3 (249.4) 35.45 (14.35)

22.0 °C (71.6 °F) 4,939.5 (1505.6) 1,792.2 (546.3) 174.80 (70.74)

0.8 fps (0.2 m/s) current

29.0 °C (84.2 °F) 101.4 (30.9) 66.0 (20.1) 0.13 (0.05)

28.0 °C (82.4 °F) 174.3 (53.1) 84.8 (25.8) 0.29 (0.12)

27.0 °C (80.6 °F) 279.3 (85.1) 111.8 (34.1) 0.62 (0.25)

26.0 °C (78.8 °F) 411.7 (125.5) 145.8 (44.4) 1.19 (0.48)

25.0 °C (77.0 °F) 663.5 (202.2) 210.5 (64.2) 2.76 (1.12)

24.0 °C (75.2 °F) 1,233.2 (375.9) 356.8 (108.8) 8.69 (3.52)

23.0 °C (73.4 °F) 2,989.6 (911.2) 808.1 (246.3) 47.70 (19.30)

22.0 °C (71.6 °F) 6,727.2 (2050.5) 1,768.4 (539.0) 234.90 (95.06)

(a) The discharge temperature is 30 °C (86 °F), and the ambient summer temperature is assumed to be 21.1 °C 

(70 °F).

Source: Adapted from NES, 1976
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August 2010 4-17 NUREG-1437, Supplement 40

Table 4-11. Kewaunee Power Station Thermal Plume Characteristics in Winter under 

Extreme Conditions

Isotherm Temperature(a) Distance in ft (m) Width in ft (m) Area in ac (ha)

No current

15.0 °C (59.0 °F) 101.5 (30.9) 77.1 (23.5) 0.15 (0.06)

10.0 °C (50.0 °F) 331.2 (100.9) 119.7 (36.5) 0.78 (0.32)

5.0 °C (41.0 °F) 1,411.0 (430.1) 486.4 (148.3) 13.55 (5.48)

4.0 °C (39.2 °F) 2,101.9 (366.3) 751.2 (229.0) 31.18 (12.62)

3.0 °C (37.4 °F) 3,337.1 (1017.1) 1,224.7 (373.3) 80.70 (32.66)

2.0 °C (35.6 °F) 4,994.8 (1522.4) 1,860.2 (567.0) 183.46 (74.24)

1.0 °C (33.8 °F) 9,920.4 (3023.7) 3,748.4 (1142.5) 734.26 (297.14)

1.2 fps (0.37 m/s) current

15.0 °C (59.0 °F) 132.7 (40.4) 51.7 (15.8) 0.14 (0.06)

10.0 °C (50.0 °F) 671.8 (204.8) 99.3 (30.3) 1.32 (0.53)

5.0 °C (41.0 °F) 2,274.3 (693.2) 462.3 (140.9) 20.76 (8.40)

4.0 °C (39.2 °F) 3,176.2 (968.1) 629.7 (191.9) 39.49 (15.98)

3.0 °C (37.4 °F) 4,800.2 (1463.1) 1,147.3 (349.7) 108.74 (44.01)

2.0 °C (35.6 °F) 7,183.0 (2189.4) 1,589.2 (484.4) 225.39 (91.21)

1.0 °C (33.8 °F) 14,257.0 (4345.5) 2,900.9 (884.2) 816.63 (330.48)

(a) The discharge temperature is 15.5 °C (59.9 °F), and the ambient winter temperature is assumed to be 0 °C 

(32 °F).

Source: Adapted from NES, 1976

NES (1976a) also considered biological studies conducted by Industrial BIO-TEST Laboratories, 

Inc., from 1971 through 1975 to determine any impacts that the KPS thermal discharge may 

have on the fish community. A comparison of preoperational and operational data showed no 

noticeable changes in the aquatic community as a result of thermal changes near the KPS 

discharge. No major changes in species composition, seasonal abundance, spatial distribution, 

or use of affected area were observed. Densities of major macroinvertebrate taxa remained 

similar between preoperational and operational studies, and no changes to the benthic 

community were detected as a result of KPS thermal discharge. The demonstration concluded 

that “the thermal component of the [KPS] discharge has not disturbed the balanced indigenous 

communities of fish, shellfish, and wildlife in Lake Michigan” (NES, 1976).

On September 13, 1976, the WDNR granted alternative effluent limitations for KPS and 

exempted the thermal component of the Wisconsin Administration Code (DEK, 2008). As a 

result of this exemption, the current WPDES permit for KPS does not contain thermal effluent 

limitations. Under Dominion’s license, Appendix B of the Environmental Protection Plan, 

Dominion is required to report fish kills as an “unusual or important event.” To date, Dominion 

has not reported any fish kills related to thermal effluent discharge from the KPS cooling 

system.

On June 30, 2010, the WDNR published a notice that a rule order has been filed with the 

Legislative Reference Bureau amending two chapters of the Wisconsin Administrative Code to 

create thermal standards for surface water discharges and to specify procedures for these 

thermal standards to be implemented as part of a WPDES permit (WAC, 2010). The Wisconsin 

Natural Resources Board adopted the new rule in January 2010, but it will not take effect until 
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NUREG-1437, Supplement 40 4-18 August 2010

the first of the month following publication in the Wisconsin Administrative Code. The rule is 

expected to be published in August 2010, which would make the effective date September 1, 

2010. The rule will likely increase the monitoring frequency for effluent temperature and flow 

but may not necessarily result in temperature limits for all regulated facilities. For those facilities 

for which it is determined that thermal limits are appropriate, standards will be assessed monthly 

(WNRB, 2010). The WDNR is in the process of developing guidance documents relating to the 

rule order (WDNR, 2010). As part of this rule, the WDNR will also establish procedures for 

calculating thermal limitations for WPDES-permitted discharges. Once the rule is effective, KPS 

may be subject to thermal discharge limitations, such as a monthly upper limit on the 

temperatures of discharged waters. In this case, DEK would have to monitor intake and 

discharge temperatures and report them to the WDNR on an annual or semi-annual basis. 

These limitations would most likely be addressed during the WPDES permit renewal or a 

timeline specified in the final rule. The NRC does not have authority to regulate thermal 

conditions, and therefore, relies on the State to set appropriate guidelines for thermal discharge 

through the WPDES permitting process.

The staff has reviewed available information, including the applicant’s ER (DEK, 2008), the 

current WPDES permit (WDNR, 2005a), the CWA Section 316(a) Demonstration (NES, 1976), 

and other applicable sources of information on heat shock. Plant operating conditions have not 

changed significantly since the original 316(a) Demonstration. Therefore, it can be reasonably 

concluded that the extent and distribution of KPS’s thermal plume has remained relatively 

unchanged. The staff evaluated the potential impacts to aquatic resources due to heat shock 

during continued operation and determined that thermal impacts are likely to be limited because 

of the design and location of the KPS discharge structure. Furthermore, the staff concludes that 

the potential impacts to fish and shellfish due to heat shock during the renewal term are SMALL. 

The staff identified potential mitigation measures, including closed-cycle cooling, helper cooling 

towers, derating the plant, and operating under reduced intake flows. The staff did not identify 

any cost benefit studies applicable to these mitigation measures. However, the NRC does not 

have the authority to mandate these measures; it is the WDNR’s jurisdiction to impose any 

restrictions or modifications to the cooling system to reduce the impact of heat shock under the 

WPDES permitting process.

4.5.5 Total Impacts on Aquatic Resources

Impingement, entrainment, and heat shock all act on the same populations of aquatic 

resources. The purpose of this section is to provide perspective on the total impact of cooling 

system operation on fish and other aquatic resources. The WDNR, not the NRC, is responsible 

for issuing and enforcing WPDES permits. Because the individual level of impact associated 

with impingement, entrainment, and thermal impacts is SMALL, the staff believes that the total 

impact from all of these sources together on aquatic resources would also be SMALL through 

the period of license renewal. 

4.6 TERRESTRIAL RESOURCES

The issues related to terrestrial resources applicable to the KPS site are discussed below and 

listed in Table 4-12. There are no Category 2 issues related to terrestrial resources for license 

renewal. The staff did not identify any new and significant information during the review of the 

applicant’s ER (DEK, 2008), the site audit, the scoping process, or the evaluation of other 

available information. Therefore, the staff concludes that there would be no impacts related to 

these issues beyond those discussed in the GEIS. The GEIS concludes that the impacts are 
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August 2010 4-19 NUREG-1437, Supplement 40

SMALL, and additional site-specific mitigation measures are not likely to be sufficiently 

beneficial to implement.

Table 4-12. Terrestrial Resources Issues. Section 2.2.6 of this SEIS provides a description of 

the terrestrial resources at KPS and in the surrounding area.

Issues GEIS Section Category

Power line ROW management (cutting herbicide application) 4.5.6.1 1

Bird collisions with power lines 4.5.6.1 1

Impacts of electromagnetic fields on flora and fauna (plants, agricultural 

crops, honeybees, wildlife, livestock) 4.5.6.3 1

Floodplains and wetland on power line ROW 4.5.7 1

4.7 THREATENED AND ENDANGERED SPECIES

Table 4-13. Threatened or Endangered Species. Section 2.2.7 of this document describes the 

threatened or endangered species on or near KPS.

Issue GEIS Section Category

Threatened or endangered species 4.1 2

This site-specific, or Category 2 issue, requires consultation with the appropriate agencies to 

determine whether or not threatened or endangered species are present and whether or not 

they would be adversely affected by the continued operation of KPS during the license renewal 

term. The characteristics and habitats of threatened and endangered species in the vicinity of 

the KPS site are discussed in Sections 2.2.6 and 2.2.7 of this SEIS.

The NRC contacted the U.S. Fish and Wildlife Service (USFWS) on September 20, 2008, 

regarding threatened and endangered species at the KPS site (NRC, 2008). A description of the 

site and the in-scope transmission lines and an assessment of the Federally-listed threatened 

and endangered species potentially occurring on or near the KPS site were provided in this 

letter. The USFWS provided its response on October 28, 2008, indicating that the Hine’s 

emerald dragonfly (Somatochlora hineana) and the piping plover (Charadrius melodus) have the 

potential to occur in the vicinity of KPS (USFWS, 2008a).

4.7.1 Aquatic Species

The staff has reviewed information provided by the applicant and information publicly available 

and has contacted the Green Bay Field Office of the USFWS (NRC, 2008). Currently, no 

threatened or endangered aquatic species are known to occur within Lake Michigan on or in the 

vicinity of the KPS site or within any streams crossed by in-scope transmission line ROWs. 

Therefore, license renewal of KPS would have no effect on any Federally- or State-listed 

aquatic species, and mitigation measures need not be considered.

4.7.2 Terrestrial Species 

The staff contacted the USFWS and the WDNR to request information that could assist in 

assessing the environmental impacts associated with license renewal. On October 28, 2008, the 

USFWS indicated that no known Federally-listed threatened or endangered species occur within 
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NUREG-1437, Supplement 40 4-20 August 2010

the project area; therefore, the proposed project would not likely adversely affect any 

Federally-listed species (USFWS, 2008). 

There are five Federally-listed threatened or endangered terrestrial species that potentially 

occur on the KPS site, although these species have not been documented on the site: the 

piping plover (Charadrius melodus), the Hine’s emerald dragonfly (Somatochlora hineana), the 

Karner blue butterfly (Lycaeides melissa samuelis), the dune or Pitcher’s thistle (Cirsium 

pitcheri), and the dwarf lake iris (Iris lacustris). The bald eagle (Haliaeetus leucocephalus) and 

the peregrine falcon (Falco peregrinus) were formerly Federally-listed as threatened and may 

also be found in the vicinity of the KPS site. Four State-listed species were identified as species 

for consideration of the proposed license renewal of KPS, including the Caspian tern (Sterna 

caspia), the osprey (Pandion haliaetus), and the formerly listed bald eagle and peregrine falcon. 

Section 2.2.7 of this SEIS describes these species in greater detail (USFWS, 2008a), 

(DEK, 2008).

Because no threatened or endangered species are known to occur on or in the vicinity of the 

KPS site, operation of the site and its associated transmission lines are not expected to 

adversely affect any threatened or endangered species during the license renewal term. 

Therefore, the staff concludes that adverse impacts to threatened or endangered species during 

the period of extended operation would be SMALL. A potential mitigation measure that could 

further reduce this SMALL impact include would be for DEK and American Transmission 

Company to report the existence of any Federally- or State-listed endangered or threatened 

species within or near the transmission line ROWs to the WNDR and/or USFWS if any such 

species are identified during the period of extended operations. In particular, if any evidence of 

injury to or mortality of migratory birds, State-listed species, or Federally-listed threatened or 

endangered species is observed onsite or within the transmission line ROWs, coordination with 

the appropriate State or Federal agency would minimize impacts to the species and, in the case 

of Federally-listed species, ensure compliance with the Endangered Species Act. The staff 

finds several adequate mitigation measures currently in place at the KPS site and within its 

associated transmission lines. They include: nest construction and placement for the peregrine 

falcon, environmental review checklists, environmental evaluation forms, and best management 

practices.

4.8 HUMAN HEALTH

The human health issues applicable to KPS are discussed below and listed in Table 4-14 for 

Category 1, Category 2, and uncategorized issues.

Table 4-14. Human Health Issues. Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 

contains more information on these issues.

Issue GEIS Section Category

Microbiological organisms (occupational health) 4.3.6 1

Noise 4.3.7 1

Radiation exposures to public (license renewal term) 4.6.1, 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
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August 2010 4-21 NUREG-1437, Supplement 40

4.8.1 Radiological Human Health Issues

The staff did not identify any new and significant information regarding radiological human 

health issues during its review of the applicant’s ER (DEK, 2008), the site audit, or the scoping 

process. 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 be warranted. The 

information presented below is a discussion of selected radiological programs conducted at 

KPS, which monitor the impacts of radioactive effluents on the environment and members of the 

public.

4.8.1.1 Radiological Environmental Monitoring

KPS conducts a radiological environmental monitoring program (REMP) in the site environs to 

assess the radiological impact, if any, to its employees, the public, and the environment. KPS 

issues an annual environmental monitoring report which contains a discussion of the 

environmental data, and includes graphs which trend the data from prior years. The objectives 

of the REMP include the following:

● measure and evaluate the levels of radiation and radioactive material in the site 

environs to assess the radiological impacts, if any, of plant operation on the 

environment

● supplement the results of the radiological effluent monitoring program by 

verifying that the measurable concentrations of radioactive material and levels 

of radiation are not higher than expected based on the measurement of 

radioactive effluents and modeling for the applicable exposure pathways

● provide data on the radiation dose to the public by direct or indirect pathways of 

exposure

● demonstrate compliance with applicable Federal regulatory requirements.

The KPS REMP collects samples of environmental media in the site environs for analysis to 

measure the amount of radioactivity, if any, in the samples. The media samples are 

representative of the radiation exposure pathways to the public from all plant radioactive 

effluents. The REMP measures the aquatic, terrestrial, and atmospheric environment for 

radioactivity, as well as ambient gamma radiation. Ambient gamma radiation pathways include 

radiation from buildings, plant structures, and airborne material that may be released from the 

plant. In addition, the REMP also measures background radiation (i.e., cosmic sources, global 

fallout, and naturally occurring radioactive material, including radon). Thermoluminescent 

dosimeters are used to measure direct radiation. The atmospheric environmental monitoring 

consists of sampling the air for particulates and radioiodine. Terrestrial environmental 

monitoring consists of analyzing samples of milk and food products. The aquatic environmental 

monitoring consists of analyzing samples of surface water, drinking water, groundwater, fish, 

and sediment from Lake Michigan. There is also an onsite groundwater protection program 

designed to monitor the onsite plant environment for indication of leaks from plant systems and 

pipes carrying radioactive liquid.

The staff reviewed the KPS radioactive environmental monitoring reports from 2004 through 

2008 to look for any significant impacts to the environment or any unusual trends in the data 
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NUREG-1437, Supplement 40 4-22 August 2010

(DEK, 2005), (DEK, 2006), (DEK, 2007), (DEK, 2008a), (DEK, 2009). The staff’s review of the 

KPS REMP reports showed no unusual trends in the data and showed no measurable impact 

from the operations at KPS on the environment.

The Wisconsin Department of Health Services (WDHS) conducts a yearly independent 

comprehensive environmental radioactivity survey program around the two nuclear power plant 

sites, KPS and Point Beach Nuclear Plant (PBNP), in Wisconsin. The program collects various 

types of samples of environmental media, similar to that obtained by KPS, from the site 

environs. The sampling program includes samples of air, precipitation, ambient gamma 

radiation, surface water, fish, shoreline sediment, soil, milk, well water, and vegetation.

The staff reviewed the WDHS 2007 environmental survey program report for the KPS and 

PBNP sites. The State reported that it observed radioactivity levels associated with natural 

background and fallout from atmospheric weapons testing. No radioactivity attributable to the 

operation of KPS and PBNP was observed (WDHS, 2008).

Based on the review of the radiological environmental monitoring data from KPS and the 

WDHS, the staff concludes that there are no measurable radiological impacts from the 

operations at KPS on the environment. 

4.8.1.2 Radioactive Effluent and Dose Information

The staff reviewed KPS historical data on radioactive releases and the calculated dose to a 

hypothetical maximally exposed individual to verify that the doses are within the dose limits 

specified in 10 CFR Part 20 and are as low as is reasonably achievable (ALARA) per the dose 

design objectives in Appendix I to 10 CFR Part 50.

Dose estimates for members of the public are calculated based on liquid and gaseous effluent 

release data and atmospheric and aquatic transport models. The KPS 2008 annual radioactive 

effluent release report (DEK, 2009) contains a detailed presentation of radioactive discharges 

and the resultant calculated doses. The following summarizes the calculated dose to a member 

of the public located at the KPS site boundary from radioactive liquid and gaseous effluents 

released during 2008:

● The whole-body dose to an offsite member of the public from liquid effluents 

was 1.04 x 10-3 milliroentgen equivalent man (mrem) (1.04 x 10-5 millisievert 

(mSv), which is below the 3 mrem (0.03 mSv) dose criterion in Appendix I to 

10 CFR Part 50.

● The organ (gastrointestinal tract) dose to an offsite member of the public from 

liquid effluents was 4.19 x 10-3 mrem (4.19 x 10-5 mSv), which is below the 

10 mrem (0.1 mSv) dose criterion in Appendix I to 10 CFR Part 50.

● The air dose at the site boundary from gamma radiation in gaseous effluents 

was 4.21 x 10-6 mrad (4.21 x 10-8 mGy), which is below the 10 mrad (0.1 mGy) 

dose criterion in Appendix I to 10 CFR Part 50.

● The air dose at the site boundary from beta radiation in gaseous effluents was 

1.07 x 10-5 mrad (1.07 x 10-7 mGy), which is below the 20 mrad (0.2 mGy) dose 

criterion in Appendix I to 10 CFR Part 50.
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August 2010 4-23 NUREG-1437, Supplement 40

● The organ (liver) dose to an offsite member of the public from radioactive iodine 

and radioactive particulate material in gaseous effluents was 5.55 x 10-4 mrem 

(5.55 x 10-6 mSv), which is below the 15 mrem (0.15 mSv) dose criterion in 

Appendix I to 10 CFR Part 50.

Based on the staff review and assessment of the KPS radioactive waste system performance in 

controlling radioactive effluents and the resultant doses to members of the public in 

conformance with the ALARA criteria, the staff found that the 2008 radiological effluent data for 

KPS are consistent, with reasonable variation attributable to operating conditions and outages 

and with the 5-year historical radiological effluent releases and resultant doses. These results 

demonstrate that KPS is operating in compliance with Federal radiation protection standards 

contained in 10 CFR Part 20 and Appendix I to 10 CFR Part 50.

The applicant has no plans to conduct refurbishment activities during the license renewal term, 

thus, no change to radiological conditions is expected. Continued compliance with regulatory 

requirements is expected during the license renewal term. Thus, the radiological impacts are not 

expected to change during the license renewal term, and there are no impacts beyond those 

discussed in the GEIS. Therefore, the staff concludes that the radiological impacts to human 

health from the continued operation of KPS during the license renewal term would be SMALL.

4.8.2 Electromagnetic Fields – Acute Shock

Based on the GEIS, the NRC found that electric shock resulting from direct access to energized 

conductors or from induced charges in metallic structures has not been a problem at most 

operating plants and generally is not expected to be a problem during the period of extended 

operation. However, a site-specific review is required to determine the significance of the 

electric shock potential along the portions of the transmission lines within the scope of the SEIS.

The GEIS states that it is not possible to determine the significance of the electric shock 

potential without a review of the conformance of each nuclear plant transmission line with 

National Electrical Safety Code (NESC) and Institute of Electrical and Electronics Engineers 

(IEEE) 2007 criteria. 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 in the vicinity of 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 provide an assessment of the potential shock hazard 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.

As a result of the Wisconsin Legislature Act 9 of 1999, Wisconsin Public Service Corporation 

and Wisconsin Power and Light Company (owners of KPS at the time) transferred ownership of 

their transmission lines to ATC. The transmission Interconnection Agreement for KPS between 

ATC, DEK, and Midwest Independent Transmission System Operator (MISO) constitutes that 

ATC is the transmission system operator, and MISO is the independent system operator.

All transmission lines associated with KPS were constructed in accordance with NESC and 

industry guidance in effect at that time (AEC, 1972). Since the lines were constructed, a new 

criterion has been added to the NESC for power lines with voltages exceeding 98 kilovolt (kV). 

This criterion states that the minimum clearance for a line must limit induced currents due to 

static effects to 5 milliamperes (mA). ATC has reviewed the transmission lines for compliance 
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NUREG-1437, Supplement 40 4-24 August 2010

with this criterion (DEK, 2008) and indicated that all transmission lines within the scope of this 

review have been restudied. The results show there are no locations under the transmission 

lines that have the capacity to induce more than 5 mA in a vehicle parked beneath them. No 

induced shock hazard to the public should occur since the lines are operating within original 

design specifications and meet current NESC clearance standards.

The staff has reviewed the available information, including the applicant’s evaluation and 

computational results. Based on this information, the staff evaluated the potential impacts for 

electric shock resulting from operation of KPS and its associated transmission lines. The staff 

concludes that the potential impacts from electric shock during the renewal period would be 

SMALL.

The staff identified a variety of measures that could mitigate potential acute electromagnetic 

fields (EMF) impacts resulting from continued operation of the KPS transmission lines. These 

mitigation measures would include erecting barriers along the length of the transmission line to 

prevent unauthorized access to the ground beneath the conductors and installing road signs at 

road crossings. These mitigation measures could reduce human health impacts by minimizing 

public exposures to electric shock hazards. The staff did not identify any cost benefit studies 

applicable to the mitigation measures mentioned above.

4.8.3 Electromagnetic Fields – Chronic Effects

In the GEIS, the chronic effects of 60-hertz (Hz) EMFs from power lines were not designated as 

Category 1 or 2, and will not be, until a scientific consensus is reached on the health 

implications of these fields.

The potential for chronic effects from these fields continues to be studied and is 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 (1999) contains 

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 a 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 was not sufficient to cause the staff to change its position with respect to the 

chronic effects of electromagnetic fields. This position is expressed in footnote 5 of Table B-1 of 

Appendix B to Subpart A of 10 CFR Part 51:

If, in the future, the Commission finds that, contrary to current indications, a 

consensus has been reached by appropriate Federal health agencies that there 

are adverse health effects from electromagnetic fields, the Commission will 

require applicants to submit plant-specific reviews of these health effects as part 

of their license renewal applications. Until such time, applicants for license 

renewal are not required to submit information on this issue. 
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August 2010 4-25 NUREG-1437, Supplement 40

The staff considers the GEIS finding of “uncertain” still appropriate and will continue to follow 

developments on this issue.

4.9 SOCIOECONOMICS

Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, which are applicable 

to socioeconomic impacts during the renewal term are listed in Table 4-15. As stated in the 

GEIS, the impacts associated with these Category 1 issues were determined to be of no 

significance or SMALL, and plant-specific mitigation measures would not be sufficiently 

beneficial to be warranted.

Table 4-15. Category 1 Issues Applicable to Socioeconomics During the Renewal Term 

Issue GEIS Section Catergory

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: education (license renewal term) 4.7.3.1 1

Aesthetic impacts (license renewal term) 4.7.6 1

Aesthetic impacts of transmission lines (license renewal term) 4.5.8 1

4.9.1 Generic Socioeconomic Issues

The staff reviewed and evaluated the applicant’s ER (DEK, 2008), scoping comments, other 

available information, and visited KPS in search of new and significant information that would 

change the conclusions presented in the GEIS. No new and significant information was 

identified during this review and evaluation. Therefore, it is expected that there would be no 

impacts related to these Category 1 issues during the renewal term beyond those discussed in 

the GEIS. Table 4-16 lists the Category 2 socioeconomic issues, which require plant-specific 

analysis, and an environmental justice impact analysis that was not addressed in the GEIS.

Table 4-16. Category 2 Issues Applicable to Socioeconomics and Environmental Justice 

During the Renewal Term

Issue GEIS Section Catergory

Housing impacts 4.7.1 2

Public services: public utilities 4.7.3.5 2

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

Environmental justice Not addressed(a) 2

(a) Guidance related to environmental justice was not in place at the time the GEIS and the associated revision 

to 10 CFR Part 51 was prepared. Therefore, environmental justice must be addressed in plant-specific 

reviews.
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NUREG-1437, Supplement 40 4-26 August 2010

4.9.2 Housing Impacts

Appendix C of the GEIS presents a population characterization method based on two factors, 

sparseness and proximity (GEIS, Section C.1.4). Sparseness measures population density 

within 20 mi (32 km) of the site, and proximity measures population density and city size within 

50 mi (80 km). Each factor has categories of density and size (GEIS, Table C.1). A matrix is 

used to rank the population category as low, medium, or high (GEIS, Figure C.1).

According to the 2000 Census, approximately 86,224 people lived within 20 mi of KPS, which 

equates to a population density of 132 persons per mi2 (DEK, 2008). This density translates to 

GEIS Category 4, least sparse (greater than, or equal to, 120 persons per mi2 within 20 mi). 

Approximately 723,900 people live within 50 mi of KPS (DEK, 2008). This equates to a 

population density of 202 persons per mi2

. Applying the GEIS proximity measures, KPS is 

classified as proximity Category 4 (greater than, or equal to, 190 persons per mi2 within 50 mi). 

Therefore, according to the sparseness and proximity matrix presented in the GEIS, rankings of 

sparseness Category 4 and proximity Category 4 result in the conclusion that KPS is located in 

a high population area.

Since Kewaunee, Manitowoc, and Brown counties are not subject to growth control measures 

that would limit housing development, any changes in employment at KPS would have little 

noticeable effect on housing availability in these counties. Considering that DEK has no plans to 

add non-outage employees during the license renewal period, employment levels at KPS would 

remain relatively constant with no additional demand for permanent housing during the license 

renewal term. Based on this information, there would be no impact on housing during the 

license renewal term beyond what has already been experienced.

4.9.3 Public Services: Public Utilities

Impacts on public utility services are considered SMALL if the existing infrastructure could 

accommodate any plant-related demand without a noticeable effect on the level of service. 

Impacts are considered MODERATE if the demand for service or use of the infrastructure is 

sizeable and would noticeably decrease the level of service or require additional resources to 

maintain the level of service. Impacts are considered LARGE when new programs, upgraded or 

new facilities, or substantial additional staff is needed because of plant-related demand. In the 

absence of new and relevant information to the contrary, the only significant impacts on public 

utilities would be on public water supplies.

Analysis of impacts on the public water systems considered both plant demand and 

plant-related population growth. Section 2.1.3 of this SEIS describes the permitted withdrawal 

rate and actual use of water for reactor cooling at KPS. 

Because DEK has no plans to add non-outage employees during the license renewal period, 

employment levels at KPS would remain relatively unchanged with no additional demand for 

public water services. Public water systems in the region would be adequate to meet the 

demands of residential and industrial customers in the area. Therefore, there would be no 

additional impact to public water services during the license renewal term beyond what is 

currently being experienced.
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August 2010 4-27 NUREG-1437, Supplement 40

4.9.4 Offsite Land Use

Offsite land use during the license renewal term is a Category 2 issue. Table B-1 of 

10 CFR Part 51, Subpart A, Appendix B notes that, “significant changes in land use may be 

associated with population and tax revenue changes resulting from license renewal.”

Section 4.7.4 of the GEIS defines the magnitude of land-use changes as a result of plant 

operation during the license renewal term as follows:

● SMALL - Little new development and minimal changes to an area’s land-use 

pattern.

● MODERATE - Considerable new development and some changes to the 

land-use pattern.

● LARGE - Large-scale new development and major changes in the land-use 

pattern.

Tax revenue can affect land use because it enables local jurisdictions to provide the public 

services (e.g., transportation and utilities) necessary to support development. Section 4.7.4.1 of 

the GEIS states that the assessment of tax-driven land-use impacts during the license renewal 

term should consider: (1) the size of the plant’s tax payments relative to the community’s total 

revenues, (2) the nature of the community’s existing land-use pattern, and (3) the extent to 

which the community already has public services in place to support and guide development.

If the plant’s tax payments are projected to be small relative to the community’s total revenue, 

tax-driven land-use changes during the plant’s license renewal term would be SMALL, 

especially where the community has pre-established patterns of development and has provided 

public services to support and guide development. Section 4.7.2.1 of the GEIS states that if new 

tax payments are less than 10 percent of the taxing jurisdiction’s revenue, the significance level 

would be SMALL. If tax payments are 10 to 20 percent of the community’s total revenue, new 

tax driven land-use changes would be MODERATE. If tax payments are greater than 20 percent 

of the community’s total revenue, new tax-driven land-use changes would be LARGE. This 

would be especially true where the community has no pre-established pattern of development or 

has limited public services available to support and guide development.

4.9.4.1 Population-Related Impacts

DEK has no plans to add non-outage employees during the license renewal period. Therefore, 

there would be no plant operations-driven population increase in the vicinity of KPS. 

Additionally, there would be no population-related offsite land use impacts during the license 

renewal term beyond what has already been experienced.

4.9.4.2 Tax-Revenue-Related Impacts

As previously discussed in Chapter 2, by State law, DEK makes annual gross revenue tax 

payments in lieu of taxes (PILOTs) to the State of Wisconsin. Since DEK started making 

payments, population levels and land use conditions have not changed significantly, which 

might indicate that these tax revenues have had little or no effect on land use activities within 

the county.
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NUREG-1437, Supplement 40 4-28 August 2010

In 2009, the Wisconsin Department of Revenue changed the methodology for computing the 

utility aid payment. Because of the changes to the Wisconsin Shared Revenue Program 

(WSRP) methodology for taxing public utilities in the State of Wisconsin, KPS was taxed 

differently beginning in tax-year 2009. The WSRP utility payment from the State of Wisconsin to 

the town of Carlton and Kewaunee County increased over previous years (NRC, 2010). 

Although these changes increased the size of the payment, the overall tax-revenue-related 

impact from KPS in Kewaunee County and the town of Carlton will not change because KPS 

does not directly pay taxes to these jurisdictions, and there is no direct correlation between the 

amount of taxes KPS pays to the State of Wisconsin and the distribution of funds to local 

jurisdictions.

DEK has no plans to add non-outage employees during the license renewal period. Therefore, 

employment levels would remain relatively unchanged. After the 2009 tax payment increase, 

annual PILOTs will likely remain unchanged throughout the license renewal period. Based on 

this information, there would be no tax-revenue-related offsite land use impacts during the 

license renewal term beyond what has already been experienced.

4.9.5 Public Services: Transportation Impacts During Operations

Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, states, “Transportation impacts (level of 

service) of highway traffic generated...during the term of the renewed license are generally 

expected to be of small significance. However, the increase in traffic associated with additional 

workers and the local road and traffic control conditions may lead to impacts of moderate or 

large significance at some sites.” All applicants are required by 10 CFR 51.53(c) (3) (ii) (J) to 

assess the impacts of highway traffic generated by the proposed project on the level of service 

of local highways during the term of the renewed license. 

Since DEK has no plans to add non-outage employees during the license renewal period, there 

would be no noticeable change in traffic volume and levels of service on roadways in the vicinity 

of KPS. Therefore, there would be no transportation impacts during the license renewal term 

beyond what is currently being experienced.

4.9.6 Historic and Archaeological Resources

The National Historic Preservation Act (NHPA) requires Federal agencies to consider the effects 

of their undertakings on historic properties. Historic properties are defined as resources that are 

eligible for listing on the National Register of Historic Places (NRHP). The criteria for eligibility 

are listed in 36 CFR, “Parks, Forests, and Public Property,” Part 60, Section 4, “Criteria for 

Evaluation,” (36 CFR Part 60.4) and include: (1) association with significant events in history, 

(2) association with the lives of persons significant in the past, (3) distinctive characteristics of 

type and period of construction, and (4) sites or places that have yielded or are likely to yield 

important information (ACHP, 2009). The historic preservation review process (Section 106 of 

the NHPA) is outlined in regulations issued by the ACHP in 36 CFR, “Parks, Forests, and Public 

Property,” Part 800, “Protection of Historic Properties” (36 CFR Part 800).

The issuance of a renewed operating license for a nuclear power plant is a Federal action that 

could affect historic properties on or near the nuclear plant site and transmission lines. In 

accordance with the provisions of the NHPA, the NRC is required to make a reasonable effort to 

identify historic properties included in, or eligible for inclusion in, the NRHP in the area of 

potential effect (APE). The APEs for license renewal are the nuclear power plant site, 

transmission lines, and immediate environs. If historic properties are present, the NRC is 
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August 2010 4-29 NUREG-1437, Supplement 40

required to contact the State Historic Preservation Office (SHPO), assess the potential impact, 

and resolve any possible adverse effects of the undertaking (license renewal) on historic 

properties. The NRC is also required to notify the SHPO if historic properties would not be 

affected by license renewal or if no historic properties are present.

Dominion contacted the Wisconsin Historical Society (WHS) requesting information on historic 

and archaeological resources in the vicinity of KPS and describing the proposed action (license 

renewal) (DEK, 2008). In October 2007, Dominion forwarded its Phase 1 Archaeological Survey 

(AVD Archaeological Services, Inc. (AVD)) to the WHS for review and comment (DEK, 2008). In 

December 2007, the WHS concurred with the archaeological assessment (WHS, 2007).

In accordance with 36 CFR 800.8(c), the NRC contacted the WHS (NRC, 2008a), the Advisory 

Council on Historic Preservation (ACHP) (NRC, 2008b), and federally recognized American 

Indian Tribes to initiate Section 106 consultation. These letters are presented in Appendix D.

As discussed in Section 2.2.9, a search of the WHS site files identified no previously recorded 

historic properties at KPS; however, the AVD report indicates that portions of site 47KE72 could 

extend onto KPS property. In addition, there are no eligible or listed NRHP properties located on 

the KPS site.

A review of WHS records found only 141 historic and archaeological sites within Kewaunee 

County compared with more than 500 each for bordering Manitowoc, Brown, and Door counties 

(AVD, 2007). Only 14 archaeological sites have been recorded in Carlton Township. Five of 

these sites are cemeteries, and the remaining are pre-contact sites (AVD, 2007). Three 

archaeological sites are located within 1 mile of the KPS site.

In 2007, DEK contracted with AVD to conduct a Phase 1 survey of the KPS site. Approximately 

80 ac of the site were heavily disturbed from construction of KPS. A majority of the remaining 

land is open grassland, and approximately 407 ac are leased agricultural cropland. The survey 

identified three known archaeological sites (47KE10, 47KE72, and 47KE44 [BKE-0044]) within 

1 mile of KPS and nine new isolated artifact finds on the KPS site. However, there remains a 

potential for additional prehistoric sites and historic (camp) sites to be in the area. This area was 

part of the Potawatomi hunting, farming, and gathering lands. In addition, historical records 

indicate that American Indians used the Sandy Bay area for fishing and hunting (AVD, 2007).

The area in the vicinity of KPS was also settled by Euro-Americans who farmed the area prior to 

the construction of KPS. While there are no visible remnants of the former farmhouses and 

outbuildings at KPS, subsurface portions of these buildings could remain. During NRC’s 

walkover survey, the staff noted the presence of barbed wire fencing, farm equipment, 

rudimentary farm bridges, and historic artifact scatters on KPS property. 

Site 47KE10 is a campsite/village of unknown prehistoric affiliation. Very little information about 

this site exists within the WHS database. The site is located offsite and would not be affected by 

plant operation.

In 1996, site 47KE72 was recorded and listed as a Late Archaic site of unknown purpose. The 

extent of this site remains undetermined. Portions of this archaeological site could extend onto 

the KPS site. According to the site file, previous land owners recovered a few artifacts which 

remain in a private collection. Any land disturbing activities near 47KE72 should be surveyed 

prior to any disturbance. 
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Site 47KE44 is the Sandy Bay Cemetery (St. John’s Cemetery) and was associated with St. 

John’s Church. The church was founded in 1869, and the congregation disbanded in 1947. The 

church no longer exists; however, subsurface portions of the church could remain. Burials 

associated with 15 families are located in this cemetery with the last burial dating to 1943. In 

1969, the cemetery was turned over to Carlton Township (AVD, 2007). The township maintains 

the cemetery.

Nine locations on the KPS site yielded artifacts. Location #71 was a scatter of 19th to 

20th century (domestic) artifacts found in the vicinity of a former farm. A single diagnostic point 

was recovered at location #72, which could date to either the Late Archaic or Woodland time 

periods (AVD, 2007). No other lithic materials were recovered in this area. One thermally altered 

piece of chert was recovered from Location #73. AVD noted that this piece of chert was 

probably pushed to this location during construction of KPS. One chert diagnostic fragment 

(Location #74) was recovered in a cultivated field. The fragment appears to date to the Middle 

Woodland Period. A uniface of off-white chert was found at Location #75. There is no sign of 

utilization on the edge of the piece (AVD, 2007). No other lithic materials were recovered from 

this location. 

A projectile point chert tip was recovered from Location #76. No temporal affiliation can be 

assigned to this point. An oolitic chert projectile point fragment that potentially dates to either the 

Late Archaic or Woodland time periods was recovered from Location #77 (AVD, 2007). A side 

notched chert projectile point (tip missing) was found at Location #78. This point bears 

resemblance to the Madison side-notched type (AVD, 2007). A possible chert tool which had 

indications of pressure flaking on one edge was recovered at Location #79 (AVD, 2007). In total, 

one historic scatter, five projectile point fragments, one possible chert scraping or cutting tool, 

and two possible tools were recovered. These finds indicate that pre-contact American Indians 

hunted in this area and provide evidence of Euro-American occupation. According to AVD, all 

farmstead-related artifacts are out of context due to the demolition of the buildings prior to the 

construction of KPS. The fixed projectile point fragments and three pieces of chert were single 

items found without context or association with other artifacts. AVD stated that either the 

projectile points were merely discarded or lost in use or later dispersed/damaged by farm

equipment (AVD, 2007). 

DEK has established a Cultural Resources Protection Plan for the protection of historic and 

archaeological resources at KPS. In its plan, KPS has an inadvertent discovery (stop work) 

provision. Should historic and archaeological resources be encountered during land disturbing 

activities, work will be halted and the WHS will be consulted for guidance (DEK, 2009b).

DEK currently has no planned changes or ground disturbing activities associated with license 

renewal at KPS. However, given the potential for the discovery of additional historic and 

archaeological resources at the KPS site, DEK needs to ensure that these resources are 

considered prior to any ground disturbance during future plant operations and maintenance 

activities. DEK has a stop work order within its Cultural Resource Protection Plan and 

procedures to ensure that proper notification is taken to protect these resources should they be 

discovered.

Based on review of WHS archaeological file surveys, assessments, and other information, the 

potential impacts of continued operations and maintenance on historic and archaeological 

resources at KPS would be SMALL. DEK could reduce any potential impacts to historic and 

archaeological resources located at KPS by training staff in the Section 106 consultation 

process and cultural awareness training to ensure that informed decisions are made prior to any 
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August 2010 4-31 NUREG-1437, Supplement 40

ground disturbing activities. In addition, KPS forwarded its Cultural Resources Protection Plan to 

the WHS for review and comment. The WHS had no official comments but encouraged DEK to 

implement its plan. DEK implemented this plan in September 2009, which should ensure that 

historic and archaeological resources are protected at the KPS site. Any revisions to the 

Cultural Resources Protection Plan should be developed in consultation with the NRC and the 

WHS. In addition, lands not surveyed should be investigated by a qualified archaeologist prior to 

any ground disturbing activity.

4.9.7 Environmental Justice

Under Executive Order (E.O.) 12898 (59 FR 7629), Federal agencies are responsible for 

identifying and addressing potential disproportionately high and adverse human health and 

environmental impacts on minority 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). That policy states, “The NRC is committed to 

the general goals of E.O. 12898 [and] will strive to meet those goals through its normal and 

traditional NEPA review process.”

The Council of Environmental Quality (CEQ) provides the following information in Environmental 

Justice: Guidance Under the National Environmental Policy Act (NEPA) (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 defined by NEPA) and appreciably exceeds the risk 

or exposure rate for the general population or for another appropriate comparison 

group (CEQ, 1997).

Disproportionately High and Adverse Environmental Effects. A 

disproportionately high environmental impact that is significant (as defined by 

NEPA) refers to an impact or risk of an impact on the natural or physical 

environment in 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 defined 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 (CEQ, 1997).

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 KPS during the renewal term. In assessing the impacts, the 

following CEQ (1997) definitions of minority individuals and populations and low-income

population were used:

Minority individuals. Individuals who identify themselves as members of the 

following population groups: Hispanic or Latino, American Indian or Alaska 

Native, Asian, Black or African American, Native Hawaiian or Other Pacific 
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NUREG-1437, Supplement 40 4-32 August 2010

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 PB60, on Income and Poverty.

4.9.7.1 Minority Population in 2000

The 50-mi radius around KPS includes 12 counties in Wisconsin. The geographic area includes 

any census block with all or part of its area within the 50-mi radius. According to 2000 Census 

data, 7.6 percent of the population (approximately 724,241 individuals) residing within a 50-mi 

(80-km) radius of KPS identified themselves as minority individuals. The largest minority group 

was Hispanic or Latino (19,195 persons or 2.7 percent), followed by Asian (17,200 or about 

2.4 percent) (USCB, 2003). About 1.8 percent of the Kewaunee County population identified 

themselves as minorities, with Hispanic or Latino as the largest minority group (0.8 percent), 

followed by American Indian and Alaska Native (0.6 percent) (USCB, 2009) (see Table 

2.2.8.5-2).

Approximately 15 census block groups within 50 mi of KPS were determined to have high 

density minority population percentages that exceeded the State average by 20 percentage 

points or more. The largest number of high density minority block groups was Hispanic or 

Latino, with six census block groups that exceed the State average 20 percent or more. The 

greatest concentrations of high density minority population block groups are located near Green 

Bay, WI, or the Oneida Indian Reservation just west of Green Bay. No high density minority 

census block groups were found within 20 mi of KPS (DEK, 2008). The Oneida Nation Indian 

Reservation is located west of Green Bay, WI (Brown and Outagamie counties).

Based on 2000 Census data, Figure 4-1 shows the location of high density minority blocks 

within a 50-mi radius of KPS.
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August 2010 4-33 NUREG-1437, Supplement 40

Figure 4-1. Minority Blocks in 2000 within a 50-Mile Radius of Kewaunee Power Station 

(Source: DEK, 2008; USCB, 2003)

Kewaunee
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NUREG-1437, Supplement 40 4-34 August 2010

4.9.7.2 Low-Income Population in 2000

According to 2000 Census data, approximately 7,418 families and 41,197 individuals 

(approximately 3.9 and 5.7 percent, respectively) residing within a 50-mi radius of KPS were 

identified as living below the Federal poverty threshold in 1999 (USCB, 2003). The 1999 

Federal poverty threshold was $17,029 for a family of four.

According to census data estimates, the median household income for Wisconsin in 2007 was 

$50,567, with 10.8 percent of the State population living below the Federal poverty threshold. 

Kewaunee County had the highest median household income average ($53,356) and the lowest 

percentage (7.3 percent) of individuals living below the poverty level when compared to the 

State average and the other three counties. Manitowoc County had the lowest median 

household income of the four counties ($48,175) and a lower percentage (8.6 percent) of 

individuals living below the poverty level when compared to the State. Brown County had a 

median household income of $52,452 and the highest percentage (10.3 percent) of individuals 

living below the poverty level among the three counties (USCB, 2009).

Census block groups were considered high density low-income block groups if the percentage 

of households below the Federal poverty threshold exceeded the State average by 20 percent 

or more. Based on 2000 Census data, there were 2 block groups within the 50-mi radius of KPS 

that exceeded the State average for low income households by 20 percent or more. The census 

block groups with low-income populations were located in Brown County and in Green Bay, WI 

(DEK, 2008). Figure 4-2 shows the location of the high density low-income census block groups 

within a 50-mi radius of KPS.
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August 2010 4-35 NUREG-1437, Supplement 40

Figure 4-2. Low-Income Block Groups within a 50-Mile Radius of Kewaunee Power 

Station (Source: DEK, 2008; USCB, 2003)

Kewaunee
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NUREG-1437, Supplement 40 4-36 August 2010

4.9.7.3 Analysis of Impacts

Consistent with the impact analysis for the public and occupational health and safety, the 

affected populations are defined as minority and low-income populations who reside within a 

50-mi radius of KPS. Based on the analysis of environmental health and safety impacts 

presented in Chapter 4 of this SEIS for other resource areas, there would be no 

disproportionately high and adverse impacts to minority and low-income populations from the 

continued operation of KPS during the license renewal period.

The NRC analyzed the risk of radiological exposure through the consumption patterns of special 

pathway receptors, including subsistence consumption of fish, native vegetation, surface 

waters, sediments, and local produce. The NRC also analyzed the absorption of contaminants 

in sediments through the skin and inhalation of plant materials. The special pathway receptors 

analysis is important to the environmental justice analysis because consumption patterns may 

reflect the traditional or cultural practices of minority and low-income populations in the area. 

This analysis is presented below.

4.9.7.4 Subsistence Consumption of Fish and Wildlife

Section 4-4 of E.O. 12898 (1994) directs Federal agencies, whenever practical 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. The staff considered whether or not there were any means 

for minority or low-income populations to be disproportionately affected by examining impacts to 

American Indian, Hispanic, and other traditional lifestyle special pathway receptors. In addition, 

the staff considered special pathways that took into account the levels of contaminants in native 

vegetation, crops, soils and sediments, surface water, fish, and game animals in the vicinity of 

KPS.

DEK has an ongoing comprehensive REMP at KPS that assesses the radiological impact of site 

operations on the environment. The REMP program monitors radiation levels in atmospheric, 

terrestrial, and aquatic environments. All samples are collected by DEK personnel and are 

shipped to a laboratory for analysis.

To assess the radiological impact of the plant on the environment, the monitoring program at 

KPS uses indicator-control sampling. Samples are collected at nearby indicator locations 

downwind and downstream from the plant and at distant control locations upwind and upstream 

from the plant. A plant effect would be indicated if the radiation level at an indicator location was 

significantly larger than at the control location. The difference would also have to be greater 

than could be accounted for by typical fluctuations in radiation levels arising from other naturally 

occurring sources.

Samples are collected from the aquatic and terrestrial pathways in the vicinity of KPS. The 

aquatic pathways include fish, surface water, slime, bottom sediment, and groundwater. The 

terrestrial pathways include airborne particulates, milk, domestic meat, eggs, garden 

vegetables, grass and cattle feed, soil, and direct radiation. During 2007, analyses performed on 

collected samples of environmental media showed no significant or measurable radiological 

impact from KPS operations (DEK, 2008b).

Surface water sampling at KPS consists of monthly samples from three locations on Lake 

Michigan and three creeks (North, Middle, and South creeks) that pass through the site. All 

samples are analyzed for gamma-emitting isotopes. Tritium activity is measured through one 
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August 2010 4-37 NUREG-1437, Supplement 40

composite sample from South Creek. All results from the 2007 REMP were below the required 

lower limit of detection (DEK, 2008b).

In bottom sediment samples, the mean gross beta concentrations measured lower at the 

indicator locations than the control locations. Cesium-134 measured below detection levels in all 

samples. A low level of cesium-137 was observed in one of the two control samples tested. On 

average, cesium-137 measurements are lower than, or similar to, levels observed from 1979 

through 2006. Levels of strontium-89 and strontium-90 measured below respective detection 

limits in all samples (DEK, 2008b).

In fish, gross beta concentration was primarily due to potassium-40 activity. A concentration of 

cesium-137 was detected in one of three tested samples in levels lower than those observed 

between 1979 and 1991, but at similar levels to those seen from 1992 through 2006. The 

strontium-89 and strontium-90 concentrations were below detection levels in all samples 

(DEK, 2008b).

According to the 2007 KPS REMP, 126 milk samples were collected and analyzed for low-level

iodine-131 by radiochemical separation. All samples were below detection levels. Naturally 

occurring potassium-40 results were almost identical in all samples. Strontium-89 

concentrations measured below detection levels in all samples. Low levels of strontium-90 were 

found in 62 of the 84 samples tested. Mean values were almost identical for indicator and 

control sample locations and are similar to or less than averages seen from 1990 through 2006 

(DEK, 2008b).

Groundwater was collected from two onsite wells and analyzed for tritium and gamma emitting 

radionuclides. All samples were tested for tritium and gamma emitting isotopes. Tritium 

concentrations measured below detection levels. Gamma-emitting isotopes measured below 

respective detection levels (DEK, 2008b).

In domestic meat and egg samples, gross alpha concentration measured below detection levels 

for both indicator and control locations. Gamma-spectroscopic analyses showed that almost all 

beta activity was due to naturally occurring potassium-40. All other gamma-emitting isotopes 

were below their respective detection levels (DEK, 2008b).

In vegetables, gamma-spectroscopic analyses showed that almost all beta activity was due to 

naturally occurring potassium-40 and was below respective levels of detection. Levels of 

strontium-89 and strontium-90 measured below their respective levels of detection 

(DEK, 2008b).

In two samples (clover and oats) gamma-spectroscopic analyses showed that almost all beta 

activity was due to naturally occurring potassium-40 and beryllium-7 observed in the samples. 

Beryllium-7 is produced continuously in the upper atmosphere by cosmic radiation. Other 

gamma-emitting isotopes were below their respective levels of detection. Levels of strontium-89 

and strontium-90 measured below their respective levels of detection (DEK, 2008b).

In grass and cattlefeed samples, gamma-spectroscopic analyses showed that almost all beta 

activity was due to naturally occurring potassium-40 and beryllium-7. Other gamma-emitting 

isotopes were below their respective levels of detection. Levels of strontium-89 measured below 

the levels of detection in grass and cattlefeed samples. Strontium-90 activity was found in one 

of twelve cattlefeed samples tested, and was similar or lower than levels observed from 1996 

through 2006 (DEK, 2008b).
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NUREG-1437, Supplement 40 4-38 August 2010

Gross alpha concentrations in soil samples at the indicator locations were similar to 

concentrations at the control locations. Levels of strontium-89 measured below the levels of 

detection. Low levels of strontium-90 activity were detected in 9 of 14 samples tested (DEK, 

2008b).

Low levels of cesium-137 were detected in 12 of 14 soil samples, similar at both indicator and 

control locations. Potassium-40 was detected in all samples and averaged the same at indicator 

and control locations. All other gamma-emitting isotopes were below their respective detection 

levels. These levels of detected activities are similar to those observed from 1990 through 2006. 

The data suggests no evidence of a plant effect on soil measurements (DEK, 2008b).

The results of the KPS 2007 REMP sampling demonstrate that the routine operation at KPS has 

had no significant or measurable radiological impact on the environment. No elevated radiation 

levels were detected in the offsite environment as a result of plant operations and the storage of 

radioactive waste. The results of the REMP continue to demonstrate that the operation of KPS 

did not result in a significant measurable impact to a member of the general population or 

adversely impact the environment as a result of radiological effluents.

Based on recent monitoring results, concentrations of contaminants in native leafy vegetation, 

soils and sediments, surface water, and fish in areas surrounding KPS have been quite low (at 

or near the threshold of detection) and seldom above background levels. Consequently, 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 fish and 

wildlife.

4.10 EVALUATION OF NEW AND POTENTIALLY SIGNIFICANT INFORMATION

The new and significant assessment process that DEK used during preparation of the KPS ER 

(DEK, 2008) license renewal application included: 

(1) interviews with DEK, Dominion Resources Services, Inc., WPSC, and ATC subject 

experts on information related to the conclusions in the GEIS as they relate to KPS

(2) review of DEK and KPS environmental management systems for how current 

programs manage potential impacts and/or provide mechanisms for KPS staff to 

become aware of new and significant information

(3) correspondence with State and Federal regulatory agencies to determine if the 

agencies had concerns 

(4) review of documents related to environmental issues at KPS and regional environs 

(5) credit for oversight provided by inspections of plant facilities and environmental 

monitoring operations by State and Federal regulatory agencies

(6) independent review of plant-related information contracted by DEK with industry 

experts on license renewal and environmental impacts

DEK stated in the KPS ER (DEK, 2008) that it is aware of no new and significant information 

regarding the environmental impacts of KPS license renewal. 
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August 2010 4-39 NUREG-1437, Supplement 40

The staff evaluated this information during its independent review of the KPS ER, the scoping 

process, the site audit, and interviews with knowledgeable DEK personnel. The staff concluded 

that there is no new and significant information related to the environmental impacts of the KPS 

license renewal.

4.11 CUMULATIVE IMPACTS

The staff considered potential cumulative impacts in its environmental analysis of continued 

operation of KPS. For the purposes of this analysis, past actions are those related to the 

resources at the time of the power plant licensing and construction; present actions are those 

related to the resources at the time of current operation of the power plant; and future actions 

are considered to be 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 future actions would occur is dependent on the 

type of action considered and is described below for each impact area.

The impacts of the proposed action, as described in Sections 4.1 through 4.9, are combined 

with other past, present, and reasonably foreseeable future actions regardless of what agency 

(Federal or nonfederal) or person undertakes such other actions.

4.11.1 Cumulative Impacts on Water and Aquatic Resources 

This section addresses the impacts of the proposed action that relate to the withdrawal and 

discharge of lake water by the KPS once-through cooling system, combined with other past, 

present, and future actions that occur within the defined geographic area of Lake Michigan. The 

geographic area considered for the analysis of cumulative impacts on aquatic resources 

focuses on the western portion of Lake Michigan.

The water quality of Lake Michigan directly affects the aquatic resources in the vicinity of KPS. 

Lake Michigan’s water quality in turn is affected, and will continue to be affected, by boating and 

fishing, agricultural runoff, and development along and near the waterfront. Water quality has 

been a recognized issue within the Great Lakes for over a century. The Great Lakes Water 

Quality Agreement, which was first signed in 1972, was formed to address the deteriorating 

water quality within the Great Lakes. Numerous fish species in Lake Michigan have 

consumption advisories as a result of elevated levels of mercury. Atrazine and other compounds 

found in herbicides and pesticides also contribute to the lake’s water quality problems. These 

compounds affect water quality most in the spring and summer months, corresponding to 

agricultural production. Atrazine concentrations, specifically, may be increasing under present 

loads to Lake Michigan (Brent et al., 2001). However, with continued bi-national management 

efforts, including the Great Lakes Fishery Commission, Great Lakes Water Quality Agreements, 

and the International Joint Commission, which are discussed in Section 2.2.5, “Aquatic 

Resources,” water quality is expected to improve in the future.

Lake Michigan has undergone drastic changes in its fish communities due to exotic species 

introductions. As discussed in Section 2.2.5, “Aquatic Resources,” the sea lamprey (Petromyzon 

marinus) and alewife (Alosa pseudoharengus) have had the most pronounced impact on native 

aquatic populations. Overfishing and predation by sea lamprey is thought to be responsible for 

the extirpation of lake trout (Salvelinus namaycush) in Lake Michigan (USGS, 2008). Sea 

lamprey have also led to the extinction of three deepwater cisco species: the long jaw cisco 

(Coregonus alpenae), the deepwater cisco (C. johannae), and the blackfin cicso (C. nigripinnis) 
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NUREG-1437, Supplement 40 4-40 August 2010

(Fuller et al., 2007). Alewives negatively impact water clarity by consuming zooplankton, 

outcompeting native species for food, and also preying on other species’ eggs (Crowder, 1980). 

Future management challenges will include keeping the salmonid community stable given the 

available forage base and suppressing the alewife population growth to a level that does not

threaten the continued existence of native species (Eshenroder et al., 1995).

PBNP is located about 5 mi (8 km) south of KPS along Lake Michigan. PBNP is a two unit

pressurized-water reactor plant with a once-through cooling system and an independent spent 

fuel storage installation. PBNP received a renewed license through 2030 and 2033 for Units 1 

and 2, respectively, and, therefore, will continue to operate during the term of KPS’s continued 

operation. The PBNP SEIS (NRC, 2005) concluded that the impacts of continued operation of 

PBNP on the impingement and entrainment of aquatic organisms and heat shock to aquatic 

organisms are all SMALL. Studies at PBNP indicated that alewives and rainbow smelt 

(Osmerus mordax) were the primary species in both impingement and entrainment samples. 

Though both cooling systems alone have been determined to have a SMALL effect on aquatic 

organisms, the combined impact of KPS and PBNP on the alewife and rainbow smelt 

populations, specifically, may be noticeable, though these combined impacts have not been 

specifically studied, and both the alewife and rainbow smelt are considered invasive, nuisance 

species. The PBNP SEIS concluded that cumulative impacts from heat shock are not expected 

to be any greater when both plants are considered because the KPS and PBNP heated 

discharge mixing zones do not overlap (NRC, 2005).

The staff has determined that the cumulative impacts on aquatic resources resulting from all 

past, present, and reasonably foreseeable future actions, including non-KPS actions, would be 

MODERATE. This designation is largely the result of past actions including water quality issues 

and native aquatic community destabilization due to invasive species introductions.

4.11.2 Cumulative Impacts on Terrestrial Resources

This section addresses past, present, and future actions that could result in adverse cumulative 

impacts to terrestrial resources, including wildlife populations, upland habitats, wetlands, Lake 

Michigan shoreline, riparian zones, invasive species, protected species, and land use. For 

purposes of this analysis, the geographic area considered in the evaluation includes the KPS 

site, the adjacent shoreline both to the north and south, any wetlands on the KPS site or 

adjacent to the KPS site, and the in-scope transmission line ROWs identified in Section 2.1.5 of 

this SEIS.

Before construction of KPS, terrestrial communities on the surrounding area supported forested 

habitat, wetland habitat, Lake Michigan coastline, and agricultural lands. With the construction 

of KPS, 60 ac (24 ha) were converted to developed areas for the reactor building and other 

plant structures.

Construction of the transmission line ROWs maintained by ATC for the KPS site resulted in 

changes to the plant species and possibly wildlife within the ROWs. Habitat fragmentation 

resulting from the transmission line ROWs likely caused effects such as change in light, wind, 

and temperature, an increased susceptibility to invasive species, and a possible reduction in 

habitat ranges for certain species. ROW maintenance has likely had past impacts and is likely to 

have present and future impacts on the terrestrial habitat, which may include the buildup of 

herbicides, prevention of natural selection stages, an increase in edge species, a decrease in 

interior species, and an increase in invasive species. Continuing to lease agricultural land to 
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August 2010 4-41 NUREG-1437, Supplement 40

farmers for areas within the transmission line ROWs will help reduce some of these potential 

impacts.

Neither DEK nor ATC manage invasive species on their land holdings. Therefore, a potential 

exists for invasive species to be introduced on or in the vicinity of the KPS site or its associated 

transmission line ROWs from present and future actions. Introduction of these species may 

contribute to the establishment of an invasive species population, which could compete with 

native populations for resources and degrade areas of terrestrial habitat. 

Erosion to the Lake Michigan shoreline on the KPS site and its associated transmission lines 

from activities such as boating and fishing have the potential for adverse cumulative impacts. 

Continued maintenance for erosion on the shoreline by KPS should minimize impacts.

Prior and continued residential, commercial, agricultural, and industrial development of the 

areas surrounding the KPS site and its associated transmission line ROWs may impact 

terrestrial habitat in the area. Increases in both commercial and residential development have 

occurred in these areas over the past 40 years. As this area continues to grow, additional runoff 

from roads and impervious surfaces, development adjacent to wetlands and riparian zones, and 

an increase in waste releases could have future impacts on the terrestrial habitat. Section 

2.2.8.3 of this SEIS discusses offsite land use in the vicinity of KPS.

The potential cumulative effects of climate change could result in a variety of changes to 

terrestrial resources on and around the KPS site. Increases in average annual temperature and 

increased frequency of heat waves, droughts, and heavy rainfall events all have the potential to 

impact wildlife populations, protected species, upland habitats, wetlands, riparian zones, and 

invasive species. Increased precipitation could change vegetation composition on the KPS site, 

potentially increasing wetlands and decreasing riparian communities due to coastal erosion. 

Long-term effects of climate change on terrestrial resources could include a shift in forest 

composition or even an overall loss of forests, loss of bird diversity, a change in local mammal 

populations, and an increase in the range of invasive species and other pests (CEQ, 1997). 

The staff believes that the cumulative impacts during the term of license renewal on terrestrial 

habitat and associated species, when added to past, present, and reasonably foreseeable 

future actions, would be SMALL.

4.11.3 Cumulative Impacts on Human Health

The NRC and the EPA established radiological dose limits for protection of the public and 

workers from both 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. As discussed in Section 4.8.1 

of this SEIS, the doses resulting from operation of KPS are below regulatory limits and the 

impacts of these exposures would be SMALL. For the purposes of this analysis, the 

geographical area considered is within a 50-mi (80-km) radius of the KPS site.

EPA regulations in 40 CFR Part 190 limit the dose to members of the public from all sources in 

the nuclear fuel cycle, including nuclear power plants, fuel fabrication facilities, waste disposal 

facilities, storage of spent nuclear fuel in dry casks, and transportation of fuel and waste. In 

addition, as discussed in Section 4.8.1, KPS has conducted a REMP around its site since 

before operations began in 1974. This program measures radiation and radioactive materials 

from KPS and all other sources, including the nearby PBNP. In 2005, the NRC completed an 

SEIS regarding the PBNP license renewal application. The NRC concluded that the cumulative 
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NUREG-1437, Supplement 40 4-42 August 2010

doses from PBNP and KPS were within the dose limits in 10 CFR Part 20 and 40 CFR Part 190 

(NRC, 2005).

As discussed in Section 4.8.1 of this report, the staff reviewed the radiological environmental 

radiation monitoring results for KPS for the 5-year period from 2004 through 2008 as part of the 

cumulative impacts assessment. Cumulative radiological impacts from all uranium fuel cycle 

facilities within a 50-mi (80-km) radius of the KPS site, which includes PBNP, are limited by the 

dose limits in 10 CFR Part 20 and 40 CFR Part 190. Based on the staff review of the 

radiological environmental monitoring data from KPS and the State of Wisconsin, the 

radioactive effluent release data from KPS, and the SEIS regarding the PBNP license renewal, 

the cumulative radiological impacts to the public from the operation of KPS during the renewal 

term would be SMALL. The NRC and the State of Wisconsin will regulate any future 

development or actions in the vicinity of the KPS site that could contribute to cumulative 

radiological impacts. Therefore, the staff has concluded that the cumulative radiological impacts 

to human health from the continued operation of KPS during the license renewal term would be 

SMALL.

The staff determined that the electric-field-induced currents from the KPS transmission lines are 

well below the NESC recommendations for preventing electric shock from induced currents. 

Therefore, the KPS transmission lines do not detectably affect the overall potential for electric 

shock from induced currents within the analysis area. With respect to chronic effects of EMFs, 

although the GEIS finding of “not applicable” is appropriate to KPS, the transmission lines 

associated with KPS are not likely to detectably contribute to the regional exposure to 

ELF-EMFs. Therefore, the staff determined that the cumulative impacts of the continued 

operation of the KPS transmission lines would be SMALL. The staff identified a variety of 

measures that could mitigate potential acute EMF impacts resulting from the continued 

operation of the KPS’s transmission lines. These mitigation measures would include erecting 

barriers along the length of the transmission line to prevent unauthorized access to the ground 

beneath the conductors and installing road signs at road crossings. These mitigation measures 

could reduce human health impacts by minimizing public exposures to electric shock hazards. 

The staff did not identify any cost benefit studies applicable to these mitigation measures.

4.11.4 Cumulative Impacts on Socioeconomics and Historical and Archaeological 

Resources

As discussed in Section 4.4 of this SEIS, continued operation of KPS during the license renewal 

term would have no impact on socioeconomic conditions in the region beyond those already 

experienced. Since DEK has no plans to hire additional workers during the license renewal 

term, overall expenditures and employment levels at KPS would remain relatively constant with 

no additional 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. There would also be no disproportionately high and adverse health and 

environmental impacts on minority and low-income populations in the region. Based on this and 

other information presented in this chapter, there would be no cumulative socioeconomic 

impacts from the continued operation of KPS during the license renewal term beyond what is 

currently being experienced.

Any ground disturbing activities during the license renewal term could, however, result in the 

cumulative loss of historic and archaeological resources. Historic and archaeological resources 

are non-renewable; therefore, the loss of archaeological resources is cumulative. The continued 
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August 2010 4-43 NUREG-1437, Supplement 40

operation of KPS during the license renewal term has the potential to impact historic and 

archaeological resources.

As discussed in Section 4.9.6, continued operation of KPS during the license renewal term 

would have a SMALL impact on archaeological resources. While archaeological surveys were 

not conducted prior to the construction of KPS, DEK has conducted a Phase I survey to identify 

historic and archaeological resources on the KPS site. DEK has established a Cultural 

Resources Protection Plan to improve the protection of archaeological resources at KPS. DEK 

could also train staff to ensure that historic and archaeological resources are protected at the 

KPS site.

DEK has no plans to alter the KPS site for license renewal. Any future land disturbing activities 

would be carried out under corporate procedures. These procedures have stop work provisions 

in the case of any inadvertent discoveries. Should plans change, further consultation would be 

initiated by DEK with the NRC and WHS. Because impacts to historic and archaeological 

resources from the continued operation of KPS would be SMALL, the cumulative environmental 

impacts to historic and archaeological resources would be SMALL.

4.11.5 Cumulative Impacts on Air Quality 

KPS is located in Kewaunee County, WI, which belongs to the Lake Michigan Intrastate Air 

Quality Control Region (AQCR) designated by the EPA and codified in 40 CFR 81.67 and 

Chapter 404.03 of the Wisconsin Administrative Code. Seventeen counties in the State of 

Wisconsin belong to the Lake Michigan Intrastate AQCR, three counties among them (Door 

County, Manitowoc County, and Sheboygan County) are currently designated by the EPA as 

8-hour ozone nonattainment areas. Kewaunee County is a maintenance county for 8-hour 

ozone and is in attainment for all other criteria pollutants (EPA, 2009).

As discussed in Section 2.2.2.1, “Regional Air Quality Impacts,” WDNR has primary 

responsibility for regulating air emission sources and conducting ambient air monitoring within 

the State of Wisconsin. WDNR is in the process of registering the Horicon, WI monitoring site as 

a National Core (NCore) multi-pollutant higher-sensitivity monitoring station, therefore, fulfilling

the EPA’s final amendments to the ambient air monitoring regulations for criteria pollutants 

contained in 40 CFR Parts 53 and 58. KPS is recognized as a Synthetic Minor facility, non-Part 

70 by WDNR due to the quantities of emissions and restrictions on the hours of operation of its 

stationary sources of criteria pollutants (DEK, 2009a).

In April 2009, the EPA published the official United States inventory of greenhouse gas (GHG) 

emissions that identifies and quantifies the primary anthropogenic sources and sinks of GHGs 

(EPA, 2009a). GHG inventories, such as this, are mechanisms developed by the United Nations 

Framework Convention on Climate Change that enable participating countries to compare their 

relative global contributions from different emission sources and GHGs to assess their impact 

on climate change. In its report, the 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 like power plants, and approximately a third 

come from transportation. Industrial processes (production of cement, steel, and aluminum), 

agriculture, forestry, other land use, and waste management are also sources of GHG 

emissions in the United States (EPA, 2009a).
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NUREG-1437, Supplement 40 4-44 August 2010

Potential cumulative effects of climate change on the Great Lakes Region, whether from natural 

cycles or anthropogenic (man-induced) activities, could result in a variety of changes to the air 

quality of the area. As projected in the “Global Climate Change Impacts in the United States” 

report by the United States Global Change Research Program (USGCRP, 2009), average 

annual temperatures in the Great Lakes Region and Midwest are expected to rise, causing 

more frequent extreme weather events. The climate of the Midwest, Wisconsin in particular, is 

projected to become drier in summer, causing mild to significant reductions in Great Lakes 

water levels and reduced ice cover. Reduced ice cover will contribute to faster evaporation in 

winter, causing water deficits. The projected increase in winter and spring precipitation will 

cause more frequent occurrences of severe weather events. Increases in average annual 

temperatures, increased occurrences of intense rainfall or drought, and changes in wind 

patterns could affect concentrations and long-range transport of air pollutants. The formation of 

air pollutants partially depends on temperature and humidity and interactions between hourly 

changes in the physical and dynamic properties of the atmosphere, including circulation 

features, wind, topography, and energy use (IPCC, 2009).

In 1993, WDNR conducted the “Wisconsin Greenhouse Gas Emissions Inventory and Emission 

Reduction Cost Study,” which led to the development of a Climate Change Action Plan in 1998. 

The Wisconsin GHG emissions inventory is periodically updated per this plan. In 2007, the 

enactment of E.O. 191 in Wisconsin led to the creation of the Governor’s Task Force on Global 

Warming, which outlined its mission, goals, and recommendations in the 2008 final report to the 

governor, “Wisconsin’s Strategy for Reducing Global Warming” (WDNR, 2009a). WDNR is also 

a member of the Wisconsin Initiative on Climate Change Impacts that assesses and evaluates 

climate change impacts on specific Wisconsin natural resources, industry, agriculture, tourism, 

and other human activities.

Consistent with the findings in the GEIS, the staff concludes that the impacts from the continued 

operation of KPS on air quality are SMALL. In addition, as no refurbishment is planned at KPS 

during the license renewal period, no additional air emissions would result from refurbishment 

activities. With respect to GHG, the EPA has not established limits on such emission sources, 

as further evaluation of data is still needed. Therefore, the staff concludes that, combined with 

the emissions from other past, present, and reasonably foreseeable future actions, cumulative 

hazardous and criteria air pollutant emissions on air quality from KPS-related actions would be 

SMALL.

4.11.6 Summary of Cumulative Impacts

The staff considered the potential impacts resulting from the operation of KPS during the period 

of extended operation and other past, present, and future actions in its vicinity. The 

determination is that most of the potential cumulative impacts resulting from KPS operation 

during the period of extended operation would be SMALL.
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August 2010 4-45 NUREG-1437, Supplement 40

Table 4-17. Summary of Cumulative Impacts on Resource Areas. The cumulative impacts 

were determined to be SMALL for most of the resource areas.

Resource Area Impact Discussion

Water/Aquatic Resources MODERATE See Section 4.11.1

Terrestrial Resources SMALL See Section 4.11.2

Human Health SMALL See Section 4.11.3

Socioeconomics/Historical and 

Archaeological Resources SMALL See Section 4.11.4

Air Quality SMALL See Section 4.11.5

4.12 REFERENCES

10 CFR 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for Protection 

Against Radiation.”

10 CFR 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

Production and Utilization Facilities.”

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

Regulations for Domestic Licensing and Related Regulatory Functions.”

36 CFR 60. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, Part 60, 

Section 4, “Criteria for Evaluation.”

36 CFR 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, Part 

800, “Protection of Historic Properties.”

40 CFR 53. Code of Federal Regulations, Title 40, Protection of Environment, Part 53, “Ambient 

Air Monitoring Reference and Equivalent Methods.”

40 CFR 58. Code of Federal Regulations, Title 40, Protection of Environment, Part 58, “Ambient 

Air Quality Surveillance.”

40 CFR 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 

“Environmental Radiation Protection Standards for Nuclear Power Operations.”

59 FR 7629. The President, Washington, D.C., “Federal Actions to Address Environmental 

Justice in Minority Populations and Low-Income Populations.” Federal Register, Vol. 59, No. 32, 

February 16, 1994.

69 FR 41575. U.S. Environmental Protection Agency, “National Pollutant Discharge Elimination 

System – Final Regulations to Establish Requirements for Cooling Water Intake Structures at 

Phase II Existing Facilities: Final Rule.” Federal Register, Volume 69, pp. 41575. July 9, 2004.

69 FR 52040. U.S. Nuclear Regulatory Commission, Washington, D.C, “Policy Statement on the 

Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions.” Federal 

Register, Vol. 69, No. 163, pp. 52040-52048, August 24, 2004.

72 FR 37107. U.S. Environmental Protection Agency, “National Pollutant Discharge Elimination 

System – Suspension of the Regulations Establishing Requirements for Cooling Water Intake 

Structures at Phase II Existing Facilities,” Federal Register, Volume 72, No. 130, pp. 37107–

37109. July 9, 2007.
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NUREG-1437, Supplement 40 4-46 August 2010

33 USC 1326. Title 33, Section 1326 of the United States Code, Thermal Discharges.

Advisory Council on Historic Preservation (ACHP). 2009. “National Register Evaluation Criteria.” 

Available URL: http://www.achp.gov/nrcriteria.html (accessed September 8, 2009). 

AVD Archaeological Services, Inc. (AVD). 2007. “Phase I Archaeological Survey at the 

Kewaunee Power Station in Kewaunee County, Wisconsin,” Prepared for Dominion Energy 

Kewaunee, Kewaunee, WI. [Non-public document. Withheld per 36 CFR 800.11(c)]

Bigelow, H.B. and W.C. Schroeder. 1953. “Alewife,” Fishes of the Gulf of Maine. Fishery 

Bulletin 74, U.S. Fish and Wildlife Service. Available URL: http://www.gma.org/fogm/Default.htm

(accessed July 21, 2009). Agencywide Documents Access and Management System (ADAMS)

Accession No. ML093250060.

Brent, R., J. Schofield, and K. Miller. 2001. “Results of the Lake Michigan Mass Balance Study: 

Atrazine Data Report,” U.S. EPA Great Lakes National Program Office, EPA 905R-01-010, 

December 2001. Available URL: http://www.epa.gov/glnpo/lmmb/results/atra_final.pdf

(accessed May 18, 2009). ADAMS Accession No. ML093250007.

Bunnell, et al. 2007. “Status and Trends of Prey Fish Populations in Lake Michigan, 1992-2006.” 

Lake Michigan Committee, U.S. Geological Survey, March 20, 2007. Available URL:

http://www.michigandnr.com/publications/pdfs/fishing/research/Charlevoix/130_2006LakeMichig

anAcoustic.pdf

Clean Water Act (CWA) of 1977 (P.L. 95-217).

(accessed November 24, 2009).

Council of Environmental Quality (CEQ). 1997. “Environmental Justice: Guidance Under the 

National Environmental Policy Act (NEPA),” 1997.

Crawford, S. S. 2001. “Salmonine Introductions to the Laurentian Great Lakes: An Historical 

Review and Evaluation of Ecological Effects,” Executive Summary, Canadian Special 

Publication of Fisheries and Aquatic Sciences. Available URL:

http://www.uoguelph.ca/~scrawfor/research/research_greatlakes/research_greatlakes_fisheries/

research_greatlakes_fisheries_issues/research_greatlakes_fisheries_issues_salmon_monogra

ph.shtml

Crowder, L.B. 1980. “Alewife, Rainbow Smelt, and Native Fishes in Lake Michigan: Competition 

or Predation?” Environmental Biology of Fishes, 5(3): 225-233.

(accessed July 15, 2009). ADAMS No. ML093250009. 

Dominion Energy Kewaunee, Inc. (DEK). 2005. “2004 Annual Environmental Monitoring 

Report,” Kewaunee Power Station, Kewaunee, WI. ADAMS Accession No. ML051250449.

Dominion Energy Kewaunee, Inc. (DEK). 2006. “2005 Annual Environmental Monitoring 

Report.” Kewaunee Power Station, Kewaunee, WI. ADAMS Accession No. ML061240127.

Dominion Energy Kewaunee, Inc. (DEK). 2007. “2006 Annual Environmental Monitoring 

Report,” Kewaunee Power Station, Kewaunee, WI. ADAMS Accession No. ML071350508.

Dominion Energy Kewaunee, Inc. (DEK). 2008. “Applicant’s Environmental Report – Operating 

License Renewal Stage,” Appendix E of Application for Renewed Operating License, Kewaunee 

Power Station, Docket No. 50-305, August 2008. ADAMS Accession No. ML082341039.

Dominion Energy Kewaunee, Inc. (DEK). 2008a. “2007 Annual Environmental Monitoring 

Report,” Kewaunee Power Station, Kewaunee, WI. ADAMS Accession No. ML081340603.

Dominion Energy Kewaunee, Inc. (DEK). 2008b. “2007 Radiological Annual Environmental 

Monitoring Report,” Kewaunee Power Station, Kewaunee, WI, April 24, 2008. ADAMS 

Accession No. ML0813406033.
Environmental Impacts of Operation

August 2010 4-47 NUREG-1437, Supplement 40

Dominion Energy Kewaunee, Inc. (DEK). 2009. “2008 Annual Environmental Monitoring 

Report,” Kewaunee Power Station, Kewaunee, WI. ADAMS Accession No. ML091480351.

Dominion Energy Kewaunee, Inc. (DEK) 2009a. “Response To Request To Docket Information 

Related To The Environmental Site Audit for Kewaunee Power Station,” Enclosure A –

Meteorology and Air Compliance, Kewaunee Power Station. ADAMS Accession No. 

ML09190514.

Dominion Energy Kewaunee, Inc. (DEK) 2009b. “Cultural Resources Protection Plan,”

Kewaunee Power Station. ADAMS Accession No. ML101320123.

Dominion Energy Kewaunee, Inc. (DEK). 2010. “Dominion Energy Kewaunee, Inc. (DEK) 

Kewaunee Power Station Application for Renewed Operating License Comments on Draft 

Supplement 40 to the Generic Environmental Impact Statement,” Docket No. 50-305,

April 12, 2010. ADAMS Accession No. ML101060515.

Dominion Resource Services, Inc (Dominion). 2008. Letter from P. Faggert, Dominion Energy 

Kewaunee, Inc., to D. Hantz, Wisconsin Department of Natural Resources. Subject: Reply to 

Information Requirements Related to Cooling Water Intake Structures, WPDES Permit 

WI-000-071571, January 4, 2008. ADAMS Accession No. ML083520612.

Dominion Resource Services, Inc. (Dominion). 2009. “Dominion’s plan to address Greenhouse 

Gases.” Available URL: http://www.dom.com/about/environment/pdf/ghg_report.pdf (accessed 

June, 2009). ADAMS Accession No. ML093250061.

EA Engineering, Science, and Technology, Inc. (EAE). 2007. “Impingement Mortality and 

Entrainment Characterization Report, Kewaunee Power Station, March 2006–February 2007,” 

Prepared for Dominion Resources Services, Inc., Glen Allen, VA. ADAMS Accession No. 

ML083520612. 

Edsall, T.A. and M.I. Saxon. 1970. “The Effect of Temperature on the Rate of Development and 

Survival of Alewife Eggs and Larvae,” Trans. Am. Fish. Soc. 99(2): 376-380. ADAMS Accession 

No. ML093250062.

Environmental Protection Agency (EPA). 2009. “EPA Green Book Nonattainment Areas for 

Criteria Pollutants.” Available URL: http://www.epa.gov/air/oaqps/greenbk/index.html (accessed 

May, 2009). ADAMS Accession No. ML093250063.

Environmental Protection Agency (EPA). 2009a. “2009 U.S. Greenhouse Gas Inventory 

Report.” Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990–2007. Available URL:

http://www.epa.gov/climatechange/emissions/usinventoryreport.html

Eshenroder, et al. 1995. “Fish-Community Objectives for Lake Michigan,” Great Lakes Fishery 

Commission Publication Spec. Pub. 95-3. Available URL: 

(accessed June, 2009). 

ADAMS Accession No. ML093250064.

http://www.glfc.org/pubs/SpecialPubs/Sp95_3.pdf (accessed July 15, 2009). ADAMS Accession 

No. ML093250065.

Fay, C. W., R. J. Neves, and G. B. Pardue. 1983. “Species Profiles: Life Histories and 

Environmental Requirements of Coastal Fishes and Invertebrates (Mid-Atlantic) –

Alewife/Blueback Herring,” U.S. Fish and Wildlife Service Biol. Rep. 82 (11.45), U.S. Army 

Corps of Engineers, TR EL-82-4. Available URL: 

http://www.nwrc.usgs.gov/wdb/pub/species_profiles/82_11-009.pdf (accessed July 21, 2009). 

ADAMS Accession No. ML093250066.
Environmental Impacts of Operation

NUREG-1437, Supplement 40 4-48 August 2010

Froese, R. and D. Pauly. Ed. 2009. “Cyprinus carpio carpio: Common Carp,” FishBase, May 

2009 Version. Available URL: http://www.fishbase.org/Summary/SpeciesSummary.php?id=1450

(accessed July 20, 2009). ADAMS Accession No. ML093250067.

Fuller, P., E. Maynard, and D. Raikow. 2007. “Alosa pseudoharengus,” USGS Nonindigenous 

Aquatic Species Database. Available URL:

http://nas.er.usgs.gov/queries/FactSheet.asp?speciesID=490

Institute of Electrical and Electronics Safety Code (IEEE). 2007. National Electric Safety Code.

(accessed January 6, 2009). 

ADAMS Accession No. ML093250022.

Intergovernmental Panel on Climate Change (IPCC). 2009. “IPCC Fourth Assessment Report: 

Working Group II Report, Climate Change 2007: Impacts, Adaptation and Vulnerability.” 

Available URL:

http://www.ipcc.ch/publications_and_data/publications_ipcc_fourth_assessment_report_wg2_re

port_impacts_adaptation_and_vulnerability.htm

Madenjian et al. 2005. “Recruitment Variability of Alewives in Lake Michigan,” Transactions of 

the American Fisheries Society 134: 218-230. Available URL:

(accessed June, 2009). ADAMS Accession No. 

ML093250068.

http://www.glerl.noaa.gov/pubs/fulltext/2005/20050002.pdf

Madenjian et al. 2008. “Status and Trends of Prey Fish Populations in Lake Michigan, 2007,” 

Lake Michigan Committee, Great Lakes Fishery Commission, Published by the U.S. Geological 

Survey. March 20, 2008. Available URL: 

(accessed July 20, 2009). ADAMS 

Accession No. ML093250069.

http://www.glsc.usgs.gov/files/reports/2007LakeMichiganPreyfish.pdf (accessed July 21, 2009). 

ADAMS Accession No. ML093250070.

National Institute of Environmental Health Sciences (NIEHS). 1999. “NIEHS Report on Health 

Effects from Exposure to Power Line Frequency and Electric and Magnetic Fields,” Publication 

No. 99–4493, Research Triangle Park, North Carolina.

National Environmental Policy Act of 1969 (NEPA). 42 USC 4321, et seq.

Nalco Environmental Sciences (NES). 1976. Kewaunee Nuclear Power Plant 316(b) 

Demonstration: Environmental Effects of Existing Cooling Water Intake Structures. ADAMS 

Accession No. ML083520612.

National Historic Preservation Act of 1966 (NHPA), 16 USC 470, et seq.

National Oceanic and Atmospheric Administration (NOAA). 2007. “Annual Commercial Landing 

Statistics,” Database. Available URL:

http://www.st.nmfs.noaa.gov/st1/commercial/landings/annual_landings.html

U.S. Atomic Energy Commission (AEC). 1972. “Final Environmental Statement Related to the 

Operation of Kewaunee Nuclear Power Plant,” Wisconsin Public Service Corporation, Docket 

No. 50-305, Directorate of Licensing, Washington, D.C., December 1972. ADAMS Accession 

No. ML082820122.

(accessed July 21, 

2009). ADAMS Accession No. ML093250071.

U.S. Census Bureau (USCB). 2003. “LandView 6 – Census 2000 Profile of General 

Demographic Characteristics DP-1 (100%) and Census Profile of Selected Economic 

Characteristics DP-3, Summary of Census Block Groups in a 50-mile radius around the KPS 

(44.342222 Lat., -87.536111 Long.).”
Environmental Impacts of Operation

August 2010 4-49 NUREG-1437, Supplement 40

U.S. Census Bureau (USCB). 2009. American FactFinder, Census 2000 information and State 

and County QuickFacts on Kewaunee, Manitowoc, and Brown Counties. Available URLs:

http://factfinder.census.gov and http://quickfacts.census.gov (accessed July 2009).

U.S. Fish and Wildlife Service (USFWS). 2003. “12-Month Finding for a Petition to List the 

Kootenai River Burbot (Lota lota) as Threatened or Endangered,” Federal Register

68(47):11574-11579, March 11, 2003.

U.S. Fish and Wildlife Service (USFWS). 2008. Letter from L. Clemency, Field Supervisor, 

Green Bay Field Office, U.S. Fish and Wildlife Service, to D. Pelton, Branch Chief, Division of 

License Renewal. Subject: Reply to Request for Species List for License Renewal Application 

Review of Kewaunee Power Station, Kewaunee County, WI, October 28, 2008. ADAMS 

Accession No. ML083390643.

U.S. Fish and Wildlife Service (USFWS). 2008a. Letter to the NRC regarding the Renewal 

Application Review of Kewaunee Power Station, Kewaunee County, WI, October 28, 2008. 

ADAMS Accession No. ML 083390643.

U.S. Geological Survey (USGS). 2008. “Sea Lamprey.” Available URL:

http://www.glsc.usgs.gov/main.php?content=research_lamprey&title=Invasive%20Fish0&menu=

research_invasive_fish

United States Global Change Research Program (USGCRP). 2009. Global Climate Change 

Impacts in the United States. Cambridge University Press. 

(accessed November 4, 2008). ADAMS Accession No. ML093250040.

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2, Washington, D.C. 

ADAMS Accession Nos. ML040690705 and ML040690738.

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1, 

Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final 

Report,” NUREG-1437, Volume 1, Addendum 1, Washington, D.C. ADAMS Accession No.

ML040690720.

U.S. Nuclear Regulatory Commission (NRC). 2005. Generic Environmental Impact Statement 

for the Renewal of Nuclear Power Plants: Regarding Point Beach Nuclear Plant, Units 1 and 2,

Final Report, NUREG-1437, Supplement 23, Office of Nuclear Reactor Regulation, Washington, 

D.C. ADAMS Accession No. ML052230490.

U.S. Nuclear Regulatory Commission (NRC). 2008. Letter from D. Pelton, Branch Chief, 

Division of License Renewal, to L. Clemency, Field Supervisor, Green Bay Field Office, U.S. 

Fish and Wildlife Service. Subject: Request for List of State Protected Species Within the Area 

Under Evaluation for the Kewaunee Power Station License Renewal Application Review. 

September 30, 2008. ADAMS Accession No. ML082610748.

U.S. Nuclear Regulatory Commission (NRC). 2008a. Letter from D. Pelton, U.S. Nuclear 

Regulatory Commission, Washington, D.C., to S. Banker, Wisconsin Historical Society, 

Madison, Wisconsin. Subject: Kewaunee Power Station License Renewal Application Review 

(Case #07-0127/KE). ADAMS Accession No. ML082670685.

U.S. Nuclear Regulatory Commission (NRC). 2008b. Letter from D. Pelton, U.S. Nuclear 

Regulatory Commission, Washington, D.C., to D. Klima, Advisory Council on Historic 

Preservation, Washington, D.C. Subject: Kewaunee Power Station License Renewal Application 

Review. ADAMS Accession No. ML082610168.
Environmental Impacts of Operation

NUREG-1437, Supplement 40 4-50 August 2010

U.S. Nuclear Regulatory Commission (NRC). 2010. E-Mail re NRC Follow-Up Request for Tax 

Info on Kewaunee License Renewal. ADAMS Accession No. ML101550354.

Wisconsin Administrative Record (WAC). 2010. “Environmental Protection — General, Chs. 

NR 100—WPDES, Chs. NR 200—Water Regulation, Chs. NR 300—Water Supply, Chs. NR 

800—CR 09−123.” No. 654, pg. 44. July 1, 2010. Available URL: 

http://www.legis.state.wi.us/rsb/code/register/reg654b.pdf (accessed July 23, 2010).

Wisconsin Department of Health Services, Division of Public Health (WDHS). 2008. “State of 

Wisconsin 2007 Point Beach – Kewaunee Environmental Radioactivity Survey,” Madison, WI. 

ADAMS Accession No. ML083400062. 

Wisconsin Department of Natural Resources (WDNR). 2005. Letter from R. Rasmussen, 

Wisconsin Department of Natural Resources, to P. Faggert, Dominion Energy Kewaunee, Inc., 

transmitting WPDES Permit and Permit Fact Sheet. Subject: WPDES Permit Reissuance No.

WI-0001571-07-0 – Kewaunee Power Station, State Highway 42, Kewaunee, WI, July 18, 2005. 

Wisconsin Department of Natural Resources (WDNR). 2005a. State of Wisconsin Department 

of Natural Resources Permit to Discharge Under the Wisconsin Pollutant Discharge Elimination 

System, Permit No. WI-0001571-07-0, Kewaunee Power Station, July, 2005. ADAMS Accession 

No. ML083520612.

Wisconsin Department of Natural Resources (WDNR). 2007. Letter from D. Hantz, Wisconsin 

Department of Natural Resources, to P. Faggert, Dominion Energy Kewaunee, Inc. Subject: 

Requirements for Cooling Water Intake Structures – WPDES Permit WI-0001571-07. December 

3, 2007. ADAMS Accession No. ML083520612.

Wisconsin Department of Natural Resources (WDNR). 2009a. “Global Climate Change, Reports 

and Documents.” Available URL: http://dnr.wi.gov/air/aq/global/climatechange/reports.html

(accessed June, 2009). ADAMS Accession No. ML093250072.

Wisconsin Department of Natural Resources (WDNR). 2009b. “Lake Michigan.” Available URL: 

http://www.dnr.state.wi.us/org/water/greatlakes/LakeMichigan.html (accessed July 28, 2009). 

ADAMS Accession No. ML093250073.

Wisconsin Department of Natural Resources (WDNR). 2010. “Thermal Water Quality 

Standards.” April 23, 2010. Available URL:

http://dnr.wi.gov/org/water/wm/wqs/thermalrulesrevisions.htm (accessed July 23, 2010).

Wisconsin Natural Resources Board (WNRB). 2010. “WT-36-07, Order of the State of 

Wisconsin Natural Resources Board Repealing, Renumbering, Renumber and Amending, 

Amending and Creating Rules.” January 2010. Available URL: 

http://dnr.wi.gov/org/water/wm/wqs/Thermal_final_rule_order_Jan2010.pdf (accessed July 23, 

2010).

Wisconsin Historical Society (WHS). 2007, Fax from S. Banker to P. Faggert, December 3, 

2007, Request for SHPO Comment and Consultation on a Federal Undertaking. ADAMS 

Accession No. ML100850057.
August 2010 5-1 NUREG-1437, Supplement 40

5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS

This chapter describes the environmental impacts from postulated accidents that might occur 

during the period of extended operation. 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. Two classes of postulated accidents, 

listed in Table 5-1 below, are evaluated in the Generic Environmental Impact Statement for 

License Renewal of Nuclear Plants (GEIS), NUREG-1437 (NRC, 1996), (NRC, 1999). These 

are design-basis accidents (DBAs) and severe accidents.

Table 5-1. Issues Related to Postulated Accidents. Two issues related to postulated 

accidents are evaluated under the National Environmental Policy Act (NEPA) in the license 

renewal review: DBAs and severe accidents.

Issue GEIS Section Category 

DBAs 5.3.2; 5.5.1 1

Severe accidents 5.3.3; 5.3.3.2; 5.3.3.3; 5.3.3.4; 

5.3.3.5; 5.4; 5.5.2

2

5.1 DESIGN-BASIS ACCIDENTS

In order to receive U.S. Nuclear Regulatory Commission (NRC) approval to operate a nuclear 

power facility, an applicant for an initial operating license must submit a safety analysis report 

(SAR) as part of its application. The SAR presents the design criteria and design information for 

the proposed reactor and comprehensive data on the proposed site. The SAR also discusses 

various hypothetical accident situations and the safety features that are provided to prevent and 

mitigate accidents. The staff reviews the application to determine whether or not the plant 

design meets NRC regulations and requirements and includes, in part, the nuclear plant design 

and its anticipated response to an accident.

DBAs are those accidents that both the licensee and the 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. A number 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. The acceptance 

criteria for DBAs are described in Title 10 of the Code of Federal Regulations (10 CFR) Part 50 

and Part 100.

The environmental impacts of DBAs are evaluated during the initial licensing process, and the 

ability of the plant to withstand these accidents is demonstrated to be acceptable before 

issuance of the operating license. The results of these evaluations are found in license 

documentation such as the applicant’s final safety analysis report (FSAR), the safety evaluation 

report (SER), the final environmental statement (FES), and Section 5.1 of this supplemental 

environmental impact statement (SEIS). A licensee is required to maintain the acceptable 

design and performance criteria throughout the life of the plant, including any period of extended 

operation. The consequences for these events are evaluated for the hypothetical maximum 

exposed individual; as such, changes in the plant environment will not affect these evaluations. 
Environmental Impacts of Postulated Accidents

NUREG-1437, Supplement 40 5-2 August 2010

Because of the requirements that continuous acceptability of the consequences and aging 

management programs must be in effect for the period of extended operation, the 

environmental impacts as calculated for DBAs should not differ significantly from initial licensing 

assessments over the life of the plant, including the period of extended operation. Accordingly, 

the design of the plant relative to DBAs during the period of extended operation is considered to 

remain acceptable, and the environmental impacts of DBAs 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; the current licensing basis of the plant is to be maintained by the licensee under its 

current license and, therefore, under the provisions of 10 CFR Section 54.30, is not subject to 

review under license renewal.

No new and or significant information related to DBAs was identified during the review of the 

Dominion Energy Kewaunee, Inc.’s (DEK) environmental report (ER) (DEK, 2008), site audit, 

the scoping process, or evaluation of other available information. Therefore, there are no 

impacts related to these issues beyond those discussed in the GEIS.

5.2 SEVERE ACCIDENT MITIGATION ALTERNATIVES 

Regulation under 10 CFR 51.53(c) (3) (ii) (L) requires that license renewal applicants consider 

alternatives to mitigate severe accidents if the staff has not previously evaluated severe 

accident mitigation alternatives (SAMAs) for the applicant's plant in a GEIS or related 

supplement or in an environmental assessment. The purpose of this consideration is to ensure 

that plant changes (i.e., hardware, procedures, and training) with the potential for improving 

severe accident safety performance are identified and evaluated. SAMAs have not been 

previously considered for Kewaunee Power Station (KPS); therefore, the remainder of Chapter 

5 addresses those alternatives.

5.2.1 Introduction

This section presents a summary of the SAMA evaluation for KPS conducted by DEK and the 

staff’s review of that evaluation. The staff performed its review with contract assistance from 

Information Systems Laboratories. The staff’s review is available in full in Appendix F of this 

document; the SAMA evaluation is available in full in DEK’s ER.

The SAMA evaluation for KPS was conducted with a four step approach. In the first step, DEK 

quantified the level of risk associated with potential reactor accidents using the plant-specific 

probabilistic risk assessment (PRA) and other risk models.

In the second step, DEK examined the major risk contributors and identified possible ways 

(SAMAs) for reducing that risk. Common ways of reducing risk are changes to components, 

systems, procedures, and training. DEK identified 189 potential SAMAs for KPS. DEK 

performed an initial screening to determine if any SAMAs could be eliminated because they: 

(1) are not applicable at KPS due to design differences, (2) have been effectively implemented 

at KPS, (3) have estimated costs that would exceed the dollar value associated with completely 

eliminating all severe accident risk at KPS, or (4) have a very low benefit because they are 
Environmental Impacts of Postulated Accidents

August 2010 5-3 NUREG-1437, Supplement 40

associated with a non-risk-significant system. This screening reduced the list of potential 

SAMAs to 64.

In the third step, DEK estimated the benefits and the costs associated with each of the 

remaining SAMAs. Estimates were made of how much each SAMA could reduce risk. Those 

estimates were developed in terms of dollars in accordance with NRC guidance for performing 

regulatory analyses (NRC, 1997). The cost of implementing the proposed SAMAs was also 

estimated.

Finally, in the fourth step, the costs and benefits of each of the remaining SAMAs were 

compared to determine whether or not the SAMA was cost beneficial, meaning the benefits of 

the SAMA were greater than the cost (a positive cost benefit). DEK concluded in its ER that 

several of the SAMAs evaluated are potentially cost-beneficial (DEK, 2008). However, in 

response to staff inquiries regarding estimated benefits for certain SAMAs and lower cost 

alternatives, several additional potentially cost-beneficial SAMAs were identified (DEK, 2009).

The potentially cost-beneficial SAMAs 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 pursuant to 10 CFR Part 54. DEK’s SAMA analyses and the staff’s review are 

discussed in more detail below.

5.2.2 Estimate of Risk

DEK submitted an assessment of SAMAs for KPS as part of the ER (DEK, 2008). This 

assessment was based on the most recent KPS 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 KPS individual plant examination 

(IPE) (WPSC, 1992) and individual plant examination of external events (IPEEE) 

(WPSC, 1994).

For the purpose of the SAMA evaluation, the baseline core damage frequency (CDF) is 

approximately 7.7 x 10-5 per year. The CDF value is based on the risk assessment for internally 

initiated events. DEK did not include the contributions from external events within the KPS risk 

estimates; however, it did account for the potential risk reduction benefits associated with 

external events by increasing the estimated benefits for internal events by a factor of two. The 

breakdown of CDF by initiating event is provided in Table 5-2 that follows.
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NUREG-1437, Supplement 40 5-4 August 2010

Table 5-2. Kewaunee Power Station Internal Events Core Damage Frequency

Initiating Event CDF

(Per Year)

% Contribution to 

CDF

Internal floods 4.5 x 10-5 58

Transient with main feedwater available 6.5 x 10-6 8

Loss of component cooling water 6.0 x 10-6 8

Steam generator tube rupture (SGTR) 4.7 x 10-6 6

Loss of offsite power 3.9 x 10-6 5

Stuck open pressurizer power-operated relief value (PORV) 2.0 x 10-6 3

Loss of service water 1.9 x 10-6 3

Loss of main feedwater 1.6 x 10-6 2

Small loss-of-coolant accident (LOCA) 1.2 x 10-6 2

Vessel failure 9.5 x 10-7 1

Loss of instrument air 8.0 x 10-7 1

All others 2.5 x 10-6 3

Total CDF (internal events) 7.7 x 10-5 100

As shown in this table, events initiated by internal flooding are the dominant contributors to 

CDF.

DEK estimated the dose to the population within 50 miles (80 km) of the KPS site to be 

approximately 0.302 person-sievert (Sv) (30.2 person-rem) per year. The breakdown of the total 

population dose by containment release mode is summarized in Table 5-3. Containment bypass 

events (such as transients with an induced SGTR or SGTR-initiated accidents with a stuck open 

safety relief valve on the ruptured steam generator) and late containment failures without 

containment spray dominate the population dose risk at KPS.

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

Containment Release Mode

Population Dose 

(Person-Rem(a)

Per Year)

% Contribution

Late containment failure without containment sprays 8.6 29

Interfacing-systems loss-of-coolant accident (ISLOCA) with 

scrubbing 0.2 <1

ISLOCA without scrubbing 0.9 3

SGTR with failure of secondary side isolation 19.5 64

SGTR with successful secondary side isolation 0.9 3

Other 0.1 1

Total 30.2 100

(a) One person-rem = 0.01 person-Sv

The staff has reviewed DEK’s data and evaluation methods and concludes that the quality of the 

risk analyses is adequate to support an assessment of the risk reduction potential for candidate 
Environmental Impacts of Postulated Accidents

August 2010 5-5 NUREG-1437, Supplement 40

SAMAs. Accordingly, the staff based its assessment of offsite risk on the CDFs and offsite 

doses reported by DEK.

5.2.3 Potential Plant Improvements

Once the dominant contributors to plant risk were identified, DEK searched for ways to reduce 

that risk. In identifying and evaluating potential SAMAs, DEK considered insights from the 

plant-specific PRA and SAMA analyses performed for other operating plants that have 

submitted license renewal applications. DEK identified 189 potential risk-reducing improvements 

(SAMAs) to plant components, systems, procedures, and training. A detailed cost-benefit 

analysis was performed for each of the SAMAs.

DEK removed all but 64 of the SAMAs from further consideration because they are not 

applicable at KPS due to design differences, have already been effectively implemented at KPS, 

have estimated costs that would exceed the dollar value associated with completely eliminating 

all severe accident risk at KPS, or have a very low benefit because they are associated with a 

non-risk-significant system. A detailed cost-benefit analysis was performed for each of the 

remaining SAMAs.

The staff concludes that DEK used a systematic and comprehensive process for identifying 

potential plant improvements for KPS, and the set of potential plant improvements identified by 

DEK is reasonably comprehensive and, therefore, acceptable.

5.2.4 Evaluation of Risk Reduction and Costs of Improvements

DEK evaluated the risk reduction potential of the remaining 64 SAMAs. The SAMA evaluations 

were performed using generally conservative assumptions.

DEK estimated the costs of implementing the candidate SAMAs through the application of 

engineering judgment, the use of other licensee’s estimates for similar improvements, and the 

use of KPS actual experience for similar improvements. The cost estimates conservatively did 

not include the cost of replacement power during extended outages required to implement the 

modifications nor did they include contingency costs associated with unforeseen implementation 

obstacles.

The staff reviewed DEK’s bases for calculating the risk reduction for the various plant 

improvements and concludes that the rationale and assumptions for estimating risk reduction 

are reasonable and generally conservative (i.e., the estimated risk reduction is higher than what 

would actually be realized). Accordingly, the staff based its estimates of averted risk for the 

various SAMAs on DEK’s risk reduction estimates.

The staff reviewed the bases for the applicant’s cost estimates. For certain improvements, the 

staff also compared the cost estimates to estimates developed elsewhere for similar 

improvements, including estimates developed as part of other licensees’ analyses of SAMAs for 

operating reactors and advanced light-water 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 the risk reduction and the cost estimates provided by DEK are sufficient 

and appropriate for use in the SAMA evaluation.
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NUREG-1437, Supplement 40 5-6 August 2010

5.2.5 Cost Benefit Comparison

The cost benefit analysis performed by DEK was based primarily on NUREG/BR-0184, 

Regulatory Analysis Technical Evaluation Handbook (NRC, 1997) and was executed consistent 

with this guidance. NUREG/BR-0058, Regulatory Analysis Guidelines of the U.S. Nuclear 

Regulatory Commission, has been revised to reflect the agency’s revised policy on discount 

rates. Revision 4 of NUREG/BR-0058 states that two sets of estimates should be 

developed─one at three percent and one at seven percent (NRC, 2004). DEK provided both 

sets of estimates (DEK, 2008).

DEK identified 14 potentially cost-beneficial SAMAs in the ER’s baseline analysis:

● SAMA 66 - Install a new feedwater source. (The evaluated SAMA actually 

involved proceduralizing use of existing water sources.)

● SAMA 80 - Add redundant ventilation systems. (The evaluated SAMA actually 

involved staging temporary equipment and providing procedures and power 

source connections.)

● SAMA 82, 83, 170, 171 - Add switchgear room ventilation response. (The 

evaluated SAMA actually involved staging backup fans in switchgear rooms, 

adding switchgear room high temperature alarm, staging temporary fans and 

ducts along with power cords for safeguards alley room cooling, and providing 

high temperature alarms for the safeguards alley.)

● SAMA 169 - Provide flood protection for MCC-52E, -62E, and -62H.

● SAMA 172 - Provide an additional alarm for extremely low condensate storage 

tank level.

● SAMA 173 - Protect auxiliary building mezzanine cooling units from spray.

● SAMA 174 - Protect boric acid transfer pumps from spray.

● SAMA 175 - Protect a-train component cooling water pump from spray.

● SAMA 176 - Install larger sump pumps in safeguards alley.

● SAMA 177 - Install watertight barrier between 480 VAC switchgear rooms.

● SAMA 181 - Install break-away mechanisms on emergency diesel generator 

(EDG) room doors.

DEK performed additional analyses to evaluate the impact of parameter choices and 

uncertainties on the results of the SAMA assessment (DEK, 2008). Based on this, DEK 

concluded that no additional SAMAs would be cost beneficial even at the 95 percentile risk 

values.

DEK also considered the impact of simultaneous implementation of several of the SAMAs from 

both a benefit and a cost standpoint. DEK concluded that while the simultaneous 

implementation of several SAMAs would not increase the total benefit beyond that for each 
Environmental Impacts of Postulated Accidents

August 2010 5-7 NUREG-1437, Supplement 40

SAMA individually, the implementation cost could be reduced. Based on the evaluation of 

similar SAMAs involving improvements in room cooling and ventilation, DEK concluded that the 

following three additional SAMAs involving diesel room cooling improvements would be cost 

beneficial:

● SAMA 81 - Add an EDG room high temperature alarm or redundant louver and 

thermostat

● SAMA 166 - Open doors for alternate diesel generator room cooling

● SAMA 167 - Proceduralize actions to open EDG room doors on loss of heating, 

ventilation, and air conditioning (HVAC) and implement portable fans

Finally, DEK reviewed the analysis of the K107Aa PRA, prepared subsequent to the SAMA 

evaluation documented in the ER, and found one new contributor to risk that could be impacted 

by a candidate SAMA. DEK concluded that a new SAMA addressing this contributor, loss of 

screenhouse ventilation, could be cost-effectively combined with similar SAMAs 81, 82, 83, 160, 

166, 167, 170, and 171.

● Implementation of temporary screenhouse ventilation, including installing 

additional temperature detectors

DEK committed to further review these SAMAs for implementation as part of DEK’s ongoing 

performance improvement program (DEK, 2008), (DEK, 2009).

The staff concludes that, with the exception of the potentially cost-beneficial SAMAs discussed 

above, the costs of the SAMAs evaluated would be higher than the associated benefits.

5.2.6 Conclusions

The staff reviewed DEK’s analysis and concluded that the methods used and the 

implementation of those methods is sound. The treatment of SAMA benefits and costs support 

the general conclusion that the SAMA evaluations performed by DEK are reasonable and 

sufficient for the license renewal submittal.

Based on its review of the SAMA analysis, the staff concurs with DEK’s identification of areas in 

which risk can be further reduced in a cost-beneficial manner through the implementation of all 

or a subset of potentially cost-beneficial SAMAs. Given the potential for cost-beneficial risk 

reduction, the staff considers that further evaluation of these SAMAs by DEK is warranted. 

However, none of the potentially cost-beneficial SAMAs 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 pursuant to 10 CFR Part 54.

5.3 REFERENCES

10 CFR 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

Production and Utilization Facilities.”

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

Regulations for Domestic Licensing and Related Regulatory Functions.”
Environmental Impacts of Postulated Accidents

NUREG-1437, Supplement 40 5-8 August 2010

10 CFR 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for Renewal 

of Operating Licenses for Nuclear Power Plants.”

10 CFR 100. Code of Federal Regulations, Title 10, Energy, Part 100, “Reactor Site Criteria.”

Dominion Energy Kewaunee, Inc. (DEK). 2008. “Kewaunee Power Station, Licensee’s 

Environmental Report Operating License Renewal Stage,” August, 2008. Agencywide 

Documents Access and Management System (ADAMS) Accession No. ML082341039.

Dominion Energy Kewaunee, Inc. (DEK). 2009. Letter from Leslie N. Hartz, Dominion, to U.S. 

Nuclear Regulatory Commission Document Control Desk. Subject: Kewaunee Power Station, 

Response to Request Additional Information Regarding Severe Accident Mitigation Alternative 

for Kewaunee Power Station License Renewal Application, March 9, 2009. ADAMS Accession 

No. ML090690458.

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2, Washington, D.C. 

ADAMS Accession Nos. ML040690705 and ML040690738.

U.S. Nuclear Regulatory Commission (NRC). 1997. Regulatory Analysis Technical Evaluation 

Handbook, NUREG/BR-0184, Washington, D.C., January 1997.

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1, 

Summary of findings on NEPA issues for license renewal of nuclear power plants,” 

NUREG-1437, Volume 1, Addendum 1, Washington, D.C. ADAMS Accession No.

ML040690720.

U.S. Nuclear Regulatory Commission (NRC). 2004. Regulatory Analysis Guidelines of the U.S. 

Nuclear Regulatory Commission, NUREG/BR-0058, Revision 4, Washington, D.C., September 

2004.

Wisconsin Public Service Corporation (WPSC). 1992. Letter from C. R. Steinhardt, WPSC to 

U.S. Nuclear Regulatory Commission Document Control Desk. Subject: Docket No. 50-305, 

Operating License No. DPR-43, Kewaunee Nuclear Power Plant, Response to Generic Letter 

88-20, Individual Plant Examination, December 1, 1992. ADAMS Accession No. ML080170462.

Wisconsin Public Service Corporation (WPSC). 1994. Letter from C. R. Steinhardt, WPSC to 

U.S. Nuclear Regulatory Commission Document Control Desk. Subject: Docket No. 50-305, 

Operating License No. DPR-43, Kewaunee Nuclear Power Plant, Response to Generic Letter 

88-20, Supplement 4. Individual Plant Examination of External Events, June 28, 1994. ADAMS 

Accession No. ML080170459.
August 2010 6-1 NUREG-1437, Supplement 40

6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE, 

SOLID WASTE MANAGEMENT, AND GREENHOUSE GAS EMISSIONS

6.1 THE URANIUM FUEL CYCLE AND SOLID WASTE MANAGEMENT

This section addresses issues related to the uranium fuel cycle and solid waste management 

during the period of extended operation. 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 

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437 

(NRC, 1996), (NRC, 1999) details the potential generic impacts of the radiological and 

nonradiological environmental impacts of the uranium fuel cycle and transportation of nuclear 

fuel and wastes, as listed in Table 6-1 below. The GEIS is based, in part, on the generic impacts 

provided in Table S-3, “Table of Uranium Fuel Cycle Environmental Data,” in Title 10 of the 

Code of Federal Regulations (CFR), Section 51.51(b), and in Table S-4, “Environmental Impact 

of Transportation of Fuel and Waste to and from One Light-Water-Cooled Nuclear Power 

Reactor,” in 10 CFR 51.52(c). The GEIS also addresses the impacts from radon-222 and 

technetium-99.

The staff of the U.S. Nuclear Regulatory Commission (NRC) did not identify any new and 

significant information related to the uranium fuel cycle during the review of the Dominion 

Energy Kewaunee, Inc. (DEK) environmental report (ER) (DEK, 2008), the site audit, 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

designated as SMALL, except for the collective offsite radiological impacts from the fuel cycle 

and from high-level waste and spent fuel disposal.
Environmental Impacts of the Uranium Fuel Cycle

NUREG-1437, Supplement 40 6-2 August 2010

Table 6-1. Issues Related to the Uranium Fuel Cycle and Solid Waste Management Nine 

generic issues are related to the fuel cycle and solid waste management. There are no 

site-specific issues.

Issue GEIS Section 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
Environmental Impacts of the Uranium Fuel Cycle

August 2010 6-3 NUREG-1437, Supplement 40

6.2 GREENHOUSE GAS EMISSIONS

This section provides a discussion of potential impacts from greenhouse gases (GHGs) emitted 

during the nuclear 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 implemented. 

6.2.1 Existing Studies

Since the development of the GEIS, the relative volumes of GHGs emitted by nuclear and other 

electricity generating methods have been widely studied. However, estimates and projections of 

the carbon footprint of the nuclear power life cycle vary depending on the type of study 

conducted. Additionally, considerable debate also exists among researchers regarding the 

relative impacts of nuclear and other forms of electricity generation on GHG emissions. Existing 

studies on GHG emissions from nuclear power plants generally take two different 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 nuclear 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, large-scale public policy or investment 

evaluations of whether an expansion of nuclear power is likely to be a technically, economically, 

and/or politically feasible means of achieving global GHG reductions. Examples of the studies 

identified by the staff during the subsequent literature search include:

● evaluations to determine whether 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 Protocols 

(Schneider, 2000), (IAEA, 2000), (NEA, 2002). Ultimately, the parties to the 

Kyoto Protocol did not approve nuclear power as a component under the Clean 

Development Mechanism (CDM) due to safety and waste disposal concerns 

(NEA, 2002).

● analyses developed to assist governments, including the United States, in 

making long-term investment and public policy decisions in nuclear power 

(Keepin, 1988), (Hagen et al., 2001), (MIT, 2003). 

Although the qualitative studies sometimes reference and critique the existing quantitative 

estimates of GHGs produced by the nuclear fuel cycle or 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 are typically 

not directly applicable to an evaluation of GHG emissions associated with the proposed license 

renewal for a given nuclear power plant.
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NUREG-1437, Supplement 40 6-4 August 2010

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 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 (2005), Fritsche (2006), Parliamentary Office of Science 

and Technology (POST) (2006), Atomic Energy Authority Technology (AEA) (2006), Weisser 

(2006), Fthenakis and Kim (2007), and Dones (2007).

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:

● energy sources that may be used to mine uranium deposits in the future

● reprocessing or disposal of spent nuclear fuel

● 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

equivalents per unit of electric energy produced

● performance of future fossil fuel power systems

● projected capacity factors for alternative means of generation

● 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 (i.e., 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 the case of license renewal, a GHG analysis for that portion of the plant’s life cycle (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. In 

addition, the proposed action of license renewal would also not involve additional GHG 

emissions associated with facility decommissioning because that decommissioning must occur 

whether the facility is relicensed or not. However, in some of the aforementioned studies, the 

specific contribution of GHG emissions from construction, decommissioning, or other portions of 

a 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 

plant’s life cycle. Nonetheless, these studies provide 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.
Environmental Impacts of the Uranium Fuel Cycle

August 2010 6-5 NUREG-1437, Supplement 40

In Tables 6-2, 6-3, and 6-4, the staff presents the results of the aforementioned quantitative 

studies to provide 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) 

onward suggest that uranium ore grades and uranium enrichment processes are leading 

determinants in the ultimate GHG emissions attributable to nuclear power generation. These 

studies indicate 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.

6.2.1.3 Summary of Nuclear Greenhouse Gas Emissions Compared to Coal

Considering that coal fuels the largest share of electricity generation in the United States and 

that its burning results in the largest emissions of GHGs for any of the likely alternatives to 

nuclear power generation, including Kewaunee Power Station (KPS), most of the available 

quantitative studies focused on comparisons of the relative GHG emissions of nuclear to 

coal-fired generation. The quantitative estimates of the GHG emissions associated with the 

nuclear fuel cycle (and, in some cases, the nuclear life cycle), as compared to an equivalent 

coal-fired plant, are presented in Table 6-2. The following chart does not include all existing 

studies but provides an illustrative range of estimates developed by various researchers.

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 to increase because of declining ore grade.

Andseta et al. (1998) Nuclear energy produces 1.4 percent of the GHG emissions compared to coal.

Note: Future reprocessing and use of nuclear-generated electrical power in the mining 

and enrichment steps are likely to change the projections of earlier authors, such as 

Mortimer (1990).

Spadaro et al. (2000) Nuclear—2.5 to 5.7 g Ceq/kWh 

Coal—264 to 357 g Ceq/kWh

Storm van Leeuwen and 

Smith (2005)

Authors did not evaluate nuclear versus coal.

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—>1000 g Ceq/kWh

Note: Decrease of uranium ore grade to 0.03 percent 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 percent.

Weisser (2006) 

(Compilation of results 

from other studies)

Nuclear—2.8 to 24 g Ceq/kWh

Coal—950 to 1250 g Ceq/kWh

Fthenakis and Kim 

(2007)

Authors did not evaluate nuclear versus coal.

Dones (2007) Author did not evaluate nuclear versus coal.
Environmental Impacts of the Uranium Fuel Cycle

NUREG-1437, Supplement 40 6-6 August 2010

6.2.1.4 Summary of Nuclear Greenhouse Gas Emissions Compared to Natural Gas

The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle (and, in 

some cases, the nuclear life cycle), as compared to an equivalent natural gas-fired plant, are

presented in Table 6-3. The following chart does not include all existing studies but provides an 

illustrative range of estimates developed by various researchers.

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

Source GHG Emission Results

Mortimer (1990) Author did not evaluate nuclear versus natural gas.

Andseta et al. (1998) Author did not evaluate nuclear versus natural gas.

Spadaro et al. (2000) Nuclear—2.5 to 5.7 g Ceq/kWh 

Natural Gas—120 to 188 g Ceq/kWh

Storm van Leeuwen 

and Smith (2005)

Nuclear fuel cycle produces 20 to 33 percent of the GHG emissions compared to 

natural gas (at high ore grades).

Note: Future nuclear GHG emissions 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 percent 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 percent.

Weisser (2006) 

(Compilation of results 

from other studies)

Nuclear—2.8 to 24 g Ceq/kWh

Natural Gas—440 to 780 g Ceq/kWh

Fthenakis and Kim 

(2007)

Authors did not evaluate nuclear versus natural gas.

Dones (2007) Author critiqued methods and assumptions of Storm van Leeuwen and Smith (2005) 

and concluded that the nuclear fuel cycle produces 15 to 27 percent of the GHG 

emissions of natural gas.

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 nuclear fuel 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 due to their different 

sources and locations. For example, the efficiency of solar and wind energy is highly dependent 

on the location in which the power generation facility is installed. 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 

chart does not include all existing studies but provides an illustrative range of estimates 

developed by various researchers.
Environmental Impacts of the Uranium Fuel Cycle

August 2010 6-7 NUREG-1437, Supplement 40

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

Source GHG Emission Results

Mortimer (1990) Nuclear—230,000 tons CO2

Hydroelectric—78,000 tons CO2

Wind power—54,000 tons CO2

Tidal power—52,500 tons CO2

Note: Future GHG emissions from nuclear to increase because of declining ore grade.

Andseta et al. (1998) Author did not evaluate nuclear versus renewable energy sources.

Spadaro et al. (2000) Nuclear—2.5 to 5.7 g Ceq/kWh 

Solar photovoltaic (PV)—27.3 to 76.4 g Ceq/kWh

Hydroelectric—1.1 to 64.6 g Ceq/kWh

Biomass—8.4 to 16.6 g Ceq/kWh

Wind—2.5 to 13.1 g Ceq/kWh

Storm van Leeuwen 

and Smith (2005)

Author did not evaluate nuclear versus renewable energy sources.

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 to 93 g Ceq/kWh

Solar PV—35 to 58 g Ceq/kWh

Wave/Tidal—25 to 50 g Ceq/kWh

Hydroelectric—5 to 30 g Ceq/kWh

Wind—4.64 to 5.25 g Ceq/kWh

Note: Decrease of uranium ore grade to 0.03 percent would raise nuclear to 

6.8 g Ceq/kWh. 

Weisser (2006) 

(Compilation of results 

from other studies)

Nuclear—2.8 to 24 g Ceq/kWh 

Solar PV—43 to 73 g Ceq/kWh

Hydroelectric—1 to 34 g Ceq/kWh

Biomass—35 to 99 g Ceq/kWh

Wind—8 to 30 g Ceq/kWh

Fthenakis and Kim 

(2007)

Nuclear—16 to 55 g Ceq/kWh 

Solar PV—17 to 49 g Ceq/kWh

Dones (2007) Author did not evaluate nuclear versus renewable energy sources.

6.2.2 Conclusions: Relative Greenhouse Gas Emissions

The sampling of data presented in Tables 6-2, 6-3, and 6-4 above demonstrates the challenges 

of any attempt to determine the specific amount of GHG emission attributable to nuclear energy 

production sources, as different assumptions and calculation methodology will yield differing 

results. The 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.
Environmental Impacts of the Uranium Fuel Cycle

NUREG-1437, Supplement 40 6-8 August 2010

First, the various studies indicate a general consensus that nuclear power currently produces 

fewer GHG emissions than fossil-fuel-based electrical generation, e.g., the GHG emissions from 

a complete nuclear fuel cycle currently range from 2.5 to 55 g Ceq/kWh, as compared to the use 

of coal plants (264 to 1,250 g Ceq/kWh) and natural gas plants (120 to 780 g Ceq/kWh). The 

studies also provide estimates of GHG emissions from five renewable energy sources based on 

current technology. These estimates included solar-photovoltaic (17 to 125 g Ceq/kWh), 

hydroelectric (1 to 64.6 g Ceq/kWh), biomass (8.4 to 99 g Ceq/kWh), wind (2.5 to 30 g Ceq/kWh), 

and tidal (25 to 50 g Ceq/kWh). The range of these estimates is wide, but the general conclusion 

is that current GHG emissions from the nuclear fuel cycle are of the same order of magnitude as 

from these renewable energy sources.

Second, the studies indicate no consensus on future relative GHG emissions from nuclear 

power and other sources of electricity. There is substantial disagreement among the various 

authors regarding the GHG emissions associated with declining uranium ore concentrations, 

future uranium enrichment methods, and other factors, including changes in technology. Similar 

disagreement exists regarding future GHG emissions associated with coal and natural gas for 

electricity generation. Even the most conservative studies conclude that the nuclear fuel cycle 

currently produces fewer GHG emissions than fossil-fuel-based sources 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 fuel cycle exceed those of 

fossil-fuel-based sources) or whether cross-over will occur at all. 

Considering the current estimates and future uncertainties, it appears that GHG emissions 

associated with the proposed KPS relicensing action are likely to be lower than those 

associated with fossil-fuel-based energy sources. The staff based this conclusion on the

following rationale:

(1) As shown in Tables 6-2 and 6-3, the current estimates of GHG emissions from the 

nuclear fuel cycle are far below those for fossil-fuel-based energy sources.

(2) KPS license renewal will involve continued GHG emissions due to uranium mining, 

processing, and enrichment but 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).

(3) Few studies predict that nuclear fuel cycle emissions will exceed those of fossil fuels 

within a timeframe that includes the KPS 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 timeframe.

In comparing GHG emissions among the proposed KPS license renewal action and renewable 

energy sources, it appears likely that there will be future technology improvements and changes 

in mining, processing, and constructing facilities of all types. Currently, the GHG emissions 

associated with the nuclear fuel cycle and renewable energy sources are within the same order 

of magnitude. Because nuclear fuel production is the most significant contributor to possible 

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 

would be lower than those associated with KPS at some point during the period of extended 

operation. 
Environmental Impacts of the Uranium Fuel Cycle

August 2010 6-9 NUREG-1437, Supplement 40

The staff provides an additional discussion about the contribution of GHGs to cumulative air 

quality impacts in Section 4.11.5 of this SEIS. 

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.”

AEA Technology (AEA). 2006. “Carbon Footprint of the Nuclear Fuel Cycle, Briefing Note,”

Prepared for British Energy, March 2006.

Andseta et al. 1998. “CANDU Reactors and Greenhouse Gas Emissions,” Canadian Nuclear 

Association, 11th Pacific Basin Nuclear Conference, Banff, Alberta, Canada, May 1998.

Dominium Energy Kewaunee (DEK). 2008. “Kewaunee Power Station, Applicant’s 

Environmental Report, Operating License Renewal Stage,” Glen Allen, VA. Agencywide 

Documents Access and Management System (ADAMS) Accession Nos. ML082341020, 

ML082341038, and ML082341039.

Dones, R. 2007. “Critical Note on the Estimation by Storm Van Leeuwen J.W., and Smith P. of 

the Energy Uses and Corresponding CO2 Emissions for the Complete Nuclear Energy Chain,”

Paul Sherer Institute, April 2007.

Fritsche, U.R. 2006. “Comparison of Greenhouse-Gas Emissions and Abatement Cost of 

Nuclear and Alternative Energy Options from a Life-Cycle Perspective,” Oko-Institut, Darmstadt 

Office, January 2006.

Fthenakis, V.M. and H.C. Kim. 2007. “Greenhouse-gas emissions from solar-electric and 

nuclear power: A life cycle study,” Energy Policy, Volume 35, Number 4.

Hagen, R.E., J.R. Moens, and Z.D. Nikodem. 2001. “Impact of U.S. Nuclear Generation on 

Greenhouse Gas Emissions.” International Atomic Energy Agency, Vienna, Austria. November 

2001.

International Atomic Energy Agency (IAEA). 2000. “Nuclear Power for Greenhouse Gas 

Mitigation under the Kyoto Protocol: The Clean Development Mechanism (CDM),” November

2000.

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, United States House of Representatives. 

June 1988. 

Massachusetts Institute of Technology (MIT). 2003. “The Future of Nuclear Power: An 

Interdisciplinary MIT Study.”

Mortimer, N. 1990. “World Warms to Nuclear Power,” SCRAM Safe Energy Journal, December 

1989 and January 1990. Available URL:

http://www.no2nuclearpower.org.uk/articles/mortimer_se74.php

Organization for Economic Co-Operation and Development, Nuclear Energy Agency (NEA).

2002. Nuclear Energy and the Kyoto Protocol.

(accessed February 29, 2007).

Parliamentary Office of Science and Technology (POST). 2006. “Carbon Footprint of Electricity 

Generation,” Postnote, Number 268, October 2006.
Environmental Impacts of the Uranium Fuel Cycle

NUREG-1437, Supplement 40 6-10 August 2010

Schneider, M. 2000. Climate Change and Nuclear Power, World Wildlife Fund for Nature, April 

2000.

Spadaro, J.V., L. Langlois, and B. Hamilton. 2000. “Greenhouse Gas Emissions of Electricity 

Generation Chains: Assessing the Difference,” IAEA Bulletin 42/2/2000, Vienna, Austria.

Storm van Leeuwen, J.W. and P. Smith 2005. Nuclear Power—The Energy Balance, August 

2005.

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2, Washington, D.C, 

1996. ADAMS Accession Nos. ML040690705 and ML040690738.

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1, 

Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final 

Report,” NUREG-1437, Volume 1, Addendum 1, Washington, D.C. ADAMS Accession No.

ML040690720.

Weisser, D. 2006. “A Guide to Life-Cycle Greenhouse Gas (GHG) Emissions from Electric 

Supply Technologies.” Available URL: 

http://www.iaea.org/OurWork/ST/NE/Pess/assets/GHG_manuscript_preprint_versionDanielWeisser.pdf (accessed May 19, 2009).
August 2010 7-1 NUREG-1437, Supplement 40

7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING

Decommissioning is defined as the safe removal of a nuclear facility from service and the 

reduction of residual radioactivity to a level that permits release of the property for unrestricted 

use and termination of the license. The U.S. Nuclear Regulatory Commission (NRC) issued a 

generic environmental impact statement (GEIS) for decommissioning (NRC, 2002) that 

evaluated environmental impacts from the activities associated with the decommissioning of any 

reactor before or at the end of an initial or renewed license.

The staff did not identify any new and significant information during the review of the Dominion 

Energy Kewaunee, Inc. (DEK) environmental report (DEK, 2008), the site audit, or the scoping 

process. Therefore, there are no impacts related to these issues beyond those discussed in the 

GEISs (NRC, 1996), (NRC, 1999), (NRC, 2002). For all of these issues, the GEISs concluded 

that the impacts are SMALL.

Table 7-1. Issues Related to Decommissioning. Decommissioning would occur regardless if 

Kewaunee Power Station (KPS) is 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.

Issue 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

7.1 REFERENCES

Dominium Energy Kewaunee, Inc. (DEK). 2008. “Kewaunee Power Station, Applicant’s 

Environmental Report, Operating License Renewal Stage,” Glen Allen, VA. Agency-wide

Documents Access and Management System (ADAMS) Accession Nos. ML082341020, 

ML082341038, and ML082341039.

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2, Washington, D.C. 

ADAMS Accession Nos. ML040690705 and ML040690738.

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1, 

Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final 

Report,” NUREG-1437, Volume 1, Addendum 1, Washington, D.C. ADAMS Accession No. 

ML040690720.

U.S. Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement 

for Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of 

Nuclear Power Reactors, NUREG-0586, Supplement 1, Washington, D.C. ADAMS Accession 

Nos. ML023500228 and ML023500412.
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August 2010 8-1 NUREG-1437, Supplement 40

8.0 

The National Environmental Policy Act of 1969 (NEPA) mandates that each environmental 

impact statement (EIS) consider alternatives to any proposed major Federal action. U.S. 

Nuclear Regulatory Commission (NRC) regulations implementing NEPA for license renewal 

require that a supplemental environmental impact statement (SEIS) considers and weighs the 

environmental effects of the proposed action [license renewal]; the environmental impacts of 

alternatives to the proposed action; and alternatives available for reducing or avoiding adverse 

environmental impacts, per Title 10 of the Code of Federal Regulations (CFR) Section 51.71(d) 

(10 CFR 51.71(d)). In this case, the proposed Federal action is issuing a renewed license for

Kewaunee Power Station (KPS), which will allow the plant to operate for 20 years beyond its 

current license expiration date.

ENVIRONMENTAL IMPACTS OF ALTERNATIVES

In this chapter, the staff examines the potential environmental impacts of alternatives to issuing 

a renewed operating license for KPS.

While the Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear 

Plants, NUREG-1437 (NRC, 1996), (NRC, 1999), 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. Therefore, 

the staff must evaluate environmental impacts of alternatives on a site-specific basis.

In accordance with the GEIS, alternatives to the proposed action of issuing a renewed KPS 

operating license must meet the purpose and need for issuing a renewed license; 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) decision 

makers (10 CFR 51.71(f)).

The staff ultimately makes no decision regarding whether an alternative or the proposed action 

is implemented since that decision falls to utility, State, or other Federal officials. Comparing the 

environmental effects of these alternatives will assist the staff in deciding whether the 

environmental impacts of license renewal are so great that preserving the option of license 

renewal for energy-planning decision makers would be unreasonable (10 CFR 51.95(c)(4)). If 

the NRC acts to issue a renewed license, 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 decision makers may no longer elect to 

continue operating KPS and will have to resort to another alternative, which may or may not be 

one of the alternatives the staff considers in this section in order to meet their energy needs.

In addition to evaluating alternatives to the proposed action, when appropriate, the staff also 

examines alternatives that may reduce or avoid environmental impacts of the proposed action; 

the staff does so to illustrate how such alternatives may act to mitigate potential impacts of 

license renewal.

In evaluating alternatives to license renewal, the 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 KPS

operating license expires. Given that only 3 years remain before the KPS license expires, the 

options the staff considers in this section are generally commercially available today.
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NUREG-1437, Supplement 40 8-2 August 2010

In-Depth 

Alternatives:

• Natural gas-fired 

combined-cycle

• Coal-fired alternative

• Combination including 

gas-fired, conservation, 

and wind (Combination 

Option 1) or wood-fired 

(Combination Option 2)

Other Alternatives 

Considered:

• Wind power

• Wood-fired

• Conservation

• Solar power

• Conventional 

hydroelectric power

• Geothermal power

• Biofuels

• New nuclear

• Oil-fired power

• Fuel cells

• Municipal solid waste

• Delayed retirement

Second, the staff screens the alternatives to remove 

those that cannot meet future system needs. Then, the 

staff screens the remaining options to remove those for 

which the cost or benefits do not justify inclusion in the 

range of reasonable alternatives. Any alternatives 

remaining constitute alternatives to the proposed action 

that the staff evaluates in-depth throughout this section. 

In Section 8.5, the staff briefly addresses each alternative 

that was removed during screening.

The staff initially considered 14 discrete potential 

alternatives to the proposed action and narrowed the list 

to the two single source alternatives and two combination 

alternatives considered in this chapter.

Once the staff identified the in-depth alternatives, it 

referred to generic environmental impact evaluations in 

the GEIS. The GEIS provides overviews of some energy 

technologies available at the time of its publishing in 

1996, though it does not reach any conclusions regarding 

which alternatives are most appropriate nor does it 

precisely categorize impacts for each site. Since 1996, 

many energy technologies have evolved significantly in 

capability and cost effectiveness, while regulatory 

structures have changed to either promote or impede the 

development of particular alternatives. 

Where applicable, the staff uses information in the GEIS 

and includes updated information from 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 

Dominion Energy Kewaunee, Inc. (DEK) in the KPS 

environmental report (ER). 

For each in-depth analysis, the staff analyzes environmental impacts across seven impact 

categories: air quality, groundwater use and quality, surface water use and quality, ecology, 

human health, socioeconomics, and waste management. As in earlier chapters of this SEIS, the 

staff uses the NRC’s three-level standard of significance—SMALL, MODERATE, or LARGE—to 

indicate the intensity of environmental effects for each alternative that the staff evaluates indepth.
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August 2010 8-3 NUREG-1437, Supplement 40

Energy Outlook: Each year 

the EIA, part of the DOE, 

issues its updated Annual 

Energy Outlook (AEO). AEO 

2009 indicates that natural 

gas will account for most 

new electrical capacity 

through 2030, with 

significant contributions from 

new renewable sources and 

coal, as well as some growth 

in nuclear capacity 

(EIA, 2009a)

“Natural-gas-fired plants account for 

53 percent of capacity additions in the 

reference case [2008-2030], as compared 

with 22 percent for renewables, 18 percent 

for coal-fired plants, and 5 percent for 

nuclear. Escalating construction costs have 

the largest impact on capital-intensive 

technologies, including renewables, coal, 

and nuclear [ ]; but Federal tax incentives, 

State energy programs, and rising prices 

for fossil fuels increase the 

cost-competitiveness of renewable and 

nuclear capacity. In contrast, uncertainty 

about future limits on GHG [greenhouse 

gas] emissions and other possible 

environmental regulations ... reduces the 

competitiveness of coal.” 

By placing the detailed alternatives analyses in 

this order, the staff does not imply which 

alternative would have the least impact or which 

alternative an energy planning decision maker 

would be most likely to implement. Whenever 

possible, the staff considers effects from locating 

the alternative at the existing site, as well as at 

an alternate site. In general, impacts are smaller 

at an existing site because infrastructure 

necessary to support a power plant already 

exists, nearby populations are accustomed to 

power plant operations, and the site has already 

been disturbed to some degree. 

Sections 8.1 through 8.3 include the staff’s 

analyses of environmental impacts of alternatives 

to license renewal. These include a gas-fired 

alternative located both at the KPS site and at a 

different site (8.1), a coal-fired alternative at the 

KPS site and an alternate site (8.2), and two 

combination alternatives that include gas-fired 

capacity onsite as well as conservation and either 

wind power or wood-fired power (8.3). In 

Section 8.4, the staff briefly discusses purchased 

power. In Section 8.5, the staff addresses 

alternatives excluded from in-depth analysis and 

addresses why they were excluded. Finally, in 

Section 8.6, the staff considers the environmental 

effects that may occur if the NRC takes no action 

and does not issue renewed licenses for KPS.

8.1 GAS-FIRED GENERATION

In this section, the staff evaluates the environmental impacts of natural gas-fired generation at 

both the KPS site and at an alternate site. 

Natural gas fueled 21 percent of electric generation in the United States in 2008, accounting for 

the second greatest share of electrical power after coal (EIA, 2009b). Like coal-fired power 

plants, natural gas-fired plants may be affected by perceived or actual action to limit greenhouse 

gas (GHGs) emissions, though they produce markedly fewer GHGs per unit of electrical output 

than coal-fired plants. Natural gas-fired power plants are feasible, commercially available

options for providing electrical generating capacity beyond the current license terms for KPS. 

EIA projects that gas-fired generation will account for the largest share of capacity additions in 

the United States through 2030 (EIA, 2009a).

Combined-cycle power plants differ significantly from power plants that generate electricity 

solely from a steam cycle, as almost all coal-fired and all existing domestic nuclear power plants 

do. 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—through a 

second, steam-turbine cycle. The first, gas-turbine stage (similar to a large jet engine) burns 

natural gas that turns a driveshaft to power an electric generator. Ducts carry the hot exhaust 
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NUREG-1437, Supplement 40 8-4 August 2010

from the turbine to a heat recovery steam generator, which then produces steam to drive 

another turbine and produce additional electrical power. The combined-cycle approach is 

significantly more efficient than any one cycle on its own; efficiencies can reach or exceed 

60 percent. Natural gas combined-cycle generation requires significantly less cooling water and 

smaller cooling towers than the existing KPS, partly because of greater thermal efficiency and 

partly because gas turbines do not require condenser cooling, as steam turbines do. 

In order to replace the 556 megawatts-electric (MWe) output that KPS currently supplies, the 

staff selected a gas-fired alternative that uses two General Electric Company (GE) MS7001FB 

combined-cycle units, which together produce a net of 560 MWe (roughly 4 percent of gross 

plant output would power auxiliary systems, so the gross output is approximately 585 MWe). 

While any number of commercially available combined-cycle units could be installed in a variety 

of combinations to replace the power currently produced by KPS, the MS7001FB is an efficient 

model that operates at a heat rate of 5,950 British thermal units per kilowatt hour (Btu/kWh) or 

57.3 percent thermal efficiency (GE, 2007). GE and other manufacturers, like Siemens, offer 

similar high efficiency models, including several that slightly exceed the thermal efficiency of this 

model. Cooling towers for this alternative would likely be mechanical draft-type towers 

approximately 65 feet (ft) (20 meters (m)) in height.

In addition to cooling towers, other visible structures onsite would include the turbine buildings 

and heat recovery steam generators (which may be enclosed in the turbine building), two 

exhaust stacks, an electrical switchyard, and, possibly, equipment associated with a natural gas 

pipeline, like a compressor station. The GEIS estimated that a 1,000 MWe gas-fired alternative 

would require 110 acres (ac) (40 hectares (ha)), meaning this 560-MWe plant would require 

64 ac (26 ha). In their ER, DEK (2008) indicated that the plant would require 26 ac (11 ha), a 

number more consistent with minimum utility needs as demonstrated by existing power plants 

(including Dominion Resources’ Fairless Energy Works located in Falls Township, PA). The 

staff uses DEK’s estimate for the purposes of the following analysis. According to DEK, a 

gas-fired plant constructed onsite would also require 272 ac (110 ha) for a natural gas pipeline. 

A gas-fired plant constructed at an alternate site would likely require a new pipeline spur, as 

well. For the purpose of this analysis, the staff assumes that a gas-fired alternative at an 

alternate site would require a similar amount of land for a pipeline and associated right-of-way 

(ROW). 

This 560-MWe power plant would consume 25.3 billion cubic feet (ft3

) (718 million cubic meters 

(m3

)) of natural gas annually, assuming an average heat content of 1,021 British thermal units 

per cubic feet (Btu/ft3

) (EIA, 2008). Natural gas would be extracted from the ground through 

wells in another region of the United States, then treated to remove impurities (like hydrogen 

sulfide), and blended to meet pipeline gas standards, before being piped through the interstate 

pipeline system to the power plant site. This gas-fired alternative would produce relatively little 

waste, which would primarily be in the form of spent catalysts used for emissions controls. 

Environmental impacts from the gas-fired alternative will be greatest during construction. Site 

crews will clear vegetation from the site, prepare the site surface, and begin excavation before 

other crews begin actual construction on the plant and any associated infrastructure, including a 

pipeline spur to serve the plant and electricity transmission infrastructure connecting the plant to 

existing transmission lines. 

Constructing the gas-fired alternative on the KPS site would allow the gas-fired alternative to 

make use of the site’s existing transmission system, as well as take advantage of partially 

cleared areas of the site. 
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August 2010 8-5 NUREG-1437, Supplement 40

A gas-fired unit constructed offsite may cause additional construction-related impacts depending 

on the nature of the site selected. A site that has never been developed will likely experience 

greater impacts than a site that was previously industrial; a site near other power plants or 

industrial facilities will likely experience smaller impacts than a site surrounded by farmland or 

relatively natural surroundings.

Table 8-1. Summary of Environmental Impacts of Gas-Fired Combined-Cycle Generation 

Compared to Continued Kewaunee Power Station Operation

Gas-fired combined-cycle Continued

KPS Operation At the KPS site At an alternate site

Air Quality MODERATE MODERATE SMALL

Groundwater SMALL SMALL SMALL

Surface Water SMALL SMALL to MODERATE SMALL

Ecology SMALL to MODERATE SMALL to MODERATE SMALL

Human Health SMALL SMALL SMALL

Socioeconomics SMALL to MODERATE SMALL to MODERATE SMALL

Waste Management SMALL SMALL SMALL

8.1.1 Air Quality

Kewaunee County, WI, where KPS is located, is in EPA Region 5 and is in attainment for all 

criteria pollutants, except ozone. Kewaunee County is a maintenance area for 8-hour ozone 

(EPA, 2009a).

A new gas-fired generating plant in Kewaunee County would qualify as a new major-emitting 

industrial facility and require New Source Review (NSR) and Prevention of Significant 

Deterioration of Air Quality review under the Clean Air Act (CAA), as adopted by the Wisconsin 

Department of Natural Resources (WDNR) in the Wisconsin Administrative Code and its 

statutes (EPA, 2008a), (Wis. Adm. Code, Chapters NR400-499), (Wis. Stats., Chapter 285). 

The EPA delegated the authority of regulating the issuance of construction and operating 

permits to the WDNR, which coordinates the Wisconsin air pollution control permit program for 

new and existing pollution sources. A natural gas-fired plant would also need to comply with the 

standards of performance for electric utility steam generating units set forth in 40 CFR 60 

Subpart Da. 

Section 169A of the CAA (42 U.S.C. 7401 et seq.) 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 EPA issued a regional haze rule in 1999 

(64 FR 35714). The rule specifies that for each mandatory Class I Federal area located within a 

State, the State must establish goals that provide for reasonable progress toward achieving 

natural visibility conditions through developing and implementing air quality protection plans to 

reduce the pollution that causes visibility impairment. There are five regional planning 

organizations (RPO) that are collaborating on the visibility impairment issue and developing the 

technical basis for these plans. Wisconsin, Illinois, Indiana, Michigan, and Ohio belong to the 

Midwest Regional Planning Organization (Midwest RPO) that, along with tribes, Federal 

agencies, and other interested parties, identifies regional haze and visibility issues and develops 

strategies to address them. The visibility protection regulatory requirements, contained in 

40 CFR Part 51, Subpart P, include the review of the new sources that would be constructed in
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NUREG-1437, Supplement 40 8-6 August 2010

the attainment or unclassified areas and may affect visibility in any Class I Federal area 

(40 CFR 51.307). If a coal-fired plant were located close to a mandatory Class I area, additional 

air pollution control requirements would be imposed. 

There are no mandatory Class I Federal areas in the State of Wisconsin or in close proximity to 

KPS. The closest mandatory Class I Federal areas to KPS are Seney Wilderness Area, MI, 

located 149 miles (mi) northeast from KPS, and Isle Royale National Park, MI, located 255 mi 

northwest of KPS.

The emissions from the natural gas-fired alternative at the KPS site, based on published EIA 

data, EPA emission factors (EPA, 1998), and on performance characteristics for this alternative 

and implemented emission controls, would be:

● Sulfur oxides (SOx) – 43.98 tons (39.90 Metric ton(s) (MT)) per year

● Nitrogen oxides (NOx) – 141.00 tons (127.91 MT) per year

● Carbon monoxide (CO) – 29.31 tons (26.59 MT) per year

● Total suspended particles (TSP) – 24.58 tons (22.30 MT) per year

● Particulate matter (PM) PM10 – 24.58 tons (22.30 MT) per year

● Carbon dioxide (CO2) – 1,513,164.22 tons (1,372,719.49 MT) per year

The new, natural gas-fired plant would have to comply with Title IV of the CAA reduction 

requirements for sulfur dioxide (SO2) and NOx, which are the main precursors of acid rain and a 

major cause of reduced visibility. Title IV establishes maximum SO2 and NOx emission rates for 

existing plants and a system of SO2 emission allowances that can be used, sold, or saved for 

future use by new plants. On March 10, 2005, the EPA issued the Clean Air Interstate Rule 

(CAIR), which would create large permanent reductions in SO2 and NOx across 28 eastern 

States and the District of Columbia. However, petitions for review of the CAIR and CAIR Federal 

Implementation Plans (FIPs), including the provisions establishing the CAIR NOx annual and 

ozone season and SO2 trading programs, were filed in the U.S. Court of Appeals for the D.C. 

Circuit. 

On July 11, 2008, the Court issued an opinion vacating and remanding the CAIR and CAIR 

FIPs. After requested rehearing of the Court’s decision, the Court granted rehearing only to the 

extent that it remanded the rules to the EPA without vacating them on December 23, 2008. This 

ruling leaves CAIR and the CAIR FIPs, including the CAIR trading programs, in place until the 

EPA issues a new rule to replace CAIR in accordance with the July 11, 2008, decision. 

Wisconsin is among the States covered by this rule (EPA, 2009b). WDNR adopted the rule and 

allocated annual NOx allowances for new electricity generating units subject to CAIR as 

specified in Chapter NR 432 of the Wisconsin Administrative Code in 2009. The NOx 

allowances are allocated from a “new unit set-aside” reserved pool of allowances, which 

represents 7 percent of Wisconsin’s total budget of NOx allowances. 

As stated above, the new, natural gas-fired alternative would produce 43.98 tons (39.90 MT) per 

year of SOx and 141.00 tons (127.91 MT) per year of NOx based on the use of the dry low NOx 

combustion technology and use of the selective catalytic reduction (SCR) in order to 

significantly reduce NOx emissions. 

The new plant would be subjected to the continuous monitoring requirements of SO2, NOx, and 

CO2 specified in 40 CFR Part 75. The natural gas-fired plant would emit approximately 

1,513,164.22 tons (1,372,719.49 MT) per year of unregulated CO2 emissions. As of today, there 

is no required reporting of GHG emissions. In response to the Consolidated Appropriations Act 

of 2008, the EPA proposed a rule that would require mandatory reporting of GHG emissions 
Environmental Impacts of Alternatives

August 2010 8-7 NUREG-1437, Supplement 40

from large sources, such as the presented alternative. The rule would allow for the collection of 

accurate and comprehensive emissions data to inform future policy decisions. The EPA 

proposes that suppliers of fossil fuels or industrial GHGs, manufacturers of vehicles and 

engines, and facilities that emit 25,000 MT or more per year of GHG emissions submit annual 

reports to the EPA. The gases covered by the proposed rule are CO2, methane (CH4), nitrous 

oxide (N2O), hydrofluorocarbons (HFC), perfluorocarbons (PFC), sulfur hexafluoride (SF6), and 

other fluorinated gases including nitrogen trifluoride (NF3), and hydrofluorinated ethers (HFE).

In 1993, WDNR conducted the “Wisconsin Greenhouse Gas Emissions Inventory and Emission 

Reduction Cost Study,” and, in 1998, developed the Climate Change Action Plan. The 

Wisconsin GHG emissions inventory is periodically updated. In 2007, following the signing of 

Executive Order (E.O.) 191 by the governor of Wisconsin, the Governor’s Task Force on Global 

Warming was created. The Task Force outlined its mission, goals, and recommendations in the 

2008 final report to the governor, “Wisconsin’s Strategy for Reducing Global Warming” (WDNR, 

2009).

The gas-fired alternative would emit 24.58 tons (22.30 MT) per year of PM having an 

aerodynamic diameter less than or equal to 10 micrometer (μm) (PM10) (40 CFR 50.6a). All 

emitted particulates are PM10.

In December 2000, the EPA issued regulatory findings (EPA, 2000a) on emissions of hazardous 

air pollutants from electric utility steam-generating units. Natural gas-fired power plants were 

found by the EPA to emit hazardous air pollutants, such as arsenic, formaldehyde, and nickel. 

Unlike coal and oil-fired power plants, the EPA did not determine that emissions of hazardous 

air pollutants from natural gas-fired power plants should be regulated under Section 112 of the 

CAA.

Activities associated with the construction of a new, natural gas-fired plant onsite or offsite 

would cause some additional air effects as a result of equipment emissions and fugitive dust 

from the operation of the earth moving and material handling equipment. Exhaust emissions 

from workers’ vehicles and motorized construction equipment would be temporary. Construction 

crews would employ dust-control practices in order to control and reduce fugitive dust, which 

would be temporary in nature. The staff concludes that the impact of vehicle exhaust emissions 

and fugitive dust from operation of the earth-moving and material handling equipment would be 

SMALL.

The overall air-quality impacts of a new, natural gas-fired plant located at the KPS site or at an 

alternate site would be MODERATE, primarily due to emissions released during plant operation.

8.1.2 Groundwater Use and Quality

The use of groundwater for a natural gas-fired combined-cycle plant (onsite or offsite) would 

likely be limited to supply wells for drinking water and possibly filtered service water for system 

cleaning purposes. For an onsite alternative, total usage would likely be much less than KPS 

because fewer workers would be onsite and because the gas-fired alternative would have fewer 

auxiliary systems requiring service water.

No effects on groundwater quality would be apparent except during the construction phase due 

to temporary dewatering (if necessary) and run-off control measures. Because of the temporary 

nature of construction and the likelihood of reduced groundwater usage during operation as 

compared to KPS, the impact of the gas-fired alternative (onsite or offsite) would be SMALL.
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NUREG-1437, Supplement 40 8-8 August 2010

8.1.3 Surface Water Use and Quality

Total withdrawals of surface water from Lake Michigan would be much less for an onsite 

gas-fired plant than the 400,000 gallons per minute (gpm) (891 cubic feet per second (cfs) or 

25.2 cubic meter per second (m3/s)) average currently used by KPS. However, by switching 

from the open-cycle cooling system currently used by KPS to a closed-cycle cooling system 

used by the proposed alternative, consumptive water losses will increase. Because the onsite 

gas-fired plant would draw water from Lake Michigan and not a small river with reduced flow, 

the NRC concludes the impact of surface water use from the onsite alternative would be 

SMALL. If the alternate offsite location is also adjacent to Lake Michigan, the staff concludes 

that the impact of surface water use will also be SMALL, but could be MODERATE, if the plant 

withdrew cooling water from a small river with low flow.

A new gas-fired plant (onsite or offsite) would be required to obtain a Wisconsin Pollutant 

Discharge Elimination System (WPDES) permit from the WDNR for regulation of industrial 

wastewater, storm water, and other discharges. Assuming the plant operates within the limits of 

this permit, the impact from any possible site runoff and effluent discharges on surface water 

quality would be SMALL.

8.1.4 Aquatic and Terrestrial Ecology

8.1.4.1 Aquatic Ecology

A new gas-fired plant would require a source of water for the plant’s closed-cycle cooling 

system and a discharge point for cooling tower blowdown. Locating the plant on the existing 

KPS site will enable some already-existing buildings and infrastructure to be used; however, 

impacts to aquatic ecology are likely during construction regardless of where the plant is 

located. Site disturbance will likely increase erosion and sedimentation runoff into Lake 

Michigan and nearby streams, increasing turbidity. While site procedures and management 

practices, as well as using already-existing structures on the KPS site when possible, may limit 

this effect, the impact will likely be noticeable. Overall construction effects are expected to be 

less significant for the gas-fired alternative than the coal-fired alternative because the amount of 

site disturbance is less, and many of the major plant components are smaller and require less 

onsite fabrication.

During operations, the gas-fired alternative would require significantly less water for cooling than 

either the coal-fired alternative or the existing KPS unit, which would minimize the potential for 

impingement and entrainment and lessen the thermal discharge from the plant. Spills occurring 

during onsite activities will need to be appropriately handled, and runoff from new, impervious 

surfaces (e.g., roads and rooftops) may affect aquatic ecology, as could deposition of airborne 

pollutants to surface water, though these impacts are likely to be less pronounced than those 

from the coal-fired alternative.

Overall impacts to aquatic ecology from a gas-fired alternative are expected to be SMALL.

8.1.4.2 Terrestrial Ecology

Constructing the natural gas alternative, if the location is offsite, will require approximately 32 ac 

(13 ha) of land. Land requirements would be minimal if the location is on the current KPS site. 

These land disturbances form the basis for impacts to terrestrial ecology. (Gas extraction and 

collection will also affect terrestrial ecology in offsite gas fields, although, as noted in 
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August 2010 8-9 NUREG-1437, Supplement 40

Section 8.1, much of this land is likely already disturbed by gas extraction, and the incremental 

effects of this alternative on gas field terrestrial ecology are difficult to gauge.)

Impacts to terrestrial ecology will be minor if the selected site is the current KPS site because 

the site has been previously disturbed. Impacts to terrestrial ecology could be adverse if the 

location is offsite; however, locating an offsite gas-fired plant on a previously disturbed site 

would minimize impacts. There is potential for disturbance of some areas with trees, Lake 

Michigan shoreline, or wetlands, and possible habitat fragmentation would occur. Construction 

of any additional transmission line ROWs, a lengthy pipeline, or additional roads on undisturbed 

or less-disturbed areas could adversely impact terrestrial ecology by fragmenting or destroying 

habitats. However, a pipelined fuel source and a small workforce would help to minimize the 

need for additional transportation infrastructure. 

In addition, construction onsite, if some shorelines are impacted, or some of the forested lands 

and/or wetlands are converted to building facilities may eliminate onsite habitats and alter the 

site for a long period of time. Some areas onsite, such as any buffer areas, may remain 

undeveloped and could still harbor habitat for terrestrial species, though site lighting, noise, and 

activities may degrade the value of any remaining ecosystems. Deposition of air pollutants from 

this alternative may affect terrestrial ecology, but it is unlikely to be noticeable. Impacts to 

terrestrial resources from a natural gas combined-cycle alternative at both the KPS site and an 

alternate site would like be SMALL to MODERATE. Some of these impacts could be mitigated if 

the location of the gas-fired alternative is either placed on the current KPS site or on a 

previously disturbed location.

8.1.5 Human Health

The effects of gas-fired generation on human health are generally low, although in Table 8-2 of 

the GEIS (NRC, 1996), the staff identified cancer and emphysema as potential health risks from 

gas-fired plants. These risks are likely attributable to NOx emissions that contribute to ozone

formation, which in turn contribute to health risks. It is expected that appropriate emission 

controls installed on the gas-fired alternative option would maintain NOx emissions well below 

EPA air quality standards established for the protection of human health. In addition, the use of 

emissions trading or offset requirements would ensure that the overall NOx in the region will not 

increase. There are potential health risks to plant workers from handling spent catalysts used to 

filter the emissions because they may contain toxic heavy metals. However, the use of 

protective equipment and adherence to safety requirements would minimize the danger to the 

workers. It is expected that the facility would operate in compliance with Federal and State 

safety and emission standards.

Overall, the impacts on human health of the natural gas-fired alternative are likely to be SMALL.

8.1.6 Socioeconomics

8.1.6.1 Land Use

The analysis of land use impacts focuses on the amount of land area that would be affected by 

the construction and operation of a two–unit, natural gas-fired combined-cycle power plant at 

the KPS site and an alternative site. Land-use impacts would vary depending on where the plant 

would be located and whether construction would take place on undeveloped land or within a

previously disturbed industrial (brownfield) area.
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DEK indicated that over 298 ac (121 ha) of land would be needed to support a natural gas-fired 

alternative capable of replacing KPS, including pipeline (DEK, 2008). The GEIS, however, 

estimates 110 ac (45 ha) of land would be needed to support a 1,000-MWe generating station 

(NRC, 1996). DEK estimated that 272 ac would be needed for a natural gas pipeline connection 

to KPS. This amount of land use would include other plant structures and associated 

infrastructure. By scaling the GEIS estimate, the 590-MWe KPS plant could require up to 336 ac 

(136 ha) of land.

However, if additional land would be necessary for a buffer around plant structures or to support 

transmission lines at an alternate site and gas pipelines at both KPS and at an alternate site, the 

staff believes the DEK estimate to be reasonable, although additional land may be used for 

buffer around plant structures or to support transmission lines. Even assuming additional land 

use for these purposes, total land required by the natural gas-fired alternative is unlikely to 

exceed 298 ac (121 ha) for all uses, excluding land for natural gas wells and collection stations. 

Land use impacts from construction would be SMALL and could be further reduced if the power 

plant is collocated at an alternate site with another generating station or on a previously 

industrial site like KPS. Impacts could be further mitigated at an alternate site by constructing 

new transmission lines in existing ROWs. 

In addition to onsite land requirements, land would be required offsite for natural gas wells and 

collection stations. The GEIS estimates that 3,600 ac (1,457 ha) would be required for wells, 

collection stations, and pipelines to bring the gas to a 1,000-MWe generating facility. If this land 

requirement were scaled with generating capacity, a natural gas-fired power plant at KPS could 

require 2,124 ac (860 ha). Most of this land requirement would occur on land where gas 

extraction already occurs. In addition, some natural gas could come from outside of the United 

States and be delivered as liquefied gas.

The elimination of uranium fuel for KPS could partially offset offsite land requirements. In the 

GEIS, the staff estimated that approximately 1,000 ac (405 ha) would not be needed for mining 

and processing uranium during the operating life of a 1,000-MWe nuclear power plant. For KPS, 

roughly 590 ac (239 ha) of uranium mining area would no longer be needed. Overall land use 

impacts from a gas-fired power plant would be SMALL to MODERATE, depending on local land 

use and the availability of land near the proposed site.

8.1.6.2 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 a new, natural gas-fired power plant could affect regional 

employment, income, and expenditures. Two types of job creation may occur: 

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

long-term socioeconomic impact; and (2) operation-related jobs in support of power plant 

operations, which have the greater potential for permanent, long-term socioeconomic impacts. 

The staff estimated workforce requirements of power plant construction and operations for the 

natural gas-fired power plant alternative in order to determine their possible effect on current 

socioeconomic conditions.

The GEIS projects a workforce of 1,200 for a 1,000-MWe plant, which means a workforce of 

approximately 708 for a 590-MWe plant. During construction, the communities surrounding the 

power plant site would experience increased demand for rental housing and public services, 

although these effects would be moderated if the alternate construction site is located near an 
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August 2010 8-11 NUREG-1437, Supplement 40

urban area with many skilled workers. The relative economic effect of construction workers on 

local economy and tax base would vary over time. 

After construction, local communities may be temporarily affected by the loss of construction 

jobs and associated loss in demand for business services, and the rental housing market could 

experience increased vacancies and decreased prices. As noted in the GEIS, the 

socioeconomic impacts at a rural construction site could be larger than at an urban site because 

the workforce would have to move to be closer to the construction site. The impact of 

construction on socioeconomic conditions could range from SMALL to MODERATE depending 

on whether the new power plant would be located at KPS or an alternate site. The 

socioeconomic impacts of power plant construction could be further reduced if the power plant 

is located near an urban area with many skilled workers.

DEK estimated a power plant operations workforce of 20 (DEK, 2008), while scaled GEIS 

estimates indicate up to 89 workers (150 operations workers for a 1,000-MWe plant). The DEK 

estimate appears to be low but is consistent with trends toward lowering labor costs by reducing 

the size of power plant operations workforces. Nevertheless, depending on location, the small 

number of operations workers would not likely have a noticeable effect on socioeconomic 

conditions in the region. Therefore, socioeconomic impacts associated with the operation of a 

gas-fired power plant could be SMALL at KPS or an alternate site.

8.1.6.3 Transportation

During construction, approximately 700 workers would be commuting to the site. In addition to 

commuting workers, trucks would transport construction materials and equipment to the 

worksite 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. Pipeline construction and modification to existing natural gas pipeline systems 

could also have an impact.

During plant operations, transportation impacts would almost disappear. As noted in this 

section, relatively few workers are required to operate the gas-fired alternative. Since fuel is 

transported by pipeline, most transportation infrastructure would experience little increased use 

from plant operations. 

Overall, the gas-fired alternative would have a SMALL impact on transportation conditions in the 

region around KPS or at an alternate site. Transportation impacts at an alternate site would 

depend on road capacity and average daily volume.

8.1.6.4 Aesthetics

Aesthetic resources are the natural and man-made features that give a particular landscape its 

character and aesthetic quality. The aesthetics impact analysis focuses on the degree of

contrast between the power plant and the surrounding landscape and the visibility of the power 

plant.

The two gas-fired units could be approximately 100 ft (30 m) tall, with two exhaust stacks up to 

175 ft (53 m) tall or taller depending on the topography at an alternate site. Some structures 

may require aircraft warning lights. Power plant infrastructure would generally be smaller and 

less noticeable than KPS. Mechanical draft cooling towers would generate condensate plumes 

and operational noise. Noise during power plant operations would be limited to industrial 
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NUREG-1437, Supplement 40 8-12 August 2010

processes and communications. Pipelines delivering natural gas fuel could be audible offsite 

near compressors.

In addition to new power plant structures, the alternate plant site may require the construction of 

transmission lines and natural gas pipelines. The transmission lines would have a lasting visual 

effect on the landscape.

In general, aesthetic changes would be limited to the immediate vicinity of KPS or an alternate 

site. Impacts would likely to be SMALL to MODERATE at KPS or an alternate site and would 

depend on the amount of new transmission lines required.

8.1.6.5 Historic and Archaeological Resources

Cultural resources are the indications of human occupation and use of the landscape as defined 

and protected by a series of Federal laws, regulations, and guidelines. Prehistoric resources are 

physical remains of human activities that predate written records; they generally consist of 

artifacts that may alone or collectively yield information about the past. Historic resources 

consist of physical remains that postdate the emergence of written records; in the United States, 

they are architectural structures or districts, archaeological objects, and archaeological features 

dating after 1492. Ordinarily, sites less than 50 years old are not considered historic, but 

exceptions can be made for such properties if they are of particular importance, such as 

structures associated with the development of nuclear power (e.g., Shippingport Atomic Power 

Station) or Cold War themes. American Indian resources are sites, areas, and materials 

important to American Indians for religious or heritage reasons. Such resources may include 

geographic features, plants, animals, cemeteries, battlefields, trails, and environmental features. 

The cultural resource analysis encompassed the power plant site and adjacent areas that could 

potentially be disturbed by the construction and operation of alternative power plants.

The potential for historic and archaeological resources can vary greatly depending on the 

location of the proposed site. To consider a project’s effects on historic and archaeological 

resources, any proposed areas will need to be surveyed to identify and record historic and 

archaeological resources, identify cultural resources (e.g., traditional cultural properties), and 

develop possible mitigation measures to address any adverse effects from ground disturbing 

activities. Studies will be needed for all areas of potential disturbance at the proposed plant site 

and along associated corridors where new construction will occur (e.g., roads, transmission 

corridors, rail lines, or other ROWs). In most cases, project proponents should avoid areas with 

the greatest sensitivity.

The impact for a gas-fired alternative at the KPS site would be SMALL. As noted in 

Section 4.9.6, DEK conducted a survey of the KPS site in 2007 and developed a Cultural 

Resources Protection Plan. This plan includes pre-job briefings for workers and an inadvertent 

discovery (stop work) provision. Depending on the resource richness of an alternative site 

ultimately chosen for the gas-fired alternative, impacts could range from SMALL to 

MODERATE.

8.1.6.6 Environmental Justice

The environmental justice impact analysis evaluates the potential for disproportionately high and 

adverse human health and environmental effects on minority and low-income populations that 

could result from the construction and operation of a new, natural gas-fired 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 
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August 2010 8-13 NUREG-1437, Supplement 40

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. The minority and low-income populations are subsets of 

the general public residing around the site, and all are exposed to the same hazards generated 

from various power plant operations.

Minority and low-income populations could be affected by the construction and operation of a 

new, natural gas-fired power plant. Some of these effects have been identified in resource areas 

discussed in this section. The extent of disproportionate effect is difficult to determine since it 

would depend on the location of the natural gas-fired power plant. For example, increased 

demand for rental housing during construction could disproportionately affect low-income 

populations. However, demand for rental housing could be mitigated if the alternate plant site is 

constructed near a metropolitan area.

Impacts on minority and low-income populations from the construction and operation of a 

natural gas-fired power plant alternative could range from SMALL to MODERATE, due to the 

small number of workers needed to construct and operate the natural gas-fired power plant.

8.1.7 Waste Management

During the construction stage of this alternative, land clearing and other construction activities 

would generate waste that can be recycled, disposed onsite, or shipped to an offsite waste 

disposal facility. If the alternative were constructed at the KPS site or any previously disturbed 

site, the amounts of wastes produced during land clearing would be reduced.

During the operational stage, spent SCR catalysts, which are used to control NOx emissions 

from the natural gas-fired plants, would make up the majority of the waste generated by this 

alternative. 

The staff concluded in the GEIS (NRC, 1996) that a natural gas-fired plant would generate 

minimal waste and the waste impacts would be SMALL for a natural gas-fired alternative 

located at the KPS site or offsite.

8.2 COAL-FIRED GENERATION

Coal-fired generation accounts for a greater share of U.S. electrical power generation than any 

other fuel (EIA, 2009b). While coal-fired power plants are widely used and are likely to remain 

widely used, the staff notes that future coal capacity additions may be affected by perceived or 

actual efforts to limit GHG emissions. For now, the staff considers a coal-fired alternative to be a 

feasible, commercially available option that could provide electrical generating capacity after 

KPS’s current license expires. 

Supercritical technologies are increasingly common in new coal-fired plants. Supercritical plants 

operate at higher temperatures and pressures than most existing coal-fired plants (beyond 

water’s “critical point,” where boiling no longer occurs and no clear phase change occurs 

between steam and liquid water). Operating at higher temperatures and pressures allows this 

coal-fired alternative to operate at a higher thermal efficiency than many existing coal-fired 

power plants do. While supercritical facilities are more expensive to construct, they consume 

less fuel for a given output, reducing environmental impacts. Based on technology forecasts 

from EIA, the staff expects that a new, supercritical coal-fired plant beginning operation in 2014 
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NUREG-1437, Supplement 40 8-14 August 2010

would operate at a heat rate of 9,069 Btu/kWh, or approximately 38 percent thermal efficiency 

(EIA, 2009c).

In a supercritical coal-fired power plant, burning coal heats pressurized water. As the 

supercritical steam/water mixture moves through plant pipes to a turbine generator, the 

pressure drops, and the mixture flashes to steam. The heated steam expands across the 

turbine stages, which then spin and turn the generator to produce electricity. After passing 

through the turbine, any remaining steam is condensed back to water in the plant’s condenser.

In most modern U.S. facilities, condenser cooling water circulates through cooling towers or a 

cooling pond system (either of which are closed-cycle cooling systems). Older plants often 

withdraw cooling water directly from existing rivers or lakes and discharge heated water directly 

to the same body of water (called open-cycle cooling). In this case, a coal-fired alternative 

constructed on the KPS site would withdraw makeup water from and discharge blowdown 

(water containing concentrated dissolved solids and biocides) from cooling towers back to Lake 

Michigan. As KPS currently uses a once-through cooling system, it is possible that a new 

coal-fired plant on the KPS site could continue to use the existing KPS intake for a once-through 

cooling system. The staff will evaluate a closed-cycle option, as it results in lower operational 

impacts to aquatic life. At the same time, a closed-cycle option may increase aesthetic impacts 

as well as construction-stage impacts. 

In order to replace the 556 net MWe that KPS currently supplies, the coal-fired alternative would 

need to produce roughly 618 gross MWe, using about 6 percent of power output for onsite 

power usage. Onsite electricity demands include scrubbers, cooling towers, coal-handling 

equipment, lights, communication, and other onsite needs. A supercritical coal-fired power plant 

equivalent in capacity to KPS and using the same cooling system would require less cooling 

water than KPS because the alternative operates at a higher thermal efficiency. 

The coal-fired power plant would consume 2.27 million tons (2.06 million MT) of coal annually, 

assuming an average heat content of 8,967 British thermal units per pound (Btu/lb) (EIA, 2008). 

EIA reported that most coal consumed in Wisconsin originates in Wyoming. Given current coal 

mining operations in the State of Wyoming, the coal used in this alternative would likely be 

mined in surface mines, then mechanically processed and washed, before being transported–

via an existing rail spur–to the power plant site. Limestone for scrubbers would also arrive by 

rail. This coal-fired alternative would then produce roughly 123,400 tons (112,000 MT) of ash, 

and roughly 42,300 tons (38,400 MT) of scrubber sludge annually. As noted above, much of the 

coal ash and scrubber sludge could be reused depending on local recycling and reuse markets.

Environmental impacts from the coal-fired alternative will be greatest during construction. Site 

crews will clear the plant site of vegetation, prepare the site surface, and begin excavation 

before other crews begin actual construction on the plant and any associated infrastructure. 
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August 2010 8-15 NUREG-1437, Supplement 40

Table 8-2. Summary of Environmental Impacts of the Coal-Fired Alternative Compared to 

Continued Kewaunee Power Station Operation

Coal-Fired Alternative Continued KPS 

Operation At the KPS Site At an Alternative Site

Air Quality MODERATE MODERATE SMALL

Groundwater SMALL SMALL SMALL

Surface Water SMALL SMALL to MODERATE SMALL

Ecology MODERATE MODERATE SMALL

Human Health SMALL SMALL SMALL

Socioeconomics SMALL to LARGE SMALL to LARGE SMALL

Waste Management MODERATE MODERATE SMALL

8.2.1 Air Quality

The coal-fired generation air quality impacts can be substantial because of the significant 

quantity of SOx, NOx, particulates, CO emissions, hazardous air pollutants (HAPs) such as 

mercury, and naturally occurring radioactive materials resulting from the process. However, 

many of these pollutants can be effectively controlled by various technologies.

KPS is located in Kewaunee County, WI, which is a maintenance area for 8-hour ozone and in 

attainment for all other criteria air pollutants. A new coal-fired generating plant would qualify as 

a new major-emitting industrial facility and would require NSR and Prevention of Significant 

Deterioration of Air Quality review under the CAA (EPA, 2008a). The NSR program requires that 

a permit be obtained before construction of the new major-emitting industrial facility (42 U.S.C.

7475(a)). The EPA delegated the authority of regulating the issuance of the construction and 

operating permits to the WDNR, which coordinates the Wisconsin air pollution control permit 

program for new and existing pollution sources. The new coal-fired generating plant would also 

have to comply with the new source performance standards for coal-fired plants set forth in 

40 CFR 60 Subpart Da. The standards establish limits for PM and opacity (40 CFR 60.42Da), 

SO2 (40 CFR 60.43Da), and NOx (40 CFR 60.44Da). 

Section 169A of the CAA 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 EPA issued a new regional haze rule in 1999 (64 FR 35714). 

The rule specifies that for each mandatory Class I Federal area located within a State, the State 

must establish goals that provide for reasonable progress toward achieving natural visibility 

conditions through developing and implementing air quality protection plans to reduce the 

pollution that causes visibility impairment. As noted in Section 8.1.1, there are RPOs 

collaborating on the visibility impairment issue, developing the technical basis for these plans. 

Wisconsin, Illinois, Indiana, Michigan, and Ohio belong to the Midwest RPO that, along with 

tribes, Federal agencies, and other interested parties, identifies regional haze and visibility 

issues and develops strategies to address them. The visibility protection regulatory 

requirements, contained in 40 CFR Part 51, Subpart P, include the review of the new sources 

that would be constructed in the attainment or unclassified areas and may affect visibility in any 

Class I Federal area (40 CFR 51.307). If a coal-fired plant were located close to a mandatory 
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NUREG-1437, Supplement 40 8-16 August 2010

Class I area, additional air pollution control requirements would be imposed. There are no 

mandatory Class I Federal areas in the State of Wisconsin or in close proximity to KPS. The 

closest mandatory Class I Federal areas to KPS are Seney Wilderness Area, MI, located 149 mi 

northeast from KPS, and Isle Royale National Park, MI, located 255 mi northwest from KPS.

The emissions from the coal-fired alternative at the KPS site, based on published EIA data, EPA 

emission factors (EPA, 1998), and on performance characteristics for this alternative and 

implemented emission controls, would likely be:

● SOx – 775.81 tons (703.80 MT) per year

● NOx – 567.11 tons (514.47 MT) per year

● TSP – 61.70 tons (55.97 MT) per year

● PM10 – 123.40 tons (111.95 MT) per year

● PM2.5 – 61.70 tons (55.97 MT) per year

● CO – 567.11 tons (514.47 MT) per year

● Mercury (Hg) – 0.09 tons (0.08 MT) per year

8.2.1.1 Sulfur Oxides Emissions and Nitrogen Oxides Emissions 

The coal-fired alternative at the KPS site would likely use wet, limestone-based scrubbers to 

remove SOx. The EPA indicates that this technology can remove more than 95 percent of SOx 

from flue gases (EPA, 1998). The staff projects total SOx emissions would be 775.81 tons 

(703.80 MT) per year.

On March 10, 2005, the EPA issued the CAIR, which would create large permanent reductions 

in SO2 and NOx across 28 eastern States and the District of Columbia. However, petitions for 

review of the CAIR and CAIR FIPs, including the provisions establishing the CAIR NOx annual 

and ozone season and SO2 trading programs, were filed in the U.S. Court of Appeals for the 

D.C. Circuit. On July 11, 2008, the Court issued an opinion vacating and remanding the CAIR

and CAIR FIPs. After requested rehearing of the Court’s decision, the Court granted rehearing 

only to the extent that it remanded the rules to the EPA without vacating them on December 23, 

2008. This ruling leaves CAIR and the CAIR FIPs, including the CAIR trading programs, in place 

until the EPA issues a new rule to replace CAIR in accordance with the July 11, 2008, decision. 

Wisconsin is among the States covered by this rule (EPA, 2009b). WDNR adopted the rule and 

allocated annual NOx allowances for new electricity generating units subject to CAIR as 

specified in Chapter NR 432 of the Wisconsin Administrative Code in 2009. The NOx 

allowances are allocated from a “new unit set-aside” reserved pool of allowances, which 

represents 7 percent of Wisconsin’s total budget of NOx allowances. 

SOx emissions from a new coal-fired power plant would be subject to the requirements of 

Title IV of the CAA. Title IV was enacted to reduce emissions of SO2 and NOx, the two principal 

precursors of acid rain, by restricting emissions of these pollutants from power plants. Title IV 

caps aggregate annual power plant SO2 emissions and imposes controls on SO2 emissions 

through a system of marketable allowances. The EPA issues one allowance for each ton of SO2

that a unit is allowed to emit. New units do not receive allowances but are required to have 

allowances to cover their SO2 emissions. Owners of new units must, therefore, purchase 

allowances from owners of other power plants or reduce SO2 emissions at other power plants 

they own. Allowances can be banked for use in future years. Thus, provided a new coal-fired 

power plant is able to purchase sufficient allowances to operate, it would not add to net regional 

SO2 emissions, although it might do so locally.
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A coal-fired alternative constructed either at the KPS site or offsite would most likely employ 

various available NOx-control technologies, which can be grouped into two main categories: 

combustion modifications and post-combustion processes. Combustion modifications include 

low-NOx burners, over fire air, flue gas recirculation, and operational modifications. 

Post-combustion processes include SCR, selective noncatalytic reduction, and hybrid 

processes. An effective combination of the combustion modifications and post-combustion 

processes can reduce NOx emissions by up to 95 percent. DEK would use the combination 

low-NOx burners, over fire air, and SCR technologies in order to reduce NOx emissions from 

this alternative. Assuming the use of such technologies at the KPS site, NOx emissions after 

scrubbing are estimated at 567.11 tons (514.47 MT) annually.

Section 407 of the CAA establishes technology-based NOx emissions limitations. A new 

coal-fired power plant would be subject to the new source performance standards for such 

plants as indicated in 40 CFR 60.44a(d)(1). This regulation limits the discharge of any gases 

that contain NOx to 200 nanograms (ng) per joule (J) of gross energy output (equivalent to 1.6 

pound (lb)/megawatt hours (MWh)), based on a 30-day rolling average. 

8.2.1.2 Particulate Emissions

The new coal-fired power plant would use fabric filters to remove particulates from flue gases. 

DEK indicates that fabric filters would remove 99.9 percent of PM (DEK, 2008). The EPA notes 

that filters are capable of removing in excess of 99 percent of PM and that SO2 scrubbers 

further reduce PM emissions (EPA, 2008b). As such, the staff believes the DEK removal factor 

is appropriate. Based on this, the new supercritical coal-fired plant would emit 123.40 tons 

(111.95 MT) per year of PM10 and approximately 61.70 tons (55.97 MT) per year of PM2.5. In 

addition, coal-handling equipment would introduce fugitive dust emissions when fuel is being 

transferred to onsite storage and then reclaimed from storage for use in the plant.

During the construction of a coal-fired plant, onsite activities would also generate fugitive dust. 

Vehicles of the workers and motorized equipment would also create exhaust emissions during 

the construction process. However, these impacts would be intermittent and short-termed. 

There would be dust-control measures implemented in order to minimize dust generation.

8.2.1.3 Carbon Monoxide Emissions

Based on EPA emission factors (EPA, 1998), the staff estimates that the total CO emissions 

would be approximately 567.11 tons (514.47 MT) per year.

8.2.1.4 Hazardous Air Pollutants Including Mercury

The EPA is in the process of developing emissions standards for power plants under Section 

112 of the CAA, including mercury emissions, following the D.C. Circuit Court’s February 8, 

2008, ruling that vacated EPA’s Clean Air Mercury Rule (CAMR) (EPA, 2009c). Before CAMR, 

the EPA determined that coal- and oil-fired electric utility steam-generating units are significant 

emitters of HAPs (EPA, 2000a). The EPA determined that coal plants emit arsenic, beryllium, 

cadmium, chromium, dioxins, hydrogen chloride, hydrogen fluoride, lead, manganese, and 

mercury (EPA, 2000a). The EPA concluded that mercury is the HAP of greatest concern and 

that: (1) a link exists between coal combustion and mercury emissions, (2) electric utility 

steam-generating units are the largest domestic source of mercury emissions, and (3) 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 resulting from mercury 

exposures caused by the consumption of contaminated fish (EPA, 2000a). In light of the court’s 

decision, the EPA will revisit mercury regulation, although it is possible that the agency will 
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NUREG-1437, Supplement 40 8-18 August 2010

continue to regulate mercury as a HAP, thus requiring the use of best available control 

technology to prevent its release to the environment. The Wisconsin Mercury Rule, revised in 

2008, requires all new coal-fired power plants to achieve Maximum Achievable Control 

Technology (MACT) in order to reduce emissions of HAPs, including mercury, and specifies that 

the permitted mercury reduction shall not be less than 90 percent of the removal of mercury 

from combusted coal (WDNR, 2008). 

8.2.1.5 Carbon Dioxide

A coal-fired plant would also have unregulated CO2 emissions during operations, as well as 

during mining, processing, and transportation. The coal-fired plant would emit between 

4,176,024.00 tons (3,788,425.25 MT) to 4,326,548.00 tons (3,924,978.32 MT) of CO2 per year, 

depending on the type and quality of the coal. 

8.2.1.6 Summary of Air Quality

While the GElS analysis mentions global warming from unregulated CO2 emissions and acid 

rain from SOx and NOx emissions as potential impacts, it does not quantify emissions from 

coal-fired power plants. However, the GElS analysis implies that air impacts would be 

substantial (NRC, 1996). The above analysis shows that emissions of air pollutants, including 

SOx, NOx, CO, and particulates, exceed those produced by the existing nuclear power plant, as 

well as those of the other alternatives considered in this section. Operational emissions of CO2

are also much greater under the coal-fired alternative. Adverse human health effects, such as 

cancer and emphysema, have also been associated with air emissions from coal combustion 

and are discussed further in Section 8.2.5.

The NRC analysis for a coal-fired alternative at an alternate site indicates that impacts from the 

coal-fired alternative would have clearly noticeable effects, but given existing regulatory 

regimes, permit requirements, and emissions controls, the coal-fired alternative would not 

destabilize air quality. Therefore, the appropriate characterization of air impacts from a coal-fired 

plant located at the KPS site would be MODERATE. Existing air quality would result in varying 

needs for pollution control equipment to meet applicable local and Federal requirements or 

varying degrees of participation in emissions trading schemes.

8.2.2 Groundwater Use and Quality

If the onsite coal-fired alternative continued to use groundwater for drinking water and service 

water, the need for groundwater at the plant would be minor, with supply wells used for potable 

drinking water and various service water functions. Total usage would likely be much less than 

KPS because fewer workers would be onsite and because the coal-fired unit would have fewer 

auxiliary systems requiring service water. No effect on groundwater quality would be apparent. If

an alternative site is chosen, the need for groundwater use for plant operations would likely be 

minor.

Construction of a coal-fired plant (onsite or offsite) could have a localized effect on groundwater 

due to temporary dewatering and run-off control measures. Because of the temporary nature of 

construction and the likelihood of reduced groundwater usage during operation, the impact of 

the coal-fired alternative would be SMALL.
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August 2010 8-19 NUREG-1437, Supplement 40

8.2.3 Surface Water Use and Quality

Because the onsite alternative would draw water from Lake Michigan, most of the approximately 

8,000 gpm (0.5 m3

/s) needed for maximum withdrawal would be taken from the lake with an 

average consumptive loss of about 10 million gallons per day (mgd) (0.4 m3

/s). The alternative 

would use a closed-cycle system with cooling towers, which would increase consumptive water 

losses from the currently operating open-cycle cooling system used by KPS. However, because 

the onsite coal-fired plant would draw water from Lake Michigan and not a small river, the NRC 

concludes the impact of surface water use would be SMALL. If the chosen alternative site is 

also adjacent to Lake Michigan, the NRC concludes that the impact of surface water use will 

also be SMALL but could increase to MODERATE if the plant relies on a small river with low 

flow for cooling water.

Any new coal-fired plant in the area (onsite or offsite) would be required to obtain a WPDES 

permit from the WDNR for regulation of industrial wastewater, storm water, and other 

discharges. Assuming the plant operates within the limits of this permit, the impact from any 

possible runoff from coal piles and effluent discharges on surface water quality would be 

SMALL.

8.2.4 Aquatic and Terrestrial Ecology

A new coal-fired plant would require a source of water for the plant’s cooling system, most likely 

a closed-cycle cooling tower system, and a discharge point for cooling tower blowdown. 

Locating the plant on the existing KPS site will enable some already-existing buildings and 

infrastructure to be used; however, impacts to aquatic ecology are likely during construction 

regardless of where the plant is located. Site disturbance will likely increase erosion and 

sedimentation runoff into Lake Michigan and nearby streams, increasing turbidity. While site 

procedures and management practices, as well as using already-existing structures on the KPS 

site when possible, may limit this effect, the impact will likely be noticeable. 

Surface mining of coal, which would occur offsite, is associated with degradation of aquatic 

communities due to acid mine drainage, sedimentation, and diversion or destruction of streams, 

lakes, and ponds. High sediment levels can kill fish directly, bury spawning beds, and alter 

water temperature and flow. Federal law requires mining operations to meet standards for 

protecting surface and groundwater from contamination, which would minimize sedimentation 

and other contaminants to the extent possible. Transportation of coal and limestone would likely 

occur via barge and would also contribute to erosion. Manitowoc, located 18 mi (29 kilometers 

(km) south-southwest of the KPS site, and Green Bay, located 27 mi (44 km) west-northwest of 

the site, have coal docks, though no rail spur connects the site to either location. A new docking 

facility would likely need to be constructed, which would require dredging bottom sediments and 

construction of breakwaters and docks. Dredging of bottom sediments will disrupt aquatic 

communities and, depending on the extent of dredging, could impair benthic communities by 

removing suitable substrate.

Following construction, the greater thermal efficiency of the coal-fired alternative versus the 

existing KPS unit will result in slightly less consumptive water use for cooling and blowdown. 

During operations, disposal of waste materials will have to comply with local and State 

regulations, some of which are intended to prevent runoff into surface water. Management of 

runoff from coal piles will also be necessary. Spills occurring during onsite activities will need to 

be appropriately handled, and runoff from new, impervious surfaces (e.g., roads and rooftops) 

may affect aquatic ecology, as could deposition of acids or chemicals emitted through the 
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NUREG-1437, Supplement 40 8-20 August 2010

plant’s stacks. Given current regulations, as well as the emission controls discussed in the Air

Quality section, these impacts may be noticeable, but are not likely to be destabilizing.

Overall impacts to aquatic ecology from a coal-fired alternative are expected to be MODERATE.

As indicated in previous sections, constructing the coal-fired alternative will require 129 ac 

(52 ha) of land if located offsite and will not require additional land if located on the current KPS 

site. Coal mining operations will also affect terrestrial ecology in offsite coal mining areas, 

although some of the land is likely already disturbed by mining operations. Onsite and offsite 

land disturbances form the basis for impacts to terrestrial ecology.

Impacts to terrestrial ecology will vary based on the degree to which the proposed plant site is 

already disturbed. On a previous industrial site, impacts to terrestrial ecology would be minor, 

unless substantial transmission line ROWs, railways, or roads would need to be constructed 

through less disturbed areas. These construction activities may have a cumulative effect of 

fragmenting or destroying habitats. Any onsite or offsite water disposal by landfilling will also 

affect terrestrial ecology at least through the time period when the disposal area is reclaimed. 

Some areas onsite, such as buffer areas, may remain undeveloped and could serve as habitat 

for terrestrial species, though site lighting, noise, and activities may degrade the value of these 

ecosystems. Deposition of acid rain or other emissions can also affect terrestrial ecology. Given 

the emission controls discussed in Section 8.2.1, air deposition impacts may be noticeable but 

are not likely to be destabilizing. Impacts to terrestrial resources from a coal-fired alternative 

would be SMALL to MODERATE and occur mostly during construction. Some of these impacts 

could be mitigated if the location of the coal-fired alternative is the current KPS site or on a 

previously disturbed location. 

8.2.5 Human Health

Coal-fired power plants introduce worker risks from coal and limestone mining, from coal and 

limestone transportation, and from disposal of coal combustion and scrubber wastes. In 

addition, there are public risks from inhalation of stack emissions and the secondary effects of 

eating foods grown in areas subject to deposition from plant stacks.

In Table 8-2 of the GEIS (NRC, 1996), the staff stated that human health impacts (cancer and 

emphysema) could result from inhalation of toxins and particulates, but it did not identify the 

significance of these impacts. Enforcement by the EPA and/or State agencies of regulations 

restricting harmful emissions from coal-fired plants has significantly reduced the potential health 

effects but has not eliminated them. These agencies also impose site-specific emission limits, 

as needed, to protect human health. Even if the coal-fired alternative were located in a 

designated nonattainment area, the use of emission trading or offset mechanisms could prevent 

further regional degradation. However, localized effects could be visible. Many of the byproducts 

of coal combustion responsible for health effects are largely controlled, captured, or converted 

to a benign state in modern power plants, although some level of health effects may remain.

Aside from emission impacts, the coal-fired alternative introduces the risk of coal pile fires and 

for those plants that use coal combustion liquid and sludge waste impoundments, the release of 

the waste due to a failure of the impoundment. However, the occurrence of these types of 

events is relatively rare.

It is expected that the facility would operate in compliance with Federal and State safety and 

emission standards. 
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August 2010 8-21 NUREG-1437, Supplement 40

Overall, the impacts on human health of the coal-fired alternative are likely to be SMALL.

8.2.6 Socioeconomics

8.2.6.1 Land Use

As discussed in 8.1.6, the analysis of land use impacts focuses on the amount of land area that 

would be affected by the construction and operation of a coal-fired power plant at the KPS site 

and an alternative site. Land-use impacts would vary depending on where the plant would be 

located and whether construction would take place on undeveloped land or within a previously 

disturbed industrial (brownfield) area.

DEK indicated that 136 ac (55 ha) of land would be needed to support a coal-fired alternative 

capable of replacing KPS. The GEIS estimates 1,700 ac (700 ha) would be needed to support a 

1,000-MWe generating station (NRC, 1996). This amount of land use includes power plant 

structures and associated coal delivery and waste disposal infrastructure. By scaling GEIS 

estimates, a 590-MWe plant could require approximately 1,000 ac (405 ha) of land.

However, if additional land would be necessary for a buffer around plant structures or to support 

transmission lines at an alternate site and rail and barge offloading facilities at KPS and an 

alternate site, the staff believes the DEK estimate to be low and additional land would be 

needed to support a rail yard and coal offloading facility. Even assuming additional land use for 

these purposes, total land required by the coal-fired alternative is unlikely to exceed 1,000 ac 

(405 ha) for all uses, excluding coal mining. The coal-fired alternative would require 

approximately 30 ac (12 ha) of land area for waste disposal. Land use impacts from 

construction would be MODERATE to LARGE and could be reduced if the power plant is 

collocated at an alternate site with another generating station or on a previously industrial site 

like KPS. Impacts could be further mitigated at an alternate site by constructing new 

transmission lines in existing ROWs.

Offsite land use impacts would occur from coal mining in addition to land use impacts from the 

construction and operation of the new power plant. The GEIS indicates that approximately 

22,000 ac (8,903 ha) of land could be affected by mining coal and waste disposal to support a 

1,000-MWe coal plant during its operational life (NRC, 1996). Therefore, to replace KPS, 

approximately 12,980 ac (5,253 ha) of land could be affected by coal mining. However, most of 

the land in existing coal mining areas has already experienced some level of disturbance. The 

elimination of the need for uranium mining to supply fuel for KPS would partially offset this 

offsite land use impact. The GEIS estimates that approximately 1,000 ac (405 ha) of land would 

be affected by uranium mining and processing for a 1,000-MWe nuclear plant. For KPS, roughly 

590 ac (239 ha) of land used for uranium mining and processing would no longer be needed.

Based on this information, land use impacts could range from MODERATE to LARGE, 

depending on local land use and the availability of land near the proposed site. Some portion of 

this impact could be mitigated by constructing the rail spur in existing ROWs.

8.2.6.2 Socioeconomics

The GEIS projected a peak workforce of 1,200 to 2,500 workers for a 1,000-MWe plant or a 

peak of 708 to 1,475 workers for a replacement for KPS. During construction, the communities 

surrounding the power plant site would experience increased demand for rental housing and 

public services, although these effects would be moderated if the alternate construction site is 
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NUREG-1437, Supplement 40 8-22 August 2010

located near an urban area with many skilled workers. The relative economic effect of 

construction workers on local economy and tax base would vary over time.

After construction, local communities may be temporarily affected by the loss of construction 

jobs and associated loss in demand for business services, and the rental housing market could 

experience increased vacancies and decreased prices. As noted in the GEIS, the 

socioeconomic impacts at a rural construction site could be larger than at an urban site because 

the workforce would need to relocate closer to the construction site. The impact of construction 

on socioeconomic conditions could range from MODERATE to LARGE depending on whether 

the new power plant would be located at KPS or an alternate site. The socioeconomic impacts 

of power plant construction could be further reduced if the power plant is located near an urban 

area with many skilled workers.

DEK estimated an operational workforce of 79 (DEK, 2008), while scaling estimates from the 

GEIS indicate the need for 148 workers (250 operations workers for a 1,000-MWe plant). The 

DEK estimate appears low but is consistent with trends calling for decreased workforces at 

power facilities. Even at rural sites, impacts are unlikely to be large. The small number of 

operations workers would not likely have a noticeable effect on socioeconomic conditions in the 

region. Depending on location, operations impacts would likely be SMALL to MODERATE.

8.2.6.3 Transportation

During construction, approximately 1,500 workers would be commuting to the site. In addition to 

commuting workers, trucks would transport construction materials and equipment to the 

worksite 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. Trains and/or barges could also be used to deliver large components to the KPS 

site or an alternate site. Transportation impacts are likely to be MODERATE to LARGE during 

construction.

During operations, approximately 150 workers would be commuting to the coal-fired power 

plant. Frequent deliveries of coal and limestone by rail and barge could add to the overall 

transportation impact. Onsite coal storage would make it possible to receive several trains per 

day. Limestone could also likely be delivered by rail and barge, which could add additional traffic 

(though considerably less traffic than that generated by coal deliveries).

The coal-fired alternative would likely create SMALL to MODERATE transportation impacts 

during plant operations depending on whether coal and limestone is delivered by rail and barge. 

Transportation impacts at an alternate site would depend on road capacity and average daily 

volume. 

8.2.6.4 Aesthetics

The coal-fired alternative’s boiler building would be up to 200 ft (61 m) tall and may be visible 

offsite in daylight hours at KPS and depending on the topography at an alternate site. The 

exhaust stack would be up to 500 ft (183 m) high. If the coal-fired alternative makes use of 

natural-draft cooling towers, then additional impacts would occur from the towers, which may be 

several hundred feet tall and topped with condensate plumes. Mechanical draft towers would 

also generate condensate plumes but would be markedly shorter than natural-draft towers. 

Other buildings onsite may also affect aesthetics. Noise and light from plant operations, as well 

as lighting on plant structures, may be detectable offsite.
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August 2010 8-23 NUREG-1437, Supplement 40

In addition to new power plant structures, the alternate plant site may require the construction of 

transmission lines. The transmission lines would have a lasting visual effect on the landscape.

In general, aesthetic changes would be limited to the immediate vicinity of KPS or an alternate 

site. Impacts would likely to be SMALL to MODERATE at KPS and an alternate site and would 

depend on the amount of new transmission lines required.

8.2.6.5 Historic and Archaeological Resources

Cultural resources are the indications of human occupation and use of the landscape as defined 

and protected by a series of Federal laws, regulations, and guidelines. Prehistoric resources are 

physical remains of human activities that predate written records; they generally consist of 

artifacts that may alone or collectively yield information about the past. Historic resources 

consist of physical remains that postdate the emergence of written records; in the United States, 

they are architectural structures or districts, archaeological objects, and archaeological features 

dating after 1492. Ordinarily, sites less than 50 years old are not considered historic, but 

exceptions can be made for such properties if they are of particular importance, such as 

structures associated with the development of nuclear power (e.g., Shippingport Atomic Power 

Station) or Cold War themes. American Indian resources are sites, areas, and materials 

important to American Indians for religious or heritage reasons. Such resources may include 

geographic features, plants, animals, cemeteries, battlefields, trails, and environmental features. 

The cultural resource analysis encompassed the power plant site and adjacent areas that could 

potentially be disturbed by the construction and operation of alternative power plants. 

The potential for historic and archaeological resources can vary greatly depending on the 

location of the proposed site. To consider a project’s effects on historic and archaeological 

resources, any proposed areas will need to be surveyed to identify and record historic and 

archaeological resources, identify cultural resources (e.g., traditional cultural properties), and 

develop possible mitigation measures to address any adverse effects from ground disturbing 

activities. Studies will be needed for all areas of potential disturbance at the proposed plant site 

and along associated corridors where new construction will occur (e.g., roads, transmission 

corridors, rail lines, or other ROWs). In most cases, project proponents should avoid areas with 

the greatest sensitivity.

The impact for a coal-fired alternative at the KPS site would be SMALL. As noted in 

Section 4.9.6, DEK conducted a survey of the KPS site in 2007 and developed a Cultural 

Resources Protection Plan. This plan includes pre-job briefings for workers and an inadvertent 

discovery (stop work) provision. Depending on the resource richness of an alternative site 

ultimately chosen for the coal-fired alternative, impacts could range from SMALL to 

MODERATE.

8.2.6.6 Environmental Justice

The environmental justice impact analysis evaluates the potential for disproportionately high and 

adverse human health and environmental effects on minority and low-income populations that 

could result from the construction and operation of a new coal-fired 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. The minority and low-income populations are subsets of the general public 
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NUREG-1437, Supplement 40 8-24 August 2010

residing around the site, and all are exposed to the same hazards generated from various 

power plant operations.

Minority and low income populations could be affected by the construction and operation of a 

new coal-fired power plant. Some of these effects have been identified in resource areas 

discussed in this section. The extent of disproportionate effect is difficult to determine since it 

would depend on the location of the coal-fired power plant. For example, increased demand for 

rental housing during construction could disproportionately affect low-income populations. 

However, demand for rental housing could be mitigated if the alternate plant site is constructed 

near a metropolitan area. Impacts on minority and low-income populations from the construction 

and operation of a coal-fired power plant alternative could range from SMALL to MODERATE.

8.2.7 Waste Management

The coal-fired, supercritical power plant would be constructed either onsite or offsite. Waste 

would be generated during construction of this alternative. During operation of this alternative, 

ash (a dry solid) and sludge (a semi-solid by-product of emission control system operation) 

waste streams would be generated. The staff estimates that a 618-megawatt (MW) power plant 

would generate annually a total 60,823.94 tons (55,178.55 MT) of dry solid ash and scrubber 

sludge. Disposal of the waste from the 40-year operation of this alternative would require 

approximately 136 ac (55 ha). Disposal of the waste could noticeably affect land use and 

groundwater quality, but with proper siting and implementation of monitoring and management 

practices, it would not destabilize resources. After closure of the waste site and revegatation, 

the land could be available for other uses.

The impacts from waste generated during operation of this coal-fired alternative would be 

MODERATE; the impacts would be clearly visible but would not destabilize any important 

resource.

The impacts from waste generated during the construction stage would be short-term. The 

amount of construction waste is small compared to the amount of waste generated during the 

operational stage and could be recycled. Overall, the impacts from waste generated during the 

construction stage would be SMALL.

Therefore, the staff concludes that impacts from construction and operation of this alternative 

would be MODERATE.

8.3 COMBINATION ALTERNATIVES

In this section, the staff evaluates the environmental impacts that may occur from a combination 

of alternatives, some of which may not be capable of individually replacing the power from KPS, 

but which may have relatively low environmental impacts or rely on renewable fuel sources. In 

this section, the staff will evaluate two combination alternatives that include onsite gas-fired 

generation, energy conservation, and either wind power (in option 1) or wood-fired power (in 

option 2).

Combination Option 1

● 280 MW gas-fired capacity on the KPS site

:
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August 2010 8-25 NUREG-1437, Supplement 40

● 229 MW equivalent conservation

● 47 MW wind power (157 MW of wind turbines at several sites; 30 percent 

capacity factor)

Combination Option 2

● 280 MW gas-fired capacity on the KPS site

:

● 229 MW equivalent conservation

● 47 MW wood-fired plant

Wisconsin has substantial conservation resources, but a recent study commissioned by the 

Wisconsin Public Service Commission indicates that it will take several years to ramp programs 

to offset the power generated by KPS (Energy Center of Wisconsin, 2009). By the start of 2014 

(the KPS license expires on December 21, 2013), Wisconsin could offset 4.8 percent of peak 

load and 4.8 percent of total energy consumption. These estimates explicitly do not include the 

potential for behavior-based programs to reduce consumption. Assuming that 50 percent of this 

potential could offset a base load duty cycle, roughly 229 MW (on a total energy consumption 

basis) or 360 MW (on a peak load basis) could be achieved by the time the KPS license 

expires. Using the lower number, 229 MW, to be conservative, conservation/energy efficiency 

could offset roughly 41 percent of KPS output. Most of the remaining output for both alternatives 

would come from a 280 MW gas-fired combined-cycle power plant at the current plant site (half 

of the pure gas-fired alternative).

Some wind turbines could be located onsite or across nearby agricultural areas with little 

long-term land use impact. As noted in Section 8.5.1, this area is also home to Wisconsin’s best 

wind potential and existing transmission lines. The other option relies on offsite wood-fired 

power that would likely be located in the northern part of the State near steady wood supply 

streams.

Table 8-3. Summary of Environmental Impacts of the Combination Alternative Compared 

to Continued Kewaunee Power Station Operation

Combination Alternative

Option 1 Continued KPS Operation – Gas, 

Conservation, Wind

Option 2 – Gas, 

Conservation, Wood

Air Quality MODERATE MODERATE SMALL

Groundwater SMALL SMALL SMALL

Surface Water SMALL SMALL SMALL

Ecology SMALL to LARGE SMALL to LARGE SMALL

Human Health SMALL to MODERATE SMALL to MODERATE SMALL

Socioeconomics SMALL to MODERATE SMALL to MODERATE SMALL

Waste Management SMALL SMALL SMALL
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NUREG-1437, Supplement 40 8-26 August 2010

8.3.1 Air Quality

Kewaunee County, WI, where KPS is located, belongs to EPA Region 5 and is in attainment for 

all criteria pollutants, except ozone. Kewaunee County is a maintenance area for 8-hour ozone 

(EPA, 2009a).

This alternative is a combination of a 280 MW gas-fired combined-cycle power plant, 

constructed onsite, and two options: option 1 relies on wind power for the remainder of the 

electrical energy produced; option 2 relies on offsite wood-fired power.

A new gas-fired generating plant, proposed to be built in Kewaunee County, would qualify as a 

new major-emitting industrial facility and require an NSR and Prevention of Significant 

Deterioration of Air Quality review under the CAA, enforced by WDNR, along with other air 

pollution control requirements in the Wisconsin Administrative Code and its statutes (EPA, 

2008a), (Wis. Adm. Code, Chapters NR400-499). The EPA delegated the authority of regulating 

the issuance of construction and operating permits to the WDNR, which was codified in NR406 

and NR407 of the Wisconsin Administrative Code. The natural gas-fired plant would also need 

to comply with the standards of performance for electric utility steam generating units set forth in 

40 CFR Part 60 Subpart Da.

Section 169A of the CAA 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 EPA issued a new regional haze rule in 1999 (64 FR 35714). 

The rule specifies that for each mandatory Class I Federal area located within a State, the State 

must establish goals that provide for reasonable progress toward achieving natural visibility 

conditions through developing and implementing air quality protection plans to reduce the 

pollution that causes visibility impairment. As noted in Sections 8.1.1 and 8.2.1, there are five 

RPOs collaborating on the visibility impairment issue and developing the technical basis for 

these plans. The Midwest RPO, along with tribes, Federal agencies, and other interested parties 

identifies regional haze and visibility issues and develops strategies to address them. The 

visibility protection regulatory requirements, contained in 40 CFR Part 51, Subpart P, include the 

review of the new sources that would be constructed in the attainment or unclassified areas and 

may affect visibility in any Class I Federal area (40 CFR 51.307). If a coal-fired plant were 

located close to a mandatory Class I area, additional air pollution control requirements would be 

imposed. There are no mandatory Class I Federal areas in the State of Wisconsin or in the 

close proximity to KPS. The closest mandatory Class I Federal areas to KPS are Seney 

Wilderness Area, MI, located 149 mi northeast from KPS, and Isle Royale National Park, MI, 

located 255 mi northwest from KPS. 

The emissions from the natural gas-fired alternative at the KPS site, based on published EIA 

data, EPA emission factors (EPA, 1998), and on performance characteristics for this alternative 

and implemented emission controls, would likely be:

● SOx – 21.99 tons (19.95 MT) per year

● NOx – 70.50 tons (63.96 MT) per year

● CO – 14.66 tons (13.30 MT) per year

● TSP – 12.29 tons (11.15 MT) per year

● PM10 – 12.29 tons (11.15 MT) per year

● CO2 – 756,582.11 tons (686,359.75 MT) per year

The new, natural gas-fired plant would have to comply with Title IV of the CAA reduction 

requirements for SO2 and NOx, which are main precursors of acid rain and major causes of 
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August 2010 8-27 NUREG-1437, Supplement 40

reduced visibility. Title IV establishes maximum SO2 and NOx emission rates for existing plants 

and a system of SO2 emission allowances that can be used, sold, or saved for future use by 

new plants. 

On March 10, 2005, the EPA issued the CAIR, which would create large permanent reductions 

in SO2 and NOx across 28 eastern States and the District of Columbia. However, petitions for 

review of the CAIR and CAIR FIPs, including the provisions establishing the CAIR NOx annual 

and ozone season and SO2 trading programs, were filed in the U.S. Court of Appeals for the 

D.C. Circuit. On July 11, 2008, the Court issued an opinion vacating and remanding the CAIR 

and CAIR FIPs. After requested rehearing of the Court’s decision, the Court granted rehearing 

only to the extent that it remanded the rules to the EPA without vacating them on December 23, 

2008. This ruling leaves CAIR and the CAIR FIPs, including the CAIR trading programs, in place 

until the EPA issues a new rule to replace CAIR in accordance with the July 11, 2008, decision. 

Wisconsin is among the States covered by this rule (EPA, 2009b). WDNR adopted the rule and 

allocated annual NOx allowances for new electricity generating units subject to CAIR as 

specified in Chapter NR 432 of the Wisconsin Administrative Code in 2009. The NOx 

allowances are allocated from a “new unit set-aside” reserved pool of allowances, which 

represents 7 percent of Wisconsin’s total budget of NOx allowances.

As stated above, the new, natural gas-fired alternative would produce 21.99 tons (19.95 MT) per 

year of SOx and 70.50 tons (63.96 MT) per year of NOx based on the use of the dry low NOx 

combustion technology and use of the SCR in order to significantly reduce NOx emissions.

The new plant would be subjected to the continuous monitoring requirements of SO2, NOx, and 

CO2 specified in 40 CFR Part 75. The natural gas-fired plant would emit approximately 

756,582.11 tons (686,359.75 MT) per year of unregulated CO2 emissions. As of today, there is 

no required reporting of GHG emissions. In response to the Consolidated Appropriations Act of 

2008, the EPA proposed a rule that would require mandatory reporting of GHG emissions from 

large sources, such as the presented alternative. The rule would allow for the collection of 

accurate and comprehensive emissions data to inform future policy decisions. The EPA 

proposes that suppliers of fossil fuels or industrial GHGs, manufacturers of vehicles and 

engines, and facilities that emit 25,000 MT or more per year of GHG emissions submit annual 

reports to the EPA. The gases covered by the proposed rule are CO2, CH4, N2O, HFC, PFC, 

SF6, and other fluorinated gases including NF3 and HFE.

The natural gas-fired portion of this alternative would emit 12.29 tons (11.15 MT) of PM per year 

having an aerodynamic diameter less than or equal to 10 μm (PM10) (40 CFR 50.6(a)), based on 

the assumption that effective fabric filters or electrostatic precipitators would be used to 

minimize emissions.

In December 2000, the EPA issued regulatory findings on emissions of HAPs from electric utility 

steam-generating units, which indicated that natural gas-fired plants emit HAPs, such as 

arsenic, formaldehyde, and nickel, and stated that (EPA, 2000a): 

. . . the impacts due to 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. 

There would be no emissions from the wind-powered portion of option 1 for this alternative.
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NUREG-1437, Supplement 40 8-28 August 2010

When fossil fuels are burned in the production of electricity, a variety of gases and particulates 

are formed and, if not captured by pollution control equipment, will be released into the 

atmosphere. The pollutants released during electricity production depend upon complex 

relationships between factors, such as fuel type and mix (sulfur content of coal, gas utilization), 

operational mode (combustion temperatures), technologies employed (combustion processes, 

environmental equipment), and regulatory constraints (nonattainment and maintenance areas). 

The emissions from the wood-fired component of option 2, based on published EIA data, EPA 

emission factors (EPA, 1998), performance characteristics for this alternative, and implemented 

emission controls, would likely be:

● SOx – 58.33 tons (52.92 MT) per year

● NOx (with SCR) – 285.80 tons (259.27 MT) per year

● CO – 349.96 tons (317.48 MT) per year

● TSP (filtered) – 233.31 tons (211.66 MT) per year

● PM10 (filtered) – 172.65 tons (156.63MT) per year

● PM2.5 (filtered) – 151.65 tons (137.58 MT) per year

● CO2 – 454,950.60 tons (412,724.24 MT) per year

The wood-fired combustion facility would be subject to the Federal and State air emissions 

regulations described above for the natural gas-fired component of this alternative. Option 2 

would also produce 172.65 tons (156.63 MT) per year of PM having an aerodynamic diameter 

less than or equal to 10 μm (PM10) (40 CFR 50.6(a)) and 151.65 tons (137.58 MT) per year of 

the PM less than 2.5 μm in diameter (PM2.5), which have to meet the national primary and 

secondary ambient air quality standards (40 CFR 50.7a).

Activities associated with the construction of the new, natural gas-fired plant onsite or offsite 

KPS would cause some additional air effects as a result of equipment emissions and fugitive 

dust from operation of the earth-moving and material handling equipment. Vehicles of workers 

and construction motorized equipment exhaust emissions would be temporary. The construction 

crews would employ dust-control practices in order to control and reduce fugitive dust, which 

would be temporary in nature. The staff concludes that the impact of vehicle exhaust emissions 

and fugitive dust from operation of the earth-moving and material handling equipment would be 

SMALL. 

The overall air-quality impacts of the combination alternative consisting of a natural gas-fired 

plant located at the KPS site and wind power (option 1) or of a natural gas-fired plant located at 

the KPS site and wood-fired power (option 2) would be MODERATE.

8.3.2 Groundwater Use and Quality

Impacts to groundwater use and quality from the gas-fired portion of the combination alternative 

would be similar to those identified for the wholly gas-fired alternative in Section 8.1.2, though 

roughly half as large in magnitude. These impacts would be SMALL.

An onsite or offsite wind alternative would likely use much less groundwater than KPS uses for 

its operations. The current average withdrawal rate at KPS is less than 100 gpm (0.01 m3

/s), 

and pumping tests indicate this rate will not cause an effect on nearby supply wells. A reduction 

in this withdrawal rate means that impacts of the combination alternative would remain SMALL.

An offsite wood-fired alternative would likely rely on a minimal amount of groundwater for its 

operations because not many workers would be onsite and because the wood-fired unit would 
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August 2010 8-29 NUREG-1437, Supplement 40

be relatively small and would have few auxiliary systems requiring service water. This 

combination alternative would use less groundwater than KPS. A reduction in the current KPS 

withdrawal rate means that impacts of the combination alternative would remain SMALL.

8.3.3 Surface Water Use and Quality

Impacts to surface water use and quality from the gas-fired portion of the combination 

alternative would be similar to those identified for the wholly gas-fired alternative in 

Section 8.1.2, though roughly half as large in magnitude. These impacts would be SMALL.

An onsite or offsite wind alternative would consume significantly less surface water than the 

amount consumed by KPS for cooling purposes. The maximum consumptive use would be 

reduced to a fraction of the surface water withdrawn by the open-cycle cooling system currently 

in use by KPS. A reduction in this withdrawal rate means that impacts of the combination 

alternative would be SMALL.

An offsite wood-fired alternative would likely consume only a small amount of surface water as 

compared to the amount consumed by KPS for cooling purposes because the wood-fired unit is 

relatively small and would have few auxiliary systems requiring service water. This combination 

alternative would use less surface water than KPS. Assuming that the offsite location uses 

water from a large enough body of water to support its operations, the impacts of the 

combination alternative would be SMALL.

8.3.4 Aquatic and Terrestrial Ecology

The conservation portion of the combination alternative will have positive impacts on aquatic 

communities because less power would need to be generated. Requiring less power will 

decrease the cooling water requirements and pollutant deposition of the gas-fired alternative. 

The gas-fired portion of the combination alternative would have similar effects to those 

discussed in Section 8.2.4, “Aquatic and Terrestrial Ecology;” however, because the gas-fired 

portion of this alternative would only produce 280 MW, rather than 560 MW for the gas-fired 

alternative, the imprint of the plant may be smaller, and therefore, erosion and sedimentation 

during construction and pollutant deposition during operation are expected to be less. Impacts 

from wind-powered and wood-fired portions of this alternative would vary depending on the 

location and ecology of the site but would likely be minimal. Construction in a previously 

disturbed area would have lower impacts to aquatic communities than construction in an 

undisturbed area. Impacts during operation of the wind-powered option are expected to be 

minimal as it does not require a source of cooling water. Some deposition of carbon compounds 

and PM would occur on nearby waterways as a result of burning wood waste. Overall impacts to 

aquatic ecology from combination alternatives are expected to be SMALL.

The largest potential impact to terrestrial resources would occur from the wind turbines. Wind 

turbines have the potential to require large amounts of undisturbed land. There would be a 

potential to mitigate some of these impacts by locating the turbines offshore on Lake Michigan. 

ROW maintenance would continue, although no additional transmission lines would be 

necessary. The construction activities that would occur for the combination alternatives are the 

construction of a combined-cycle gas-fired power plant and any retrofit-related construction and 

the wood-fired power plant or the wind-powered plant. The combined-cycle gas-fired power 

plant activities would be confined to previously disturbed areas at the KPS site. Some habitat 

fragmentation impacts on the KPS site may occur. Impacts to terrestrial ecology would be 

SMALL to LARGE.
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8.3.5 Human Health

The human health risks from a combination of alternatives include the combined-cycle gas-fired 

plant already discussed in 8.1.5. The GEIS (NRC, 1996) notes that the environmental impacts 

of the conservation/demand-side management alternative are likely to be centered on indoor air 

quality. This is due to increased weatherization of the home in the form of extra insulation and 

reduced air turnover rates from the reduction in air leaks. However, the actual impact from the 

conservation alternative is highly site specific and not yet well-established. For wind power, the 

GEIS notes that, except for a potentially small number of occupational injuries associated with 

the construction and routine maintenance of the units, human health would not be affected by 

routine operations. The occupational human health impacts for the operation of a wood-fired 

facility would be comparable to that of agriculture, which is high. This is primarily due to the 

routine movement and handling of large amounts of wood waste that would be needed to fuel 

the plant. The use of protective equipment and adherence to safety requirements would 

minimize the danger to workers. The burning of the wood would generate air emissions that can 

impact human health. The most significant would involve the release of PM. However, these 

emissions can be controlled effectively with existing technology. It is expected that the facilities 

would operate in compliance with Federal and State safety and emission standards.

The human health risks from the combination of alternatives are uncertain but considered to be 

SMALL to MODERATE.

8.3.6 Socioeconomics

8.3.6.1 Land Use

The GEIS generically evaluates the impacts of nuclear power plant operations on land use both 

on and off each power plant site. The analysis of land use impacts for the combination 

alternative focuses on the amount of land area that would be affected by the construction and 

operation of a single, natural gas-fired unit power plant at KPS, an offsite wind energy 

generating power, an offsite wood-fired power plant, and demand-side energy conservation.

Approximately 285 ac (115 ha) would be needed to support a single, natural gas-fired unit 

combination alternative including the gas pipeline, according to staff scaling of DEK estimates. 

By scaling the GEIS estimate, a 292-MWe (gross capacity) plant could require up to 

approximately 304 ac (123 ha) of land, including pipeline. The staff believes that the DEK 

estimate is reasonable. Nevertheless, land use impacts from construction of the natural 

gas-fired power plant at KPS would be SMALL.

In addition to onsite land requirements, land would be required offsite for natural gas wells and 

collection stations. The GEIS estimates that 3,600 ac (1,457 ha) would be required for wells, 

collection stations, and pipelines to bring the gas to a 1,000-MWe generating facility. If this land 

requirement were scaled with a 292-MWe generating capacity, the natural gas-fired power plant 

at KPS could require 1,051 ac (425 ha). Most of this land requirement would occur on land 

where gas extraction already occurs. In addition, some natural gas could come from outside of 

the United States and be delivered as liquefied gas.

The wind farm option of the combination alternative producing 47 MWe of electricity would 

require approximately 10,000 ac (4,050 ha) spread over several locations with approximately 

40 ac (16 ha) in actual use. The wood-fired option of the combination alternative producing 

47 MWe of electricity would require approximately 90 ac (36 ha).
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August 2010 8-31 NUREG-1437, Supplement 40

Since existing transmission lines would be used, land use impacts from the energy conservation 

alternative would be SMALL. Quickly replacing and disposing of old inefficient appliances could 

generate waste material and potentially increase the size of landfills. Given the time for program 

development and implementation, the replacement process would need to begin as soon as 

possible. Some older appliances would simply be replaced by more efficient appliances as they 

fail (especially in the case of frequently replaced items like light bulbs). In addition, many items 

(like home appliances or industrial equipment) have substantial recycling value and would likely 

not be disposed of in landfills.

The elimination of uranium fuel for KPS could partially offset offsite land requirements. In the 

GEIS, the staff estimated that approximately 1,000 ac (405 ha) would not be needed for mining 

and processing uranium during the operating life of a 1,000-MWe nuclear power plant. For KPS, 

roughly 590 ac (239 ha) of uranium mining area would no longer be needed. Overall land use 

impacts from the combination alternative would be SMALL to MODERATE. 

8.3.6.2 Socioeconomics

As previously discussed, 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 a new, single, natural gas-fired 

power plant at the KPS site and wind farm or wood-fired power generating plant could affect 

regional employment, income, and expenditures. Two types of job creation would occur: 

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

long-term socioeconomic impact; and (2) operation-related jobs in support of power generating 

operations, which have the greater potential for permanent, long-term socioeconomic impacts. 

Construction and operations workforce requirements for the combination alternative were 

determined in order to measure their possible effect on current socioeconomic conditions.

Based on GEIS projections and a workforce of 1,200 for a 1,000-MWe plant, a single 292-MWe 

unit at KPS would require a peak estimated construction workforce of 350 workers. Additional 

estimated construction workforce requirements for this combination alternative would include 

300 construction workers for the wind farm option and 131 construction workers for the 

wood-fired option. The number of additional workers would cause a short-term increase in the 

demand for services and temporary (rental) housing in the region around the construction site.

After construction and depending on the size of the community, some local communities may be 

temporarily affected by the loss of the construction jobs and associated loss in demand for 

business services. The rental housing market could also experience increased vacancies and 

decreased prices. The impact of construction on socioeconomic conditions for each of the three 

power generating facilities would be SMALL.

Following construction, a single unit, gas-fired power plant at KPS could provide up to 10 jobs, 

based on scaled DEK estimates, or up to 44 jobs based on GEIS estimates. Additional 

estimated operations workforce requirements for this combination alternative would include 

50 operations workers for the wind farm option and 13 operations workers for the wood-fired 

option. Given the small numbers of operations workers at these facilities, socioeconomic 

impacts associated with the operation of the natural gas-fired power plant at KPS, wind farm, 

and wood-fired power generating plant would be SMALL.

Socioeconomic effects of an energy efficiency program would be SMALL. As noted in the GEIS, 

the program would likely employ additional workers. Lower-income families, in particular, could 
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NUREG-1437, Supplement 40 8-32 August 2010

benefit from weatherization and insulation programs because low-income households 

experience home energy burdens four times greater than the average household (OMB, 2007).

8.3.6.3 Transportation

Transportation impacts would be SMALL because the number of employees commuting to KPS, 

wind farm, and wood-fired power generating plant would be small. Any transportation effects 

from the energy efficiency alternative would be widely distributed across the State and would 

not be noticeable.

Construction and operation of a natural gas-fired power plant, wind farm, and wood-fired power 

generating plant would increase the number of vehicles on roads in the vicinity of these 

facilities. During construction, cars and trucks would deliver workers, materials, and equipment 

to the worksite. The increase in vehicular traffic would peak during shift changes resulting in 

temporary levels of service impacts and delays at intersections. Pipeline construction and 

modification to existing natural gas pipeline systems could also have an impact.

During plant operations, transportation impacts would almost disappear. Given the small 

number of workers at these facilities, impacts on local roads from the operation of the natural 

gas-fired power plant at KPS, the wind farm, and wood-fired power generating plant would be 

SMALL. Transportation impacts at the wind farm and wood-fired power generating plant would 

also depend on current road capacities and average daily traffic volumes. 

8.3.6.4 Aesthetics

As previously discussed, aesthetic resources are the natural and man-made features that give a 

particular landscape its character and aesthetic quality. The aesthetics impact analysis focuses 

on the degree of contrast between the power plant and the surrounding landscape and the 

visibility of the power plant.

A single, natural gas-fired unit located at KPS could be approximately 100 ft (30 m) tall, with an 

exhaust stack up to 175 ft (53 m) tall. The impact would be moderated by higher elevations and 

vegetation. Power plant infrastructure would generally be smaller and less noticeable than the 

KPS containment and turbine buildings. Mechanical draft cooling towers would 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 a short-term impact. Noise from the pipelines 

could be audible offsite near compressors.

In general, aesthetic changes would be limited to the immediate vicinity of KPS and the wind 

farm facilities. The wind farm would have the greatest aesthetic effect. Compared to a 

fossil-fueled power plant unit on 46 to 1,400 ac, the 32,000-ac (13,000 ha) wind farm (with wind 

turbines over 300 ft (100 m) tall) would dominate the view and would be the major focus of 

viewer attention. Therefore, overall aesthetic impacts from the construction and operation of the 

combination alternative would be SMALL to MODERATE.

In addition to seeing new power plant structures at KPS, the wind farm and wood-fired power 

generating plant may require the construction of transmission lines. The transmission lines 

would have a lasting visual effect on the landscape.

Impacts from energy efficiency programs would be SMALL. American Transmission Corporation 

(ATC) would continue to use the existing transmission lines. Some noise impacts could occur in 
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August 2010 8-33 NUREG-1437, Supplement 40

instances of energy efficiency upgrades to major building systems, though this impact would be 

intermittent and short-lived.

In general, aesthetic changes would be limited to the immediate vicinity of KPS, the wind farm, 

and wood-fired power generating plant. Impacts would likely be SMALL to MODERATE at KPS 

and other sites and would depend on the amount of new transmission lines required.

8.3.6.5 Historic and Archaeological Resources

Cultural resources are the indications of human occupation and use of the landscape as defined 

and protected by a series of Federal laws, regulations, and guidelines. Prehistoric resources are 

physical remains of human activities that predate written records; they generally consist of 

artifacts that may alone or collectively yield information about the past. Historic resources 

consist of physical remains that postdate the emergence of written records; in the United States, 

they are architectural structures or districts, archaeological objects, and archaeological features 

dating after 1492. Ordinarily, sites less than 50 years old are not considered historic, but 

exceptions can be made for such properties if they are of particular importance, such as 

structures associated with the development of nuclear power (e.g., Shippingport Atomic Power 

Station) or Cold War themes. American Indian resources are sites, areas, and materials 

important to American Indians for religious or heritage reasons. Such resources may include 

geographic features, plants, animals, cemeteries, battlefields, trails, and environmental features. 

The cultural resource analysis encompassed the power plant site and adjacent areas that could 

potentially be disturbed by the construction and operation of alternative power plants.

The analysis of land use impacts for the combination alternative focuses on the amount of land 

that would be affected by the construction and operation of a single, natural gas-fired unit power 

plant at KPS, an offsite wind energy generating plant, a wood-fired facility, and demand-side 

energy conservation. The impact of constructing and operating a combination alternative at the 

KPS site would be SMALL, due to previous onsite survey work and Dominion’s Cultural 

Resources Protection Plan. As discussed in Section 8.2.6, depending on the resource richness 

of an alternative site ultimately chosen for the wind power alternative, impacts will range from 

SMALL to MODERATE.

Impacts to historic and archaeological resources from implementing the energy efficiency 

programs would be SMALL. A conservation alternative would not affect land use or historical or 

cultural resources onsite or elsewhere in the State.

8.3.6.6 Environmental Justice

The environmental justice impact analysis evaluates the potential for disproportionately high and 

adverse human health and environmental effects on minority and low-income populations that 

could result from the construction and operation of a new, natural gas-fired power plant, wind 

farm, and wood-fired power generating 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. The minority and 

low-income populations are subsets of the general public residing around the site, and all are 

exposed to the same hazards generated from various power plant operations.

Minority and low-income populations could be affected by the construction and operation of a 

new, natural gas-fired power plant, wind farm, and wood-fired power generating plant. The 
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NUREG-1437, Supplement 40 8-34 August 2010

extent of disproportionate effect is difficult to determine since it would depend on the location of 

these power generating facilities. Some of these effects have been identified in resource areas 

discussed in this section. For example, increased demand for rental housing during construction 

could disproportionately affect low-income populations. However, demand for rental housing 

could be mitigated if the power generating facilities are constructed near a metropolitan area. 

Impacts on minority and low-income populations under the combination alternative could range 

from SMALL to MODERATE, due to the small number of workers needed to construct and 

operate the natural gas-fired power plant, wind farm, and wood-fired power generating plant.

Weatherization programs could target low-income residents as a cost-effective energy efficiency 

option since low-income populations tend to spend a larger proportion of their incomes paying 

utility bills (according to the Office of Management and Budget, low income populations 

experience energy burdens more than four times as large as those of average households 

(OMB, 2007)). Impacts to minority and low-income populations from energy efficiency programs 

would be SMALL, depending on program design and enrollment.

8.3.7 Waste Management

During the construction stage of this alternative, land clearing and other construction activities 

would generate waste that can be recycled, disposed onsite, or shipped to an offsite waste 

disposal facility. If the alternative were constructed at the KPS site or any previously disturbed 

site, the amounts of wastes produced during land-clearing would be reduced.

During the operational stage, spent SCR catalysts, which are used to control NOx emissions 

from the natural gas-fired plants, would make up the majority of the waste generated by this 

alternative. 

There would be a small amount of waste generated during the construction of the wind power 

facilities and minimal waste associated with its maintenance.

As stated in the GEIS (NRC, 1996), the wood-fired component of this alternative would produce 

a considerable amount of fly ash, which can be successfully used as beneficial fertilizer and soil 

conditioner.

The staff concludes that overall waste impacts of the combination alternative consisting of a 

natural gas-fired plant located at the KPS site and the wind power (option 1) or the natural 

gas-fired plant located at KPS and wood-fired power (option 2) would be SMALL.

8.4 PURCHASED POWER

In the ER (DEK, 2008), DEK indicated that it was unlikely that purchased power would be 

available in sufficient capacity over the 20-year period of extended operation in order to serve 

as an alternative to license renewal. DEK further indicated that it was likely that relying on 

purchased power would simply shift the responsibility to construct new facilities to replace KPS 

to other generators. In addition, DEK indicated that transmission constraints in northeastern 

Wisconsin make it unlikely that out-of-State purchased power could be imported in sufficient 

quantity to offset KPS’s capacity. The staff has reviewed these assertions and finds them to be 

reasonably reflective of the challenges facing purchased power as an alternative to license 

renewal. As a result, the staff has not separately evaluated purchased power as an alternative 

to license renewal.
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August 2010 8-35 NUREG-1437, Supplement 40

8.5 ALTERNATIVES CONSIDERED BUT DISMISSED

In this section, the staff discusses the energy alternatives that it determined either would not 

individually meet the purpose and need identified in the GEIS or whose costs preclude 

consideration in greater depth. The staff considered several of these alternatives in the 

combination alternatives in Section 8.3. 

8.5.1 Wind Power

The American Wind Energy Association and the DOE indicate that Wisconsin currently has 

449 MW of installed wind capacity (AWEA, Undated). The greatest potential for wind power 

generation in Wisconsin is in the east-central and northeast part of the State, which includes the 

KPS site. Wind power potential ranges from class 3 to class 4 in this area, according to wind 

speed maps published by the Wisconsin Office of Energy Independence (2008). 

Despite Wisconsin’s good wind power potential, wind power is not yet suitable for stand-alone 

large base load capacity. When paired with energy storage or a readily dispatchable power 

source like hydropower, wind could serve as a means of providing base load power. Even if 

suitable, additional backup capacity could be found to support a completely wind-powered 

option, replacing KPS with wind turbines would require more than a doubling of Wisconsin’s 

current capacity by 2013. 

Given wind power’s intermittency and the lack of available backup, as well as the current level 

of implementation in Wisconsin, the staff did not consider wind power as a stand-alone 

alternative to license renewal. However, given Wisconsin’s significant wind resource, the staff 

did consider wind power as a portion of a combination alternative. 

8.5.2 Wood-Fired Power

Two generating stations in Wisconsin currently rely on wood for a portion of their fuel. In 2007, 

these facilities burned 315,811 tons of wood with a heat output of 3,437 billion British thermal 

units (Btu) (Wisconsin Office of Energy Independence, 2008). Further, wood currently 

constitutes the primary renewable energy source in the State. 

In 1999, DOE researchers estimated that Wisconsin has biomass fuel resources consisting of 

urban, mill, agricultural, and forest residues, as well as speculative potential for energy crops. 

Excluding potential energy crops, DOE researchers projected that Wisconsin had 

7,149,128 tons (6,485,579 MT) of plant-based biomass available at $50 per ton delivered 

(Walsh et al., 2000) (costs are in 1995 dollars). Wood-fired power plants in Wisconsin report an 

average heat content of 5,441.5 Btu/lb of wood fuel. Assuming a 33 percent conversion 

efficiency, using all plant-based biomass available in Wisconsin at $50 or less per ton (the 

maximum price the researchers considered) would generate roughly 7.6 terawatt-hours (TWh) 

of electricity. This is roughly two-thirds more electricity than KPS generated in 2008. However, 

most of this potential comes from agricultural residues, almost all of which (97 percent) are from 

corn production. Excluding agricultural residues (many of which are traditionally left on fields 

following harvest and provide fertilization for the following year’s crops), the total potential is 

2 TWh, or less than half of KPS’s 2008 production.

Walsh et al. (2000) go on to note that these estimates of biomass capacity contain substantial 

uncertainty and that potential availability does not mean biomass will actually be available at the 

prices indicated or that resources will be usably free of contamination. Some of these plant 
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NUREG-1437, Supplement 40 8-36 August 2010

wastes already have reuse value and would likely be more costly to deliver because of 

competition. Others, such as forest residues, may prove unsafe and unsustainable to harvest on 

a regular basis.

As a result of limited resource availability, the staff did not consider wood-fired as a stand-alone 

alternative to license renewal. The staff did, however, consider wood-fired as a portion of a 

combination alternative.

8.5.3 Energy Conservation

The Public Service Commission of Wisconsin commissioned a Statewide study of energy 

efficiency and customer-sited renewable energy potential in 2009 (Energy Center of Wisconsin, 

2009). The study’s base case results indicated that by 2018, the achievable potential of 

efficiency savings could amount to 13 percent of total electricity sales, 12.9 percent of peak 

demand, and 8.7 percent of natural gas sales in the State. These estimates are a small fraction 

of the total economic potential identified in the State. The study estimates that by 2012, the 

State could save 1,200 gigawatt-hours (GWh) or 250 MW in peak electricity demand. KPS’s 

operating license will expire in 2013, by which time an additional 1.6 percent of electricity 

demand and total energy could be saved. This amount is less than the power produced by KPS 

in the course of a year, and so, energy efficiency was not considered as a stand-alone 

alternative to license renewal. 

The energy efficiency potential in the State is significant, however, and energy efficiency 

measures tend to have low environmental consequences. As a result, the staff did consider 

energy efficiency as a portion of a combination alternative.

8.5.4 Solar Power

Solar technologies use the sun’s energy to produce electricity. Wisconsin receives between 

4 and 4.5 kilowatt-hours (kWh) per square meter per day, or approximately 0.4 kWh of solar 

radiation per square foot per day, for solar collectors oriented at an angle equal to the 

installation’s latitude (NREL, 2009). At this level of incident solar radiation, photovoltaics are 

likely to be more effective than solar thermal power plants. Because flat-plate photovoltaics tend 

to be roughly 25 percent efficient, a solar-powered alternative would require roughly 3,200 ac 

(1,300 ha) of collectors to provide an amount of electricity equivalent to that generated by KPS 

in 2008. Space between collectors and associated infrastructure increase this land requirement. 

This amount of land, while large, is consistent with the land required for coal and natural gas 

fuel cycles. This amount of power generation, however, would occur only during the day and 

would necessitate some sort of power storage, introducing additional efficiency losses. As noted 

in Section 8.5.1, “Wind Power,” energy storage technologies are in the early stages of 

development and are not yet large enough to provide enough backup capacity to replace KPS.

Given the challenges in meeting base load requirements, the staff did not evaluate solar power 

as an alternative to license renewal of KPS.

8.5.5 Hydroelectric Power

According to researchers at Idaho National Energy and Environmental Laboratory, Wisconsin 

has an estimated 452.9 MWe of technically available, undeveloped hydroelectric resources at 

102 project sites throughout the State (INEEL, 1996). As such, the average potential project is 

small, with no potential sites having greater than a 20-MW potential.
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August 2010 8-37 NUREG-1437, Supplement 40

The staff notes that the total available hydroelectric potential is smaller than the capacity of KPS 

and thus, did not consider hydroelectric power as an alternative to license renewal.

8.5.6 Geothermal Power

Geothermal energy has an average capacity factor of 90 percent and can be used for base load 

power where available. However, geothermal electric generation is limited by the geographical 

availability of geothermal resources (NRC, 1996). As illustrated by Figure 8.4 in the GEIS, no 

feasible location for geothermal capacity exists to serve as an alternative to KPS. The staff 

concluded that geothermal energy is not a reasonable alternative to license renewal of KPS.

8.5.7 Biofuels

In addition to wood and municipal solid-waste fuels, discussed in Section 8.5.11, there are other 

concepts for biomass-fired electric generators, including direct burning of energy crops (crops 

grown specifically as fuel or feedstock for fuel), conversion to liquid biofuels, and biomass 

gasification. In the GEIS, the staff indicated that none of these technologies had progressed to 

the point of being competitive on a large scale or of being reliable enough to replace a base 

load plant such as KPS. After reevaluating current technologies, the staff finds that other 

biomass-fired alternatives are still unable to reliably serve as an alternative to the continued 

operation of KPS and does not consider biofuels to be a viable alternative to KPS license 

renewal.

8.5.8 New Nuclear Power

Sources in the nuclear industry have recently indicated that reactor projects currently under 

development are likely 8 or 9 years from completion, or possibly online in the 2016–2017 

timeframe (Nucleonics Week, 2008). This is 3 to 4 years after the expiration of the license for 

KPS. Further, potential plant owners or operators wishing to submit a new proposal specifically 

to offset the capacity of KPS would require additional time to develop an application. Given the 

relatively short time remaining on the current KPS operating license compared to the time to 

license and construct a new nuclear power plant, the staff has not evaluated new nuclear 

generation as an alternative to license renewal.

8.5.9 Oil-fired Power

EIA’s 2009 Annual Energy Outlook indicates that oil-fired power will not account for any 

additions to capacity in the United States (EIA, 2009a). The variable costs of oil-fired generation 

tend to be greater than those of the nuclear or coal-fired options, and oil-fired generation tends 

to have greater environmental impacts than natural gas-fired generation. The high cost of oil 

(even prior to the record high prices of 2008) has prompted a steady decline in its use for 

electricity generation. Thus, the staff did not consider oil-fired generation as an alternative KPS 

license renewal.

8.5.10 Fuel Cells

Fuel cells oxidize fuels without combustion and related environmental side effects. Power is 

produced electrochemically by passing a hydrogen-rich fuel over an anode and air (or oxygen) 

over a cathode and separating the two by an electrolyte. The only byproducts (depending on 

fuel characteristics) are heat, water, and CO2. Hydrogen fuel can come from a variety of 

hydrocarbon resources by subjecting them to steam under pressure. Natural gas is typically 

used as the source of hydrogen.
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At the present time, fuel cells are not economically or technologically competitive with other 

alternatives for base load electricity generation. EIA projects that fuel cells may cost $5,360 per 

installed kilowatts (kWs) (total overnight costs), or 2.5 times the construction cost of new 

coal-fired generating capacity and 5.7 times the cost of new, advanced gas-fired, 

combined-cycle capacity (EIA, 2009c). In addition, fuel cell units are likely to be small in size 

(the EIA reference plant is 10 MWe). While it may be possible to use a distributed array of fuel 

cells to provide an alternative to KPS, it would be extremely costly to do so and would require 

56 reference-size units. Accordingly, the staff does not consider fuel cells as an alternative to

KPS license renewal.

8.5.11 Municipal Solid Waste

Municipal solid waste combustors incinerate waste to produce steam, hot water, or electricity. 

Combustors use three types of technologies—mass burn, modular, and refuse-derived fuel.

Mass burning is currently the method used most frequently in the United States and involves 

little to no sorting, shredding, or separation. Consequently, toxic or hazardous components 

present in the waste stream are combusted, and toxic constituents are exhausted to the air or 

become part of the resulting solid wastes. Currently, approximately 89 waste-to-energy plants 

operate in the United States. These plants generate approximately 2,700 MWe, or an average 

of approximately 30 MWe per plant (IWSA, 2007). Approximately 19 average-sized plants will 

be necessary to provide the same level of output as the other alternatives to KPS license 

renewal. 

The GEIS indicates that the overall level of construction impact from a waste-fired plant will be 

similar to that for a coal-fired power plant. The GEIS also indicates that waste-fired plants have 

the same or greater operational impacts than coal-fired technologies (including impacts on the 

aquatic environment, air, and waste disposal). The initial capital costs for municipal solid-waste 

plants are greater than for comparable steam-turbine technology at coal-fired facilities or at 

wood-fired facilities because of the need for specialized waste separation and handling 

equipment (NRC, 1996).

Regulatory structures that once supported municipal solid waste incineration no longer exist. 

For example, the Tax Reform Act of 1986 made capital-intensive projects such as municipal 

waste combustion facilities more expensive relative to less capital-intensive waste disposal 

alternatives such as landfills. Also, the 1994 Supreme Court decision C&A Carbone, Inc. v. 

Town of Clarkstown, NY, struck down local flow control ordinances that required waste to be 

delivered to specific municipal waste combustion facilities rather than landfills that may have 

had lower fees. Additionally, environmental regulations have increased the capital cost 

necessary to construct and maintain municipal waste combustion facilities.

Given the small average installed size of municipal solid waste plants and the unfavorable 

regulatory environment, the staff does not consider municipal solid waste combustion to be a 

feasible alternative to KPS license renewal.

8.5.12 Delayed Retirement

In the KPS ER, DEK indicated that few base load plants are likely to retire in the near future in 

Wisconsin. DEK identified roughly 315 MW of capacity operated by other generators in the 

State, which is significantly less than the 590 MW currently produced by KPS. Further, delaying 

retirement of older, coal-fired plants is likely to carry additional environmental impacts, as they 
Environmental Impacts of Alternatives

August 2010 8-39 NUREG-1437, Supplement 40

typically have less-advanced emissions controls. As a result, the staff did not consider delayed 

retirement as an alternative to KPS license renewal.

8.6 NO-ACTION ALTERNATIVE

This section will examine the environmental effects that will occur if the NRC takes no action. 

No action in this case means that the NRC does not issue a renewed operating license for KPS, 

and its license simply expires at the end of the current license term in 2013. If the NRC takes no 

action, the plant will shutdown at or before the end of the current license. After shutdown, plant 

operators will initiate decommissioning according to 10 CFR 50.82.

The staff notes that no action is the only alternative considered in-depth that does not satisfy the 

purpose and need for this SEIS, as it does not meet system needs beyond the term of the 

current license. The no-action alternative would not meet the energy needs currently met by 

KPS or that the alternatives evaluated in Sections 8.1 through 8.3 would satisfy. Assuming that 

a need currently exists for the power generated by KPS, the no-action alternative would require 

the appropriate energy planning decision makers to rely on another alternative or conservation 

to replace or offset KPS’s capacity.

In this section, the staff addresses only those impacts that arise directly as a result of plant 

shutdown. The staff has already addressed environmental impacts from decommissioning and 

related activities in several other documents. These documents include the Final Generic 

Environmental Impact Statement on Decommissioning of Nuclear Facilities, NUREG-0586, 

Supplement 1 (NRC, 2002), the license renewal GEIS (Chapter 7; NRC, 1996), and Chapter 7 

of this SEIS. These analyses either directly address or bound the environmental impacts of 

decommissioning whenever DEK ceases operating KPS.

The staff notes that, even with a renewed operating license, KPS will eventually 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 staff will address the impacts in this 

section. As with decommissioning effects, it is likely that shutdown effects will be similar whether 

they occur at the end of the current license or at the end of a renewed license. The only 

difference is that the impacts will occur 20 years sooner if no action is taken.

Table 8-4. Summary of Environmental Impacts of No Action Compared to Continued 

Kewaunee Power Station Operation

No Action Continued KPS Operation

Air Quality SMALL SMALL

Groundwater SMALL SMALL

Surface Water SMALL SMALL

Ecology SMALL SMALL

Human Health SMALL SMALL

Socioeconomics SMALL to MODERATE SMALL

Waste Management SMALL SMALL
Environmental Impacts of Alternatives

NUREG-1437, Supplement 40 8-40 August 2010

8.6.1 Air Quality

When the plant stops operating, there would be a reduction in emissions from activities related 

to plant operation, such as the use of diesel generators and employees’ vehicles. In Chapter 4, 

the staff determined that these emissions would have a SMALL impact on air quality during the 

renewal term. Therefore, if the emissions decrease, the impact to air quality would also 

decrease and would be SMALL.

8.6.2 Groundwater Use and Quality

The use of groundwater would diminish as plant personnel are removed from the site and 

operations cease. Some consumption of groundwater may continue as a small staff remains 

onsite to maintain facilities prior to decommissioning. Overall impacts would be smaller than 

during operations but would remain SMALL.

8.6.3 Surface Water Use and Quality

The rate of consumptive use of surface water would decrease as the plant is shut down and the 

reactor cooling system continues to remove the heat of decay. Wastewater discharges would 

also be reduced considerably. Shutdown would reduce the already SMALL impact on surface 

water resources and quality.

8.6.4 Aquatic and Terrestrial Resources

Plant shutdown will minimally affect aquatic resources. In Chapter 4 of this SEIS, the staff 

concludes that the impacts of continued operation on aquatic resources will be SMALL. No 

additional land disturbances on or offsite would occur. Maintenance of transmission line ROWs 

will continue, regardless of plant operation. Shutdown will reduce the already SMALL impacts to 

aquatic ecology. As such, the staff concludes that impacts to aquatic resources as a result of 

plant shutdown will be SMALL

Shutdown will minimally affect terrestrial resources. In Chapter 4 of this SEIS, the staff 

concluded that the impacts of continued operation on terrestrial resources will be SMALL. No 

additional land disturbances onsite or offsite would occur. Maintenance of transmission line 

ROWs would continue through 20 years, regardless of plant operation. Shutdown would reduce 

the already SMALL impacts to terrestrial ecology. Accordingly, the staff concludes that impacts 

to terrestrial resources as a result of plant shutdown would be SMALL.

8.6.5 Human Health

Human health risks would decrease following plant shutdown. The plant, which is currently 

operating within regulatory limits, would release less radioactive gaseous and liquid material into 

the environment. Thus, members of the public would receive less radiation exposure. Also after 

shutdown, the variety of potential accidents (radiological and industrial) at the plant would be 

reduced to a limited set associated with shutdown events and fuel handling and storage. In 

Chapter 4 of this SEIS, the staff concluded that the impacts of continued plant operation on 

human health would be SMALL. In Chapter 5, the staff concluded that the impacts of accidents 

during operation would be SMALL. Therefore, shutdown of the plant at the end of its license will 

decrease radioactive emissions and the variety of potential accidents. The staff concludes that 

the impacts to human health following plant shutdown would be SMALL.
Environmental Impacts of Alternatives

August 2010 8-41 NUREG-1437, Supplement 40

The no-action alternative would cause KPS to enter the decommissioning phase. Environmental 

impacts from the decommissioning activities of any reactor before or at the end of an initial or 

renewed license are evaluated in the Generic Environmental Impact Statement for 

Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of 

Nuclear Power Reactors, NUREG-0586, Supplement 1 (NRC, 2002). The document concluded 

that the human health impacts from decommissioning a power reactor are SMALL. In Chapter 7 

of this SEIS, the staff used information contained in NUREG-0586, Supplement 1, its review of 

the applicant’s ER, the site audit, and the public scoping process to conclude that the impacts to 

human health during the decommissioning phase of KPS would be SMALL.

The staff concludes that the impacts to human health for the no-action alternative would be 

SMALL.

8.6.6 Socioeconomics

8.6.6.1 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 KPS 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.

8.6.6.2 Socioeconomics

Plant shutdown would have an impact on socioeconomic conditions in the region around KPS. 

Plant shutdown would eliminate up to 735 jobs and would reduce tax revenue in the region. The 

loss of these contributions, which may not entirely cease until after decommissioning, would 

have a SMALL to MODERATE impact. See Appendix J to NUREG-0586, Supplement 1 

(NRC, 2002) for additional discussion of the potential socioeconomic impacts of plant 

decommissioning. 

8.6.6.3 Transportation

Traffic volumes on the roads in the vicinity of KPS would be reduced after plant shutdown. Most 

of the reduction in traffic volume would be associated with the loss of jobs at the plant. 

Deliveries to the plant would be reduced until decommissioning. Transportation impacts would 

be SMALL as a result of plant shutdown.

8.6.6.4 Aesthetics

Plant structures and other facilities would remain in place until decommissioning, and plumes 

from the plant’s cooling towers would disappear entirely. Noise caused by plant operation would 

cease. Aesthetic impacts of plant closure would be SMALL.

8.6.6.5 Historic and Archaeological Resources

Plant shutdown will likely have no noticeable immediate impacts on historic and archaeological 

resources. Decommissioning methods would be described in a post-shutdown decommissioning 

activities report, which is required to be submitted to the NRC within 2 years following cessation 

of operations. NRC requirements ensure that the decommissioning activities would be subject to 

a Section 106 review in accordance with the National Historic Preservation Act (NHPA). It is 

unlikely that plant staff will begin deconstruction or remediation before decommissioning. 

Because existing transmission lines will remain energized, transmission line ROW maintenance 
Environmental Impacts of Alternatives

NUREG-1437, Supplement 40 8-42 August 2010

would continue. In Chapter 4 of this SEIS, the NRC concluded that the impacts of continued 

plant operation on historic and archaeological resources could be SMALL. 

Impacts from the no-action alternative would also be SMALL, since KPS would be 

decommissioned with no alternative power plant to replace it. A separate environmental and 

Section 106 review would be conducted for decommissioning. That assessment will address the 

protection of historic and archaeological resources.

8.6.6.6 Environmental Justice

Termination of power plant operations would not disproportionately affect minority and 

low-income populations outside of the immediate vicinity of KPS because minority and 

low-income populations are generally concentrated in urban areas. Impacts to all other resource 

areas would be SMALL to MODERATE. Thus, impacts from plant shutdown would be SMALL. 

See Appendix J of NUREG-0586, Supplement 1 (NRC, 2002), for additional discussion of these 

impacts.

8.6.7 Waste Management

If the no-action alternative were implemented, the generation of high-level waste would stop and 

the generation of low-level and mixed waste would decrease. Impacts from implementation of 

the no-action alternative are expected to be SMALL.

8.7 ALTERNATIVES SUMMARY

In this chapter, the staff considered the following alternatives to KPS license renewal:

● a gas-fired combined-cycle plant at the KPS site and an undetermined alternate 

site

● a coal-fired plant at the KPS site and an undetermined alternative site

● two combinations of alternatives including gas-fired capacity, energy 

conservation, and either wind power (option 1) or wood-fired power (option 2)

Finally, the staff considered the effects of no action by the NRC. Impacts for all alternatives are 

summarized in Table 8-5. The impacts of license renewal for KPS are similar to or smaller than 

the impacts of the alternatives considered in this chapter in all resource areas, with the 

exception of no action. No action, however, would necessitate additional action on the part of 

other entities to either replace or offset the power produced by KPS and thus, would result in 

additional impacts similar to those discussed in the other sections of this chapter. 
Environmental Impacts of Alternatives

August 2010 8-43 NUREG-1437, Supplement 40

Table 8-5. Summary of Environmental Impacts of Proposed Action and Alternatives

KPS 

License 

Renewal

Gas-fired 

at the KPS 

Site

Gas-fired 

at an 

Alternate

Site

Coal-Fired 

at the KPS 

Site

Coal-Fired 

at an

Alternate 

Site

Combination 

Option 1

Combination 

Option 2

No-Action 

Alternative

Air Quality SMALL MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE SMALL

Groundwater SMALL SMALL SMALL SMALL SMALL SMALL SMALL SMALL

Surface Water SMALL SMALL SMALL to 

MODERATE SMALL SMALL to 

MODERATE SMALL SMALL SMALL

Ecology SMALL SMALL to 

MODERATE

SMALL to 

MODERATE MODERATE MODERATE SMALL to 

LARGE

SMALL to 

LARGE SMALL

Human Health SMALL SMALL SMALL SMALL SMALL SMALL to 

MODERATE

SMALL to 

MODERATE SMALL

Socioeconomics SMALL SMALL to 

MODERATE

SMALL to 

MODERATE

SMALL to 

LARGE

SMALL to 

LARGE

SMALL to 

MODERATE

SMALL to 

MODERATE

SMALL to 

MODERATE

Waste 

Management SMALL SMALL SMALL MODERATE MODERATE SMALL SMALL SMALL

8.8 REFERENCES

10 CFR 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

Production and Utilization Facilities.”

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

Regulations for Domestic Licensing and Related Regulatory Functions.”

40 CFR 51. Code of Federal Regulations, Title 40, Protection of Environment, Part 51, 

“Requirements for Preparation, Adoption, and Submittal of Implementation Plans.”

40 CFR 60. Code of Federal Regulations, Title 40, Protection of Environment, Part 60, 

“Standards of Performance for New Stationary Sources.”

40 CFR 75. Code of Federal Regulations, Title 40, Protection of Environment, Part 75, 

“Continuous Emission Monitoring.”

64 FR 35714. U.S. Environmental Protection Agency, “Regional Haze Regulations.” Federal 

Register, Volume 64, pp. 35714-35774. July 1, 1999.

American Wind Energy Association (AWEA). Undated. “Resources: U.S. Wind Energy Projects 

(As of 12/31/2008).” Available URL: http://www.awea.org/projects/

Clean Air Act of 1963 (CAA), as amended, 42 U.S.C. 7401 et seq.

(accessed September 12, 

2009). 

Dominion Energy Kewaunee, Inc. (DEK). 2008. “Applicant’s Environmental Report – Operating

License Renewal Stage,” Appendix E of Application for Renewed Operating License, Kewaunee 

Power Station, Docket No. 50-305, August 2008. Agencywide Documents Access and 

Management System (ADAMS) Accession No. ML082341039.
Environmental Impacts of Alternatives

NUREG-1437, Supplement 40 8-44 August 2010

Energy Center of Wisconsin. 2009. “Energy Efficiency and Customer-Sited Renewable 

Resource Potential in Wisconsin for the Years 2012 and 2018,” Prepared by Energy Center of 

Wisconsin, August 2009. Available URL: http://www.ecw.org/ecwresults/WI-Potential-Aug09.pdf

(Alternate URL: http://psc.wi.gov/aboutus/pscreports/reports-index.htm) (accessed 

September 12, 2009). 

Energy Information Administration (EIA). 2008. “Cost and Quality of Fuels for Electric Plants 

2006 and 2007,” DOE/EIA-0191(2007), Washington, D.C., December 2008. Available URL: 

http://tonto.eia.doe.gov/FTPROOT/electricity/019107.pdf

Energy Information Administration (EIA). 2009a. “Annual Energy Outlook 2009 with Projections 

to 2030,” DOE/EIA-0383(2009), Washington, D.C., March 2009. Available URL: 

(accessed September 14, 2009). 

http://tonto.eia.doe.gov/FTPROOT/forecasting/0383(2009).pdf (accessed September 12, 2009).

Energy Information Administration (EIA). 2009b. “Net Generation by Energy Source: Total (All 

Sectors),” Table 1.1 from Electric Power Monthly for June 2009. Available URL: 

http://www.eia.doe.gov/cneaf/electricity/epm/table1_1.html (accessed September 14, 2008).

Energy Information Administration (EIA). 2009c. “Assumptions to the Annual Energy Outlook 

2009 with Projections to 2030,” DOE/EIA 0554 (2009), Washington, D.C., March 2009. 

Available URL: http://tonto.eia.doe.gov/FTPROOT/forecasting/0554(2009).pdf (accessed 

September 14, 2009).

Environmental Protection Agency (EPA). 1998. Compilation of Air Pollutant Emission Factors, 

Volume 1: Stationary Point and Area Sources: AP 42, Fifth Edition, “Section 1.1: Bituminous 

and Subbituminous Coal Combustion: Final Section Supplement E.” Washington, D.C.

Environmental Protection Agency (EPA). 2000a. “Regulatory Finding on Emissions of 

Hazardous Air Pollutants from Electric Utility Steam Generating Units,” Federal Register, 

Volume 65, No. 245, pp. 79825-79831, Washington, D.C. (December 20, 2000).

Environmental Protection Agency (EPA). 2000b. “Notice of Regulatory Determination on Wastes 

from the Combustion of Fossil Fuels,” Federal Register, Volume 65, pp.32214-32237, 

Washington, D.C. (May 22, 2000).

Environmental Protection Agency (EPA). 2008a. “New Source Review.” Available URL: 

http://www.epa.gov/nsr/. ADAMS Accession No. ML083450073.

Environmental Protection Agency (EPA). 2008b. “Basic Concepts of Environmental Science. 

Module 6: Fabric filters.” Available URL: 

http://www.epa.gov/apti/bces/module6/matter/control/control.htm#fabric (accessed June 2009). 

ADAMS Accession No. ML091760654.

Environmental Protection Agency (EPA). 2009a. “The Green Book Nonattainment Areas for 

Criteria Pollutants.” Available URL: http://www.epa.gov/air/oaqps/greenbk/index.html (accessed 

May 2009).

Environmental Protection Agency (EPA). 2009b. “Clean Air Interstate Rule, Wisconsin.” 

Available URL: http://www.epa.gov/CAIR/wi.html (accessed June 2009). ADAMS Accession No. 

ML092010055.

Environmental Protection Agency (EPA). 2009c. “Clean Air Mercury Rule.” Available URL: 

http://www.epa.gov/air/mercuryrule/ (accessed June, 2009). ADAMS Accession No. 

ML082880732.
Environmental Impacts of Alternatives

August 2010 8-45 NUREG-1437, Supplement 40

General Electric Company (GE). 2007. “Gas Turbine and Combined Cycle Products.” 

May 2007. Available URL: http://www.gepower.com/prod_serv/products/gas_turbines_cc/

en/downloads/gasturbine_cc_products.pdf (accessed January 6, 2009). ADAMS Accession No. 

ML082880731.

Idaho National Engineering and Environmental Laboratory (INEEL). 1996. “U.S. Hydropower 

Resource Assessment for Wisconsin,” DOE/ID-10430(WI), Idaho Falls, ID, May 1996. Available 

URL: http://hydropower.inl.gov/resourceassessment/pdfs/states/wi.pdf (accessed 

September 12, 2009).

Integrated Waste Services Association (IWSA). 2007. “Waste-to-Energy and the Production Tax 

Credit.” Washington, D.C. Available URL: http://www.wte.org/docs/FactSheetPTC.pdf (accessed 

May 24, 2007). ADAMS Accession No. ML083050223.

National Renewable Energy Laboratory (NREL). 2009. “United States Atlas of Renewable 

Resources,” Interactive Map. Available URL: http://mapserve2.nrel.gov/website/Resource_Atlas/

viewer.htm

Nucleonics Week. 2008. “U.S. New Reactors More Likely Online in 2016 and Beyond, NEI 

Official Says,” Volume 49, No. 15. April 10, 2008.

(accessed September 12, 2009).

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2, Washington, D.C. 

ADAMS Accession Nos. ML040690705 and ML040690738.

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1, 

Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report,” 

NUREG-1437, Volume 1, Addendum 1, Washington, D.C. ADAMS Accession No.

ML040690720.

U.S. Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement 

on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of 

Nuclear Power Reactors, NUREG-0586, Supplement 1, Volumes 1 and 2, Washington, D.C. 

U.S. Office of Management and Budget (OMB). 2007. “Detailed Information on the Low Income 

Home Energy Assistance Program Assessment.” Available URL: http://www.whitehouse.gov/

omb/expectmore/detail/10001059.2003.html

Walsh, et al. 2000. “Biomass Feedstock Availability in the United States: 1999 State Level 

Analysis.” Available URL: 

(accessed July 10, 2007). ADAMS Accession No. 

ML082880730.

http://bioenergy.ornl.gov/resourcedata/index.html (accessed May 22, 

2007). ADAMS Accession No. ML083050223.

Wisconsin Department of Natural Resources (WDNR). 2008. “Factsheet on Rule to Control 

Mercury Emissions from Coal-Fired Power Plants.” ADAMS Accession No. ML092010055.

Wisconsin Department of Natural Resources (WDNR). 2009. “Global Climate Change. Reports 

and Documents.” Available URL: http://dnr.wi.gov/air/aq/global/climatechange/reports.html

(accessed June, 2009).
Environmental Impacts of Alternatives

NUREG-1437, Supplement 40 8-46 August 2010

Wisconsin Office of Energy Independence. 2008. 2008 Wisconsin Energy Statistics Book.

Available URL: 

http://energyindependence.wi.gov/subcategory.asp?linksubcatid=2825&linkcatid=2847&linkid=1

451&locid=160 (accessed September 12, 2009).
August 2010 9-1 Draft NUREG- 1437, Supplement 40

9.0 CONCLUSION

This supplemental environmental impact statement (SEIS) contains the environmental review of 

the Dominion Energy Kewaunee, Inc. (DEK) application for the renewed operating license for 

Kewaunee Power Station (KPS) as required by Title 10, Part 51, of the Code of Federal 

Regulations (10 CFR Part 51) that implements the National Environmental Policy Act (NEPA). 

This chapter presents the conclusions and recommendations from the site-specific 

environmental review of KPS and summarizes site-specific environmental issues of license 

renewal that were identified during the review. 

9.1 ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL

Our review of site-specific environmental issues in this SEIS leads the staff to conclude that 

issuing a renewed license would have SMALL impacts for the Category 2 and uncategorized 

issues applicable to license renewal of KPS.

The requirements for the assessment of refurbishing in a license renewal of operating nuclear 

power plants include the preparation of an integrated plant assessment (IPA) under 

10 CFR 54.21. The IPA must identify and list systems, structures, and components subject to an 

aging management review. Items that are subject to aging and might require refurbishment 

include, for example, the reactor vessel, piping, supports, and pump casings, as well as those 

that are not subject to periodic replacement. In the case of KPS, the IPA did not identify the 

need of major refurbishment or replacement actions to maintain the functionality of important 

systems, structures, and components during the KPS license renewal period. Also, the IPA did 

not identify the need for modifications to any of the KPS facilities associated with the license 

renewal.

Currently, no threatened or endangered aquatic species are known to occur within Lake 

Michigan on, or in the vicinity of the KPS site or within any streams crossed by in-scope 

transmission line right-of-ways (ROWs); therefore, license renewal of KPS would have no effect 

on any Federally or State-listed aquatic species, and mitigation measures need not be 

considered.

Operation of the KPS site and its associated transmission lines is not expected to adversely 

affect any threatened or endangered species during the license renewal term; therefore, the 

staff concludes that adverse impacts to threatened or endangered species during the period of 

extended operation would be SMALL. There are several mitigation measures currently in place 

at the KPS site and along its associated transmission lines, which the staff finds to be adequate. 

Mitigation measures include: nest construction and placement for the peregrine falcon, 

environmental review checklists, environmental evaluation forms, and best management 

practices.

9.2 COMPARISON OF THE ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL 

AND ALTERNATIVES 

In the conclusion to Chapter 8, the staff determined that impacts from license renewal are 

generally similar to, or smaller than, the impacts of alternatives to license renewal. In comparing 

likely environmental impacts from gas-fired, coal-fired, and two combinations of alternatives, 
Conclusion

NUREG-1437, Supplement 40 9-2 August 2010

including gas-fired capacity, energy conservation, and either wind power (option 1) or 

wood-fired power (option 2), to the environmental impacts from license renewal, the staff found 

that license renewal would result in the lowest environmental impact. On the basis of its 

analysis, the staff found that the impacts of license renewal are reasonable in light of the 

impacts from the alternatives to the license renewal. 

9.3 RESOURCE COMMITMENTS

9.3.1 Unavoidable Adverse Environmental Impacts 

Unavoidable adverse environmental impacts are impacts that would occur after implementation 

of all feasible mitigation measures. Implementing 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 the 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 (EPA) emissions standards, though 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 any 

standards or administrative control limits. Construction and operation of non-nuclear power 

generating facilities would also result in unavoidable exposure to hazardous and toxic chemicals 

to workers and the general public.

Also unavoidable would be the generation of spent nuclear fuel and waste material, including 

low-level radioactive waste, hazardous waste, and nonhazardous waste. 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 regulations. 

Due to the costs of handling these materials, power plant operators would be expected to 

conduct all activities and optimize all operations in a way that would generate the smallest 

amount of waste practical.

9.3.2 Relationship Between Local Short-Term Uses of the Environment and the 

Maintenance and Enhancement of 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 during which 

continued power generating activities would take place.

Power plant operations would necessitate short-term use of the environment and commitments 

of resources and would also commit certain resources (e.g., land and energy) indefinitely or 

permanently. Certain short-term resource commitments would be substantially greater under 
Conclusion

August 2010 9-3 NUREG-1437, Supplement 40

most energy alternatives, including license renewal, than under the no-action alternative due to 

the continued generation of electrical power, as well as continued use of generating sites and 

associated infrastructure. During operations, all energy alternatives would entail 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 would 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 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 would 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 spent nuclear fuel, low-level radioactive waste, hazardous 

waste, and nonhazardous waste would require an increase in energy and would consume 

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 would be 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 

Irreversible and irretrievable commitments of resources for electrical power generation would 

include the commitment of land, water, energy, raw materials, and other natural and man-made 

resources required for power plant operations. This section describes the irreversible and 

irretrievable commitments of resources that have been identified in this SEIS. A commitment of 

resources is irreversible when primary or secondary impacts limit the future options for a 

resource. An irretrievable commitment refers to the use or consumption of resources neither 

renewable nor recoverable for future use. In general, the commitment of capital, energy, labor, 

and material resources would also be irreversible.

The implementation of any of the energy alternatives considered in this SEIS would entail the 

irreversible and irretrievable commitments 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 would essentially be unrecoverable.

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 fuels 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.

The irreversible and irretrievable commitments of material resources include materials that 

cannot be recovered or recycled, materials that are rendered radioactive and cannot be

decontaminated, and materials consumed or reduced to unrecoverable forms of waste; 
Conclusion

NUREG-1437, Supplement 40 9-4 August 2010

however, none of the resources used by these power generating facilities is in short supply, 

and, for the most part, are readily available.

Various materials and chemicals, including acids and caustics, would be required to support 

operations activities. These materials would be derived from commercial vendors, and their 

consumption is not expected to affect local, regional, or national supplies.

The treatment, storage, and disposal of spent nuclear fuel, low-level radioactive waste, 

hazardous waste, and nonhazardous waste would require the irretrievable commitment of 

energy and fuel and would result in the irreversible commitment of space in disposal facilities.

9.4 RECOMMENDATION

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

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

makers. This determination is based on: (1) the analysis and findings in the GEIS; (2) 

information submitted in DEK’s Environmental Report; (3) consultation with other Federal, State, 

and local agencies; (4) the staff’s own independent review; and (5) a consideration of public 

comments received during the scoping process and the draft SEIS comment period.
August 2010 10-1 NUREG-1437, Supplement 40

10.0 LIST OF PREPARERS

This supplemental environmental impact statement (SEIS) was prepared by members of the 

Office of Nuclear Reactor Regulation, with assistance from other U.S. Nuclear Regulatory 

Commission (NRC) organizations and contract support from Information Systems Laboratory.

Table 10-1. List of Preparers. Information Systems Laboratory provided contract support for 

the severe accident mitigation alternatives (SAMA) analysis presented in Chapter 5 and 

Appendix F.

Name Affiliation Function or Expertise

Nuclear Regulatory Commission

Briana Balsam

April BeBault

Nuclear Reactor Regulation

Nuclear Reactor Regulation

Ecology

Air Quality, Ecology

Dennis Beissel Nuclear Reactor Regulation Hydrology

Richard Bulavinetz Nuclear Reactor Regulation Aquatic Ecology

Daniel Doyle

Andrew Imboden

Stephen Klementowicz

Nuclear Reactor Regulation

Nuclear Reactor Regulation

Nuclear Reactor Regulation

Project Manager

Branch Chief

Radiation Protection

Dennis Logan Nuclear Reactor Regulation Ecology

Robert Palla Nuclear Reactor Regulation Severe Accident Mitigation 

Alternatives

Bo Pham Nuclear Reactor Regulation Branch Chief

Jeffrey Rikhoff Nuclear Reactor Regulation Socioeconomics, Land Use, 

Environmental Justice, Historical 

and Cultural Resources

Andrew Stuyvenburg Nuclear Reactor Regulation Alternatives

Jeremy Susco

Allison Travers

Nuclear Reactor Regulation

Nuclear Reactor Regulation

Project Manager

Hydrology, Nonradiological Waste

SAMA Contractor

Bruce Mrowca Information Systems Laboratory Severe Accidents Mitigation 

Alternatives

Robert Schmidt Information Systems Laboratory Severe Accidents Mitigation 

Alternatives
THIS PAGE IS INTENTIONALLY LEFT BLANK
APPENDIX A

COMMENTS RECEIVED ON THE ENVIRONMENTAL REVIEW
THIS PAGE IS INTENTIONALLY LEFT BLANK
August 2010 A-1 NUREG-1437, Supplement 40

A. COMMENTS RECEIVED ON THE KEWAUNEE POWER STATION 

LICENSE RENEWAL ENVIRONMENTAL REVIEW

A.1 COMMENTS RECEIVED DURING SCOPING

The scoping process related to the review of the Kewaunee Power Station (KPS) license 

renewal application submitted by Dominion Energy Kewaunee, Inc. (DEK), began on October 9, 

2008, with the publication of the U.S. Nuclear Regulatory Commission’s (NRC’s) Notice of Intent 

to conduct scoping in the Federal Register (73 FR 59678). The scoping process included two 

public meetings held at the Town Hall in Carlton, Wisconsin, on October 22, 2008. 

Approximately 60 members of the public attended the meetings. After the NRC’s prepared 

statements pertaining to the license renewal process, the meetings were open for public 

comments. Attendees provided oral statements that were recorded and transcribed by a 

certified court reporter. All written statements submitted at the public meeting were appended to 

the transcript. Transcripts of the entire meeting are an attachment to the Scoping Meeting 

Summary dated November 17, 2008 (NRC, 2008a). In addition to the comments received during 

the public meetings, comments were received by letter and by electronic mail and were 

addressed by the staff.

At the conclusion of the scoping period, the staff reviewed the transcripts and all written material 

to identify specif comments and issues. Each commenter was given a unique identifier so that 

every comment could be traced back to its author. Table A-1 identifies individuals providing 

comments applicable to the environmental review, their Commenter ID, and each person’s set 

of comments. The individuals are listed in the order in which they spoke at the public meeting 

and in alphabetical order for the comments received by letter or e-mail. To maintain consistency 

with the Scoping Summary Report, 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 and 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 Category 1 issues (generic issues), Category 2 issues (site-specific 

issues), or issues not addressed in the Generic Environmental Impact 

Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437 

(NRC, 1996), (NRC, 1999). They also address alternatives to license renewal 

and related Federal actions.

● general comments: (1) in support of or opposed to nuclear power or license 

renewal or (2) on the renewal process, the NRC’s regulations, and the 

regulatory process. These comments may or may not be specifically related to 

the KPS license renewal application.

● comments that do not identify new information for the NRC to analyze as part of 

its environmental review. 

● comments that address issues that do not fall within or are specifically excluded 

from the purview of NRC environmental regulations related to license renewal. 
Appendix A

NUREG-1437, Supplement 40 A-2 August 2010

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.

Table A-1. Commenters on the Scope of the Environmental Review. Each commenter is 

identified along with their affiliation and how their comment was submitted.

Commenter ID Commenter Affiliation (If Stated) Comment Source; ML No(s).

KPS-A Dave Hardtke Local Citizen

Afternoon Scoping Meeting; 

Evening Scoping Meeting; 

ML083190734;

ML083190744

KPS-B Stanley Lacrosse Local Citizen

Afternoon Scoping

Meeting; Written Comments; 

ML083190734;

ML083100095;

ML090440072

KPS-C Ken Paplham Board Supervisor, Town of Carlton Afternoon Scoping Meeting; 

ML083190734

KPS-D Francis Wojta Local Citizen Afternoon Scoping Meeting; 

ML083190734

KPS-E Rich Langan Congressman Steve Kagen’s Office Afternoon Scoping Meeting; 

ML083190734

KPS-F Bob Garfinkel Kewaunee County Board; Literacy 

Partners of Kewaunee County

Afternoon Scoping Meeting; 

ML083190734

KPS-G Jennifer Brown Kewaunee County Economic 

Development Corporation

Afternoon Scoping Meeting; 

ML083190734

KPS-H Lori Hucek Kewaunee County Emergency 

Management

Afternoon Scoping Meeting; 

ML083190734

KPS-I Jim Soletzki State of Wisconsin Assembly 

Representative

Afternoon Scoping Meeting; 

Written Comment; 

ML083190734; ML083100092

KPS-J Mr. Carrole Local Citizen Evening Scoping Meeting; 

ML083190744

KPS-K Steve Tadisch Local Citizen Evening Scoping Meeting; 

ML083190744

KPS-L Bob Ziegelbauer State Representative, 25th Assembly 

District; Manitowoc County Executive

Letters; ML083100586;

ML083100094

KPS-M Nancy Crowley Manitowoc County Emergency 

Services Coordinator Letter; ML083100093

KPS-N Gregory Veith IUOE Local 310 President; Dominion 

Energy Kewaunee, Inc. E-mail; ML083380455

Comments received during scoping applicable to this environmental review are presented in this 

section along with the NRC response. Comments general or outside the scope of the 

environmental review for KPS are not included here. Those comments can be found in the 

Scoping Summary Report (NRC, 2009a). Scoping comments are grouped in the following 

categories: socioeconomics; uranium fuel cycle and waste management.
Appendix A

August 2010 A-3 NUREG-1437, Supplement 40

A.1.1 Comments and Respons es: Socioeconomics (Taxes and Dis tribution of Revenues )

Comment: The nuclear plant also pays over $6 million in utility taxes to the State of Wisconsin 

every year. Wisconsin is the only State in which that utility does not stay in the municipality 

where the plant is located. Why is that? All property owners in the town of Carlton are currently 

paying full taxes as well, and deserve to be compensated. (KPS-B-1)

Comment: One reason the people of the Township of Carlton are upset is the distribution of the 

money from the utility tax which the Kewaunee Nuclear Power Plant pays. The plant occupies 

1000 acres of what was once prime agricultural land. It purchased said land from 13 “small 

farms” which includes 1 mile of lake frontage where it is possible to walk out to the water’s 

shore. Now the rest of the taxpayers have had to pay extra property taxes to help make up for 

the lost valuation of those farms. It is simply a matter of getting compensated for what the town 

has lost. (KPS-B-2)

Comment: Okay. Ms. Lopas you said that your committee oversees the, like land use and the 

water and the natural resources and all that. I have a question about land use. I’m from the town 

of Carlton. I live about three miles north of the nuclear plant. The way I understand it right now 

the utility taxes that we get from having that plant here just about equals the taxes that we would 

have gotten from homes that would have been built on that property. That means that in my 

opinion that means that nothing is gained by having the nuclear waste being stored here on this 

property which is what is going on right now. Above ground is the waste storage. The pools are 

full. So my question is what, what's going to happen when the plant closes and then the utility 

tax no longer applies? The waste is still going to be there. We’re not getting anything for that 

waste. What do we have to gain by extending the license, having more and more waste being 

piled up there, high level waste. That's part of my concern. (KPS-A-1)

Comment: You know, it, it’s a shame to listen and we have to listen and it’s not fair because I 

can tell you right now the perception of our town of Carlton by the public service commission, 

the NRC and all our elected officials as being a tax free township is not true. We pay more taxes 

than our neighboring town. And this is not right for the simple reason we had 480 signatures out 

of a possibly I think there’s maybe a little over 600 people that are voting in this town and we 

had 480 signatures against letting them put the caskets on top of the ground unless we get 

compensated. And our town officials gave them the building permit. They scared them into it. 

Giving them a line. And this is what’s all wrong because they ruined our zoning book because 

they said they didn’t need a variance, they didn't need a conditional use, they didn’t need that so 

they turned around and gave them the building permit and now they don’t even, they don't know 

us no more. They're supposed to work without trying to get a little more money out of the State. 

The State gets six million, very close, for utility tax but none of it stays. We have to share it with 

the county for 19 percent.

And I have to sort of correct Cindy a little bit. If they could put this town back the way it was 

without the nuclear plant we would pay less taxes. And this is what really makes it bad because 

in 1968 when they broke ground they bought this land real cheap. And the State says the 

assessor will be within ten percent of 100 so the assessor has to keep raising the rest of us to 

make up the difference so that’s why our taxes are higher than the Town of Franklin or the Town 

of Kewaunee. And I don’t think this is right and that’s why I’m opposing it and all the 480 

signatures are opposing relicensing that plant until this gets settled.

I’ve got them all, all our officials, even the governor. They want to take the moratorium off to 

build a nuclear plant because it's the safest, the cleanest. Like I wrote in a letter to them when I 
Appendix A

NUREG-1437, Supplement 40 A-4 August 2010

sent them all the signatures. Where are you going to put the waste? We’ve stored it for 34 years 

under water and we finally got 50,000 and then Dominion devaluated the plant and we lost, how 

much? $37,000. Now you just said just a few minutes ago that they update, update, update. It's 

running at full capacity. How come you can devaluate it? I mean that's not your doing, but it, 

that's lost us $37,000. (KPS-B-3)

Comment: I would like to like to make a little comment on that. It’s only pocket change for 

Dominion. But at the same time -- all this volunteer that we have to take is on our fire 

departments. And the fire departments don’t get a penny to do exactly what Dominion wants to 

get in so that everything is perfect. Us guys never get a penny. We don’t even get paid for the 

gas in the, in the trucks that do all the running. So I don’t -- The volunteer, the volunteer fire 

departments don't get paid. (KPS-B-4)

Comment: I’d like to differ with that. They do get paid. Any type of response that they have with 

us whether it’s training or for real they bill us. We pay them from our county’s budget that we get 

reimbursed from the plant. If a person has to take off of work we pay their wages that day 

because they have responded to a training or an exercise or a real event. That is not true. 

(KPS-H-2)

Comment: If NRC can come over here and overrule our zoning because they are that big and 

they can step on us, it’s like I told our State senator, we have only 600 voting people in the town 

and you don't give a damn about us. And that was Herb Cole. And it’s the same with Kagen’s 

office and it’s the same with every one of them. We met with them all. And Gary Visor is the only 

one that is trying to fight for us. But the State of Wisconsin is the only State that takes all the 

utility tax and sends back what they want. (KPS-J-1)

There’s no incentive for Yucca Mountain to have something done when the rods can be stored 

at the facility when they get 95 percent of the money. We get the five percent of the money 

where I think if we got compensated at the very least maybe Yucca Mountain would say hey this 

is goes here we should get that. That’s just the way I feel. (KPS-D-1)

Response: Chapter 2 of this SEIS includes a discussion of the regional tax structure and the 

distribution of present revenues to each jurisdiction and district, however, the NRC has no role 

in how States and local jurisdictions tax their utilities, assess power plant value, or how tax 

money is distributed.

A.1.2 Comments and Responses: Uranium Fuel Cycle and Was te Management

Comment: I’m Ken Paplham. I’m on the town board here for 34 years as supervisor. And back 

in January of '93 the town board passed a resolution that there would be no outdoor storage at 

the power plant. We passed a resolution at that time. And now we’re getting these stored 

outside and I think the municipality should be compensated from the Federal government of 

$250,000 a year plus $40,000 for each containment that’s stored there as long as they’re stored 

there. I don’t know why these municipalities have to put up with this storage when we had a 

resolution back in '93 that there was going to be no storage. I know the plant is in problems with 

Yucca Mountain but so I think something has to be done. Why should we live with that and like 

Cindy said right out in the open and Yucca Mountain is going to be a mile under the ground or in 

the, in a shaft there so. (KPS-C-1)

Comment: I am sending this letter to our officials on behalf of the citizens and taxpayers from 

the town of Carlton, in Kewaunee County. State and Federal officials need to take a good look 
Appendix A

August 2010 A-5 NUREG-1437, Supplement 40

at an alternative storage facility in order to keep the Kewaunee Nuclear Power Plant in 

operation. The storage the plant has in existence will soon be depleted; by the year 2011 

operation may have to be suspended until a suitable solution is found. We have come to know 

that nuclear energy is the most affordable, cleanest, most reliable, and safest way to achieve 

the emission savings that our nation has to strive for. That is why it is important to address this 

matter with the attention it deserves.

The nuclear plants new owners, Dominion, recently came to the town meeting seeking approval 

to construct the dry storage facility for spent fuel rods on site. This is due to the fact that the 

pools which currently store the spent rods are reaching their maximum capacity. It had been 

promised by the Wisconsin Public Service that the rods were to be moved to Yucca Mountain, 

yet they are unfairly being forced to be stored in the town without being fully compensated. The 

nuclear plant has paid millions, if not billions, of dollars to the Federal Government over more 

than a 30 year span for a place to store the spent rods. And yet, regrettable, nothing has ever 

happened. Every spent rod since operation began in 1974 is still stored at the plant site.

The dry storage location needs serious consideration. If nuclear power is less expensive than 

coal or natural gas, as well as cleaner, all the more important to work our hardest to maintain 

operation of the Kewaunee nuclear plant. We need our State and U.S. senators as well as 

Representatives to help do what is necessary and fair for the property owners here in the town 

of Carlton. The need for this dry storage is present and understood; let us work together for the 

benefit of everyone to create a workable solution. (KPS-B-5)

Comment: “We the undersigned believe that if Dominion (Kewaunee Nuclear Power Plant) is 

allowed to construct the dry storage facility on site which is being proposed the land owners of 

the town of Carlton should be compensated accordingly. Meaning until the spent rods are 

moved to an alternate location, only then would it be fair if compensation were to cease.” 

(KPS-B-6)

The complete petition is available at accession number ML083100095.

Comment: We have sent this letter to our officials on behalf of the citizens and taxpayers from 

the Town of Carlton, in Kewaunee County. State and Federal officials need to take a good look 

at an alternative storage facility in order to keep the Kewaunee Nuclear Power Plant in 

operation. The storage the plant has in existence will soon be depleted; by the year 2011 

operation may have to be suspended until a suitable solution is found. We have come to know 

that nuclear energy is the most affordable, cleanest, most reliable, and safest way to achieve 

the emission savings that our nation has to strive for. That is why it is important to address this 

matter with the attention it deserves.

Another concern is the “promise” once made that the spent fuel rods from this plant would be 

moved to Yucca Mountain, that has failed to happen as of yet. We are all concerned for our 

well-being and also that of our families and neighbors, the entire community. We believe this is 

God’s country and need to protect what we have for our future generations, our grandchildren 

and great-grandchildren.

The nuclear plants new owners, Dominion, recently came to the town meeting seeking approval 

to construct a dry storage facility for spent fuel rods on site. This is due to the fact that the pools 

which currently store the spent fuel rods are reaching their maximum capacity. It has been 

promised by the Wisconsin Public Service that the rods were to be moved to Yucca Mountain, 

yet they are unfairly being forced to be stored in the town without being fully compensated. The 
Appendix A

NUREG-1437, Supplement 40 A-6 August 2010

nuclear plant has paid millions, if not billions of dollars to the Federal government over more 

than a 30 year span for a place to store the spent rods. And yet, regrettably, nothing has ever 

happened. Every spent rod since operation began in 1974 is still stored at the plant site.

The dry storage location needs serious consideration. If nuclear power is less expensive than 

coal or natural gas, as well as cleaner, all the more important to work our hardest to maintain 

operation of the Kewaunee nuclear plant. We need our State and U.S. senators as well as 

Representatives to help do what is necessary and fair for the property owners here in the town 

of Carlton. The need for this dry storage is presenting and understood; let us work together for 

the benefit of everyone to create a workable solution. (KPS-B-7)

Comment: 

The town board of the town of Carlton, Kewaunee County, Wisconsin, meeting in 

a regularly scheduled session on the 12 day January, 1993, upon consideration 

of the matter and upon vote duly taken, hereby resolves that:

Resolution of Conditional Approval

The town board of the town of Carlton, Kewaunee County, Wisconsin, approves 

and supports the proposal before the State of Wisconsin to modify the addendum 

payment formula of utility tax if, and only if, all affected utilities are prohibited by 

law from moving or removing any spent fuel currently stored in pools, or to be 

stored in pools in the future, unless such removal is for the sole purpose of 

immediate transport out of the town of Carlton.

The basis for this Resolution is that the town board strongly believes that the 

remuneration to the town of Carlton from and on behalf of the nuclear power 

plant in the Town is unfairly and disproportionately low, in light of the 

environmental and health risks to the residents, livestock, and land of the town of 

Carlton and surrounding communities. (KPS-B-8)

The above Resolution is available at accession number ML090440072. The town of Carlton 

board meeting proceedings dated May 13, June 10, and July 10, 2008, were attached to the 

resolution and are also available at ML090440072.

Comment: How can it be just as safe above ground with a fence around it compared to being 

under the ground about a mile under the ground with a 5,000 I believe, 5,000 foot high mountain 

on top of it? How can it be just as safe sitting out there a few miles from my house and who 

knows how long it’s going to sit there? (KPS-A-2)

Comment: My name is Stanley Lacrosse and I’ve lived in this town for 54 years and I’ve heard 

nothing but lies all the way through. I’ve attended every meeting. And what I’m against, strongly 

oppose licensing this plant until we get these issues solved for the simple reason we have these 

caskets up there. We have to take your word for it, the NRC word for it that they’re safe. And 

you say they’ll be moved. That’s not true. They’ll never move because I got the CRS report 

updates since October of 2008 and it says right in there possibly the year 2020 they might start 

receiving. But it also states that if everyone goes there there’s not enough room. So you know 

the furthest one away will never go. (KPS-B-9)

Comment: Yeah, I’m Francis Wojta. I’m just a dairy farmer down the road. I’m probably just an 

average joe farmer. But, whoops, I just, you know, the NRC takes care of the licensing process, 

the DOE takes care of the energy process of it. And I know it’s, the Federal government is a big 

bureaucracy. And if somehow they could get together because we say our concerns to you well 

that’s the department, DOE, you have to talk to those people. And we never, the local people 
Appendix A

August 2010 A-7 NUREG-1437, Supplement 40

never get clear cut answers, you know. You started out with public service they said no rods 

would be stored here. Dominion came, we have rods stored here. They’re a good partner I feel 

and they do everything safely. We feel safe with the plant but now we’re storing nuclear rods.

Part of the, part of our tax money goes to pay for the electric bill, goes to Washington for fuel 

storage which is supposed to go to Yucca Mountain. So Yucca Mountain gets 95 percent of our 

tax money to build Yucca Mountain that was supposed to be done in 1998. Now they’re saying 

it’s supposed to be done in 2018, okay. Or whatever date it’s supposed to be done. We aren’t 

sure of that, okay. Here the rods sit here. There’s no incentive for Yucca Mountain to have 

something done when the rods can be stored at the facility when they get 95 percent of the 

money. We get the five percent of the money where I think if we got compensated at the very 

least maybe Yucca Mountain would say hey this is goes here we should get that. That’s just the 

way I feel. (KPS-D-2)

Comment: I just want to inform you a little bit that 26 plants already have gotten billions of 

dollars from the Department of Energy. One just got 56 million last March. So it’s, the 

Department of Energy is paying it out but it is not coming from the, the nuclear fund. It has come 

from us taxpayers. (KPS-C-2)

Comment: I’m from Congressman Kagen’s office. Okay. When we talk about suing the Federal 

government what happens is that anybody who is served by a nuclear power plant there’s a 

surcharge put on your electric bill. I live in Ashwaubenon and a couple of communities away. It’s 

served by and I pay a surcharge. That surcharge goes into a big pot of dollars to the 

Department of Energy. The Department of Energy holds these dollars for the formulation of a 

place like Yucca Mountain. Now some of these nuclear plants are running out of room. So 

they’re saying what do you want us to do about this Federal government you’re not taking our 

garbage. We want the garbage taken out. And the Federal government, DOE is saying sorry we 

can’t accept it just yet. So what happens here now is that okay we’re going to sue you. Well yes, 

that’s fine, we’re not suing the NRC we’re going to sue the DOE because the DOE is charged 

with formulating Yucca Mountain here. So Congress said okay if you’re going to sue we’re not 

going to let this money come from the Yucca Mountain fund. We’re going to put a pot of dollars 

over here in another pot from the general treasury of the United States. And if any nuclear plant 

is successful in suing the Federal government the money will not come out of Yucca Mountain 

fund it will come out of the general treasury fund. So what happens now is that that money that’s 

coming out of the general treasury fund is not as, has never been issued or given out to 

municipalities. It has only been given back to the nuclear plant that has successfully sued the 

government and the only use of this money is for constructing dry cask storages, okay. So that’s 

the long and the short of it. It’s only going to be used for construction of casks and it’s not going 

to go back to the municipality that is, right where the light waste is located. So I hope that kind of 

gives everybody a little bit of heads up on when we are able to sue successfully sue Uncle Sam. 

(KPS-E)

Comment: Yeah, let’s just clear the issue up here. This isn’t against Carlton against Dominion. 

Dominion is a good electrical provider and that. We need, we need power. Nuclear power is, we 

hope it’s safe. The big problem with nuclear power is the waste issue. Dominion’s good as far 

as civil projects and helping people out and being a good neighbor, okay. We’re not against 

that. We want to get the issue of the, the waste solved and we just don’t like to have it here, you 

know. (KPS-D-3)
Appendix A

NUREG-1437, Supplement 40 A-8 August 2010

Comment: I just want to ask a question here. Do anyone of these people that they would take 

one of those dry casks in their village or the city of Green Bay. Or like I asked Senator Cole if I 

put one in his parking lot -- over in the ballpark. You know what the answer is? You know what 

the answer is? No, no not in my backyard. And Mr. Soletzki said the same thing. Human error. 

Human error is all it takes just remember that. This is what we’re all worried about is that human 

error. Mr. Munsin said it’s so safe. I told him I’ll tell you what if it’s that safe how about putting it 

in writing so I can have it recorded in the courthouse that it’s good for a hundred years, so then I 

don’t have to worry about my grandkids and my great grandkids. You know I’ve been here first. 

(KPS-B-10)

Comment: I think that’s what’s broken in the system. You stand up there and say it’s not your 

issue. We go to the DOE. DOE is not in control of those rods yet. They belong to Dominion. And 

so we’re stuck with them. So who do we talk to? Dominion says they, they aren’t going to settle 

anything with us. You said you aren’t in control. The DOE says they aren’t in control but now 

whose taking responsibility for them? (KPS-A-3)

Comment: Well, I’ve got the CRS report here. And it’s an updated one for October 9th. And 

Yucca Mountain might be ready by the year 2020. It says might be. But it also says that every, 

every nuclear plant is getting reimbursed from DOE because they’re being sued so they’ll get it. 

So this is the big thing right now is when Dominion put in for theirs there was no reason why 

they couldn’t have put in for compensation for this because that would have been an expense 

for them. (KPS-J-2)

Comment: I’m Steve Tadisch. I’m a resident here. And we’re talking about this high level waste 

storage. How is that going to affect an addition to the plant or any new plants in the State or the 

United States? Are they going to give new licenses even though Yucca Mountain is not going to 

be running at the time or are they going to just prorate it kind of and -- then hope that it’s 

running? The only thing is I was going to say it also says that those spent fuel rods have to be in 

the water for five years -- before it can go in the casks. (KPS-K)

Comment: Okay. Ms. Lopas you said that your committee oversees the, like land use and the 

water and the natural resources and all that. I have a question about land use. I’m from the town 

of Carlton. I live about 3 miles north of the nuclear plant. The way I understand it right now the 

utility taxes that we get from having that plant here just about equals the taxes that we would 

have gotten from homes that would have been built on that property. That means that in my 

opinion that means that nothing is gained by having the nuclear waste being stored here on this 

property which is what is going on right now. Above ground is the waste storage. The pools are 

full. So my question is what, what’s going to happen when the plant closes and then the utility 

tax no longer applies? The waste is still going to be there. We’re not getting anything for that 

waste. What do we have to gain by extending the license, having more and more waste being 

piled up there, high level waste. That’s part of my concern. (KPS-A-1)

Comment: I’ve got them all, all our officials, even the governor. They want to take the 

moratorium off to build a nuclear plant because it’s the safest, the cleanest. Like I wrote in a 

letter to them when I sent them all the signatures. Where are you going to put the waste? We’ve 

stored it for 34 years under water and we finally got 50,000 and then Dominion devaluated the 

plant and we lost, how much? $37,000. Now you just said just a few minutes ago that they 

update, update, update. It’s running at full capacity. How come you can devaluate it? I mean 

that’s not your doing, but it, that’s lost us $37,000. (KPS-B-3)
Appendix A

August 2010 A-9 NUREG-1437, Supplement 40

Comment: Okay. My name is Dave Hardtke. I have a question on the financial environmental 

issue with this plant. If they are allowed to continue to operate we are sitting on a growing pile of 

nuclear waste. And when this plant shuts down, and it’s going to shut down someday, I have 

kids and grandchildren in the area, who is going to make up the financial loss to the town when 

this plant shuts down because we will not be getting any money from the utility tax at that point. 

And we are sitting on a pile of growing waste out here and some day our kids are going to have 

to pay the price for it. So I am against the, the license renewal right now. (KPS-A-4)

Response: The safety and environmental effects of spent fuel storage on site have been 

evaluated by the NRC and, as set forth in the Waste Confidence Rule (10 CFR 51.23), the NRC 

generically determined that such storage could be accomplished without significant 

environmental impacts. In the Waste Confidence Rule, the Commission determined that spent 

fuel can be safely stored onsite for at least 30 years beyond the plant’s life, including license 

renewal. Onsite spent fuel storage is considered a Category 1 issue, which was evaluated in the 

GEIS; therefore, accidents would be included within the analysis of the Category 1 issue of 

onsite spent fuel storage. The GEIS is based upon the assumption that storage of the spent fuel 

onsite is not permanent. The GEIS considered a variety of spent fuel and waste storage 

scenarios, including onsite storage of these materials for up to 30 years following expiration of 

the operating license, transfer of these materials to a different plant, and transfer of these 

materials to an independent spent fuel storage installation (ISFSI). For each potential scenario, 

the GEIS determined that existing regulatory requirements, operating practices, and radiological 

monitoring programs were sufficient to ensure that impacts resulting from spent fuel and waste 

storage practices would be SMALL, and therefore, are a Category 1 issue.

Furthermore, requirements for dry cask storage are outside the scope of license renewal. 

During dry cask storage, spent nuclear fuel must be "encased" in NRC-approved casks. An 

NRC-approved cask is one that has undergone a technical review of its safety aspects and 

been found to meet all of the NRC’s requirements. These requirements are specified in 

10 CFR Part 72. The comments provide no new and significant information and, therefore, will 

not be evaluated further.

A.2 COMMENTS RECEIVED ON THE DRAFT SUPPLEMENTAL ENVIRONMENTAL 

IMPACT STATEMENT

The staff transmitted the Generic Environmental Impact Statement for License Renewal of 

Nuclear Plants Supplement 40 Regarding Kewaunee Power Station, Draft Report for Comment

[NUREG-1437, Supplement 40, referred to as the draft supplemental environmental impact 

statement (SEIS)] to Federal, State, and local government agencies and interested members of 

the public. As part of the process to solicit public comments on the draft SEIS, the staff:

● placed a copy of the draft SEIS into the NRC’s Public Electronic Reading Room, 

on its license renewal website, and at the Kewaunee Public Library in 

Kewaunee, WI

● sent copies of the draft SEIS to the applicant, members of the public who 

requested copies, and certain Federal, State, and local agencies

● published a notice of availability of the draft SEIS in the Federal Register on 

February 5, 2010 (75 FR 6065)
Appendix A

NUREG-1437, Supplement 40 A-10 August 2010

● announced and held two public meetings in Carlton, WI, on March 24, 2010, to 

describe the results of the environmental review and answer questions on the 

license renewal process (Agencywide Documents Access and Management 

System (ADAMS) Accession No. ML093480077)

● placed newspaper ads and issued press releases announcing the issuance of 

the draft SEIS, the public meetings, and instructions on how to comment on the 

draft SEIS

● established an e-mail address to receive comments on the draft SEIS 

electronically

During the comment period, the staff received a total of 10 comment letters and e-mails. No 

comments were received during the two public meetings on March 24, the transcripts of which 

can be accessed online or in person from ADAMS with accession numbers ML101241060 and 

ML101241061.

The following organizations responded via letter or telephone that they have no comments on 

the draft SEIS:

● United States (U.S.) Department of the Interior (ADAMS Accession No. 

ML101060514)

● Wisconsin Coastal Management Program

● Wisconsin Department of Natural Resources

The staff has reviewed the public meeting transcripts and the comment letters that are part of 

the docket file for the application, all of which are available online at the NRC’s Public Electronic 

Reading Room (using ADAMS) or in person at the NRC’s Public Document Room at NRC 

Headquarters in Rockville, MD using the appropriate ADAMS accession number shown in Table 

A-2. A cross-reference of the author of the comment, their affiliation (if stated), the comment 

source, the Commenter ID, and the ADAMS accession number of the letter or e-mail is 

provided. Complete versions of the letters or e-mails can also be found in Section A.2.3.
Appendix A

August 2010 A-11 NUREG-1437, Supplement 40

Table A-2. Commenters on the Draft SEIS

Commenter Affiliation Comment Source Commenter ID ADAMS Accession 

Number

Steve Books Citizen E-mail A ML101110056

Diane D’Arrigo Nuclear Information and 

Resource Service E-mail B ML101130255

Dan Duchrow Wisconsin Historical 

Society Letter C ML100850057

Leslie Hartz Dominion Energy 

Kewaunee, Inc. Letter D ML101060515

John LaForge Nukewatch Letter E ML101130256

Alfred Meyer Citizen E-mail F ML101170798

Susan Michetti Citizen E-mail G ML101120599

Duncan Tam Citizen E-mail H ML101120595

Kenneth Westlake U.S. Environmental 

Protection Agency

Letter I ML101120597

The NRC staff made a determination on each comment that it was one of the following:

• A comment that was actually a question and introduces no new information

• A comment that was either related to support or opposition of license renewal in general 

(or specifically KPS) or that makes a general statement about the licensing renewal 

process

• A comment about a Category 1 issue that provided new information that required 

evaluation or one that provided no new information

• A comment about a Category 2 issue that provided information that required evaluation

or one that provided no such information

• A comment regarding alternatives to the proposed action

• A comment that raised an environmental issue that was not addressed in the GEIS or 

the draft SEIS

• A comment outside the scope of license renewal (i.e., not related to 10 CFR Parts 51 or 

54)

• A comment on safety issues pertaining to 10 CFR Part 54

• A comment that was editorial in nature

There were no new environmental issued raised, no new and significant information provided on 

Category 1 issues, and no 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. Comments without a supporting technical basis or without 
Appendix A

NUREG-1437, Supplement 40 A-12 August 2010

any new information are discussed in this appendix and not in other sections of this report. 

Relevant references that address the issues within the regulatory authority of the NRC are 

provided where appropriate. Many of these references can be obtained from the NRC Public 

Document Room. 

Where the comment or question resulted in a change in the text of the draft SEIS, the 

corresponding response refers the reader to the appropriate section of this SEIS where the 

change was made. Revisions to text in the draft SEIS are designated by vertical lines beside the 

text in this final SEIS.

Specific comments are categorized and consolidated by topic where appropriate to capture the 

common essential issues. Next to grouped comments, there is a three-component code(s)

corresponding to the Commenter ID, then the number of the comment within the letter or e-mail, 

followed by the group code shown in Table A-3. The staff responded to these comments in 

Section A.2.2 according to their group code, with a summary of the issues presented before the 

staff responses. For comments that are not grouped, the staff responded to the comments in 

Section A.2.1. Next to the comment, there is a two-component code corresponding to the 

Commenter ID and the number of the comment within the letter or e-mail. Complete versions of 

the letters or e-mails can be found in Section A.2.3

Table A-3. Technical Issue Groups. Based on their similarity, some comments were grouped 

according to the technical issues below, each of which has a unique group code.

Group Code Technical Issue

AM Aging Management

HH Human Health Issues

LE Leaks

MP Monitoring Programs

RW Radioactive Waste Management

A.2.1 Individual Comments and Res pons es

Comment A-1: In the abstract and Executive Summary the wording for the recommendation as 

“being not so great” seems possible to have a double meaning. Is “not so great” to be 

considered as negative, or positive? I would like to ask for wording that clarifies the exact 

meaning and intent of the sentence.

Commenter A: Steve Books, citizen

Response: The phrase “not so great” is derived from the NRC’s governing regulations for 

environmental reviews. Specifically, the evaluation criteria for the staff’s environmental review, 

as defined at 10 CFR 51.95(c)(4) and in the GEIS, is to “determine whether or not the adverse 

environmental impacts of license renewal are so great that preserving the option of license 

renewal for energy planning decisionmakers would be unreasonable.” The staff agrees that the 

phrase is potentially confusing and therefore slightly changed the wording where it appears in 

the Abstract, the Executive Summary, and Section 9.4.
Appendix A

August 2010 A-13 NUREG-1437, Supplement 40

Comment A-4: In the Fall of 2004, Nuclear Regulatory Commission issued a White Finding to 

the Kewaunee plant regarding the containment vessel head and lack of oversight of being able 

to close the hatch quickly. Would this situation ever arise again?

Response: This comment pertains to an operational safety issue and is beyond the scope of 

the environmental review, which addresses environmental impacts associated with operating 

KPS beyond its current license. The NRC addresses operational safety issues such as these as 

part of its ongoing oversight role, which includes among other things, rigorous inspections, 

performance monitoring, and enforcement capability to ensure safe nuclear power plant 

operation. No changes to the SEIS were made based on this comment.

Comment A-5: Severe Accident Mitigation Alternatives need to be continually researched with 

the Plant Workers for enhanced plant safety. Is this being accomplished since Dominion 

Resources have owned the facility?

Response: The staff extensively considered severe accident mitigation alternatives (SAMAs)

during the course of this environmental review (see Chapter 5 and Appendix F). In addition, 

DEK has formalized procedures and programs in place that allow for feedback from plant 

workers on any issue, including SAMAs. No changes to the SEIS were made based on this 

comment.

Comment A-6: In section 2.2.9 Historic and Archaeological Resources, is the Indian tribe name 

Oneida being incorrectly spelled Oneota?

Response: Oneota is not a misspelling of Onieda. The staff cited the source of this information

in Chapter 2. No changes to the SEIS were made based on this comment.

Comment A-7: In the Section 8.5 Alternatives Considered But Dismissed, Wind Energy is now 

more readily being implemented as base load power. Off-shore Lake Michigan wind energy was 

not discussed in the statement. The option of wind energy in the Great Lakes is missing in the 

impact statement. Iowa has 7 times the amount of wind energy that Wisconsin has, Minnesota 

and Illinois have about 3 times the amount of wind energy. Wind energy from off shore Lake 

Michigan was discussed in recent Milwaukee Journal Sentinel publications.

Response: The staff acknowledges a trend of rising implementation of onshore wind power in 

the upper Midwest and across the United States, as well as a number of proposals for offshore 

wind power installations. Currently, however, no offshore wind power facilities exist in the Great 

Lakes. Based on experience with proposed offshore wind facilities on the U.S. Atlantic coast, it 

is likely that a first-of-its-kind wind facility in Lake Michigan will take more than 5 years to move 

through environmental assessment, permitting, and approval stages. While several of the 

proposed offshore wind facilities may be large enough to replace KPS, none have yet begun 

formal environmental or permitting review. In the staff’s judgment, such a project is unlikely to 

be available by the time the KPS license expires in 2013.

The staff did, however, include onshore wind capacity as part of the combination alternative. 

The amount of generation capacity the staff attributed to the wind portion of the combination 

alternative was roughly equivalent to the largest onshore wind installation currently operating in 

Wisconsin. The staff assumed that it would operate at roughly a 30 percent capacity factor. No 

changes to the SEIS were made based on this comment.
Appendix A

NUREG-1437, Supplement 40 A-14 August 2010

Comment A-8: In the Section 8.5.3 Energy Conservation no specific mention of electricity rate 

programs that could have a statewide impact on energy conservation is not mentioned (sic). 

The local Utility in Waverly lowa has a rate program that uses inverted rates during the summer 

to attempt to off-set energy consumption due to air conditioning use. The utility charges more 

after a set amount as a way to increase revenue, and to stress energy conservation. Wisconsin 

has no utility that uses inverted rates to increase revenue, or to encourage energy conservation 

that could have an impact on electricity use.

Response: The staff considered conservation as a stand-alone alternative and removed it from 

further consideration after studies of State-wide energy conservation potential showed an 

insufficient amount to fully replace KPS. The staff did, however, consider conservation in greater 

depth as a portion of the combination alternative. The staff acknowledges that there are many 

mechanisms available to trigger increased energy conservation and thus, did not assign a 

specific program (like the “inverted rate” mechanism the commenter mentions) to achieve that 

conservation potential. The staff notes that many other mechanisms—including rebates, direct 

payments by utilities, time-of-use metering, direct utility control of certain appliances (usually 

paired with incentive payments or lower rates), and curtailable service to large customers, 

among others—can be used singly or in concert to achieve energy conservation goals. No 

changes to the SEIS were made based on this comment.

Comment A-9: In the Section 8.5.7 Biofuels, anaerobic digesters that are currently being used 

on many Wisconsin Farms are missing from the discussion. There are many farms in the 50 

mile radius of the Kewaunee Plant that make use of an anaerobic digester to make electricity 

along with other products from farm manure waste that livestock, usually dairy cows, produce 

on Wisconsin Dairy Farms. One of those farms is in Kewaunee, Pagel’s Ponderosa Dairy. 

Many cooperatives are being set up in Wisconsin to handle area farmers manure waste in the 

form of Biogas Anaerobic Digesters. This area of alternatives needs to explored and included in 

the Environmental Impact Statement (sic).

Response: As of 2009, 22 Wisconsin farms reportedly had operational anaerobic digester 

systems. Of these, 21 farms used at least a portion of the biogas produced to generate 

electricity. Total installed capacity for these biogas digesters was 11.6 megawatts (MW) in the 

fall of 2009 (all data from Kramer, 2009). The staff’s alternatives reviewer—formerly a resident 

of Wisconsin—visited several of these installations prior to joining the NRC. 

While implementation of on-farm anaerobic digesters is increasing in Wisconsin, the staff finds it 

unlikely that sufficient digester-fueled generation capacity could be constructed and operating 

by the 2013 expiration of the current KPS license. In order to replace the capacity provided by 

KPS, anaerobic digestion capacity would have to increase more than 50-fold in the next 3 years. 

As a result, the staff did not consider anaerobic digesters as an alternative to license renewal.

No changes to the SEIS were made based on this comment.

Comment B-1: Nuclear information and Resource Service (NIRS) opposes the license renewal 

of the Kewaunee Nuclear Power Station for safety, security, environmental, public and worker 

health and safety reasons.

Commenter B: Diane D’Arrigo, Nuclear Information and Resource Service (NIRS) 

Response: This is a general comment in opposition to relicensing KPS and is noted. No 

changes to the SEIS were made based on this comment.
Appendix A

August 2010 A-15 NUREG-1437, Supplement 40

Comment B-3: It is clearly irresponsible to proceed with licensing or relicensing a reactor 

without consideration and provision of proper waste management. It violates the National 

Environmental Policy Act NEPA and NRC regulations that require compliance with NEPA. 

Response: The commenter has general disagreement with how the staff considered provisions 

for radioactive waste management. (See “Radioactive Waste Management” in Section A.2.2 for 

further discussion related to this comment.) NEPA requires all Federal agencies considering a 

major Federal action (such as license renewal) take the following actions (42 USC 4321, et 

seq.):

● utilize a systematic, interdisciplinary approach for decision-making on actions 

that may have an impact on the environment

● inform and involve the public in the decision-making process

● consider significant environmental impacts associated with the action, including 

cumulative impacts

● consider alternatives and their impacts to the proposed action

● require a candid discussion and evaluation of impacts and mitigation 

alternatives

The NRC implements NEPA and the requirements established at 10 CFR Part 51 through the 

publication of the GEIS and this SEIS. No changes to the SEIS were made based on this 

comment.

Comment C-1: Appendix E, Chronology of Environmental Review, indicates that a letter was 

sent to Sherman Banker of our office (ADAMS Accession Number ML082670685) by NRC staff, 

dated October 10, 2008. We were originally informed of this project by Ms. Pamela Faggert of 

Dominion Resources Services, Inc., via correspondence dated October 31, 2007. Ms. Faggert's 

submittal was accompanied by a report titled, "A Phase I Archaeological Survey At The 

Kewaunee Power Station In Kewaunee County, Wisconsin ", prepared by Allen P. Van Dyke. 

We provided a response to Ms. Faggert on December 3, 2007, concurring that the relicensing of 

this facility will not affect historic properties. A copy of that correspondence and our response is 

provided, for incorporation into the Final EIS when it is prepared for this project.

Commenter C: Dan Duchrow, Wisconsin Historical Society

We also received a copy of the Cultural Resources Protection Plan. While we have no specific 

comment regarding the content of this document, we do encourage its implementation.

Response: This comment documents the staff’s cultural resources consultation with the State 

of Wisconsin. No changes to the SEIS were made based on this comment.
Appendix A

NUREG-1437, Supplement 40 A-16 August 2010

Commenter D: Leslie Hartz, Dominion Energy Kewaunee, Inc.

Comments D-1, D-6, D-7, D-14, D-17, D-18, D-19, D-23, and D-25 through D-29 summary: 

DEK noted minor editorial errors in the sections referenced in each of the comments. See the 

DEK letter in Section A.2.3 for the comments.

Response: The staff made the suggested corrections in the text of this SEIS.

Comment D-2: DEK has received a renewed certificate of registration for shipment of 

hazardous materials (Reg. No. 061709 551 056R), provided in Enclosure A. The expiration date 

of the renewed certificate of registration is 6/30/2010.

Response: Based on the updated certificate of registration provided, Table 1-2 in Section 1.9 

has been updated to reflect the new registration number and expiration date.

Comment D-3: DEK did not renew Permit number 0044-48-08 since KPS no longer ships

radioactive waste to South Carolina.

Response: Since KPS no longer ships radioactive waste to South Carolina, this row has been 

removed from Table 1-2 in Section 1.9.

Comment D-4: DEK has received a renewed license to ship radioactive material to Tennessee 

(License number T-WI003-L10), provided in Enclosure B. The expiration date of the renewed 

license is 12/31/2010.

Response: Based on the updated license provided, Table 1-2 in Section 1.9 has been updated

to reflect the new license number and expiration date.

Comment D-5: DEK has received a renewed Generator Site Access Permit for Utah (Permit 

No. 0704004220), provided in Enclosure C. The expiration date of the permit is 6/28/2010.

Response: Based on the updated permit provided, Table 1-2 in Section 1.9 has been updated

to reflect the new expiration date.

Comment D-8: The 50-foot buffer indicated in the statement, "Additionally, there is a 50-foot 

(15-m) minimum buffer between the ROWs and any waterways and wetlands; however, buffers 

can vary up to 200 feet (61 m), based on agreements with the landowners or the State," implies 

that a restriction on vegetation management is in place. However, within 50 feet of waterways 

and wetlands, selective hand-cutting is an acceptable means of vegetation management.

Response: No restriction was implied in the original statement. However, the statement in 

Section 2.1.5 has been revised based on the information provided in this comment to clarify that 

no restriction is implied.

Comment D-9: Two different numbers (approximately 400,000 gpm and 401,200 gpm, 

respectively) are provided for circulating water flow with two pumps running. While both 

numbers are correct (401,200 gpm is the rated design flow), DEK suggests replacing both 

sentences containing these values with the following: "The flow rate through the circulating 

water system is approximately 400,000 gpm when both circulating water pumps are running."
Appendix A

August 2010 A-17 NUREG-1437, Supplement 40

Response: The staff agrees that this would be a helpful clarification. Therefore, Sections 2.1.6 

and 2.1.7 have been updated to reflect this clarification.

Comment D-10: The two on-site groundwater wells are used for the station's potable water 

supply. DEK suggests adding these on-site groundwater wells to the list of ground water uses in 

Line 11.

Response: The staff verified that this statement agrees with DEK’s Environmental Report and 

updated Section 2.1.7.1 (DEK, 2008).

Comment D-11: DEK suggests inserting "in the intake forebay" after the words "the water 

level" to clarify that the water level at the intake forebay is approximately 571 feet when two of 

the plant's circulating water pumps are in service.

Response: The clarifying phrase was added to Section 2.1.7.2.

Comment D-12: The statement, "The KPS wells typically do not withdraw ground water during 

the summer months" is incorrect. The KPS wells withdraw ground water during all months. The 

values in Table 2-1, Potable Water Usage (Gallons) at Kewaunee Power Station, between 

August 2008 and February 2009 are the result of equipment problems. New flow totalizers were 

installed in March of 2009. Details of monthly and average daily water use from March to 

December 2009 are provided in the Well Usage Estimation Spreadsheet in Enclosure D.

Response: Based on the information in this comment and Enclosure D to this letter, the error in 

Section 2.2.3.1 was updated.

Comment D-13: DEK believes the term "two to three times per quarter" should be changed to 

"two to three times during the duration of the permit." This proposed change is consistent with 

the Wisconsin Pollutant Discharge Elimination System (WPDES) Permit No. 0001571- 07-0, 

Sections 3.2.1.6 and 3.2.3.3 which provides the requirements for Whole Effluent Toxicity (WET) 

testing at KPS, including required testing frequencies.

Response: The staff verified that this statement agrees with DEK’s Wisconsin Pollutant 

Discharge Elimination System Permit and updated the text in Section 2.2.4 (WDNR, 2005).

Comment D-15: Regarding the following sentence: "Native fish that consume smelt may have 

a decreased ability to successfully reproduce because smelt are rich in thiaminase, an enzyme 

that destroys thiamin, which is necessary for embryo development." DEK believes that "smelt" in 

these sentences should be changed to "alewives."

Response: The staff verified that the same statement is also true for alewives (Fitzsimmons et 

al., 2005); however, this fact does not change any conclusions drawn in this environmental 

review. The staff disagrees that smelt should be removed, as smelt are also rich in thiaminase

(WDNR, 2004). Therefore, Section 2.2.5 was updated to reflect the fact that both smelt and 

alewives are rich in thiaminase.

Comment D-16: This line begins with the phrase, "DEK actively manages the Joe Krofta 

Memorial Forrest..." DEK suggests deleting the word "actively" because use of this term is

subject to wide interpretation.
Appendix A

NUREG-1437, Supplement 40 A-18 August 2010

Response: Section 2.2.6 was updated to remove the word “actively”; this change does not alter

the meaning of the sentence nor does it change any conclusions drawn in this environmental 

review.

Comments D-20, D-21, and D-22: DEK believes Line 15 should be changed to read "DEK has 

established a Cultural Resources Protection Plan..."

DEK recommends changing this sentence to read "In addition, KPS forwarded its Cultural 

Resources Protection Plan to the WHS for review and comment. To date, no comments have 

been received." Letter Serial No. MISC-2009-0057, dated September 30, 2009, forwarded the 

Kewaunee Power Station Cultural Resources Protection Plan to the Wisconsin Historical 

Society.

This sentence should be changed to read "DEK has also established a 'Cultural Resources 

Protection Plan' to improve the protection of archaeological resources at KPS."

Response to D-20, D-21, and D-22: At the time of writing the draft SEIS, DEK was in the 

process of revising its Cultural Resources Protection Plan. Since the publication of the draft 

SEIS, DEK completed the revision (DEK, 2009). The staff and the Wisconsin Historical Society 

have reviewed the revised plan and have no additional comments. Sections 4.9.6 and 4.11.4 

were updated to reflect that the revision is complete. The revised plan does not change any 

conclusions drawn in this environmental review.

Comment D-24: DEK believes the term "a diesel building" should be changed to "an EDG 

room."

Response: This clarification was made in Section 5.2.5.

Commenter E: John LaForge, Nukewatch

Comment E-1 and E-5: The license renewal application noticed above should be denied.

For the above reasons, and in view of the record of dangerous and even reckless operator error 

documented below, I urge the commission to deny the application for a license renewal by 

Dominion Energy Kewaunee Inc. above.

Response to E-1 and E-5: These are general comments in opposition to relicensing KPS and 

are noted. No changes to the SEIS were made based on these comments.

Comment E-2: The Kewaunee Power Station has a poor record of operation and of accident 

response and management (see below) and must 'not be allowed to continue to risk the health 

and safety of power station workers, on-site management, the surrounding community, or the 

life of Lake Michigan. As the Nuclear Regulatory Commission (NRC) knows, the Kewaunee 

operators have repeatedly shown ineptitude in their response to unusual events, power outages 

and leaks of tritiated water from the Kewaunee Power Station.

Response to E-2 and additional response to E-5: These comments, as well as the excerpts 

located at the end of the letter, are related to the day-to-day operation of KPS. The staff’s 

environmental review is confined to environmental impacts associated with the period of 

extended operation requested by DEK. Therefore, these comments fall outside of the scope of 

this environmental review. However, the NRC addresses operational safety issues such as 
Appendix A

August 2010 A-19 NUREG-1437, Supplement 40

these as part of its ongoing oversight role, which includes among other things, rigorous 

inspections, performance monitoring, and enforcement capability to ensure safe nuclear power 

plant operation. In fact, many of the excerpts at the end of the letter point to this ongoing NRC 

oversight and involvement with such issues. No changes to the SEIS were made based on 

these comments.

Comment E-4: The license renewal application must also address the question of additional 

costs to ratepayers to cover the expense of finding the source(s) of tritium leakage, inspecting 

underground pipes that carry the power station's and its waste pool's tritiated water, repair 

and/or replacement of damaged and/or leaking piping carrying tritium, and the water 

replacement costs for nearby communities forced to pay for non-contaminated sources of 

drinking water.

Response: NRC regulations at 10 CFR 51.53(c)(2) specifically do not require an applicant to 

address the economic costs of license renewal or of the alternatives to license renewal, except 

insofar as such costs and benefits are either essential for a determination regarding the 

inclusion of an alternative in the range of alternatives considered or relevant to mitigation. In 

addition, the issues raised by these comments involve energy planning decisions that are made 

by the State, other regulators, and utility officials. The NRC does not have a role in these energy 

planning decisions. No changes to the SEIS were made based on these comments.

Commenter F

Comments F-1 and F-7: In reviewing NUREG-1437, 13 Supplement 40, draft, I find there to be 

five significant operational site conditions which are not addressed. Due to the real and present 

danger each issue presents, before the Nuclear Regulatory Commission can renew the license 

of the Kewaunee reactor, each of these five issues needs to be satisfactorily resolved, including 

a process for ongoing public input in this process. Thus I request that the NRC hold License 

Renewal in abeyance until there is satisfaction of these public health and safety issues.

: Alfred Meyer, citizen

I hereby request that no license renewal be awarded to the Kewaunee Nuclear Power Station 

until the above noted conditions have been resolved to the satisfaction of the general public.

Response to F-1 and F-7: These are general comments in opposition to relicensing KPS and

are noted. No changes to the SEIS were made based on these comments.

Comment F-4 and F-5: Tritium contamination of the Kewaunee site is not included in the 

current scope of the Decommissioning Plans - adequate funding levels must be determined 

before license renewal is adjudicated. As an example, the estimated costs of decommissioning 

(without acknowledging actual Tritium contamination, which is currently being recognized as a 

significantly more than admitted by the reactor operator Entergy, who is being sued by the state 

of Vermont) are $1 Billion, whereas there are only $500 Million in the current Vermont Yankee 

decommissioning fund. A thorough analysis must be provided for Kewaunee prior to license 

renewal.

With the likely demise of the Yucca Mountain Project, and in any case, no projected date for 

availability of a permanent geologic repository, the confidence aspect of the Waste Confidence 

Act is undermined. The EIS must now address the environmental, health and safety impacts of 

de facto permanent on site storage of the high level nuclear waste contained in the spent 

nuclear fuel before license renewal. The current standard of 60 years for SafeStore post license 

term must be reevaluated in light of the lack of any plan for disposition of HLNW. Since current 

dry cask storage technology is based on an expected 60-year lifetime, the health, safety and 
Appendix A

NUREG-1437, Supplement 40 A-20 August 2010

public health issues implicit in the use of such limited term technology for an indeterminate time

must be addressed by the EIS before license renewal is adjudicated. Public health, safety and 

decommissioning funding implications of extended on site dry cask storage, during and after 

license periods, must be included in the EIS, in particular, the need for and environmental 

impacts of maintaining existing cooling pool facilities and/or building new cooling pool structures 

that will be needed to handle any unplanned, emergency or planned transfers of spent fuel from 

initial dry cask storage units to new storage and/or transport units due to premature failure of 

said casks, extension of storage time beyond the planned lifetime of said casks, and/or

implementation of different storage and/or transport containers. Current estimates for new 

cooling pool facility construction is approximately $300 Million.

Response to F-4 and F-5: These comments discuss the impacts on the cost of KPS 

decommissioning from the cleanup of tritium leaks and from the storage of high-level nuclear 

waste. The requirement to have adequate funding to maintain public health and safety for 

decommissioning and for potential extended onsite storage of spent nuclear fuel is contained at

NRC’s regulation, 10 CFR 50.75, Reporting and recordkeeping for decommissioning planning, 

and therefore, is outside of the scope of license renewal. The regulation requires that the 

licensed owner of a nuclear power plant must have proof of financial assurance for 

decommissioning activities. The regulation requires that the amount must be adjusted annually 

to reflect economic conditions and cost estimates for decommissioning the facility. The specific 

methods acceptable to the NRC for compliance with the funding criteria are contained in the 

rule. The licensee is required to report the status of its decommissioning funding to the NRC at 

least once every 2 years. This helps to ensure that adequate funding is available to maintain the 

systems and structures needed to safely contain high-level radioactive waste. No changes were 

made to the SEIS based on these comments. (See “Radioactive Waste Management” in 

Section A.2.2 for further discussion related to this comment.)

Commenter G

Comment G-3: Worker safety is another issue.

: Susan Michetti, citizen

Response: Worker safety (other than occupational radiological exposure) is outside of the 

scope of the environmental review for license renewal. The U.S. Department of Labor’s 

Occupational Safety and Health Administration handles worker safety issues. Information and 

directions on how to file a complaint related to worker safety can be found at 

http://www.osha.gov. No changes were made to the SEIS based on this comment.

Comments G-5 and G-6: Nuclear is too expensive and too risky. It is the dirtiest energy. It 

does not qualify for sustainable clean energy based upon its dirty characteristics found in every 

aspect from mining, to transport, to operations, to waste storage and the possibility of being a 

terrorist target, to the inability to dispose of it safely anywhere. This is unacceptable to continue 

such craziness.

Nuclear power is an unsafe dirty energy white elephant that certainly is no longer cost effective 

energy and will drive up the costs of residential electricity to unacceptable levels. Based on the 

lies told historically that nuclear power would be too cheap to meter, this was a false promise 

that never came close to being truthful in the same way that safety claims do not come close to 

being truthful. The people of Wisconsin do not want new nuclear power and we do not want this 

plant to be renewed based on its history of leaking radioaction into the groundwater that has 

never been stopped and that has never been publicly identified as a located source.
Appendix A

August 2010 A-21 NUREG-1437, Supplement 40

Response to G-5 and G-6: These statements represent general oppositions to nuclear power 

and are noted. No changes were made to the SEIS based on these comments.

Comment G-7: It is unsafe to renew the license of Kewaunee nuclear plant.

Response: This is a general comment in opposition to relicensing KPS and is noted. No 

changes were made to the SEIS based on these comments.

Commenter H

Comments H-1 and H-12: Do NOT re-license Kewaunee Nuclear Power Plant

: Duncan Tam, citizen

Relicensing Kewaunee is unacceptable.

Response to H-1 and H-12: These are general comments in opposition to relicensing KPS and 

are noted. No changes were made to the SEIS based on these comments.

Comment H-4: Worker safety is an issue.

Response: Worker safety (other than occupational radiological exposure) is outside of the 

scope of the environmental review for license renewal. The U.S. Department of Labor’s 

Occupational Safety and Health Administration handles worker safety issues. Information and 

directions on how to file a complaint related to worker safety can be found at 

http://www.osha.gov. No changes were made to the SEIS based on this comment.

Comment H-5: Evacuation is an environmental issue because the presence of Lake Michigan 

prevents escape routes in 50% of the directions away from the plant.

Response: The programs for emergency preparedness at nuclear power facilities apply to all 

nuclear power facility licensees and require the specified levels of protection from each licensee 

regardless of plant design, construction, or license date. Requirements related to emergency 

planning are in the regulations in 10 CFR 50.47 and Appendix E to 10 CFR Part 50. These 

requirements apply to all operating licenses and will continue to apply to facilities with renewed 

licenses. Through its standards and required exercises, the staff reviews existing emergency 

preparedness plans throughout the life of any facility, keeping up with changing demographics 

and other site-related factors. Therefore, the staff has determined that there is no need for a 

special review of emergency planning issues in the context of an environmental review for 

license renewal. No changes were made to the SEIS based on this comment.

Comments H-8 and H-11: Nuclear is the dirtiest energy, non-sustainable energy available with 

danger in every part from mining, to transportation, to operations, to waste storage and its 

terrorist attraction, to the inability to dispose of it. This is unacceptable. We need to protect the 

environment, not destroy it.

This safety is a false promise just like electricity too cheap to meter was. The environment is 

compromised unacceptably around any nuclear plant in the US because humans aren't perfect 

and aren't responsible enough to follow the rules impeccably.

Response to H-8 and H-11: These statements represent general oppositions to nuclear power 

and are noted. No changes were made to the SEIS based on these comments.
Appendix A

NUREG-1437, Supplement 40 A-22 August 2010

Comment H-9: Nuclear pollution is excluded from our homeowners insurance, our vehicle 

insurance, and any other insurance we carry. It is so dangerous that the industry had to get the 

US Price Anderson Act passed to put a ceiling on each accident that will not pay for a small 

fraction of the damage around any major city. It is unacceptable for taxpayers to bear this risk.

Response: The NRC, in accordance with 10 CFR 51.53(c)(2), does not require an applicant to 

address the economic costs of license renewal or of the alternatives to license renewal, except 

insofar as such costs and benefits are either essential for a determination regarding the 

inclusion of an alternative in the range of alternatives considered or relevant to mitigation. The 

NRC has no role in the decisions mentioned in these comments, and its role with regards to 

licensee insurances does not extend beyond the rules and regulations in 10 CFR Part 140, 

Financial Protection Requirements and Indemnity Agreements, which is outside of the scope of 

this environmental review. No changes to the SEIS were made based on these comments.

Commenter I

Comment I-1: Section 4.8.1.2; Radioactive Effluent and Dose Information; Page 4-23, lines 

35-39: In this section, an explanation of the use of the "As Low As Reasonable Achievable" 

("ALARA") process is given. However, the use of the ALARA process is not clearly documented

throughout the Draft SEIS. The process identifies exposures that can be mitigated to the lowest 

possible exposure -- even beyond regulation -- at little or no additional cost. We suggest 

providing examples of where and how this process was used at KPS.

: Kenneth Westlake, United States Environmental Protection Agency (EPA)

Response: The ALARA discussion in Section 4.8.1 of the SEIS is designed to show that, in 

addition to showing compliance with NRC radiation protection safety limits, the doses from 

KPS’s radioactive effluents are well below the safety limits and meet the NRC’s ALARA dose 

standards in Appendix I to 10 CFR Part 50. The SEIS does not contain a discussion of the 

applicant’s processes to maintain doses ALARA because the NRC has defined and codified the 

numerical value for doses that are ALARA and does not specify a method or process that 

should be used. In addition, if the annual dose from radioactive liquid effluent from a nuclear 

power plant is below the Appendix I ALARA dose standard of 3.0 milliroentgen equivalent man 

(mrem) (0.03 millisievert (mSv)), the applicant has adequately demonstrated its compliance with 

the ALARA criterion. No additional actions are required by the licensee to further lower the 

dose.

It is important to understand NRC’s license renewal process which classifies environmental and 

human health issues as either Category 1 (generic to all nuclear power plants) or 2 (requires a 

site-specific evaluation). For license renewal, the NRC performed a comprehensive evaluation 

of all nuclear power plants in the United States to assess the scope and impact to public health 

and safety and the environment from radioactive material released from a nuclear power plant 

for an additional 20 years of operation. The specific details are contained in the GEIS

(NUREG-1437). The evaluations and conclusions reached in the GEIS provide a technical basis 

for the staff to demonstrate that the health impacts were analyzed and resolved in a generic 

fashion and thus, classify the human health issue as Category 1. Category 1 issues are those 

that have been evaluated and determined: (1) to apply to all plants, (2) to have a single 

significance level of impact (e.g., SMALL, MODERATE, or LARGE)1, and (3) that the use of 

mitigation measures to further limit adverse impacts associated with the issue have been 

considered and found to not be sufficiently beneficial to warrant implementation. Category 1 

issues are termed “generic” issues because the conclusions related to their impacts were found 

to be common to all plants. Issues that were resolved generically are not reevaluated in each 

individual plant SEIS because the conclusions reached would be the same as in the GEIS. 
Appendix A

August 2010 A-23 NUREG-1437, Supplement 40

However, if new and significant information is discovered that conflicts with the conclusion 

reached in the GEIS, then a plant-specific evaluation of the issue will be performed and reported 

in the SEIS. Category 2 issues are those that are not generic to all plants and require a 

site-specific evaluation. The human health impact from radiation is classified as a Category 1 

issue. 

The GEIS is used to avoid duplication of effort and allows the staff to focus specifically on those 

issues that are unique to a particular plant (i.e., issues that are not generic). This is an 

appropriate and effective use of the concept of tiering (40 CFR Section 1502.20) that was set 

forth by the President’s Council on Environmental Quality (CEQ) in its 1978 regulations that 

implemented the requirements of the NEPA.

In addition, protection of the public from radiation released by nuclear power plants is an 

important part of the NRC’s reactor oversight process (ROP) of inspection and enforcement of 

NRC’s regulations. The NRC has qualified inspectors that, on an ongoing periodic basis, go to 

the plant and perform a detailed inspection of the licensee’s compliance with NRC radiation 

protection regulations. The results of the inspections are all publically available. If there is an 

infraction of an NRC requirement, the NRC assesses the risk significance of the event and 

conducts enforcement actions, as appropriate. These periodic inspections ensure that the plant 

continues to operate within NRC safety standards to protect the public’s health and safety.

Thus for KPS, the staff’s evaluation found that it met NRC’s radiation protection standards and 

confirmed that the plant was within the bounding parameters and conclusions in the GEIS for a 

Category 1 issue. Therefore, in accordance with NRC standards for preparing a SEIS for license 

renewal, a detailed site-specific evaluation was not warranted .

This comment does not present any new or significant information; therefore, no changes were 

made to the SEIS based on this comment.

Note 1: Except for collective offsite radiological impacts from the fuel cycle and spent fuel and high level waste disposal.

Comment I-2: Section 4.8.1.2; Radioactive Effluent and Dose Information; Page 4-24, lines 7-

22: The dose projections provided in these bulleted items are very helpful in comparing the 

relative risks for these different exposures. However, due to different dose criteria in some of 

the bulleted items, comparability for the public may not be easily demonstrated. Using the same 

units (mrem) throughout the bulleted items would be helpful. In addition, the dose reference for 

iodine should be reflected on thyroid exposure rather than liver exposure, because the thyroid is 

the organ most exposed for the general public for gaseous iodine releases.

Response: The radiation dose units reported in the KPS DSEIS use the units required by NRC 

regulations for the particular exposure pathway. For example, the dose criterion in Appendix I to 

10 CFR Part 50 for radioactive liquid effluents is 3 mrem (0.03 mSv) to the whole body. 

Appendix I to 10 CFR Part 50 also contains standards for the radiation exposure to air from 

gamma and beta radiation in radioactive gaseous effluents, which is expressed in mrad. While 

the use of different units may be confusing, the staff reports and compares each calculated 

dose from KPS with its respective NRC dose standard using the appropriate units. This is 

designed to show a direct comparison of the doses reported by KPS to the NRC’s ALARA 

standards.

The reported maximum organ dose to the liver is correct because it is the largest calculated 

dose to an organ from radioactive iodine and radioactive particulate material. The NRC requires 
Appendix A

NUREG-1437, Supplement 40 A-24 August 2010

licensees to calculate and report the dose to the organ that receives the largest dose from 

radioactive iodine and particulates. In the case of radioactive gaseous effluents from KPS, the 

dose from radioactive particulate material resulted in a higher dose to the liver than to the 

thyroid from radioactive iodine. Therefore, in accordance with NRC requirements, KPS reported 

the dose to the liver as the maximum organ dose.

This comment does not present any new or significant information; therefore, no changes were 

made to the SEIS based on this comment.

Comment I-3: Section 4.11.3; Cumulative Impacts on Human Health; Page 4-45, lines 28-40: 

This section discusses a data collection and cumulative impacts assessment using actual data 

from this site. Results of this specific assessment would be helpful in better demonstrating the 

protectiveness and documenting the determination of relative health risk as SMALL. 

Response: The cumulative impact on human health discussion in Section 4.11.3 is designed to 

be a summary of the radiological impact data presented in Section 4.8.1.2, “Radioactive Effluent 

and Dose Information.” Section 4.8.1.2 contains the staff’s evaluation of the radiation doses 

reported by KPS, as well as a comparison to the appropriate NRC radiation protection 

standards. The comparison showed that the doses were well within NRC’s radiation protection 

standards. The radiological evaluation in Section 4.8.1.2 is summarized in Section 4.11.3 and 

refers the reader back to Section 4.8.1 for the detailed information on which the staff based its 

conclusion.

This comment does not present any new or significant information; therefore, no changes were 

made to the SEIS based on this comment.

Comment I-4: Section 8.6.5; Human Health; Page 8-43, lines 31-38, page 8-44, lines 1-14: We 

recommend providing a better description of the risk for the initial 40-year licensing period and 

then the increased risk for the additional 20 years of relicensing. By more fully discussing the 

accumulated data over the current life of the existing license, a better understanding of 

additional residual risk posed by this facility will be provided. The additional information would 

more fully demonstrate the NRC's risk determination of SMALL.

Response: The suggestion to frame risk to human health in a different discussion is noted. 

However, the staff believes that the summary discussion in Section 8.6.5 of the human health 

impacts associated with the no-action alternative is appropriate. The SEIS is not meant to 

evaluate the impacts from the original licensed 40-year period. The environmental impacts 

associated with the initial 40 years of plant operation are documented in the Final Environmental 

Statement (FES) issued in December 1972 (AEC, 1972). In addition, adding to the purposefully 

brief discussion in Section 8.6.5 would violate the spirit of 40 CFR Section 1502.2(b), which 

states that, “Impacts shall be discussed in proportion to their significance. There shall be only 

brief discussion of other than significant issues.”

This comment does not present any new or significant information; therefore, no changes were 

made to the SEIS based on this comment.

Comment I-5: Sections 2.1.2.1 and 2.1.2.2, Radioactive Liquid Waste and Radioactive 

Gaseous Waste, respectively: We recommend that both of these sections include actual 

quantitative data to give the public a better understanding of radioactive waste effluents 

associated with KPS. Please include the high, the low and the average data points from the 
Appendix A

August 2010 A-25 NUREG-1437, Supplement 40

KPS annual radioactive effluent release reports (2002 through 2008) for liquid and gaseous 

effluents.

Response: The discussion of the radioactive waste systems in Sections 2.1.2.1 and 2.1.2.2 is 

done to provide a physical description of the systems. A detailed listing of the quantities of 

radioactive waste released does not assess the significance of the action. The discussion and 

assessment contained in Section 4.8.1.2, “Radioactive Effluent and Dose Information,” contains 

the relevant information on the impacts to human health. The NRC assesses impact using dose, 

not by assessing the quantity of radioactive materials released. The applicant is required to 

calculate the dose from all radioactive effluents discharged. Compliance with NRC radiation 

protection standards is based on dose. The staff believes that reporting data on the amount of 

waste discharged without a regulatory standard to compare to would not provide an appropriate 

assessment of the impacts and would result in confusion about the significance of the quantities 

released. In addition, adding the quantitative data recommended would violate the spirit of 

40 CFR Section 1502.2(a), which states that, “Environmental impact statements shall be 

analytic rather than encyclopedic.”

This comment does not present any new or significant information; therefore, no changes were 

made to the SEIS based on this comment.

Comment I-7: Please include a description of the ISFSI in Section 2.1, Facility Description. 

Include information such as how many dry storage casks there are and how much capacity 

there is for additional dry storage casks. We also recommend listing the buildings located on the 

site.

Response: The safety and environmental effects of long-term storage of spent fuel onsite have

been assessed by the NRC, and, as set forth in its Waste Confidence Decision (codified at

10 CFR 51.23), the Commission generically determined that such storage could be

accomplished without significant environmental impact. In the Waste Confidence Decision, the

Commission determined that spent fuel can be stored onsite for at least 30 years beyond the

license operating life, which may include the term of a renewed license. At or before the end of

that period, the fuel would be removed to a permanent repository. In its Statement of

Consideration for the 1990 update of the Waste Confidence Decision (55 FR 38472), the

Commission addressed the impacts of both license renewal and potential new reactors. In its

December 6, 1999, review of the Waste Confidence Decision (64 FR 68005), the Commission

reaffirmed the findings in the rule. In addition to the conclusion regarding safe onsite storage of

spent fuel, the Commission states in the rule that there is reasonable assurance that at least

one geologic repository will be available within the first quarter of the 21st century, and sufficient

repository capacity for the spent fuel will be available within 30 years beyond the licensed life for

operation of any reactor. The Commission issued a proposed revision of the Waste Confidence

Decision in the Federal Register (73 FR 59551) for comment on October 9, 2008. This revision

provided the basis for extending the time for sufficient repository capacity for spent fuel to be

available from within 30 years beyond the licensed life for operation of any reactor to within

50 to 60 years. The proposed revision also provides reasonable assurance that spent fuel can

be stored without significant environmental impacts for at least 60 years beyond the licensed life

for reactor operation assuming storage of spent fuel in either a spent fuel storage basin or 

onsite or offsite ISFSI. Accordingly under 10 CFR 51.23(b), no site-specific discussion of any 

environmental impact of spent fuel storage in reactor facility storage pools or ISFSIs is required 

in an environmental impact statement associated with license renewal.
Appendix A

NUREG-1437, Supplement 40 A-26 August 2010

The staff also believes that a description of the spent fuel pool or the ISFSI storage area would 

not benefit a reader or decision maker in this case. Rather, adding it would go against the spirit 

of 40 CFR Section 1502.2(a), which states that, “Environmental impact statements shall be 

analytic rather than encyclopedic.”

To answer the request in the comment, there are currently two casks in the dry fuel storage 

area, and KPS plans to add two more casks in 2010. There is sufficient capacity to handle, at a 

minimum, the waste generated during 60 years of plant operation.

This comment does not present any new or significant information or arguments; therefore, no 

changes were made to the SEIS based on this comment. (See “Radioactive Waste 

Management” in Section A.2.2 for further discussion related to this comment.)

Comment I-8: Page 2-15 explains that on-site groundwater wells are used for cooling water 

make-up and plant equipment. There are also 14 groundwater monitoring wells on-site. 

Appendix B of the Draft SEIS lists potential site-specific issues that should be analyzed in the 

document. According to Appendix B, there are potential groundwater use conflicts if Ranney 

wells are used. Since groundwater wells are used at KPS, the document should clarify whether 

these wells are Ranney wells.

Response: Section 2.1.7 was updated to reflect that KPS has no Ranney wells.

Comment I-9: In Section 4.11, Cumulative Impacts, we suggest including the addition of dry 

storage casks for spent fuel as "reasonably foreseeable" future projects. The addition of dry 

storage casks should be considered when analyzing the impacts on the resources discussed in 

this Section.

Response: The discussion of cumulative impacts on human health in Section 4.11.3 does 

mention the storage of spent nuclear fuel in dry casks. As discussed in the SEIS, the 

radiological impacts from the storage of spent nuclear fuel in dry casks on the KPS site would 

be controlled in accordance with NRC and EPA radiation protection standards. Therefore, as 

discussed in the response to comment I-7, the Commission has made a generic determination 

that, if necessary, spent fuel generated in any reactor can be stored safely and without 

significant environmental impacts for at least 30 years beyond the licensed life of operation 

(which may include the term of a revised or renewed license) of that reactor at its spent fuel 

storage basin or at either onsite or offsite ISFSIs.

This comment does not present any new or significant information; therefore, no changes were 

made to the SEIS based on this comment. (See “Radioactive Waste Management” in Section 

A.2.2 for further discussion related to this comment.)

Comment I-10: Please discuss any health studies pertaining to populations living near nuclear 

power plants which have been conducted since the GEIS. Explain how these studies relate to 

the human health impacts for populations near KPS.

Response: Since the issuance of the NRC’s GEIS for license renewal in 1996, there have 

been several radiological studies dealing with the human health impacts associated with 

radioactive emissions from nuclear power plants that are considered by the NRC to be 

scientifically valid. They are as follows:
Appendix A

August 2010 A-27 NUREG-1437, Supplement 40

● In June 2000, investigators from the University of Pittsburgh found no link 

between radiation released during the 1979 accident at the Three Mile Island 

power plant and cancer deaths among nearby residents. Their study followed 

32,000 people who lived within 5 miles of the plant at the time of the accident 

(Talbot et al., 2003).

● The Connecticut Academy of Sciences and Engineering, in January 2001, 

issued a report on a study around the Haddam Neck nuclear power plant in 

Connecticut and concluded radiation emissions were so low as to be negligible 

and found no meaningful associations to the cancers studied (CASE, 2001).

● In 2001, the Florida Bureau of Environmental Epidemiology reviewed claims that 

there are striking increases in cancer rates in southeastern Florida counties 

caused by increased radiation exposures from nuclear power plants. However, 

using the same data to reconstruct the calculations, on which the claims were 

based, Florida officials were not able to identify unusually high rates of cancers 

in these counties compared with the rest of the State of Florida and the nation 

(Bureau of Environmental Epidemiology, 2001).

● In 2000, the Illinois Public Health Department compared childhood cancer 

statistics for counties with nuclear power plants to similar counties without 

nuclear plants and found no statistically significant difference (Illinois Public 

Department of Health, 2000).

● The American Cancer Society in 2004 concluded that although reports about 

cancer clusters in some communities have raised public concern, studies show 

that clusters do not occur more often near nuclear plants than they do by 

chance elsewhere in the population. Likewise, there is no evidence that links 

strontium-90 with increases in breast cancer, prostate cancer, or childhood 

cancer rates. Radiation emissions from nuclear power plants are closely 

controlled and involve negligible levels of exposure for nearby communities 

(ACS, 2004).

In 2010, the NRC asked the National Academy of Sciences (NAS) to perform a state-of-the-art 

study on cancer risk for populations surrounding nuclear power facilities. The NAS study will 

update the 1990 U.S. National Institutes of Health - National Cancer Institute (NCI) report, 

“Cancer in Populations Living near Nuclear Facilities” (NCI, 1990). The study is scheduled to 

begin in the summer of 2010 and is expected to be completed within 4 years. Information from 

the report will be considered for incorporation into future updates of NRC’s guidance and 

regulations and in future SEISs, as appropriate.

The above information was considered during the preparation of a draft revision to the 1996 

GEIS. The preliminary conclusions and information in the revised GEIS continue to support the 

current conclusions that the impact to the public from radioactive emissions from nuclear power 

plants is a Category 1 issue, and the impacts are SMALL. A draft of the revised GEIS was 

issued for public comment in July 2009, and the staff is currently evaluating comments on the 

document. The information in the revised GEIS, once it is finalized, will be used as a basis for 

the evaluation of the impacts from radioactive emissions from nuclear power plants on human 

health. Since the above studies do not contradict the conclusions in the 1996 GEIS, there is no 

need to alter the discussion or conclusions reported in the SEIS for KPS. The impacts contained 

in the 1996 GEIS remain the basis for the conclusions reported in the SEIS for KPS.
Appendix A

NUREG-1437, Supplement 40 A-28 August 2010

This comment does not present any new or significant information; therefore, no changes were 

made to the SEIS based on this comment.

Comment I-11: Page 4-47, lines 38 and 39 suggest that water levels may be reduced due to 

climate change. How will KPS adapt to this potential change?

Response: The SEIS evaluates the impacts on the environment of an additional 20 years of 

KPS operation, not the effect of the environment on KPS. If water level in the Great Lakes does 

change, the issue will be dealt with as part of the NRC’s day-to-day oversight of KPS. A 

sufficient source of condenser cooling water is a requirement that is dictated by KPS’s technical 

specifications. If, in the future, the water level in Lake Michigan drops below the level required in 

the technical specifications, KPS may be required to shut down. Nevertheless, this comment is 

outside of the scope of this environmental review. No changes were made to the SEIS based on 

this comment.

Comment I-12: We also suggest the use of native species and the management of invasive 

species in the transmission line right-of-ways and at KPS.

Response: The comment is noted. DEK and American Transmission Company are 

responsible for managing the terrestrial resources at KPS or in the transmission line right-ofways. The GEIS and Sections 2.2.6 and 4.6 of this SEIS discuss terrestrial resources and the 

impacts resulting from operating KPS for an additional 20 years in further detail; the overall 

impact on terrestrial resources has been determined to be SMALL. This comment does not 

present any new or significant information; therefore, no changes were made to the SEIS based 

on this comment.

Comment I-13: We recommend using one or two SAMAs as examples to demonstrate what is 

meant by the following statement on page xvii, lines 27-31: "Based on the review of the SAMAs 

for KPS and the plant improvements already made, we conclude that none of the potentially 

cost-beneficial SAMAs 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 

pursuant to 10 CFR Part 54."

Response: This comment refers to a statement found in the Executive Summary for this SEIS, 

which was intended to briefly summarize the SAMA findings. The staff discusses SAMAs in 

much further detail in Chapter 5 and Appendix F. The potentially cost-beneficial SAMAs 

identified in Section 5.2.5 of this SEIS (e.g., SAMA 81 - adding a diesel building high 

temperature alarm or redundant louver and thermostat) are not related to the intent of managing 

aging effects, such as corrosion or wear, of components or systems. This comment does not 

present any new or significant information; therefore, no changes were made to the SEIS based 

on this comment.

Comment I-14: Discuss how increased frequency and severity of weather events due to 

climate change may affect the safety of KPS and impact the environment.

Response: The SEIS evaluates the impacts of operating KPS for an additional 20 years, rather 

than looking at the effect of the environment on KPS. Severe weather patterns impacting the 

safe operation at KPS are addressed as part of the NRC’s day-to-day oversight of KPS, i.e., 

through compliance with the plant’s technical specifications for specific conditions. Chapter 5 of 

this SEIS also provides a discussion of the potential environmental impacts of severe accidents 

occurring from events that are beyond the plant’s design-basis accident scenarios. This 
Appendix A

August 2010 A-29 NUREG-1437, Supplement 40

comment does not present any new or significant information; therefore, no changes were made 

to the SEIS based on this comment.

Comment I-15: The Draft SEIS needs to adhere to the government-wide requirement for 

documents to be written in plain language. The Draft SEIS includes bureaucratic boilerplate 

language instead of plain language. For example, page 4-24, lines 1 and 2 state, "Dose 

estimates for members of the public are calculated based on liquid and gaseous effluent release 

data in atmospheric and aquatic transport models."

Response: Revision 2 to the NRC Editorial Style Guide, NUREG-1379 (NRC, 2009) describes

the government-wide requirements for documents to be written in plain language. While 

discussing the complex operation and environmental impacts of a nuclear power plant, the staff 

makes every effort to follow this guide and to use plain language. However, the SEIS 

discussions often cover highly technical issues and concepts, and it may not always be practical 

to avoid using some scientific terms and language. The staff attempts to strike a balance 

between overly scientific and overly simplistic such that the result is a document that is 

sufficiently analytical but readable. No changes were made to the SEIS based on this 

comment. However, the staff will note this comment to evaluate its plain language writing style 

in future documents.

Comment I-16: When regulatory dose limits are referenced, the actual dose limit language 

should also be provided as part of the plain language and transparency requirements for all 

Federal Agencies. An example of where this was accomplished was on page 4-24, lines 7 

through 22. Please strive to accomplish this throughout the Final SEIS.

Response: The SEIS reports the specific numeric regulatory dose limits when it is relevant to 

do so. For example, the specific NRC dose standards are stated in Section 4.8.1.2, “Radioactive 

Effluent and Dose Information,” in order to make a direct comparison to the dose values 

reported by KPS. In other sections of the SEIS, the staff is providing a broad summary of KPS’s 

compliance with multiple regulatory standards. Furthermore, the staff’s finding that the impact 

from KPS’s radiological emissions are small follows from the bounding conclusions reached in 

the GEIS and support the staff’s position that the actual numerical dose standards do not need 

to be repeated for a summary statement. Where appropriate, the staff includes language to 

provide the proper context, such as stating whether exposure is less than the regulatory limit 

established for the general public. This comment does not present any new or significant 

information; therefore, no changes were made to the SEIS based on this comment.

Comment I-17: The Draft SEIS does not adequately incorporate government-wide directives 

and laws regarding data quality and use. Specifically, the Draft SEIS does not adequately meet 

the requirement in OMB Circulars A-119 and A-130, PDD39 and PDD63, and the Clinger-Cohen 

Act of 1996, Information Quality Act of 2001, and the National Technology Transfer and 

Advancement Act of 1995. All of these direct Federal Agencies to use the best available quality 

data in all of the determinations for actions taken by or sanctioned by the Federal Government. 

Referring to the GEIS within the Draft SEIS does not always fulfill "best available quality data."

Response: The comment does not provide specific examples of where the DSEIS lacks the 

"best available quality data." In general, the GEIS is used to avoid duplication of effort in each 

environmental review for license renewal, so the staff can focus specifically on those issues that 

are unique to a particular plant (i.e., issues that are not generic). The radiological health 

discussion in the staff’s response to comment I-1 presents a specific example. The GEIS is an 

appropriate and effective use of the concept of tiering (40 CFR Section 1502.20) that was set 
Appendix A

NUREG-1437, Supplement 40 A-30 August 2010

forth by the President’s CEQ in its 1978 regulations that implemented the requirements of

NEPA. The CEQ noted that tiering can be a useful method of reducing paperwork and 

duplication and should be viewed as a means of accomplishing NEPA requirements in an 

efficient manner. The tiering process makes each environmental impact statement of greater 

use and meaning to the public without duplication of the analysis prepared for the previous 

impact statement.

The staff published the GEIS for license renewal in 1996 (NRC, 1996) and added an addendum

in 1999 (NRC, 1999). The passage of time alone does not invalidate the information and 

conclusions in the GEIS nor does it mean that it does not represent the best available quality 

data. With each supplement (including this SEIS for the KPS license renewal application) to the 

GEIS, the staff conducts a search for new and significant information that could alter the 

conclusions drawn in the GEIS. This search includes reviewing the applicant’s environmental 

report, reviewing public comments received during scoping and on the draft SEIS, coordinating 

with other Federal, State, and local agencies, and conducting an onsite audit, in addition to 

other research conducted while writing the SEIS. If the staff finds no new and significant

information, only then does it rely on the conclusions in the GEIS.

The staff understands that much scientific discovery and exploration has occurred since 1996 

and 1999, of which it makes every effort to stay informed. In every SEIS, the staff uses and 

references studies and information that have become available since the GEIS’s publication. In 

accordance with its 10-year review cycle and to incorporate what has been learned since its 

publication, the staff wrote and published a draft of revision 1 to the GEIS in 2009 (NRC, 

2009b). The staff is currently reviewing public comments on the draft, which it plans to publish in 

the near future.

This comment does not present any new or significant information; therefore, no changes were 

made to the SEIS based on this comment.

Comment I-18: When regulatory dose limits are referenced, the actual dose limit quantity 

should be provided as part of the plain language and transparency requirements for all Federal 

Agencies. In addition, when referencing applicable regulations, rules, and/or laws, it is important 

to reference the federal rule, regulation or law in addition to any that have been delegated to the 

State regulatory program.

Response: This comment is a partial repeat of comment I-16. The comment’s reference to 

citing regulations and laws lacks sufficient specificity to allow for changes to the SEIS. In 

general, the staff makes every effort to appropriately reference applicable documents in all of its 

publications as described in the NRC Editorial Style Guide, NUREG-1379 (NRC, 2009). No 

changes were made to the SEIS based on this comment.

Comment I-19: The Final SEIS should include how and where to find the following 

documentation for KPS: the GEIS, the radiological environmental monitoring program (REMP), 

and the independent comprehensive environmental radioactive survey program done by the 

Wisconsin Department of Health Services. Since these documents are critical to understanding 

the information found in the Draft SEIS, the Final SEIS should inform the reader how to view 

these documents with or without Internet access.

Response: All of the documents mentioned and their associated ADAMS accession numbers 

are listed in the references following Chapter 4. All are publically available in ADAMS and can 

be accessed online at the NRC’s Public Electronic Reading Room or in person at the NRC’s 
Appendix A

August 2010 A-31 NUREG-1437, Supplement 40

Public Document Room at NRC Headquarters in Rockville, MD. In addition, on the back of the 

front cover of every SEIS, there is information on how to obtain copies of NRC reference 

materials.

The SEIS contains sufficient information for interested parties to find the documents referenced 

within, in accordance with the NRC Editorial Style Guide, NUREG-1379 (NRC, 2009). No 

changes were made to the SEIS based on this comment.

A.2.2 Responses to Comments Grouped Bas ed on Similar Is s ues Rais ed

Specific comments were categorized and consolidated by topic where appropriate. Comments 

with similar and specific objectives were grouped to capture the common essential issues. Next 

to grouped comments, there is a three-component code(s) corresponding to the Commenter ID, 

then the number of the comment within the letter or e-mail, followed by the group code shown in 

Table A-3.

Comments: A-2-RW, B-2-RW, B-4-RW, F-5-RW, F-6-RW, I-6-RW

Radioactive Waste Management

Summary of issues:

● safe storage, effective monitoring, environmental consequences, and human 

health effects of storing high- and low-level radioactive waste onsite at KPS

● lack of offsite disposal sites for high- and low-level radioactive waste created by 

KPS, including whether or not KPS has sufficient capacity onsite for the waste it 

generates

● logistics of shipping high-level radioactive waste offsite

● tax payments made to local municipalities

Response:

The safety and environmental effects of long-term storage of spent fuel onsite have

been assessed by the NRC, and, as set forth in its Waste Confidence Decision (codified at

10 CFR 51.23), the Commission generically determined that such storage could be

accomplished without significant environmental impact. In the Waste Confidence Decision, the

Commission determined that spent fuel can be stored onsite for at least 30 years beyond the

license operating life, which may include the term of a renewed license. At or before the end of

that period, the fuel would be removed to a permanent repository. In its Statement of

Consideration for the 1990 update of the Waste Confidence Decision (55 FR 38472), the

Commission addressed the impacts of both license renewal and potential new reactors. In its

December 6, 1999, review of the Waste Confidence Decision (64 FR 68005), the Commission

reaffirmed the findings in the rule. In addition to the conclusion regarding safe onsite storage of

spent fuel, the Commission states in the rule that there is reasonable assurance that at least

one geologic repository will be available within the first quarter of the 21st century, and sufficient

repository capacity for the spent fuel will be available within 30 years beyond the licensed life for

operation of any reactor. The Commission issued a proposed revision of the Waste Confidence

Decision in the Federal Register (73 FR 59551) for comment on October 9, 2008. This revision
Appendix A

NUREG-1437, Supplement 40 A-32 August 2010

provided the basis for extending the time for sufficient repository capacity for spent fuel to be

available from within 30 years beyond the licensed life for operation of any reactor to within

50 to 60 years. The proposed revision also provides reasonable assurance that spent fuel can

be stored without significant environmental impacts for at least 60 years beyond the licensed life

for reactor operation assuming storage of spent fuel in either a spent fuel storage basin or 

onsite or offsite ISFSI.

Accordingly under 10 CFR 51.23(b), no site-specific discussion of any environmental impact of 

spent fuel storage in reactor facility storage pools or ISFSIs is required in an environmental

impact statement associated with license renewal. However, Chapter 6 of this SEIS contains 

information on the impacts of the uranium fuel cycle, which includes high-level radioactive 

waste.

The GEIS for license renewal (NUREG-1437) evaluated a variety of spent fuel and waste 

storage scenarios, including onsite storage of these materials for up to 30 years following 

expiration of the operating license, transfer of these materials to a different plant, and transfer of 

these materials to an ISFSI. During dry cask storage and transportation, spent nuclear fuel must 

be “encased” in NRC-approved casks. An NRC-approved cask is one that has undergone a 

technical review of its safety aspects and been found to meet all of the NRC’s requirements. 

These requirements are specified in 10 CFR Part 72 for storage casks and 10 CFR Part 71 for 

transportation casks. For each potential scenario involving spent fuel, the GEIS determined that 

existing regulatory requirements, operating practices, and radiological monitoring programs 

were sufficient to ensure that impacts resulting from spent fuel and waste storage practices 

during the term of a renewed operating license would be SMALL and is a Category 1 (generic) 

issue. This conclusion is contained in NRC regulations (Table B-1 of Appendix B to Subpart A to 

10 CFR Part 51). The Commission concluded that the impacts associated with spent fuel and 

high-level waste disposal are acceptable in that these impacts would not be so great that 

preserving the option of license renewal for energy-planning decisionmakers would be 

unreasonable. The staff’s evaluation of the KPS license renewal application did not reveal any 

new and significant information related to the storage of spent nuclear fuel. Thus, there are no 

impacts related to spent nuclear fuel storage beyond those discussed in the GEIS.

The staff notes that Wisconsin Statutes 196.493 require the Public Service Commission, as part 

of its deliberation process, include the availability of a repository for the disposal of high-level 

radioactive waste, in addition to the economic considerations for the construction of a new 

nuclear power plant within the State. The statute does not apply to the license renewal 

application for KPS since the plant was constructed prior to the effective date of this statute.

The staff’s discussion of KPS’s solid low-level radioactive waste management program is 

contained in Section 2.1.2.3 of this SEIS. There is a discussion dealing with the closure of the 

Barnwell low-level waste disposal facility to States not in the Atlantic Low-Level Waste 

Compact. The staff reported that KPS uses an offsite vendor to perform volume reduction on its 

waste. The volume-reduced waste is returned to KPS for storage. KPS reported that, based on 

its operational practices to minimize the generation of radioactive waste, it has adequate space 

for the long-term storage of its radioactive waste during the term of license renewal. In addition, 

KPS has access to the low-level radioactive waste disposal facility in Utah for its Class A waste. 

Class A waste is produced in much larger quantities than Class B and C waste. Therefore, with 

access to the Utah facility for its Class A waste during the term of license renewal, the potential 

problem of needing a large, onsite storage facility is reduced. A detailed discussion of KPS’s 

plan for the storage of low-level radioactive waste is outside of the scope of the environmental 

review process. This is because, for license renewal, the staff evaluated the low-level 
Appendix A

August 2010 A-33 NUREG-1437, Supplement 40

radioactive waste issues at all commercial nuclear power reactors in the United States and 

determined that the impacts related to the storage of low-level radioactive waste, as set forth in 

the GEIS and in Table B-1 of Appendix B to Subpart A of 10 CFR Part 51, are Category 1 

(generic) and SMALL. The finding is based on the comprehensive regulatory controls that are in 

place and the low public doses being achieved at all power reactors.

The transportation and storage of radioactive waste is discussed in Chapter 6 of the SEIS and 

Addendum 1 to the GEIS (NRC, 1999) for license renewal. The GEIS addresses both the 

radiological and nonradiological environmental impacts resulting from the storage and 

shipments of low-level radioactive waste and mixed waste to offsite disposal facilities and of 

spent fuel to a retrievable storage or permanent repository. These impacts were all determined 

to be SMALL. In addition, Table S-4 in 10 CFR 51.52 lists the environmental impacts of 

transportation of spent fuel and waste to and from a nuclear power reactor. The nonradiological 

impacts are traffic density, weight of the loaded truck or railcar, heat from the fuel cask, and 

transportation accidents. The radiological impacts include possible exposures of transport 

workers and the general public along transportation routes. Radiation exposure to these groups 

may also occur through accidents along transportation corridors. The environmental impacts 

from the transportation of fuel and waste attributable to license renewal are found to be SMALL

when they are within the range of the impact parameters identified in Table S-4.

In addition to the generic assessment done by the NRC, the DOE is responsible for the 

preparation of a detailed, site-specific environmental impact statement that discusses the 

impacts associated with the multiple modes and options available for the transportation of spent 

nuclear fuel from nuclear power plants to a licensed storage or disposal site.

The NRC ensures that the nuclear power plants are operated safely within radiation protection 

requirements; the NRC does this by licensing the plants to operate, licensing the plant 

operators, and establishing license conditions for the safe operation of each plant. Radioactive 

waste is one of the areas inspected under the NRC’s ROP inspection and enforcement 

programs. The NRC has qualified inspectors that, on an ongoing periodic basis, go to KPS to 

perform a detailed inspection of its compliance with NRC radiation protection and radioactive 

waste regulations. The results of the inspection are publically available on the NRC’s Web site

and in ADAMS. If there is a violation of an NRC requirement, the NRC assesses the risk 

significance of the event and conducts enforcement actions as appropriate. These periodic 

inspections ensure that the plant continues to operate within NRC safety standards to protect 

the public’s health and safety.

Under 10 CFR 51.53(c)(2), the NRC does not require an applicant to address the economic 

costs of license renewal or of the alternatives to license renewal, except insofar as such costs 

and benefits are either essential for a determination regarding the inclusion of an alternative in 

the range of alternatives considered or relevant to mitigation. In addition, the issues raised by 

these comments involve tax and energy planning decisions that are made by the State, other 

regulators, and utility officials. The NRC has no role in these energy planning decisions or in the 

taxes paid by the owners of nuclear power plants, which includes the taxes associated with the 

local storage of radioactive waste.

These comments do not present any new or significant information; therefore, no changes were 

made to the SEIS based on these comments.

Comments: A-3-MP, B-5-MP

Monitoring Programs
Appendix A

NUREG-1437, Supplement 40 A-34 August 2010

Summary of issues:

● desire for increased monitoring in light of past tritium leaks at KPS and recent 

leaks at other nuclear power plant sites

● desire for new testing sites and monitoring wells

● general lack of effectiveness of the monitoring programs leading to 

contamination of the site and surrounding water

● no public acceptance of the radioactive emission limits associated with the 

monitoring programs

● concerns of unpredictable changes of radioactivity emission limits by the NRC

Response:

The NRC requires DEK to control, monitor, and report the types and amounts of radioactive 

effluents discharged into the environment from routine and abnormal (e.g., spills and leaks) 

effluent discharges. The NRC’s regulations and plant-specific license conditions are designed to 

limit the radiological impact to workers and members of the public from plant operation. As part 

of its inspection and enforcement programs, the NRC performs periodic inspections of DEK’s 

compliance with NRC’s radiation protection requirements to ensure that human health is 

adequately protected.

DEK conducts a radiological environmental monitoring program (REMP) to assess the 

radiological impact, if any, to its employees, the public, and the environment in the plant’s 

environs. 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 the 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. To document its findings, KPS issues an annual 

radiological environmental operating report, which discusses the results of its monitoring 

program. The report contains data on the monitoring performed for the past year and graphs 

which trend the data from prior years. 

The REMP collects samples of environmental media in order to measure the radioactivity levels 

that may be present. The media samples are representative of the radiation exposure pathways 

that may impact the public. The REMP measures the aquatic, terrestrial, and atmospheric 

environment for radioactivity, as well as the ambient radiation. Ambient radiation pathways 

include radiation from buildings and plant structures and airborne material that may be released 

from the plant. In addition, the REMP measures background radiation (e.g., cosmic sources, 

global fallout, and naturally-occurring radioactive material, including radon). Thermoluminescent 

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 milk and food products. The aquatic 

environmental monitoring consists of analyzing samples of water from Lake Michigan, 

groundwater, drinking water, and shoreline sediment. An annual land use census is conducted 

to determine if the REMP needs to be revised to reflect changes in the environment or 
Appendix A

August 2010 A-35 NUREG-1437, Supplement 40

population that might alter the radiation exposure pathways. KPS has an onsite groundwater

protection program designed to monitor the onsite plant environment for early detection of leaks 

from plant systems and pipes containing radioactive liquid.

The staff reviewed the KPS annual radiological environmental monitoring reports for 2004 

through 2008 (which are all publically available) to look for any significant impacts to the 

environment or any unusual trends in the data. No adverse trends were observed, and the data 

showed that there was no measurable impact to the environment from operations at KPS. The 

complete evaluation is contained in Section 4.8.1 of this SEIS.

KPS also has an onsite groundwater protection program designed to monitor the onsite plant 

environment for early detection of leaks from plant systems and pipes containing radioactive 

liquid. Section 2.2.3.2 of the SEIS contains a discussion of KPS’s groundwater monitoring 

program.

One of the primary duties of the NRC is to establish regulations on the safe use of nuclear 

materials. These regulations address such issues as siting, design, construction, operation, and

the ultimate shutdown of nuclear power plants, uranium mills, fuel facilities, waste repositories,

and transportation systems, which includes the regulations governing the monitoring programs 

and the radiological effluent limits mentioned in these comments. The process of developing

these regulations is called “rulemaking.” A regulation is sometimes referred to as a “rule.” The 

rulemaking process is described in detail in 10 CFR Part 2 Subpart H. Once established, the 

rules should be perceived to be reliable and not unjustifiably in a state of transition, so as to lend 

stability to the nuclear operational and planning processes.

All rulemakings provide the public with at least one opportunity to provide comments on the 

rule(s). Often, there are several opportunities. In some cases, NRC holds meetings and 

workshops before a proposed rule is drafted. This way, members of the public can express their 

concerns early in the process and identify important issues to be covered in the rule. 

Sometimes, the NRC may publish an Advance Notice of Proposed Rulemaking in the Federal

Register to obtain public comments and provide clarification of certain issues before developing 

a proposed rule. When a proposed rule is developed, it is published in the Federal Register for 

public comment. The notice identifies an NRC contact who can reply to questions and provides 

an address for sending comments. The agency may hold meetings and workshops to discuss

the proposed rule, explain its purpose and background, and receive further comments. These

meetings are normally announced in the Federal Register. All comments are considered by the 

staff and may be factored into the final rule, which, like the proposed rule, is again published in 

the Federal Register. The NRC issues press releases for rules that have strong public interest. 

In addition, the Web site, www.regulations.gov

These comments do not present any new or significant information; therefore, no changes were 

made to the SEIS based on these comments.

, provides the status of all rulemakings in 

progress and allows for public comment on the rules.

Comments: F-2-AM, F-3-AM, G-2-AM, H-3-AM

Aging Management

Summary of issues:

● lack of aging management programs for various systems
Appendix A

NUREG-1437, Supplement 40 A-36 August 2010

● concern that nuclear power plant aging leads to general plant degradation, 

which leads to more leaks

Response:

NEPA focuses on the environmental impacts of a major Federal action (such as license 

renewal) rather than on issues related to the safety of an operation. Safety issues become 

important to the environmental review when they could result in environmental impacts, which is 

why the environmental effects of postulated accidents are considered in this SEIS. Because the 

CEQ regulations implementing NEPA do not include a safety review, the NRC has codified

regulations for conducting an environmental impact statement separate from the regulations for 

reviewing safety issues during its review of a license renewal application. The regulations 

governing the environmental review are contained in 10 CFR Part 51, and the regulations 

covering the safety review (which includes the aging management issues discussed in these 

comments) are contained in 10 CFR Part 54. For this reason, the license renewal review

process includes an environmental review that is distinct and separate from the safety review. 

Because the two reviews are separate, operational safety issues and safety issues related to 

aging are considered outside the scope for the environmental review, just as the environmental 

issues are not considered as part of the safety review.

With respect to the safety aspect of such systems and components being able to operate for 

another 20 years, the staff makes that determination as part of its license renewal safety review, 

which focuses on the programs and processes that are designed to ensure adequate protection 

of the public health and safety during the 20-year license renewal period through management 

of aging components. As part of the license renewal safety review, KPS is required to 

demonstrate that the effects of aging will be adequately managed.

These comments do not present any new or significant information; therefore, no changes were 

made to the SEIS based on these comments.

Comments: E-3-LE, F-2-LE, G-1-LE, H-2-LE, H-11-LE

Leaks

Summary of issues:

● concerns regarding a 2006 tritium leak at KPS

● concerns regarding tritium leaks in general from any nuclear power plant 

Response:

The NRC evaluates abnormal releases of tritium-contaminated water from nuclear power plants, 

particularly those that result in groundwater contamination. The NRC evaluates the releases as 

part of its ROP inspection program and makes a determination as to the potential impact to 

public health and safety. The NRC takes these unanticipated and unmonitored releases very 

seriously and reviews these incidents to ensure that nuclear power plant operators take 

appropriate action.
Appendix A

August 2010 A-37 NUREG-1437, Supplement 40

In response to the events mentioned by the commenters and past industry-wide events, the 

NRC revised its inspections of nuclear power plants to evaluate licensees’ programs to inspect, 

assess, and repair equipment and structures that could potentially leak. The NRC also placed 

additional emphasis on evaluating the licensees’ abilities to analyze additional discharge 

pathways, such as groundwater, as a result of a spill or leak. The agency’s resident inspectors, 

who work full-time at operating U.S. nuclear power plants, regularly monitor all these activities 

and any deficiencies can trigger more intensive NRC oversight of a plant.

In 2006, an NRC “lessons learned” task force examined previous inadvertent, unmonitored 

liquid releases of radioactivity from U.S. commercial nuclear power plants. The task force 

recommended changes in the agency’s regulatory program and industry efforts. The task force’s 

findings and the NRC’s response are available on the NRC Web site at: 

http://www.nrc.gov/reactors/operating/ops-experience/grndwtr-contam-tritium.html. 

In early 2010, the NRC convened a new task force to determine what, if any, changes are 

needed to its guidance and regulations related to the integrity of nuclear power plant systems 

and buried piping containing radioactive fluids and groundwater monitoring and protection. The 

task force issued its final report in June 2010, and the staff plans to issue its corresponding 

recommendations to the Commission in the fourth quarter of 2010. DEK will be required to 

follow any resulting changes to the regulations at KPS.

With regards to the leak at KPS in 2006, the staff reviewed the KPS annual radiological 

environmental monitoring reports for 2004 through 2008 (which are all publically available) to 

look for any significant impacts to the environment or any unusual trends in the data. No 

adverse trends were observed, and the data showed that there was no measurable impact to 

the environment from operations at KPS. The complete evaluation is contained in Section 4.8.1 

of this SEIS.

These comments do not present any new or significant information; therefore, no changes were 

made to the SEIS based on these comments.

Comments: B-6-HH, E-3-HH, F-2-HH, G-4-HH, G-6-HH, H-6-HH, H-7-HH, H-10-HH, H-11-HH

Human Health Issues

Summary of issues:

● concerns that adverse health effects are caused by nuclear power plants and 

their emissions of radioactive substances, especially tritium

● irreversible contamination due to nuclear power plant emissions of radioactive 

substances, especially tritium

Response:

Tritium is a naturally occurring radioactive form of hydrogen that is produced in the atmosphere 

when cosmic rays collide with air molecules. As a result, tritium is found in very small or trace 

amounts in groundwater throughout the world. It is also a byproduct of the production of 

electricity by nuclear power plants. Tritium emits a weak form of radiation, a low-energy beta 

particle similar to an electron.
Appendix A

NUREG-1437, Supplement 40 A-38 August 2010

Although radiation may cause cancers at high doses, currently there are no reputable 

scientifically conclusive data that unequivocally establish the occurrence of cancer following 

exposure to low doses, below about 10 roentgen equivalent man (rem) (0.1 sievert (Sv)).

However, 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 

higher 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, results 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 over-estimates 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 in 10 

CFR Part 20 is 100 mrem (1 mSv) for all facilities licensed by the NRC, the NRC has imposed 

additional constraints on nuclear power reactors. Each nuclear power reactor, including KPS, 

has enforceable license conditions that limit the cumulative annual whole body dose to a 

member of the public from all radioactive emissions in the offsite environment to 25 mrem 

(0.25 mSv). In addition, there are license conditions to further limit the dose to a member of the 

public from radioactive gaseous effluents to an annual dose of 5 mrem (0.05 mSv) to the whole 

body and 15 mrem (0.15 mSv) to any organ. For radioactive liquid effluents, the dose standard 

is 3 mrem (0.03 mSv) to the whole body and 10 mrem (0.1 mSv) to any organ.

Nuclear power reactors were licensed with the knowledge that they would release radioactive 

materials into the environment. NRC regulations require that the radioactive material released 

from nuclear power facilities be controlled, monitored, and reported in publically available 

documents. The amount of radioactive effluents released into the environment is known to be 

small. The radiation exposure received by members of the public from commercial nuclear 

power reactors is so low (i.e., less than a few mrem) that resulting cancers attributed to the 

radiation have not been observed and would not be expected. To put this in perspective, each 

person in this country receives a total annual dose of about 300 mrem (3 mSv) from natural 

sources of radiation (e.g., 200 mrem from naturally occurring radon, 27 mrem from cosmic rays,

28 mrem from soil and rocks, and 39 mrem from radiation within our body) and about 63 mrem 

(0.63 mSv) from man-made sources (e.g., 39 mrem from medical x-rays, 14 mrem from nuclear 

medicine, 10 mrem from consumer products, 0.9 mrem from occupations, less than 1 mrem 

from the nuclear fuel cycle, and less than 1 mrem from fallout due to weapons testing).

Although a number of studies of cancer incidence in the vicinity of nuclear power facilities have

been conducted, there are no studies to date that are accepted by the scientific community that 

show a correlation between radiation dose from nuclear power facilities and cancer incidence in 

the general public. The following is a listing of a few studies recognized by the staff:

● In 1990, at the request of Congress, the NCI conducted a study of cancer 

mortality rates around 52 nuclear power plants and 10 other nuclear facilities. 

The study covered the period from 1950 to 1984 and evaluated the change in 

mortality rates before and during facility operations. The study concluded there 

was no evidence that nuclear facilities may be linked causally with excess 

deaths from leukemia or from other cancers in populations living nearby (NCI, 

1990).

● In June 2000, investigators from the University of Pittsburgh found no link 

between radiation released during the 1979 accident at the Three Mile Island 
Appendix A

August 2010 A-39 NUREG-1437, Supplement 40

power plant and cancer deaths among nearby residents. Their study followed 

32,000 people who lived within 5 miles of the plant at the time of the accident

(Talbot et al., 2003).

● The Connecticut Academy of Sciences and Engineering, in January 2001, 

issued a report on a study around the Haddam Neck nuclear power plant in 

Connecticut and concluded radiation emissions were so low as to be negligible

and found no meaningful associations to the cancers studied (CASE, 2001).

● Also in 2001, the Florida Bureau of Environmental Epidemiology reviewed 

claims that there are striking increases in cancer rates in southeastern Florida 

counties caused by increased radiation exposures from nuclear power plants. 

However, using the same data to reconstruct the calculations, on which the 

claims were based, Florida officials were not able to identify unusually high rates 

of cancers in these counties compared with the rest of the State of Florida and 

the nation (Bureau of Environmental Epidemiology, 2001).

● In 2000, the Illinois Public Health Department compared childhood cancer 

statistics for counties with nuclear power plants to similar counties without 

nuclear plants and found no statistically significant difference (Illinois Public 

Department of Health, 2000).

● The American Cancer Society in 2004 concluded that although reports about 

cancer clusters in some communities have raised public concern, studies show 

that clusters do not occur more often near nuclear plants than they do by 

chance elsewhere in the population. Likewise, there is no evidence that links 

strontium-90 with increases in breast cancer, prostate cancer, or childhood 

cancer rates. Radiation emissions from nuclear power plants are closely 

controlled and involve negligible levels of exposure for nearby communities

(ACS, 2004).

In April 2010, the NRC asked the NAS to perform a state-of-the-art study on cancer risk for 

populations surrounding nuclear power facilities. The NAS study will update the 1990 U.S. 

National Institutes of Health - NCI report, “Cancer in Populations Living Near Nuclear Facilities”

(NCI, 1990). The study is scheduled to begin in 2010 and is expected to be completed within 4

years. Information from the report will be considered for incorporation into future updates of the 

NRC’s guidance and regulations, as appropriate.

To ensure that U.S. nuclear power plants are operated safely, the NRC licenses the nuclear 

power plants to operate, licenses the plant operators, and establishes license conditions for the 

safe operation of each plant. The NRC provides continuous oversight of plants through its ROP 

to verify that they are being operated in accordance with NRC regulations. The NRC has full 

authority to take whatever action is necessary to protect public health and safety and the 

environment and may demand immediate licensee actions, up to and including a plant 

shutdown.

As part of the license renewal process, the staff reviewed the REMP at KPS. DEK conducts a 

REMP in which radiological impacts to the environment and the public around KPS are 

monitored, documented, and compared to NRC standards. Please see the staff’s response to 

the “Monitoring Programs” comments above for a thorough explanation of the REMP at KPS in 

addition to Section 4.8.1 of this SEIS.
Appendix A

NUREG-1437, Supplement 40 A-40 August 2010

KPS also has an onsite groundwater protection program designed to monitor the onsite plant 

environment for early detection of leaks from plant systems and pipes containing radioactive 

liquid. Section 2.2.3.2 of the SEIS contains a discussion of KPS’s groundwater monitoring 

program.

The evaluation performed by the staff on the continued operation of KPS for an additional 

20 years concluded that radiation doses to the public would continue at current levels 

associated with normal operations and can be expected to remain within NRC radiation 

protection standards.

These comments do not present any new or significant information; therefore, no changes were 

made to the SEIS based on these comments.

A.2.3 Complete Versions of the Letters and E-mails Commenting on the Draft 

Supplemental Environmental Impact Statement

Commenter A

Hello:

: Steve Books, citizen

I would like to make some comments regarding the Kewaunee Nuclear Power Station, 

Kewaunee, WI.

In the abstract and Executive Summary the wording for the recommendation as “being not so 

great” seems possible to have a double meaning. Is “not so great” to be considered as negative, 

or positive? I would like to ask for wording that clarifies the exact meaning and intent of the 

sentence.

There is no inside reinforced concrete storage of the spent nuclear fuel that a local Town Board 

requested after a vote in 1993. For various safety reasons, the spent nuclear fuel rods should 

be placed inside a storage facility with ample protection from above. Nuclear fuel rods that have 

been stored since 1974 need to be safely stored, and monitored. Yucca Mountain Storage has 

failed. The storage issue should not be in any way or form, “outside the scope of license 

renewal,” no matter what the method of storage is. Storage safety is one big issue, and any 

canister that spent fuel assemblies are placed in should be placed inside reinforced concrete 

structures. The factor of nuclear storage risk, and nuclear storage payments should be 

increased to the local municipality as nuclear waste increases.

Since a power plant in the State of Vermont has had serious reactor-borne tritium and cobalt-60 

contamination to surface and groundwater, I would like to see additional testing and monitoring 

being implemented on any possible gamma emitting isotopes, gamma emitting radonuclides, 

and cancer causing tritium at the testing sites, and the creation of new testing sites to monitor 

possible contamination in the soil, water, and groundwater at or new the Kewaunee Nuclear 

Power Plant.

In the Fall of 2004, Nuclear Regulatory Commission issued a White Finding to the Kewaunee 

plant regarding the containment vessel head and lack of oversight of being able to close the 

hatch quickly. Would this situation ever arise again?

Severe Accident Mitigation Alternatives need to be continually researched with the Plant 

Workers for enhanced plant safety. Is this being accomplished since Dominion Resources have 

owned the facility?

A-1

A-2-RW

A-3-MP

A-4

A-5
Appendix A

August 2010 A-41 NUREG-1437, Supplement 40

In section 2.2.9 Historic and Archaeological Resources, is the Indian tribe name Oneida being 

incorrectly spelled Oneota?

In the Section 8.5 Alternatives Considered But Dismissed, Wind Energy is now more readily 

being implemented as base load power. Off-shore Lake Michigan wind energy was not 

discussed in the statement. The option of wind energy in the Great Lakes is missing in the 

impact statement. Iowa has 7 times the amount of wind energy that Wisconsin has, Minnesota 

and Illinois have about 3 times the amount of wind energy. Wind energy from off shore Lake 

Michigan was discussed in recent Milwaukee Journal Sentinel publications.

In the Section 8.5.3 Energy Conservation, no specific mention of electricity rate programs that 

could have a statewide impact on energy conservation is not mentioned. The local Utility in 

Waverly lowa has a rate program that uses inverted rates during the summer to attempt to 

off-set energy consumption due to air conditioning use. The utility charges more after a set 

amount as a way to increase revenue, and to stress energy conservation. Wisconsin has no 

utility that users inverted rates to increase revenue, or to encourage energy conservation that 

could have an impact on electricity use.

In the Section 8.5.7 Biofuels, anaerobic digesters that are currently being used on many 

Wisconsin Farms are missing from the discussion. There are many farms in the 50 mile radius 

of the Kewaunee Plant that make use of an anaerobic digester to make electricity along with 

other products from farm manure waste that livestock, usually dairy cows, produce on 

Wisconsin Dairy Farms One of those farms is in Kewaunee, Pagel’s Ponderosa Dairy. Many 

cooperatives are being set up in Wisconsin to handle area farmers manure waste in the form of 

Biogas Anaerobic Digesters. This area of alternatives needs to explored and included in the

Environmental Impact Statement.

These are my questions and comments.

Sincerely,

Steve Books

Mount Horeb, WI

organization: Self

address1: 211 S. 2nd St.

address2:

city: Mount Horeb

state: WI

zip: 53572

country: United States

phone: (608) 437-5478

Commenter B

Nuclear information and Resource Service (NIRS) opposes the license renewal of the 

Kewaunee Nuclear Power Station for safety, security, environmental, public and worker health 

and safety reasons.

: Diane D’Arrigo, Nuclear Information and Resource Service (NIRS) 

A) Radioactive Waste

1) So-called “low-level” radioactive waste includes all the radioactive elements as in high 

level radioactive waste—they simply are not in the irradiated fuel rods. They remain 

A-6

A-7

A-8

A-9

B-2-RW

B-1
Appendix A

NUREG-1437, Supplement 40 A-42 August 2010

radioactively hazardous for just as long as high level radioactive waste and according to the US

Government Accounting Office report (GAO/RCED-98-40R Questions on Ward Valley on 

radioactive waste pp 49-52), some “low-level” radioactive waste can give a lethal dose in 

20 minutes if exposed unshielded. Specifically Class B and C can give high doses and these 

are the wastes for which there is no disposal from the Kewaunee Nuclear Power Station. 

In the absence of permanent disposal for much of the radioactivity in so-called “low-level” 

radioactive waste, it makes no sense to keep generating the waste. 

There is no licensed disposal for Class B or C or Greater-than-Class-C radioactive waste from 

the reactor, yet there is no plan or provision in the license renewal for long term management or 

disposal of this waste. Since mid 2008, Wisconsin nuclear waste generators do not have access 

to disposal for Class B and C radioactive waste so must store it onsite.

What storage capacity exists?

For how many years?

How secure is it?

Will the waste be stored or processed and stored on site? Will it be shipped away with the 

potential for being returned? The license renewal will guarantee continued production of Class B 

and C waste but the application does not address it. There is no disposal available for 

Greater-than-Class-C waste either. How much will be generated and where and how will it be 

stored?

The conditions now are much different that when the original license was granted. Nuclear 

waste sites have operated, closed and new ones are not available.

From the Kewaunee Power Station Applicant’s Environmental Report Attachment E

[http://www.nrc.gov/reactors/operating/licensing/renewal/applications/kewaunee/kewaunee-envir-rpt.pdf

Table E-1. Environmental Authorizations for Current Operations page E-11, all 3 

licenses/permits to ship radioactive waste to licensed disposal and processing have 

expired, in 2008. (From Table E-1: South Carolina Radioactive waste transport permit 

0044-48-08 Expires 12/31/08 which allowed transportation of radioactive waste to disposal 

facility in South Carolina; Tennessee Department of Environment and Conservation License to 

ship radioactive material T-WI003-L08 Expires 12/31/08 for shipments of radioactive material to 

processing facility in Tennessee; Utah Department of Environmental Quality Site Access Permit 

0704004220 Expires 6/28/08 for access to land disposal site in Utah.) 

]

Even if the permits to transport are renewed, there is no operable, available permanent disposal 

for Class B and C waste in the United States (outside the Atlantic, Northwest and Rocky 

Mountain Compacts).

It is clearly irresponsible to proceed with licensing or relicensing a reactor without consideration 

and provision of proper waste management. It violates the National Environmental Policy Act 

NEPA and NRC regulations that require compliance with NEPA. 

Depending how long the waste stays on site, its condition and management, the doses to the 

public, worker and environment and the amount and form of the waste that accumulates, it 

could pose serious threats to the public, workers and the environment. The location of the 

reactor is unique, increasing the threat from additional nuclear waste at the site to the specific 

water and species.

B-2-RW, 

continued

B-3
Appendix A

August 2010 A-43 NUREG-1437, Supplement 40

2) High Level Radioactive Waste

In the Kewaunee Power Station Applicant’s Environmental Report Attachment E Operating 

License Renewal Stage page E-37 inadequate utility response to state law on high level waste 

is reported:

5.10.3) The Wisconsin Public Service Commission may not certify any 

nuclear power plant unless the commission finds that a federally licensed 

facility, or a facility outside of the United States which the commission 

determines will satisfy the public welfare requirements of the people of the 

state, with adequate capacity to dispose of high-level nuclear waste from 

all nuclear power plants operating in the state will be available, as 

necessary, for the disposal of the waste and the proposed nuclear power 

plant, in comparison with feasible alternatives, is economically 

advantageous to ratepayers. (See Wis. Stats. § 196.493) 

KPS Response: KPS was duly authorized by the State of Wisconsin when KPS 

was originally built. 

THAT’S IT? One of the oldest reactors in the country is allowed to ignore the current 

situation in which nuclear waste is piling up at reactors across the country with no permanent 

way to isolate it from the environment for the eons it will remain a radioactive threat to the public 

and environment? The US taxpayer is paying millions of dollars to nuclear utilities NOW and will 

be for the indefinite future because there is not high level radioactive waste disposal and NOW 

and will be for the indefinite future because there is not high level radioactive waste disposal 

and DOE foolishly promised it. NRC then affirmed its “confidence” that the waste would be 

managed but is now reconsidering that. There is simply no justification for continued generation 

of more irradiated fuel. 

3) Tritium and Routine Releases

Nuclear reactors are legally permitted to routinely release various amounts of radioactive 

materials into the air and water.

The public never accepted these emissions. They were imposed on us and the legal amounts 

and concentrations are regularly raised by the regulatory agencies (NRC and DOT) at the need 

of the utilities.

Despite this concession of public health and environmental risk, the nuclear utilities do not 

effectively monitor or report their emissions and many violated these regulations. Rather than 

discharging their routine radioactive releases through pipes into the public waters, the 

radioactivity at many reactors has leaked from the pipes, in some cases contaminating soil and 

groundwater. One of the radionuclides found leaking from reactors is tritium.

Tritium is radioactive hydrogen. It spreads with water. It is taken up by the organisms in the 

ecosystem into the same places that water goes. It can be incorporated into genetic material. 

Tritium has a half-life of 12.3 years so can be hazardous for 123 to 246 years.

From http://www.nirs.org/radiation/tritium/tritiumhome.htm

Tritium emits radioactive beta particles. Once tritium is inhaled or swallowed, its 

beta particles can bombard cells. If a particle zaps a DNA molecule in a cell, it 

:

B-4-RW

B-5-MP

B-6-HH
Appendix A

NUREG-1437, Supplement 40 A-44 August 2010

can cause a mutation. If it mutates a gene important to cell function, a serious 

disease may result. Just as water containing ordinary hydrogen and oxygen is a 

component of all living cells, tritiated water can also be incorporated into the cells 

of the body. Tritium incorporated into the DNA of plants and animals is referred to 

as organically bound tritium (OBT). Organically bound tritium can deliver 

damaging radiation doses for a much longer time than ingested tritiated water or 

inhaled tritiated water vapor. Research indicates that tritium can remain in the 

human body for more than ten years.

Routine releases and accidental spills of tritium from nuclear power plants pose a 

growing health and safety concern. Exposure to tritium has been clinically proven 

to cause cancer, genetic mutations and birth defects in laboratory animals. In 

studies conducted by Lawrence Livermore Laboratory in 1991, a comprehensive 

review of the carcinogenic, mutagenic and teratogenic effects of tritium exposure 

revealed that tritium packs 1.5 to 5 times more relative biological effectiveness 

(RBE), or biological change per unit of radiation (one rad or 0.01 gray), than 

gamma radiation or X-rays. 

Scientific Abstracts on Tritium are summarized at 

http://www.nirs.org/radiation/tritium/all16abstracts.pdf and more information on tritium is 

available at http://www.nirs.org/radiation/tritium/accidents.htm

Before any consideration of extended operation of the Kewaunee Nuclear Power Station, all 

concerns about tritium releases and any other radionuclide emissions must be resolved to the 

satisfaction of the public.

Diane D’Arrigo, NIRS

April 21, 2010

B-6-HH, 

continued
Appendix A

August 2010 A-45 NUREG-1437, Supplement 40

Commenter C: Dan Duchrow, Wisconsin Historical Society

C-1
Appendix A

NUREG-1437, Supplement 40 A-46 August 2010

Commenter D: Leslie Hartz, Dominion Energy Kewaunee, Inc.
Appendix A

August 2010 A-47 NUREG-1437, Supplement 40
Appendix A

NUREG-1437, Supplement 40 A-48 August 2010
Appendix A

August 2010 A-49 NUREG-1437, Supplement 40
Appendix A

NUREG-1437, Supplement 40 A-50 August 2010

D-2

D-1

D-4

D-3

D-5
Appendix A

August 2010 A-51 NUREG-1437, Supplement 40

D-6

D-7

D-8
Appendix A

NUREG-1437, Supplement 40 A-52 August 2010

D-10

D-9

D-12

D-11
Appendix A

August 2010 A-53 NUREG-1437, Supplement 40

D-13

D-15

D-16

D-14
Appendix A

NUREG-1437, Supplement 40 A-54 August 2010

D-18

D-17

D-19

D-20
Appendix A

August 2010 A-55 NUREG-1437, Supplement 40

D-21

D-24

D-22

D-23
Appendix A

NUREG-1437, Supplement 40 A-56 August 2010

D-28

D-27

D-25

D-26
Appendix A

August 2010 A-57 NUREG-1437, Supplement 40

D-29
Appendix A

NUREG-1437, Supplement 40 A-58 August 2010
Appendix A

August 2010 A-59 NUREG-1437, Supplement 40
Appendix A

NUREG-1437, Supplement 40 A-60 August 2010
Appendix A

August 2010 A-61 NUREG-1437, Supplement 40
Appendix A

NUREG-1437, Supplement 40 A-62 August 2010
Appendix A

August 2010 A-63 NUREG-1437, Supplement 40
Appendix A

NUREG-1437, Supplement 40 A-64 August 2010
Appendix A

August 2010 A-65 NUREG-1437, Supplement 40
Appendix A

NUREG-1437, Supplement 40 A-66 August 2010
Appendix A

August 2010 A-67 NUREG-1437, Supplement 40
Appendix A

NUREG-1437, Supplement 40 A-68 August 2010

Commenter E: John LaForge, Nukewatch

E-1

E-2

E-3-HH,

E-3-LE
Appendix A

August 2010 A-69 NUREG-1437, Supplement 40

E-3-HH,

continued

E-4

E-5
Appendix A

NUREG-1437, Supplement 40 A-70 August 2010
Appendix A

August 2010 A-71 NUREG-1437, Supplement 40

Commenter F

Date: April 23, 2010

: Alfred Meyer, citizen

RE: NUREG-1437, 13 Supplement 40, draft; Pertaining to license renewal for Kewaunee 

Nuclear Power Station, Wisconsin.

In reviewing NUREG-1437, 13 Supplement 40, draft, I find there to be five significant 

operational site conditions which are not addressed. Due to the real and present danger each 

issue presents, before the Nuclear Regulatory Commission can renew the license of the 

Kewaunee reactor, each of these five issues needs to be satisfactorily resolved, including a 

process for ongoing public input in this process.

Thus I request that the NRC hold License Renewal in abeyance until there is satisfaction of 

these public health and safety issues:

(1) There must be an age related management plan for of buried pipes with radiological

materials to protect the public health, safety and groundwater

a. Tritium leaks documented in 2006 at Kewaunee

b. Similar tritium leaks at many other U.S. reactors

c. There are no current age related management plan for buried pipes

d. The inherent problem is that the buried pipe systems cannot be easily and 

regularly inspected

e. The "leak first, fix later" scenario is insufficient to protect public health and safety.

f Tritium contamination is moving offsite towards Lake Michigan, leading to a much 

more pervasive problem for public safety, health and protection of the 

environment.

g. Therefore there is no plan for safety, health and environmental impacts of license 

renewal

h. This issue must be included in the scope and determinations of the EIS before 

license renewal is adjudicated

(2) No age related analysis of submerged electrical circuits

a. There must be a proactive inspection and maintenance program for all buried 

electrical circuits to ensure their good operating condition and dependability 

before license renewal can proceed.

(3) Tritium contamination of the Kewaunee site is not included in the current scope of the 

Decommissioning Plans - adequate funding levels must be determined before license 

renewal is adjudicated

a. As an example, the estimated costs of decommissioning (without acknowledging

actual Tritium contamination, which is currently being recognized as a 

F-2-AM,

F-2-HH,

F-2-LE

F-1

F-3-AM

F-4
Appendix A

NUREG-1437, Supplement 40 A-72 August 2010

significantly more than admitted by the reactor operator Entergy, who is being 

sued by the state of Vermont) are $1 Billion, whereas there are only $500 Million 

in the current Vermont Yankee decommissioning fund. A thorough analysis must 

be provided for Kewaunee prior to license renewal.

(4) With the likely demise of the Yucca Mountain Project, and in any case, no projected 

date for availability of a permanent geologic repository, the confidence aspect of the 

Waste Confidence Act is undermined. The EIS must now address the environmental, 

health and safety impacts of de facto permanent on site storage of the high level 

nuclear waste contained in the spent nuclear fuel before license renewal.

a. The current standard of 60 years for SafeStore post license term must be reevaluated 

in light of the lack of any plan for disposition of HLNW.

b. Since current dry cask storage technology is based on an expected 60-year 

lifetime, the health, safety and public health issues implicit in the use of such 

limited term technology for an indeterminate time must be addressed by the EIS 

before license renewal is adjudicated.

c. Public health, safety and decommissioning funding implications of extended on 

site dry cask storage, during and after license periods, must be included in the 

EIS, in particular, the need for and environmental impacts of maintaining existing 

cooling pool facilities and/or building new cooling pool structures that will be 

needed to handle any unplanned, emergency or planned transfers of spent fuel 

from initial dry cask storage units to new storage and/or transport units due to 

premature failure of said casks, extension of storage time beyond the planned 

lifetime of said casks, and/or implementation of different storage and/or transport 

containers. Current estimates for new cooling pool facility construction is 

approximately $300 Million.

(5) Public health and safety concerns of barge shipment on Lake Michigan should there be 

shipment of HLNW from the Kewaunee site to a yet-to-be-determined geologic 

repository

a. There is no road or rail transport capacity to move HLNW from the Kewaunee 

site at present.

b. Thus, barge shipment on Lake Michigan to a suitable port, such as the city of 

Milwaukee, as per DOE plans, must be addressed by the EIS.

I hereby request that no license renewal be awarded to the Kewaunee Nuclear Power Station 

until the above noted conditions have been resolved to the satisfaction of the general public.

Sincerely,

Alfred C. Meyer

312 - 11th Street N.E.

Washington, DC 20002

alfred.c.meyer@gmail.com

F-5, 

F-5-RW

F-6-RW

F-7

F-4, 

continued
Appendix A

August 2010 A-73 NUREG-1437, Supplement 40

Commenter G

In 2006, NRC reported Kewaunee leaked tritium at 1 gallon every 5 minutes into groundwater.

This is unacceptable. The last info I had the operators could not find the leak's source. This is 

extremely unacceptable.

: Susan Michetti, citizen

Tritium has a radioactive half-life of 12.3 years. As nuclear reactors age, like Kewaunee, cracks 

occur in holding tanks, waste fuel pools, and concrete floor slabs. Radioactive water leaks from 

tanks, flanges, valves, pumps, drums, pits, waste concentrators, tubes, and laundry systems. 

Leakage pathways are almost unlimited. This is environmentally unacceptable.

Worker safety is another issue.

Accidental releases as well as allowable releases cumulatively and irreversibly pollute soil, 

water, and air with radioactivity. Reckless irresponsibility has been the pattern in Wisconsin, 

from my viewpoint. If this wasn’t the case, there would have been no leakages, but leakages did 

occur demonstrating harm to the environment and to the public, particularly those who reside in 

the vicinity. This is unacceptable. Any exposure is harmful and accumulative--low level or high 

level.

Nuclear is too expensive and too risky. It is the dirtiest energy. It does not qualify for sustainable 

clean energy based upon its dirty characteristics found in every aspect from mining, to transport, 

to operations, to waste storage and the possibility of being a terrorist target, to the inability to 

dispose of it safely anywhere. This is unacceptable to continue such craziness.

Studies prove that cancers, leukemias, still births, mental retardation, and genetric problems 

increase in bellcurves around nuclear plants. Serious health risks harm people who live near the 

plant, and this is unacceptable. It's time to stop being chicken little with the head in the sand and 

refusing to see the reality that is clear to the rest of this nation regarding adverse health effects 

and the inability to keep the genie of radioactivity in the box where it belongs. Nuclear power is 

an unsafe dirty energy white elephant that certainly is no longer cost effective energy and will 

drive up the costs of residential electricity to unacceptable levels. Based on the lies told 

historically that nuclear power would be too cheap to meter, this was a false promise that never 

came close to being truthful in the same way that safety claims do not come close to being 

truthful. The people of Wisconsin do not want new nuclear power and we do not want this plant 

to be renewed bas! ed on its history of leaking radioaction into the groundwater that has never 

been stopped and that has never been publicly identified as a located source.

It is unsafe to renew the license of Kewaunee nuclear plant.

organization:

address1:

address2:

city:

state: Wl

zip: 53572

country:

phone:

G-2-AM

G-3

G-1-LE

G-4-HH

G-7

G-5

G-6,

G-6-HH
Appendix A

NUREG-1437, Supplement 40 A-74 August 2010

Commenter H

Do NOT re-license Kewaunee Nuclear Power Plant

: Duncan Tam, citizen

Environmental risks are unacceptable:

2006 leaked tritium 1 gal every 5 minutes in groundwater and they never found the source.

Kewaunee is an aging nuke reactor, predisposing it to cracks in holding tanks, waste fuel pools, 

concrete floor slabs. Radioactive water leaks from tanks, flanges, valves, pumps, drums, pits, 

waste concentrators, tubes, and laundry systems. Leakage pathways are almost unlimited. This 

is unacceptable risks.

Worker safety is an issue.

Evacuation is an environmental issue because the presence of Lake Michigan prevents escape 

routes in 50% of the directions away from the plant.

There is an acceptable 24 hr leak rate of plutonium into the air around any nuke plant.

Releases are cumulative and irreversible in polluting soil, water, and air with radioactivity.

Nuclear is the dirtiest energy, non-sustainable energy available with danger in every part from 

mining, to transportation, to operations, to waste storage and its terrorist attraction, to the 

inability to dispose of it. This is unacceptable. We need to protect the environment, not destroy 

it.

Nuclear pollution is excluded from our homeowners insurance, our vehicle insurance, and any 

other insurance we carry. It is so dangerous that the industry had to get the US Price Anderson 

Act passed to put a ceiling on each accident that will not pay for a small fraction of the damage 

around any major city. It is unacceptable for taxpayers to bear this risk.

Medical studies show leukemia, birth defects, mental retardation, and cancers to be higher in a 

bell curve around all nuclear plants. This is unacceptable.

Why are 27 US reactors spewing radioactive tritium from pipes if they are so safe? This safety is 

a false promise just like electricity too cheap to meter was.

The environment is compromised unacceptably around any nuclear plant in the US because 

humans aren't perfect and aren't responsible enough to follow the rules impeccably.

Relicensing Kewaunee is unacceptable.

Nam Myoho Renge Kyo.

For the Highest Good of All.

organization:

address1: 7203 Fortune Dr Apt 3

address2:

city: Middleton

state: WI

zip: 53562

H-1

H-4

H-2-LE

H-5

H-3-AM

H-6-HH

H-8

H-7-HH

H-9

H-11,

H-11-HH, 

H-11-LE

H-10-HH

H-12
Appendix A

August 2010 A-75 NUREG-1437, Supplement 40

Commenter I: Kenneth Westlake, United States Environmental Protection Agency (EPA)
Appendix A

NUREG-1437, Supplement 40 A-76 August 2010
Appendix A

August 2010 A-77 NUREG-1437, Supplement 40

I-2

I-6-RW

I-1

I-3

I-5

I-4
Appendix A

NUREG-1437, Supplement 40 A-78 August 2010

I-8

I-7

I-6-RW, 

continued

I-11

I-10

I-9

I-13

I-12
Appendix A

August 2010 A-79 NUREG-1437, Supplement 40

I-14

I-16

I-13,

continued

I-15

I-17

I-19

I-18
Appendix A

NUREG-1437, Supplement 40 A-80 August 2010

I-19, 

continued
Appendix A

August 2010 A-81 NUREG-1437, Supplement 40
Appendix A

NUREG-1437, Supplement 40 A-82 August 2010

A.3 REFERENCES

10 CFR 9. Code of Federal Regulations, Title 10, Energy, Part 9, “Public Records.”

10 CFR 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for Protection

Against Radiation.”

10 CFR 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of

Production and Utilization Facilities.”

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

Regulations for Domestic Licensing and Related Regulatory Functions.”

10 CFR 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for Renewal

of Operating Licenses for Nuclear Power Plants.”

10 CFR 71. Code of Federal Regulations, Title 10, Energy, Part 71, “Packaging and 

Transportation of Radioactive Material.”

10 CFR 72. Code of Federal Regulations, Title 10, Energy, Part 72, “Licensing Requirements for 

the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and 

Reactor-Related Greater Than Class C Waste.”

10 CFR 140. Code of Federal Regulations, Title 10, Energy, Part 140, “Financial Protection 

Requirements and Indemnity Agreements.”

40 CFR 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190,

“Environmental Radiation Protection Standards for Nuclear Power Operations.”

40 CFR 1500. Code of Federal Regulations, Title 40, Protection of Environment, Part 1500, 

“Council on Environmental Quality.”

55 FR 38472. U.S. Nuclear Regulatory Commission, Washington, D.C, “Waste Confidence 

Decision.” Federal Register, Vol. 55, September 18, 1990.

64 FR 68055. U.S. Nuclear Regulatory Commission, Washington, D.C, “Waste Confidence 

Decision Review: Status.” Federal Register, Vol. 64, No. 233, pp. 68055-68077, December 6, 

1999.

73 FR 59551. U.S. Nuclear Regulatory Commission, Washington, D.C, “Waste Confidence 

Decision Update.” Federal Register, Vol. 73, No. 197, pp. 59551-59570. October 9, 2008.

73 FR 59678. U.S. Nuclear Regulatory Commission, Washington, D.C, “Dominion Energy 

Kewaunee, Inc., Kewaunee Power Station; Notice of Intent To Prepare an Environmental

Impact Statement and Conduct Scoping Process.” Federal Register, Vol. 73, No. 197, 

pp. 59678-59679, October 9, 2008.

75 FR 6065. U.S. Nuclear Regulatory Commission, Washington, D.C., “Dominion Energy 

Kewaunee, Inc., Kewaunee Power Station; Notice of Availability of the Draft Supplement 40 to 

the Generic Environmental Impact Statement for License Renewal of Nuclear Plants and Public 

Meetings for the License Renewal of Kewaunee Power Station.” Federal Register, Vol. 73,

No. 24, pp. 6065, February 5, 2010.

American Cancer Society (ACS). 2004. “Cancer Facts and Figures – 2004.” Available URL:

http://www.cancer.org/downloads/STT/CAFF_finalPWSecured.pdf
Appendix A

August 2010 A-83 NUREG-1437, Supplement 40

Bureau of Environmental Epidemiology, Florida Department of Health. 2001. “Report 

Concerning Cancer Rates in Southeastern Florida.” In letter from David R. Johnson to 

Interested Parties, July 18, 2001. Available URL:

http://www.fpl.com/about/nuclear/contentsfdh_report.shtml

Connecticut Academy of Science and Engineering (CASE). 2001. “Bulletin of the Connecticut 

Academy of Science and Engineering,” Volume 16.2. Hartford, CT, Spring 2001.

Dominion Energy Kewaunee, Inc. (DEK). 2008. “Applicant’s Environmental Report – Operating 

License Renewal Stage,” Appendix E of Application for Renewed Operating License, Kewaunee 

Power Station, Docket No. 50-305, August 2008. ADAMS Accession No. ML082341039.

Dominion Energy Kewaunee, Inc. (DEK) 2009. “Cultural Resources Protection Plan,” Dominion 

Energy Kewaunee, Inc., Kewaunee Power Station. ADAMS Accession No. ML101320123.

Fitzsimmons et al. 2005. “Thiamine Content and Thiaminase Activity of Ten Freshwater Stocks 

and One Marine Stock of Alewives.” Journal of Aquatic Animal Health, Vol. 17, pp. 26-35. 

Illinois Public Department of Health. 2000. “Health and Hazardous Substances Registry 

Newsletter.” Illinois Public Health, Division of Epidemiologic Studies, Illinois Department of 

Public Health, 605 W. Jefferson St., Springfield, IL, Fall 2000.

Kramer, Joe. 2009. Wisconsin Agricultural Biogas Casebook, December 2009 Edition, Prepared 

for Focus on Energy Renewables Program, Madison, WI. Available URL: 

http://www.focusonenergy.com/files/Document_Management_System/Renewables/biogas09_c

asestudy.pdf.

National Cancer Institute (NCI). 1990. Cancer in Populations Living Near Nuclear Facilities. 

Bethesda, Maryland.

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

Talbott et al. 2003. “Long Term Follow-up of the Residents of the Three Mile Island Accident 

Area: 1979-1998.” Environmental Health Perspectives, Volume 111, Number 3, pp. 341–348,

March 2003.

U.S. Atomic Energy Commission (AEC). 1972. “Final Environmental Statement Related to the 

Operation of Kewaunee Nuclear Power Plant,” Wisconsin Public Service Corporation, Docket 

No. 50-305, Directorate of Licensing, Washington, D.C., December 1972. ADAMS Accession 

No. ML082820122.

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2, Washington, D.C. 

ADAMS Accession Nos. ML040690705 and ML040690738.

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1, 

Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report,” 

NUREG-1437, Volume 1, Addendum 1, Washington, D.C. ADAMS Accession No. 

ML040690720.

U.S. Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement 

on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of 

Nuclear Power Reactors, NUREG-0586, Supplement 1, Volumes 1 and 2, Washington, D.C. 

ADAMS Accession No. ML02350041.

U.S. Nuclear Regulatory Commission (NRC). 2008a. “Summary of Public License Renewal 

Overview and Environmental Scoping Meetings Related to the Review of the Kewaunee Power 
Appendix A

NUREG-1437, Supplement 40 A-84 August 2010

Station License Renewal Application (TAC MD9409),” November 17, 2008. ADAMS Accession 

No. ML083090596. (Includes public meeting transcripts.)

U.S. Nuclear Regulatory Commission (NRC). 2009. NRC Editorial Style Guide, NUREG-1379, 

Revision 2, Washington, D.C. ADAMS Accession No. ML093200744.

U.S. Nuclear Regulatory Commission (NRC). 2009a. “Issuance of Environmental Scoping 

Summary Report Associated with the Staff’s Review of the Application by Dominion Energy 

Kewaunee, Inc., for Renewal of the Operating License for Kewaunee Power Station,” April 6, 

2009. ADAMS Accession No. ML090770880.

U.S. Nuclear Regulatory Commission (NRC). 2009b. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants, Draft NUREG-1437 Revision 1, Volumes 1 and 2, 

Washington, D.C. ADAMS Accession Nos. ML09177048 and ML09177049.

U.S. Nuclear Regulatory Commission (NRC). 2010. “Forthcoming Meeting to Discuss the Draft 

Supplemental Environmental Impact Statement for the License Renewal of Kewaunee Power 

Station,” February 19, 2010. ADAMS Accession No. ML093480077.

U.S. Nuclear Regulatory Commission (NRC). 2010a. “Summary of Public Meetings Conducted 

to Discuss the Draft Supplemental Environmental Impact Statement Related to the Review of 

the Kewaunee Power Station License Renewal Application (TAC No. MD9409),” May 18, 2010. 

ADAMS Accession No. ML101310429. (Includes public meeting transcripts.)

Wisconsin Department of Natural Resources (WDNR). 2004. “Rainbow Smelt (Osmerus 

mordax).” Available URL: http://dnr.wi.gov/invasives/fact/rainbow_smelt.htm

Wisconsin Department of Natural Resources (WDNR). 2005. State of Wisconsin Department of 

Natural Resources Permit to Discharge Under the Wisconsin Pollutant Discharge Elimination 

System, Permit No. WI-0001571-07-0, Kewaunee Power Station, July 2005. ADAMS Accession 

No. ML0835

(accessed 

November 7, 2008). ADAMS Accession No. ML093250045.
APPENDIX B

NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR 

LICENSE RENEWAL OF NUCLEAR POWER PLANTS
THIS PAGE IS INTENTIONALLY LEFT BLANK
August 2010 B-1 NUREG-1437, Supplement 40

B. NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE 

RENEWAL OF NUCLEAR POWER PLANTS

Table B-1. Summary of Issues and Findings. This table is taken from Table B-1 in Appendix 

B, Subpart A, to Title 10 of the Code of Federal Regulations (CFR) Part 51. Data supporting this 

table are contained in NUREG-1437, Generic Environmental Impact Statement for License 

Renewal of Nuclear Plants.

Issue Type of Issue Finding

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 cooling-tower-based heat 

dissipation systems and have been satisfactorily mitigated at 

other plants. They are not expected to be a problem during the 

license renewal term.
Appendix B

NUREG-1437, Supplement 40 B-2 August 2010

Issue Type of Issue Finding

Water use conflicts 

(plants with 

once-through cooling 

systems)

Generic

SMALL. These conflicts have not been found to be a problem at 

operating nuclear power plants with once-through heat dissipation 

systems.

Water use conflicts 

(plants with cooling 

ponds or cooling 

towers using make-up 

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 instream and riparian communities near these 

plants could be of moderate significance in some situations. See § 

51.53(c)(3)(ii)(A).

Aquatic Ecology

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.

Gas supersaturation 

(gas bubble disease) Generic

SMALL. Gas supersaturation was a concern at a small number of 

operating nuclear power plants with once-through cooling systems 

but has been satisfactorily mitigated. It has not been found to be a 

problem at operating nuclear power plants with cooling towers or 

cooling ponds and is not expected to be a problem during the 

license renewal term.

Low dissolved oxygen 

in the discharge Generic

SMALL. Low dissolved oxygen has been a concern at one nuclear 

power plant with a once-through cooling system but has been 

effectively mitigated. It has not been found to be a problem at 

operating nuclear power plants with cooling towers or cooling 

ponds and is not expected to be a problem during the license 

renewal term.
Appendix B

August 2010 B-3 NUREG-1437, Supplement 40

Issue Type of Issue Finding

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).

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 impingement 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.

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.
Appendix B

NUREG-1437, Supplement 40 B-4 August 2010

Issue Type of Issue Finding

Groundwater use 

conflicts (potable 

and service water; 

plants that use 

<100 gpm)

Generic SMALL. Plants using less than 100 gallons per minute (gpm) 

are not expected to cause any ground-water 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 ground-water use conflicts with nearby 

ground-water 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 which 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 ground-water depression beyond the site boundary. 

Impacts of large ground-water 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).

Groundwater quality 

degradation (Ranney 

wells)

Generic

SMALL. Ground-water 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 

ground-water 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 ground-water 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.
Appendix B

August 2010 B-5 NUREG-1437, Supplement 40

Issue Type of Issue Finding

Cooling tower impacts 

on native plants Generic

SMALL. Impacts from salt drift, icing, fogging, or increased 

humidity associated with cooling tower operation have not been 

found to be a problem at operating nuclear power plants and are 

not expected to be a problem during the license renewal term.

Bird collisions with 

cooling towers Generic

SMALL. These collisions have not been found to be a problem at 

operating nuclear power plants and are not expected to be a 

problem during the license renewal term.

Cooling pond impacts 

on terrestrial resources Generic SMALL. Impacts of cooling ponds on terrestrial ecological 

resources are considered to be of small significance at all sites.

Power line right-of-way 

management (cutting 

and herbicide 

application)

Generic SMALL. The impacts of right-of-way (ROW) 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 

ROW

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 and 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 ROW Generic

SMALL. Ongoing use of power line ROWs would continue with no 

change in restrictions. The effects of these restrictions are of 

small significance.
Appendix B

NUREG-1437, Supplement 40 B-6 August 2010

Issue Type of Issue Finding

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 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. Electrical shock resulting from 

direct access to energized conductors or from induced charges in 

metallic structures have not been found to be a problem at most 

operating plants and generally are 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.

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).
Appendix B

August 2010 B-7 NUREG-1437, Supplement 40

Issue Type of Issue Finding

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 project-specific 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).

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 Nuclear Regulatory Commission (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).
Appendix B

NUREG-1437, Supplement 40 B-8 August 2010

Issue Type of Issue Finding

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. Off-site impacts of the uranium fuel cycle have been 

considered by the Commission in Table S-3 of this part. Based on 

information in the Generic Environmental Impact Statement 

(GEIS), impacts on individuals from radioactive gaseous and 

liquid releases including radon-222 and technetium-99 are small.

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 excepted, is calculated to be about 14,800 person 

roentgen equivalent man (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 U.S. 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 effect, which will not ever be mitigated 

(for example no cancer cure in the next thousand years), and that 

these doses projected over thousands of years are meaningful. 

However, these assumptions are questionable. In particular, 

science cannot rule out the possibility that there will be no cancer 

fatalities from these tiny doses. For perspective, the doses are 

very small fractions of regulatory limits, and even smaller fractions 

of natural background exposure to the same populations. 

Nevertheless, despite all the uncertainty, some judgment as to the 

regulatory NEPA implications of these matters should be made 

and it makes no sense to repeat the same judgment in every 

case. Even taking the uncertainties into account, the Commission 

concludes that these impacts are acceptable in that these impacts 

would not be sufficiently large to require the NEPA conclusion, for 

any plant, that the option of extended operation under 10 CFR 

Part 54 should be eliminated. Accordingly, while the commission 

has not assigned a single level of significance for the collective 

effects of the fuel cycle, this issue is considered Category 1 

[Generic].
Appendix B

August 2010 B-9 NUREG-1437, Supplement 40

Issue Type of Issue Finding

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 we assume that limits are developed along the lines of 

the 1995 National Academy of Sciences (NAS) report, “Technical 

Bases for Yucca Mountain Standards,” and that in accordance 

with the Commission’s Waste Confidence Decision, 10 CFR 

51.23, a repository can and likely will be developed at some site, 

which will comply with such limits, peak doses to virtually all 

individuals will be 100 millirem per year or less. However, while 

the Commission has reasonable confidence that these 

assumptions will prove correct, there is considerable uncertainty 

since the limits are yet to be developed, no repository application 

has been completed or reviewed, and uncertainty is inherent in 

the models used to evaluate possible pathways to the human 

environment. The NAS report indicated that 100 millirem per year 

should be considered as a starting point for limits for individual 

doses, but notes that some measure of consensus exists among 

national and international bodies that the limits should be a 

fraction of the 100 millirem per year. The lifetime individual risk 

from 100 millirem annual dose limit is about 3 x 10-3.

Estimating cumulative doses to populations over thousands of 

years is more problematic. The likelihood and consequences of 

events that could seriously compromise the integrity of a deep 

geologic repository were evaluated by the 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 population may 

be possible in the future as more is understood about the 

performance of the proposed Yucca Mountain repository. Such 

estimates would involve very 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, although the report 

articulates the view that protection of individuals will adequately 

protect the population for a repository at Yucca Mountain. 

However, EPA's generic repository standards in 40 CFR Part 191 

generally provide an indication of the order of magnitude of 

cumulative risk to 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 

amount of radioactive material released over 10,000 years. 

(continued)
Appendix B

NUREG-1437, Supplement 40 B-10 August 2010

Issue Type of Issue Finding

Offsite radiological 

impacts (spent fuel 

and high level waste 

disposal) (continued)

Generic

The cumulative release limits are based on EPA's population 

impact goal of 1,000 premature cancer deaths worldwide for a 

100,000 metric ton (MTHM) repository.

Nevertheless, despite all the uncertainty, some judgment as to the 

regulatory NEPA implications of these matters should be made 

and it makes no sense to repeat the same judgment in every 

case. Even taking the uncertainties into account, the Commission 

concludes that these impacts are acceptable in that these impacts 

would not be sufficiently large to require the NEPA conclusion, for 

any plant, that the option of extended operation under 10 CFR 

Part 54 should be eliminated. Accordingly, while the Commission 

has not assigned a single level of significance for the impacts of 

spent fuel and high level waste disposal, this issue is considered 

in Category 1 [Generic].

Nonradiological 

impacts of the uranium 

fuel cycle

Generic

SMALL. The nonradiological impacts of the uranium fuel cycle 

resulting from the renewal of an operating license for any plant 

are found to be small.

Low-level waste 

storage and disposal Generic

SMALL. The comprehensive regulatory controls that are in place 

and the low public doses being achieved at reactors ensure that 

the radiological impacts to the environment will remain small 

during the term of a renewed license. The maximum additional 

onsite land that may be required for low-level waste storage 

during the term of a renewed license and associated impacts will 

be small.

Nonradiological impacts on air and water will be negligible. The 

radiological and 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.

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 

onsite 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.
Appendix B

August 2010 B-11 NUREG-1437, Supplement 40

Issue Type of Issue Finding

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 NRC up to 62,000 megawatt days per 

metric ton of 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 § 51.52.

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 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 relicense 

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.

B.1 REFERENCES

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

Department of Energy (DOE). 1980. “Final Environmental Impact Statement: Management of 

Commercially Generated Radioactive Waste,” October 1980.

National Academy of Sciences (NAS). 1995. “Technical Bases for Yucca Mountain Standards.” 
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APPENDIX C

APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS
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August 2010 C-1 NUREG-1437, Supplement 40

C. APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS

The Atomic Energy Act authorizes States to establish programs to assume U.S. Nuclear 

Regulatory Commission (NRC) regulatory authority for certain activities. For example, through 

the Agreement State Program, started on August 11, 2003, Wisconsin assumed regulatory 

responsibility over certain byproduct, source, and small quantities of special nuclear material. 

The Wisconsin Department of Natural Resources (WDNR) is responsible for implementing the 

laws of the State and where applicable, the laws of the Federal government.

In addition to implementing 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, provided the State program is at least as stringent as the Federal program and must 

conform to the CWA and delegation of authority for the Federal National Pollutant Discharge 

Elimination System (NPDES) program from the EPA to the State. The primary mechanism to 

control water pollution is the requirement that direct dischargers to obtain an NPDES permit or 

in the case of States where the authority has been delegated from the EPA, a State Pollutant 

Discharge Elimination System (SPDES) permit, pursuant to the CWA.

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 only regulates surface waters.

C.1 STATE ENVIRONMENTAL REQUIREMENTS

Certain environmental requirements, including some discussed earlier, may have been 

delegated to State authorities for implementation, enforcement, or oversight. Table C-1 provides 

a list of representative State environmental requirements that may affect the license renewal 

application for Kewaunee Power Station (KPS).
Appendix C

NUREG-1437, Supplement 40 C-2 August 2010

Table C-1. State Environmental Requirements. KPS is subject to State requirements 

regarding its environmental program. Those requirements are briefly described below. See 

Section 1.9 for KPS’s compliance status with these requirements.

Law/Regulation Requirements

Air Quality Protection

Federal Clean Air Act (42 

USC 7401 et seq.), Ch. 285 

Wisconsin Statutes

Operation permit is required for air emissions and is issued by WDNR. Note: 

Dominion Energy Kewaunee (DEK) is considering conversion of this permit to a 

“Type A Registration Operation Permit,” Air Pollution Control Permit Number 

ROP-A01, issued by the WDNR.

Water Resources Protection

Clean Water Act (CWA) (33 

USC 1251 et seq.), Ch. 283 

Wisconsin Statutes

The NPDES permit is required for plant industrial, sanitary, and stormwater 

discharges to Lake Michigan and the unnamed tributary. The NPDES permit 

requires the compliance of each point source with authorized discharge levels, 

monitoring requirements, and other appropriate requirements. The WDNR is the 

responsible State agency for NPDES permitting.

CWA, Ch. 281 Wisconsin 

Statutes

Permit to construct and operate sanitary sewage treatment system.

CWA (33 USC 1251 et seq.), 

Ch. 283 Wisconsin Statutes

General Wisconsin Pollutant Discharge Elimination System (WPDES) industrial 

storm water discharge permit for storm water runoff from industrial facilities.

CWA, Chs. 280 and 281 

Wisconsin Statutes

Registration for non-transient, non-community water supply for KPS.

WDNR, Ch. 283 Wisconsin 

Statutes

Permit for construction of water intake and discharge structures in Lake Michigan 

for KPS’s cooling water system.

U.S. Army Corps of 

Engineers, 33 USC 403

Permit for construction of water intake and discharge structures in Lake Michigan 

for KPS’s cooling water system.

WDNR, Ch. 281 Wisconsin 

Statutes

High-capacity well approval for wells with combined capacity >100,000 gallons 

per day (gpd).

Wisconsin Department of 

Commerce (WDC), Ch. 

101.09 Wisconsin Statutes

Registration for aboveground storage tanks.

Federal Resource 

Conservation and Recovery 

Act (42 USC 6901 et seq.), 

Ch. 101.09 Wisconsin 

Statutes

Registration for underground storage tanks.

Waste Management

CWA, Ch. 281 Wisconsin 

Statutes

Permit to construct and operate sanitary sewage treatment system.

CWA, Ch. 283 Wisconsin 

Statutes

A land spreading of Wastewater Treatment Facility pretreatment sludge permit is 

required by the WPDES.

C.2 OPERATING PERMITS AND OTHER REQUIREMENTS

Table C-2 lists representative Federal, State, and local permits.
Appendix C

August 2010 C-3 NUREG-1437, Supplement 40

Table C-2. Federal, State, and Local Permits and Other Requirements. KPS is subject to 

other requirements regarding various aspects of its environmental program. Those requirements 

are briefly described below.

License, Permit, or Other Required 

Approval

Responsible 

Agency Authority Relevance and Status

Waste Management and Pollution Prevention

License to ship radioactive material 

to processing facility in Tennessee. 

Tennessee 

Department of 

Environment and 

Conservation

Tennessee Code 

Annotated 68-

202-206

KPS radioactive material is 

shipped to processing facility in 

Tennessee.

Site access permit for disposal of 

radioactive material in Utah.

Utah Department of 

Environmental 

Quality

R313-26 of Utah 

Radiation 

Control Rules

KPS radioactive material is 

disposed in Utah in land disposal 

site.

Emergency Planning and Response

Shipment of hazardous materials. U.S. Department of 

Transportation (DOT)

KPS hazardous 

materials 

shipments 

registration 

061810 551 

002S

KPS hazardous materials 

shipments to comply with DOT 

packing, labeling, and routing 

requirements.

Biotic Resource Protection

Threatened and Endangered 

Species Consultation: Required 

between the responsible Federal 

agencies and affected States to 

ensure that the project is not likely 

to: (1) jeopardize the continued 

existence of any species listed at the 

Federal or State level as endangered 

or threatened; or (2) result in 

destruction of critical habitat of such 

species.

WDNR Endangered 

Resources Review

Endangered and 

Threatened 

Species Laws 

(State Statute 

29.604 & 

Administrative 

Rule NR 27)

Review explains what rare 

species, natural communities, or 

natural features tracked in the 

Natural Heritage Inventory 

database are found in or near the 

proposed project area. Includes 

any additional steps to assure 

compliance with the Wisconsin 

Endangered Species Law.

Threatened and Endangered 

Species Consultation: Required 

between the responsible Federal 

agencies and affected States to 

ensure that the project is not likely 

to: (1) jeopardize the continued 

existence of any species listed at the 

Federal or State level as endangered 

or threatened; or, (2) result in 

destruction of critical habitat of such 

species.

U.S. Fish and 

Wildlife Service 

(USFWS)

Endangered 

Species Act, 

Section 7 (16 

USC 1536)

NRC consulted with USFWS. The 

Federal agency issuing a license 

is required to consult with 

USFWS regarding the impact of 

license renewal on threatened or 

endangered species or their 

critical habitat.

State must concur with the DEK’s 

request for certification of KPS 

license renewal.

Wisconsin 

Department of 

Administration

Federal Coastal 

Zone 

Management Act 

(16 USC 1451 et 

seq.)

Requires applicant to provide 

certification to the NRC that the 

license renewal would be 

consistent with the 

Federally-approved State coastal 

zone management program.

Cultural Resources Protection

Archaeological and Historical 

Resources Consultation: Required 

before a Federal agency approves a 

Wisconsin Historical 

Society

National Historic 

Preservation 

Act, Section 106 

NRC consulted with State and 

Tribal Historic Preservation 

Officers, and Indian Tribes 
Appendix C

NUREG-1437, Supplement 40 C-4 August 2010

License, Permit, or Other Required 

Approval

Responsible 

Agency Authority Relevance and Status

project in an area where 

archaeological or historic resources 

might be located.

(16 USC 470f) representatives regarding 

impacts of license renewal. 

Federal agency issuing a license 

is required to consider cultural 

impacts and consult with State 

Historic Preservation Officer.
APPENDIX D

CONSULTATION CORRESPONDENCE
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August 2010 D-1 NUREG-1437, Supplement 40

D. CONSULTATION CORRESPONDENCE

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 

prior to taking action that may affect threatened and endangered species, essential fish habitat, 

or historic and archaeological resources, respectively. The following pages contain copies of the 

letters listed in Table D-1. Figures contained in pages D-5 and D-6 were included with each 

letter from the NRC.

Table D-1. Consultation Correspondence. The following is a list of the consultation 

documents sent between the U.S. Nuclear Regulatory Commission (NRC) and other agencies 

in accordance with the National Environmental Policy Act (NEPA) and other requirements.

Author Recipient Date of Letter

U.S. Nuclear Regulatory Commission 

(D. Pelton)

U.S. Fish and Wildlife Service

(L. Clemency)

September 30, 2008

U.S. Nuclear Regulatory Commission 

(D. Pelton)

Advisory Council on Historic Preservation 

(D. Klima)

October 8, 2008

U.S. Nuclear Regulatory Commission 

(D. Pelton)

Wisconsin Historical Society 

(S. Banker)

October 10, 2008

U.S. Nuclear Regulatory Commission 

(D. Petlon)

Wisconsin Coastal Management Program 

(K. Angel)

October 10, 2008

U.S Nuclear Regulatory Commission 

(D. Pelton)

Wisconsin Department of Natural 

Resources (R. Kazmierczak)

October 10, 2008

U.S Nuclear Regulatory Commission 

(D. Pelton)

Menominee Indian Tribe of Wisconsin 

(L. Boivin)

October 16, 2008(a)

U.S. Fish and Wildlife Service

(L. Clemency)

U.S. Nuclear Regulatory Commission 

(D. Pelton)

October 28, 2008

U.S. Nuclear Regulatory Commission 

(B. Pham)

Wisconsin Historical Society

(M. Stevens)

January 27, 2010

Wisconsin Historical Society

(D. Duchrow)

U.S. Nuclear Regulatory Commission

(B. Pham)

February 25, 2010

U.S. Department of the Interior, U.S. 

Fish and Wildlife Service (M. Chezik)

U.S. Nuclear Regulatory Commission April 7, 2010

(a) Similar letters went to 23 other Native American Tribes listed in Section 1.8.
Appendix D

NUREG-1437, Supplement 40 D-2 August 2010
Appendix D

August 2010 D-3 NUREG-1437, Supplement 40
Appendix D

NUREG-1437, Supplement 40 D-4 August 2010
Appendix D

August 2010 D-5 NUREG-1437, Supplement 40
Appendix D

NUREG-1437, Supplement 40 D-6 August 2010
Appendix D

August 2010 D-7 NUREG-1437, Supplement 40
Appendix D

NUREG-1437, Supplement 40 D-8 August 2010
Appendix D

August 2010 D-9 NUREG-1437, Supplement 40
Appendix D

NUREG-1437, Supplement 40 D-10 August 2010
Appendix D

August 2010 D-11 NUREG-1437, Supplement 40
Appendix D

NUREG-1437, Supplement 40 D-12 August 2010
Appendix D

August 2010 D-13 NUREG-1437, Supplement 40
Appendix D

NUREG-1437, Supplement 40 D-14 August 2010
Appendix D

August 2010 D-15 NUREG-1437, Supplement 40
Appendix D

NUREG-1437, Supplement 40 D-16 August 2010
Appendix D

August 2010 D-17 NUREG-1437, Supplement 40
Appendix D

NUREG-1437, Supplement 40 D-18 August 2010
Appendix D

August 2010 D-19 NUREG-1437, Supplement 40
Appendix D

NUREG-1437, Supplement 40 D-20 August 2010
Appendix D

August 2010 D-21 NUREG-1437, Supplement 40
Appendix D

NUREG-1437, Supplement 40 D-22 August 2010
Appendix D

August 2010 D-23 NUREG-1437, Supplement 40
Appendix D

NUREG-1437, Supplement 40 D-24 August 2010
Appendix D

August 2010 D-25 NUREG-1437, Supplement 40
Appendix D

NUREG-1437, Supplement 40 D-26 August 2010
APPENDIX E

CHRONOLOGY OF ENVIRONMENTAL REVIEW
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August 2010 E-1 NUREG-1437, Supplement 40

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 

Kewaunee Power Station (KPS). All documents, with the exception of those containing 

proprietary information, are available electronically from the NRC’s Public Electronic Reading 

Room 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 Document 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 below.

E.1 ENVIRONMENTAL REVIEW CORRESPONDENCE

August 12, 2008 Dominion Energy Kewaunee, Inc. (DEK); letter from DEK forwarding 

the application for renewal of operating license for Kewaunee Power 

Station, requesting an extension of operating license for an additional 

20 years. (ADAMS Accession No. ML082341020)

August 25, 2008 Letter to DEK, “Receipt and Availability of the License Renewal 

Application for the Kewaunee Power Station.” (ADAMS Accession No. 

ML082120504)

August 29, 2008 Federal Register notice, “Dominion Energy Kewaunee, Inc.; Notice of 

Receipt and Availability of Application for Renewal of Kewaunee 

Power Station Facility Operating License No. DPR-43 for an 

Additional 20-Year Period.” (73 FR 51023)

September 2, 2008 NRC press release No. 08-161, “License Renewal Application for 

Kewaunee Nuclear Plant Available for Public Inspection.” (ADAMS 

Accession No. ML082460767)

September 25, 2008 Letter to DEK, “Determination of Acceptability and Sufficiency for 

Docketing, Proposed Review Schedule, and Opportunity for a Hearing 

Regarding the Application from Dominion Energy Kewaunee, Inc., for 

Renewal of the Operating License for the Kewaunee Power Station.” 

(ADAMS Accession No. ML082610303)

September 30, 2008 Letter to Louise Clemency, U.S. Fish and Wildlife Service, “Request 

for List of State Protected Species within the Area under Evaluation 

for the Kewaunee Power Station License Renewal Application 

Review.” (ADAMS Accession No. ML082610748)

October 1, 2008 Federal Register notice, “Notice of Acceptance for Docketing of the 

Application and Notice of Opportunity for Hearing Regarding Renewal 

of Facility Operating License No. DPR-43 for an Additional 20-Year 

Period; Dominion Energy Kewaunee, Inc.; Kewaunee Power Station.” 

(73 FR 57154)
Appendix E

NUREG-1437, Supplement 40 E-2 August 2010

October 2, 2008 Letter to DEK, “Notice of Intent to Prepare an Environmental Impact 

Statement and Conduct Scoping Process for License Renewal for 

Kewaunee Power Station.” (ADAMS Accession No. ML082520774)

October 8, 2008 Memo to David Pelton, “Forthcoming meeting to discuss the license 

renewal process and environmental scoping for Kewaunee Power 

Station, license renewal application review.” (ADAMS Accession No. 

ML082750112)

October 8, 2008 Letter to Don L. Klima, Advisory Council on Historic Preservation, 

“Kewaunee Power Station License Renewal Application Review.”

(ADAMS Accession No. ML082610168)

October 9, 2008 Federal Register notice, “Dominion Energy Kewaunee, Inc.; Notice of 

Intent to Prepare an Environmental Impact Statement and Conduct 

Scoping Process.” (73 FR 59678)

October 10, 2008 Letter to Kathleen Angel, Wisconsin Coastal Management Program, 

“Kewaunee Power Station License Renewal Application Review.” 

(ADAMS Accession No. ML082680027)

October 10, 2008 Letter to Sherman Banker, Wisconsin Historical Society, “Kewaunee 

Power Station License Renewal Application Review.” (ADAMS 

Accession No. ML082670685)

October 10, 2008 Letter to Ronald Kazmierczak, Wisconsin Department of Natural 

Resources, “Kewaunee Power Station License Renewal Application 

Review.” (ADAMS Accession No. ML082661119)

October 16, 2008 NRC press release No. 08-190, “NRC Seeks Public Input on 

Environmental Impact Statement for Kewaunee Nuclear Plant License 

Renewal Application.” (ADAMS Accession No. ML082900265)

October 16, 2008 Letter to Terrence Virden, Bureau of Indian Affairs, “Request for 

Scoping Comments Concerning the Kewaunee Power Station License 

Renewal Application Review.” (ADAMS Accession No. ML082800098)

October 16, 2008 Letter to Laurie Boivin, Menominee Indian Tribe of Wisconsin, 

“Request for Scoping Comments Concerning the Kewaunee Power 

Station License Renewal Application Review.” (ADAMS Accession 

No. ML082800098)

October 16, 2008 Letter to Steve Ortiz, Prairie Band Potawatomi Nation, “Request for 

Scoping Comments Concerning the Kewaunee Power Station License 

Renewal Application Review.” (ADAMS Accession No. ML082800098)

October 16, 2008 Letter to Eugene Bigboy, Sr., Bad River Band of Lake Superior Tribe 

of Chippewa Indians, “Request for Scoping Comments Concerning 

the Kewaunee Power Station License Renewal Application Review.” 

(ADAMS Accession No. ML082800098)
Appendix E

August 2010 E-3 NUREG-1437, Supplement 40

October 16, 2008 Letter to Jeffery D. Parker, Bay Mills Indian Community, “Request for 

Scoping Comments Concerning the Kewaunee Power Station License 

Renewal Application Review.” (ADAMS Accession No. ML082800098)

October 16, 2008 Letter to John A. Miller, Pokagon Band of Potawatomi Indians, 

“Request for Scoping Comments Concerning the Kewaunee Power 

Station License Renewal Application Review.” (ADAMS Accession 

No. ML082800098)

October 16, 2008 Letter to Rose Gurnoe-Soulier, Red Cliff Band of Lake Superior 

Chippewa Indians of Wisconsin, “Request for Scoping Comments 

Concerning the Kewaunee Power Station License Renewal 

Application Review.” (ADAMS Accession No. ML082800098)

October 16, 2008 Letter to Robert Chicks, Stockbridge Munsee Community of 

Wisconsin, “Request for Scoping Comments Concerning the 

Kewaunee Power Station License Renewal Application Review.” 

(ADAMS Accession No. ML082800098)

October 16, 2008 Darwin McCoy, Sault Ste. Marie Tribe of Chippewa Indians of 

Michigan, “Request for Scoping Comments Concerning the 

Kewaunee Power Station License Renewal Application Review.” 

(ADAMS Accession No. ML082800098)

October 16, 2008 Hazel Hindsley, St. Croix Chippewa Indians of Wisconsin, “Request 

for Scoping Comments Concerning the Kewaunee Power Station 

License Renewal Application Review.” (ADAMS Accession No. 

ML082800098)

October 16, 2008 Richard G. Hill, Oneida Tribe of Indians of Wisconsin, “Request for 

Scoping Comments Concerning the Kewaunee Power Station License 

Renewal Application Review.” (ADAMS Accession No. ML082800098)

October 16, 2008 Frank Ettawageshik, Little Traverse Bay Bands of Odawa Indians, 

“Request for Scoping Comments Concerning the Kewaunee Power 

Station License Renewal Application Review.” (ADAMS Accession 

No. ML082800098)

October 16, 2008 Larry Romanelli, Little River Band of Ottawa Indians, “Request for 

Scoping Comments Concerning the Kewaunee Power Station License 

Renewal Application Review.” (ADAMS Accession No. ML082800098)

October 16, 2008 James Williams, Jr., Lac Vieux Desert Band of Lake Superior 

Chippewa Indians, “Request for Scoping Comments Concerning the 

Kewaunee Power Station License Renewal Application Review.” 

(ADAMS Accession No. ML082800098)

October 16, 2008 Louis Taylor, Lac Courte Oreilles Band of Lake Superior Chippewa 

Indians of Wisconsin, “Request for Scoping Comments Concerning 

the Kewaunee Power Station License Renewal Application Review.” 

(ADAMS Accession No. ML082800098)
Appendix E

NUREG-1437, Supplement 40 E-4 August 2010

October 16, 2008 Victoria A. Doud, Lac du Flambeau Band of Lake Superior Chippewa 

Indians of Wisconsin, “Request for Scoping Comments Concerning 

the Kewaunee Power Station License Renewal Application Review.” 

(ADAMS Accession No. ML082800098)

October 16, 2008 Phillip Shopodock, Forest County Potawatomi Community of 

Wisconsin, “Request for Scoping Comments Concerning the 

Kewaunee Power Station License Renewal Application Review.” 

(ADAMS Accession No. ML082800098)

October 16, 2008 Robert Kewaygoshkum, Grand Traverse Band of Ottawa and 

Chippewa Indians, “Request for Scoping Comments Concerning the 

Kewaunee Power Station License Renewal Application Review.” 

(ADAMS Accession No. ML082800098)

October 16, 2008 Kenneth Meshigaud, Hannahville Indian Community, “Request for 

Scoping Comments Concerning the Kewaunee Power Station License 

Renewal Application Review.” (ADAMS Accession No. ML082800098)

October 16, 2008 Wilfred Cleveland, Ho-Chunk Nation, “Request for Scoping 

Comments Concerning the Kewaunee Power Station License 

Renewal Application Review.” (ADAMS Accession No. ML082800098)

October 16, 2008 Laura Spurr, Huron Potawatomi, Inc., “Request for Scoping 

Comments Concerning the Kewaunee Power Station License 

Renewal Application Review.” (ADAMS Accession No. ML082800098)

October 16, 2008 Susan J. LaFernier, Keweenaw Bay Indian Community, “Request for 

Scoping Comments Concerning the Kewaunee Power Station License 

Renewal Application Review.” (ADAMS Accession No. ML082800098)

October 16, 2008 Arlyn Ackley, Sokagon Chippewa Community, Mole Lake Band of 

Lake Superior Chippewa Indians, “Request for Scoping Comments 

Concerning the Kewaunee Power Station License Renewal 

Application Review.” (ADAMS Accession No. ML082800098)

October 16, 2008 John Barrett, Citizen Potawatomi Nation, “Request for Scoping 

Comments Concerning the Kewaunee Power Station License 

Renewal Application Review.” (ADAMS Accession No. ML082800098)

October 22, 2008 Letter from Bob Ziegelbauer, WI State Representative, “Comment in 

Support of Kewaunee Power Station License Renewal.” (ADAMS 

Accession No. ML083100586)

October 22, 2008 Letter from Nancy Crowley, Manitowoc County Emergency Services

Division, providing comments on Kewaunee Power Station’s license 

renewal. (ADAMS Accession No. ML083100093)

October 27, 2008 Letter to DEK, “Request for Additional Information Regarding the 

Review of the License Renewal Application for Kewaunee Power 

Station.” (ADAMS Accession No. ML082560558)
Appendix E

August 2010 E-5 NUREG-1437, Supplement 40

October 28, 2008 Letter from Louise Clemency, U.S. Fish and Wildlife Service, “Re: 

Request for Species List License Renewal Application Review 

Kewaunee Power Station Kewaunee County, Wisconsin.” (ADAMS 

Accession No. ML083390643)

November 5, 2008 E-mail from Greg Veith, International Union of Operating Engineers, 

“Comments by Greg Veith in Support of Kewaunee Power Station 

License Renewal.” (ADAMS Accession No. ML083380455)

November 17, 2008 Summary of Public License Renewal Overview and Environmental 

Scoping Meetings Related to the Review of the Kewaunee Power 

Station License Renewal Application. (ADAMS Accession No. 

ML083090452)

November 25, 2008 Letter from DEK, “Dominion Energy Kewaunee, Inc. Kewaunee Power 

Station Response to Request for Additional Information License 

Renewal Application.” (ADAMS Accession No. ML083520612)

December 3, 2008 Letter to DEK, “Project Manager Change for the License Renewal 

Review for Kewaunee Power Station.” (ADAMS Accession No. 

ML083370231)

December 9, 2008 Letter to DEK, “Revision of Schedule for the Conduct of the Review of 

the Kewaunee Power Station License Renewal Application.” (ADAMS 

Accession No. ML083370245)

January 8, 2009 “Request for Additional Information Regarding Severe Accident 

Mitigation Alternatives for Kewaunee Power Station.” (ADAMS 

Accession No. ML083250719)

February 3, 2009 Summary of Conference Call with Dominion Energy Kewaunee, Inc., 

to Discuss the Severe Accident Mitigation Alternatives Requests for 

Additional Information for Kewaunee Power Station. (ADAMS 

Accession No. ML090290287)

March 9, 2009 Letter from DEK, “Dominion Energy Kewaunee, Inc. Kewaunee Power 

Station Response to Request for Additional Information Regarding 

Severe Accident Mitigation Alternatives for Kewaunee Power Station 

License Renewal Application.” (ADAMS Accession No. 

ML090690458)

April 6, 2009 Letter to DEK, “Issuance of Environmental Scoping Summary Report 

Associated with the Staff’s Review of the Application by Dominion 

Energy Kewaunee, Inc., for Renewal of the Operating License for 

Kewaunee Power Station.” (ADAMS Accession No. ML090770880)

April 11, 2009 Letter to DEK, “Environmental Site Audit Regarding Kewaunee Power 

Station License Renewal Application.” (ADAMS Accession No. 

ML090750720)
Appendix E

NUREG-1437, Supplement 40 E-6 August 2010

April 15, 2009 Letter to DEK, “Revision of Schedule for Conduct of the Review of the 

Kewaunee Power Station License Renewal Application.” (ADAMS 

Accession No. ML090860946)

April 20, 2009 Reissuing of the Environmental Scoping Summary Report Associated 

with the Staff’s Review of the Application by Dominion Energy 

Kewaunee, Inc., for Renewal of the Operating License for Kewaunee 

Power Station (ADAMS Accession No. ML091100093)

June 1, 2009 Letter from DEK, “Dominion Energy Kewaunee, Inc. Kewaunee Power 

Station Response to Follow-Up Questions Regarding the Severe 

Accident Mitigation Alternatives for Kewaunee Power Station.” 

(ADAMS Accession No. ML091600037)

July 6, 2009 Letter from DEK, “Response to Request to Docket Information 

Related to the Environmental Site Audit for Kewaunee Power Station.” 

(ADAMS Accession No. ML091970512)

July 8, 2009 Summary of Conference Calls With Dominion Energy Kewaunee, Inc., 

to Discuss Response to Follow-Up Question Regarding Severe 

Accident Mitigation Alternatives Request for Additional Information For 

Kewaunee Power Station. (ADAMS Accession No. ML091820565)

July 8, 2009 Letter to DEK, “Environmental Project Manager Change for the 

License Renewal of Kewaunee Power Station.” (ADAMS Accession 

No. ML091880344)

July 10, 2009 Letter to DEK, “Request for Additional Information Regarding the 

Environmental Review of the License Renewal Application for 

Kewaunee Power Station.” (ADAMS Accession No. ML091890017)

July 27, 2009 Letter from DEK, “Response to Request for Additional Information 

Regarding the Environmental Review of the KPS License Renewal 

Application.” (ADAMS Accession No. ML092090277)

July 27, 2009 Letter from DEK, “Kewaunee Power Station, License Renewal 

Application First Annual Update Required by 10 CFR 54.21(b).” 

(ADAMS Accession No. ML092090314)

July 28, 2009 Letter from DEK, “Response to Follow-up Question Regarding Severe 

Accident Mitigation Alternatives.” (ADAMS Accession No. 

ML092150896)

August 12, 2009 Summary of Site Audit Related to the Review of the License Renewal 

Application for Kewaunee Power Station. (ADAMS Accession No. 

ML092050144)

October 13, 2009 Letter to DEK, “Revision of Schedule for Conduct of the Review of the 

Kewaunee Power Station License Renewal Application.” (ADAMS 

Accession No. ML092790585)
Appendix E

August 2010 E-7 NUREG-1437, Supplement 40

November 20, 2009 Letter to DEK, “Request for Additional Information for the Review of 

the Kewaunee Power Station License Renewal Application.” (ADAMS 

Accession No. ML091890836)

December 28, 2009 Letter from DEK, “Response to Request for Additional Information for 

the Review of the Kewaunee Power Station License Renewal 

Application.” (ADAMS Accession No. ML100110061)

January 27, 2010 Letter to Michael Stevens, Wisconsin Historical Society, “Kewaunee 

Power Station License Renewal Application Review.” (ADAMS 

Accession No. ML093431151)

January 29, 2010 Letter to U.S. Environmental Protection Agency, “Notice of Availability 

of the Draft Plant-Specific Supplement 40 to the Generic 

Environmental Impact Statement for License Renewal of Nuclear 

Plants Regarding Kewaunee Power Station.” (ADAMS Accession No. 

ML093240009)

January 29, 2010 Letter to DEK, “Notice of Availability of the Draft Plant-Specific 

Supplement 40 to the Generic Environmental Impact Statement for 

License Renewal of Nuclear Plants Regarding Kewaunee Power 

Station.” (ADAMS Accession No. ML093280799)

February 1, 2010 NRC press release No. 10-022, “NRC Seeks Public Input on Draft 

Environmental Impact Statement for Kewaunee Nuclear Plant License 

Renewal; Meetings Scheduled.” (ADAMS Accession No. 

ML100322044)

February 5, 2010 Federal Register notice, “Dominion Energy Kewaunee, Inc.; 

Kewaunee Power Station; Notice of Availability of the Draft 

Supplement 40 to the Generic Environmental Impact Statement for 

License Renewal of Nuclear Plants and Public Meetings for the 

License Renewal of Kewaunee Power Station.” (75 FR 6065)

February 19, 2010 Memo to Bo Pham, “Forthcoming meeting to discuss the Draft 

Supplemental Environmental Impact Statement for the License 

Renewal of Kewaunee Power Station.” (ADAMS Accession No. 

ML093480092)

February 25, 2010 Letter from Dan Duchrow, Wisconsin Historical Society, “Re: 

Kewaunee Nuclear Power Station License Renewal.” (ADAMS 

Accession No. ML100850057)

March 1, 2010 Letter to DEK, “Environmental Project Manager Change for the 

License Renewal Project for Kewaunee Power Station.” (ADAMS 

Accession No. ML100550210)
Appendix E

NUREG-1437, Supplement 40 E-8 August 2010

April 6, 2010 Letter from Kenneth A. Westlake, U.S. Environmental Protection 

Agency, “Comments on the Draft Plant-Specific Supplement 40 to the 

Generic Environmental Impact Statement (GEIS) for License Renewal 

of Nuclear Plants Regarding Kewaunee Power Station (KPS), 

Kewaunee County, Wisconsin, NUREG-1437, CEQ # 2010031.” 

(ADAMS Accession No. ML101120597)

April 7, 2010 Letter from Michael Chezik, U.S. Department of the Interior, “Re: Draft 

Generic Environmental Impact Statement, NUREG-1437, Supplement 

40, for the License Renewal of Nuclear Plants; Kewaunee Power 

Station.” (ADAMS Accession No. ML101060514)

April 12, 2010 Letter from DEK, “Dominion Energy Kewaunee, Inc. (DEK) Kewaunee 

Power Station Application for Renewed Operating License Comments 

on the Draft Supplement 40 to the Generic Environmental Impact 

Statement.” (ADAMS Accession No. ML101060515)

April 18, 2010 E-mail from Steve Books, citizen, comments on Draft NUREG-1437, 

Supplement 40. (ADAMS Accession No. ML101110056)

April 20, 2010 E-mail from Duncan Tam, citizen, “Do NOT Re-license Kewaunee 

Nuclear Plant.” (ADAMS Accession No. ML101120595)

April 20, 2010 E-mail from Susan Michetti, citizen, comments opposing license 

renewal of Kewaunee Nuclear Plant. (ADAMS Accession No. 

ML101120599)

April 21, 2010 Letter from Diane D’Arrigo, Nuclear Information and Resource 

Service, “Comments on License Extension.” (ADAMS Accession No. 

ML101130255)

April 21, 2010 Letter from John LaForge, Nukewatch, comments opposing license 

renewal of Kewaunee Power Station. (ADAMS Accession No. 

ML101130256)

April 23, 2010 E-mail from Alfred Meyer, citizen, comments on NUREG-1437, 

Supplement 40 draft. (ADAMS Accession No. ML101170798)

May 6, 2010 E-mail Between Jeremy Susco and Paul Aitken Regarding Kewaunee 

LRA Environmental Report. (ADAMS Accession No. ML101270071)

May 10, 2010 Letter to DEK, “Revision of Schedule for Conduct of the Review of the 

Kewaunee Power Station License Renewal Application.” (ADAMS 

Accession No. ML101250444)

May 10, 2010 E-mail Regarding Kewaunee Cultural Resources Protection Plan.

(ADAMS Accession No. ML101310167)
Appendix E

August 2010 E-9 NUREG-1437, Supplement 40

May 18, 2010 Summary of Public Meetings Conducted to Discuss the Draft 

Supplemental Environmental Impact Statement Related to the Review 

of the Kewaunee Power Station License Renewal Application.

(ADAMS Accession No. ML101310429)

June 3, 2010 E-mail Regarding NRC Follow-Up Request for Tax Info on Kewaunee 

License Renewal. (ADAMS Accession No. ML101550354)

July 7, 2010 Updated Permit Info re Kewaunee LRA FSEIS. (ADAMS Accession 

No. ML101890676)
Appendix E

NUREG-1437, Supplement 40 E-10 August 2010
APPENDIX F

U.S. NUCLEAR REGULATORY COMMISSION STAFF

EVALUATION OF SEVERE ACCIDENT MITIGATION 

ALTERNATIVES FOR KEWAUNEE POWER STATION IN 

SUPPORT OF LICENSE RENEWAL APPLICATION REVIEW
THIS PAGE IS INTENTIONALLY LEFT BLANK
August 2010 F-1 NUREG-1437, Supplement 40

F. U.S. NUCLEAR REGULATORY COMMISSION STAFF EVALUATION 

OF SEVERE ACCIDENT MITIGATION ALTERNATIVES FOR 

KEWAUNEE POWER STATION IN SUPPORT OF LICENSE RENEWAL 

APPLICATION REVIEW 

F.1. INTRODUCTION

Dominion Energy Kewaunee, Inc. (DEK) submitted an assessment of severe accident mitigation 

alternatives (SAMAs) for Kewaunee Power Station (KPS) as part of the environmental report 

(ER) (DEK, 2008a). This assessment was based on the most recent KPS 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 KPS individual plant examination (IPE) (WPSC, 1992) and individual 

plant examination of external events (IPEEE) (WPSC, 1994a). In identifying and evaluating 

potential SAMAs, DEK considered SAMAs that addressed the major contributors to core 

damage frequency (CDF) and large early release frequency (LERF) at KPS, as well as SAMA 

candidates for other operating plants, which have submitted license renewal applications. DEK 

identified 189 potential SAMA candidates. This list was reduced to 64 SAMAs by eliminating 

SAMAs that are not applicable at KPS due to design differences, have been effectively 

implemented at KPS, have estimated costs that would exceed the dollar value associated with 

completely eliminating all severe accident risk at KPS, or have a very low benefit because they 

are associated with a non-risk-significant system. DEK assessed the costs and benefits 

associated with each of the potential SAMAs and concluded in the ER that several of the 

candidate SAMAs evaluated are potentially cost-beneficial.

Based on a review of the SAMA assessment, the U.S. Nuclear Regulatory Commission (NRC) 

issued a request for additional information (RAI) to DEK by letter dated January 8, 2009 

(NRC, 2009a). Key questions concerned: additional details regarding the plant-specific PRA 

model and changes to the model since the IPE; identification of candidate SAMAs from the 

available plant-specific fire and seismic risk analyses; additional information regarding the Level 

2 PRA analysis and Level 3 PRA inputs; the screening of specific candidate SAMAs; and further 

information on the cost-benefit analyses of several specific candidate SAMAs and low-cost

alternatives. DEK submitted additional information by letter dated March 9, 2009 (DEK, 2009a). 

In response to the RAIs, DEK provided: information regarding PRA models and recent changes; 

additional justification for the treatment of external events; additional information on the Level 2 

and 3 PRA analysis and inputs; and additional information regarding selection, screening, and 

cost-benefit analysis of several specific SAMAs. DEK responded to six follow-up questions from 

the staff (NRC, 2009b) by letters dated June 1, 2009 (DEK, 2009b), and July 28, 2009 (DEK, 

2009c). DEK’s responses addressed the staff’s concerns and resulted in the identification of 

additional potentially cost-beneficial SAMAs.

F.2. ESTIMATE OF RISK FOR KEWAUNEE POWER STATION

DEK’s estimates of offsite risk at KPS are summarized in Section F.2.1. The summary is 

followed by the staff's review of DEK’s risk estimates in Section F.2.2.
Appendix F

NUREG-1437, Supplement 40 F-2 August 2010

F.2.1 Kewaunee’s Risk Estimates

Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA 

analysis: (1) the KPS Level 1 and 2 PRA model, which is an updated version of the IPE 

(WPSC, 1992), and (2) a supplemental analysis of offsite consequences and economic impacts 

(essentially a Level 3 PRA model) developed specifically for the SAMA analysis. The SAMA 

analysis is based on the most recent KPS Level 1 and 2 PRA model available at the time of the 

ER, referred to as version K101AASAMA. The scope of the KPS PRA does not include external 

events.

The baseline CDF for the purpose of the SAMA evaluation is approximately 7.7 x 10-5 per year 

as determined from the sum of the minimal cutsets. When determined from the sum of the event 

tree sequences, the CDF is 8.1 x 10-5 per year. The latter value was used in the SAMA 

analysis. The CDF is based on the risk assessment for internally-initiated events, which includes 

internal flooding. DEK did not include the contribution from external events within the KPS risk 

estimates; however, it did account for the potential risk reduction benefits associated with 

external events by doubling the estimated benefits for internal events. 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.2-1. This information was 

summarized from that provided in Table F-1 of the ER and in response to an RAI (DEK, 2009a). 

As shown in this table, events initiated by internal flooding are the dominant contributors to 

CDF, contributing a total of 4.5 x 10-5 per year or 58 percent of the total internal events CDF. 

Although not separately reported, station blackout (SBO) sequences contribute roughly 

3.3 x 10-6 per year (4.3 percent of the total internal events CDF), while anticipated transient 

without scram (ATWS) sequences contribute less than 1 percent to the total internal events 

CDF.

The Level 2 KPS PRA model is based on the IPE model, with updates in 2004 and May 2007. 

The Level 1/Level 2 interface utilizes plant damage states (PDS) determined from “bridge trees.”

These bridge trees extend the Level 1 analysis to include systems relevant to the Level 2 

analysis. Each PDS is then evaluated through the Level 2 containment event tree (CET) (See 

DEK, 2008a, Figure F-1). The CET probabilistically evaluates the progression of the damaged 

core with respect to release to the environment. The CET end states then are examined for 

considerations of timing and magnitude of release and assigned to release categories using a 

release category diagram (See DEK, 2008a, Figure F-2).

The result of the Level 2 model is a set of 14 release categories, also referred to as source term 

categories (STCs), with their respective frequency and release characteristics. The release 

categories and their characteristics are provided in Table F-6 and F-10 of the ER. The 

categories were defined based on the timing, duration, and magnitude of the release and 

whether the containment remains intact, fails, or is bypassed. The frequency of each release 

category was obtained by summing the frequency of the individual CET end states assigned to 

each release category. The release characteristics for the 14 release categories were based on 

analyses using the Modular Accident Analysis Program (MAAP) computer code.
Appendix F

August 2010 F-3 NUREG-1437, Supplement 40

Table F.2-1. Kewaunee Power Station Core Damage Frequency

Initiating Event CDF1

(Per Year)

% Contribution to 

CDF

Internal Floods 4.5 x 10-5 58

Transient with Main Feedwater Available 6.5 x 10-6 8

Loss of Component Cooling Water 6.0 x 10-6 8

Steam Generator Tube Rupture (SGTR) 4.7 x 10-6 6

Loss of Offsite Power 3.9 x 10-6 5

Stuck Open Pressurizer Power-Operated Relief Valve (PORV) 2.0 x 10-6 3

Loss of Service Water 1.9 x 10-6 3

Loss of Main Feedwater 1.6 x 10-6 2

Small LOCA 1.2 x 10-6 2

Vessel Failure 9.5 x 10-7 1

Loss of Instrument Air 8.0 x 10-7 1

All Others 2.5 x 10-6 3

Total CDF (internal events) 7.7 x 10-5 100

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 an 

80-kilometer (50-mile) radius) for the year 2033, emergency response evacuation modeling, and 

economic data. The magnitude of the onsite impacts (in terms of clean-up and decontamination 

costs and occupational dose) is based on information provided in NEI 05-01 (NEI, 2005), which 

in turn is based on NUREG/BR-0184 (NRC, 1997a).

In the ER, DEK estimated the dose to the population within 50 miles (mi) (80 kilometers (km)) of 

the KPS site to be approximately 0.302 person-sievert (Sv) (30.2 person-rem) per year. The 

breakdown of the total population dose by containment release mode is summarized in the 

following table:

Table F.2-2. Containment bypass events (such as transients with an induced SGTR or 

SGTR-initiated accidents with a stuck open safety relief valve on the ruptured steam 

generator) and late containment failures without containment spray dominate the 

population dose risk at Kewaunee Power Station.

Containment Release Mode

Population Dose 

(Person-Rem Per 

Year)

% Contribution

Late Containment Failure without containment sprays 8.6 29

ISLOCA with scrubbing 0.2 <1

ISLOCA without scrubbing 0.9 3

SGTR with failure of secondary side isolation 19.5 64

SGTR with successful secondary side isolation 0.9 3

Other 0.1 1

Total 30.2 100

One person-rem = 0.01 person-Sv
Appendix F

NUREG-1437, Supplement 40 F-4 August 2010

F.2.2 Review of Dominion Energy Kewaunee, Inc.’s Risk Estimates

DEK’s determination of offsite risk at KPS is based on the following three major elements of 

analysis:

● the Level 1 and Level 2 risk models that form the bases for the 1992 IPE 

submittal (WPSC, 1992) and the external events analyses of the 1994 IPEEE 

submittal (WPSC, 1994a)

● the major modifications to the IPE model that have been incorporated in the 

K101AASAMA PRA model

● the MACCS2 analyses performed 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 to determine the acceptability of DEK’s risk estimates for 

the SAMA analysis, as summarized below. 

The staff’s review of the KPS IPE is described in an NRC report dated January 15, 1997 (NRC, 

1997b). Based on a review of the IPE submittal and responses to RAIs, the staff concluded that 

the IPE submittal met the intent of Generic Letter (GL) 88-20; that is, the licensee’s IPE process 

is capable of identifying the most likely severe accidents and severe accident vulnerabilities. 

While the Staff Evaluation Report (SER) and the attached Technical Evaluation Report (TER) 

did not specifically highlight any weaknesses in the IPE, in a subsequent submittal relative to 

risk-informed in-service inspection (NMC, 2005), the licensee indicated that six weaknesses 

were identified in the IPE review. In response to an RAI, DEK addressed each weakness and 

confirmed that they are not applicable to the model used for the SAMA analysis (DEK, 2009a).

The IPE identified nine severe accident vulnerabilities associated with core damage and six 

improvements to address the first five of these vulnerabilities (WPSC, 1994a). Improvements to 

address the remaining four vulnerabilities were being given further consideration at the time of 

the IPE submittal. In a subsequent IPE submittal, all but one of the original six improvements 

were stated to have been implemented. The one improvement not implemented was to change 

the normal position of two safety injection motor operated valves from open to closed, thereby 

reducing the ISLOCA frequency. While this was included in the IPE, it was subsequently found 

that the CDF contribution of failing to open was higher than the CDF reduction from having the 

valves closed. Accordingly, implementation of this change was not considered appropriate. The 

status of the remaining four vulnerabilities was also given (WPSC, 1994b). SAMAs in the 

current evaluation address these remaining four vulnerabilities. No vulnerabilities or 

improvements associated with containment performance were identified (WPSC, 1992).

The CDF value from the 1996 KPS revised IPE (1.1 x 10-4 per year) is at the high end of the 

range of the CDF values reported in the IPEs for Westinghouse two-loop plants. Figure 11.6 of 

NUREG-1560 (NRC, 1997c) shows that the IPE-based total internal events CDF for two-loop 

Westinghouse plants ranges from 5 x 10-5 per year to 1.2 x 10-4 per year (NRC, 1997c). It is 

recognized that other plants have updated the values for CDF subsequent to the IPE submittals 

to reflect modeling and hardware changes. The internal events CDF result for KPS used for the 

SAMA analysis is somewhat higher than that for other plants of similar vintage and 
Appendix F

August 2010 F-5 NUREG-1437, Supplement 40

characteristics due to the relatively high internal flooding contribution to CDF, as described 

below.

There have been nine revisions to the PRA model between the 1992 IPE submittal and the 

model used for the SAMA analysis. A description of changes made from one model to another 

is provided in Section F.2 of the ER and is summarized in Table F.2-3. The CDF and LERF 

values have varied widely over these revisions.

In response to an RAI concerning the major reasons for these changes, DEK indicated that the 

principal reason for the changes was due to internal flood modeling (DEK, 2009a). According to 

DEK, the flood model in the 8/2003 PRA was not substantially different from that in the IPE and 

resulted in a flood CDF of 3.6 x 10-7 per year. The 12/2004 PRA incorporated what was 

considered to be a conservative model that bounded actual flooding conditions until a best 

estimate model could be developed. This model had a flooding CDF contribution of 6.8 x 10-4 

per year with the majority of the frequency due to: (1) rupture of the condenser expansion joint, 

with flood water propagating to the safeguards alley via floor drains and under doors, and 

(2) break of safety injection piping from the refueling water storage tank, with flood water 

propagating to the safeguards alley through a failed door. In 2005, design changes were made 

to mitigate these flooding contributors. Credit for these design changes, as well as planned 

internal flood modifications, was included in the K101AASAMA model and reduced the internal 

flood CDF to 4.5 x 10-5 per year.
Appendix F

NUREG-1437, Supplement 40 F-6 August 2010

Table F.2-3. Kewaunee Power Station Probabilistic Risk Assessment Historical Summary

Version Description/changes from previous model CDF

(per year)

LERF

(per year)

IPE Original IPE 6.6 x 10-5 NC

Revised IPE 

6/1996

Revised in response to RAIs, including new Human Reliability 

Analysis 

1.1 x 10-4 NC

1/1997 - Credited operator to refill RWST

- Modeled alternate cooling for air compressors

3.9 x 10-5 2.2 x 10-6

4/1998 Removed asymmetric modeling 3.6 x 10-5 1.9 x 10-6

12/2001 - Incorporated plant failure and initiating event data

- Included consideration of replacement SGs

- Converted from GRAFTER code to WinNUPRA code

- Reviewed in 6/2002 WOG Group peer review

4.1 x 10-5 4.8 x 10-6

8/2003 - Reevaluated important human error probabilities

- Updated Level 2 success criteria for power uprate

- Updated medium LOCA and ISLOCA models

- Incorporated WOG RCP seal LOCA model

- Revised steam line break analysis to include pressurized 

thermal shock

- Added quantitative shutdown model

- Resolved numerous peer review comments

3.0 x 10-5 5.3 x 10-6

12/2004 - Revised internal flooding model 

- Added need to stop safety injection following steam line break

- Added dependence of letdown on component cooling water

- Added power recovery and 480 VAC bus cross-ties

- Updated success criteria for power uprate

7.2 x 10-4 5.0 x 10-6

K101A

6/2006

- Incorporated new internal flooding model which included plant 

changes to address flooding concerns

- Incorporated revised diesel-generator reliability data

- Incorporated reactor coolant system cooldown and 

depressurization following RCP seal LOCA to avoid core 

damage

2.7 x 10-4 5.7 x 10-6

K101AA

12/2006

- Incorporated flood barriers to protect RHR pumps

- Incorporated operator actions to address flooding of battery 

room, auxiliary feedwater (AFW) room, and switchgear room 

ventilation

- Incorporated procedure changes addressing service water 

isolation and removed other isolation conservatisms

1.3 x 10-4 7.0 x 10-6

K101AASAMA

5/2007

One time only model for SAMA. Updates were carried through 

to future revisions as specified

- Revised service water model for internal flooding sequences

- Incorporated credit for planned internal flooding design 

changes (described below)

- Restructured Level 1 event trees to support revised Level 2 

model

7.7 x 10-5

(8.1 x 10-5)

9.5 x 10-6

(9.9 x 10-6)
Appendix F

August 2010 F-7 NUREG-1437, Supplement 40

Version Description/changes from previous model CDF

(per year)

LERF

(per year)

K101AB

5/2007

Update to K101AA

- Revised service water model for internal flooding sequences

Note: No internal flooding modifications included

1.1 x 10-4 5.7 x 10-6

K107A

8/2007

Subjected to independent review 1/2008

- Updated basic event database

- Updated internal flooding model to remove conservatisms

- Restructured Level 1 event trees to support revised Level 2 

model

Note: No internal flooding modifications included

7.6 x 10-5 9.8 x 10-6

K107Aa

7/2008

Updated model to “as installed” configuration of internal 

flooding modifications included in K101AASAMA model.

4.8 x 10-5 6.4 x 10-6

K107AaILRT

7/15/2008

Re-evaluated significant operator actions 4.2 x 10-5

(4.3 x 10-5)

4.9 x 10-6

(4.9 x 10-6)

NC - Not Calculated

Values in parentheses are sum of sequence frequencies

The planned internal flood modifications were discussed with the NRC on November 30, 2006 

(DEK, 2006). At the time of the SAMA analysis, three of the four planned modifications had 

been implemented, and the fourth modification, involving relocating two electrical safety-related 

supply circuit breakers (breakers 15206 and 16206), had not yet been completed. In response 

to an RAI, DEK indicated that relocation of breaker 16206 is currently planned for the next 

available opportunity, but relocation of breaker 15206, which is stated to have a much lower 

benefit, is no longer planned (DEK, 2009a). However, another design change, involving 

rerouting a wire for a Turbine Building basement fan coil unit, was completed in 2008 but not 

included in the K101AASAMA model. DEK indicated that credit for rerouting this wire would 

more than offset the impact of raising the breakers (DEK, 2009a).

Subsequent to the SAMA analysis, DEK submitted an unrelated risk-informed license 

amendment request regarding containment integrated leak rate testing (DEK, 2008b) that 

provided information on a more recent version of the PRA (i.e., the K107Aa PRA model of July 

2008). The July 2008 PRA update has a significantly lower CDF (4.8 x 10-5 per year) than that 

for the SAMA model. In response to an RAI, DEK provided information on PRA model changes 

subsequent to the K101AASAMA PRA (DEK, 2009a). A description of these changes is 

included in Table F.2-3. The majority of the CDF reduction from the SAMA model to the K107Aa 

model is attributed to the database update and the incorporation of credit for rerouting a wire 

connecting the supply breaker for the turbine building basement fan coil unit B and auxiliary 

relays (DEK, 2009a). Other changes in the model, principally incorporating several specific 

ventilation design features and requirements, had a smaller impact on CDF. It is also noted that 

the current model does not include credit for raising either breaker 15206 or 16206. The impact 

of this new PRA version on the results of the SAMA evaluation is discussed in Section 3.2 

below.

The staff considered the peer reviews performed for the KPS PRA and the potential impact of 

the review findings on the SAMA evaluation. In the ER, DEK described the June 2002 peer 

review by the (former) Westinghouse Owner’s Group (WOG) of the 12/2001 PRA model. The 

peer review identified five Level A and 49 Level B Facts & Observations (F&Os) (DEK, 2008a). 

DEK stated in the ER that all Level A F&Os (important and necessary to address before the 
Appendix F

NUREG-1437, Supplement 40 F-8 August 2010

next regular PRA update) and all but two Level B F&Os (important and necessary to address 

but disposition may be deferred until the next PRA update) have been dispositioned and that 

those items requiring model and/or documentation changes have been addressed in the PRA 

used for the SAMA analysis (K101AASAMA). One unresolved F&O pertains to not documenting 

the basis for not including room cooling as a required support system. In the SAMA model, room 

cooling is required unless a calculation shows it is not needed. The second unresolved F&O 

pertains to loss of room cooling as a separate initiating event. In response to an RAI, DEK 

discusses loss of room-cooling events and points out that the equipment needed during power 

operation is in different plant locations from that needed to respond to a reactor trip or accident. 

Consequently, the same room- cooling failures would not be expected to impact both functions. 

DEK concluded that loss of room cooling need not be treated as an initiator. In the SAMA 

model, room cooling is considered as a support function, and this has led to the identification of 

a number of room cooling related SAMAs. The staff considers this modeling approach sufficient 

for the purposes of the SAMA analysis.

In the aforementioned integrated leak rate testing submittal (DEK, 2008b), DEK described a 

review of the July 2008 revised KPS PRA (K107Aa) against Regulatory Guide (RG) 1.200, 

Revision 1, and the supporting requirements (SRs) of the ASME PRA Standard (ASME, 2003). 

In response to an RAI, DEK provided additional information on this review and the impact of its 

findings on the SAMA analysis (DEK, 2009a). DEK summarized the unmet SRs, described how 

the unmet SRs were reviewed to determine if they would have an impact on the risk insights of 

the SAMA analysis, and concluded that resolution of the unmet SRs is not expected to alter the 

findings of the SAMA analysis. 

In the ER and in response to an RAI, DEK described the PRA update process in use at KPS. 

The model is updated at least every 3 years to maintain it consistent with the as-built, 

as-operated plant, to incorporate improved thermal-hydraulic results, and to incorporate PRA 

improvements. The entire process of logging and tracking potential model changes, making the 

model changes, documenting the changes, independent review of the changes, and 

management approval of the updated model and its documentation are governed by DEK 

procedures.

Given that the KPS internal events PRA model has been peer reviewed, the peer review 

findings were all addressed, and that DEK has satisfactorily addressed staff questions regarding 

the PRA, the staff concludes that the internal events Level 1 PRA model is of sufficient quality to 

support the SAMA evaluation.

As indicated above, the KPS PRA does not include external events. In the absence of such an 

analysis, DEK used the KPS IPEEE to identify the highest risk accident sequences and the 

potential means of reducing the risk posed by those sequences (DEK, 2009a), (DEK, 2009b). 

This is discussed below and in Section F.3.2.

The KPS IPEEE was submitted in June 1994 (WPSC, 1994a) in response to Supplement 4 of 

GL 88-20 (NRC, 1991). This submittal included a seismic PRA, a fire PRA, 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 opportunities for 

seismic risk reduction were identified from the seismic IPEEE/USI A-46 reviews, walkdowns, 

and relay chatter evaluations and implemented as discussed below. In a letter dated October 5, 

1999, the staff concluded that the submittal met the intent of Supplement 4 to GL 88-20 and that 

the licensee’s IPEEE process is capable of identifying the most likely severe accidents and 

severe accident vulnerabilities (NRC, 1999).
Appendix F

August 2010 F-9 NUREG-1437, Supplement 40

The seismic PRA included in the KPS IPEEE consisted of a Level 1 seismic PRA with a 

qualitative and quantitative evaluation of containment structures and containment safeguard 

systems. The seismic PRA approach employed was a composite of seismic PRA and seismic 

margins assessment (SMA) methods. Plant seismic walkdowns and screening were conducted 

using the SMA procedures and guidance (EPRI, 1991). For the components screened out using 

high confidence in low probability of failure (HCLPF) requirements for the 0.30g peak ground 

acceleration Review Level Earthquake (RLE), “surrogate elements” were included in the PRA 

model. Inclusion of these surrogate elements is necessary to incorporate in the seismic risk 

estimates the failure of relatively robust elements at higher ground accelerations. While the 

NRC review of the seismic PRA concluded that the use of “surrogate elements” resulted in an 

identification and ranking of dominant sequences that was not meaningful, the overall 

conclusion was that the resulting CDF of 1.1 x 10-5 per year was likely to be realistic or 

conservative and that there are, with reasonable confidence, no significant vulnerabilities. The 

seismic outliers and the “bad actor” relays identified in the IPEEE were all resolved by 

modifications so that they would not contribute to seismic risk, and therefore were not included 

in the model (DEK, 2008a), (NRC, 1998). The containment performance analysis included a 

review and walkdown of the containment structures and components (penetrations, hatches, 

isolation valves, freestanding steel shell, and attached piping and conduit). All met the screening 

criteria and were therefore evaluated using the surrogate element approach, leading to a single 

containment structural failure sequence. Fragilities for containment safeguard systems (spray, 

air-cooling, and isolation) were determined based on walkdown results. Models for failures of 

these systems were then input into a simplified Level 2 analysis based on the IPE model. 

Subsequent to the IPEEE, changes made to the seismic PRA, including credit for 

seismically-rugged air accumulators and more realistic human error probabilities, led to a slight 

reduction in seismic CDF to 1.04 x 10-5 per year.

To provide additional insight into the appropriate seismic CDF to use for the SAMA evaluation, 

the staff developed an independent estimate of the seismic CDF for KPS using the 

simplified-hybrid approximation method described in a paper by Robert P. Kennedy, entitled 

“Overview of Methods for Seismic PRA and Margin Analysis Including Recent Innovations” 

(Kennedy, 1999) and using both updated 2008 seismic hazard curve data from the U.S. 

Geologic Survey (USGS, 2008) and Lawrence Livermore National Laboratory seismic hazard 

curve data (NRC, 1994). The staff’s independent calculations indicate the seismic CDF for KPS 

to be in the range of 6 x 10-6 per year to 1 x 10-5 per year depending on seismic hazard curve 

and plant fragility assumptions. Based on these estimates of the seismic CDF, the staff 

concludes that the seismic CDF given in the ER is appropriate for use in the SAMA assessment.

The KPS IPEEE fire analysis employed a combination of fire PRA methodology with the Electric 

Power Research Institute’s fire-induced vulnerability evaluation (FIVE) methodology. Fire zones 

were initially screened out if a fire did not cause an initiating event or did not involve mitigating 

equipment modeled in the PRA. Quantitative screening was then performed using fire 

frequencies based on the FIVE methodology and the assumption that fire destroyed everything 

in the zone. The sequence was then quantified using the PRA internal events model. If the CDF 

was greater than 1 x 10-6 per year, the zone was subjected to more detailed analysis. The 

potential impact on containment performance and isolation was evaluated following the core 

damage evaluation.
Appendix F

NUREG-1437, Supplement 40 F-10 August 2010

The fire model was revised in response to an RAI on potential weaknesses that were noted in 

the staff’s evaluation of the IPEEE fire analysis. This revision included adding the control room 

and cable spreading room to the fire zones evaluated, revising the human error probabilities 

(HEPs), and updating the initiating event frequencies and severity factors (DEK, 2008a),

(WPSC, 1995), (WPSC, 1998). The total fire CDF from the revised IPEEE analysis was 

estimated to be 1.8 x 10-4 per year.

In general, the fire PRA model has not been updated since the completion of the IPEEE review. 

However, when HEPs and plant failure data were updated for the internal events model, these 

updates were carried into the fire model. In addition, the fire propagation modeling for the 

auxiliary feedwater (AFW) pump B room, a dominant fire area, was updated, resulting in a fire 

CDF of about 1.4 x 10-4 per year. The important fire areas and their contributions to the fire 

CDF are listed in Table F.2-4.

In the ER, DEK identifies a number of conservatisms in the fire analysis. These are:

● Initiating-event frequencies are based on old data that does not reflect current 

housekeeping practices.

● Fire-coping strategies credited only one train and did not rely on offsite power.

● If a cable tray is damaged, all cables in the tray are assumed to be damaged.

● Fire propagation analysis is highly conservative.

● Except for AFW Pump Room B, the most severe fire was assumed to occur with 

a frequency equal to the total fire initiating event frequency for the room.

In response to an RAI, DEK indicated the fire zones to which each of the conservatisms was 

applicable. Most of the conservatisms are applicable to all fire zones, and all are applicable to 

the dominant fire zones (CDF greater than 1 x 10-6 per year).

DEK further states in the ER that changes to plant procedures made subsequent to the 

completion of the IPEEE would reduce the fire CDF by at least a factor of five from the IPEEE. 

In response to an RAI, DEK provided a reassessment of the top 100 cutsets from the fire risk 

analysis in which these fire procedures were credited (i.e., OP-KW-AOP-FP-001, “Abnormal 

Operating Procedure—Fire,” and OP-KW-AOP-FP-002, “Fire in Alternate Zone”). The 

reassessment supports a reduction in CDF of slightly more than a factor of 5. DEK concluded 

that the fire CDF would be 3.6 x 10-5 per year, based on applying the factor of 5 reduction to the 

IPEEE fire CDF of 1.8 x 10-4 per year. However, the staff notes that the assessment that led to 

this factor of 5 reduction used the updated fire PRA model with a CDF of about 1.4 x 10-4 per 

year as the baseline. Thus, the adjusted fire CDF should be 2.8 x 10-5 per year. DEK agrees 

that this is the correct value to use and that the value used in SAMA analysis is conservative. 

The fire CDF for the dominant fire zones after making this adjustment are given in Table F.2-4 

(DEK, 2009b).
Appendix F

August 2010 F-11 NUREG-1437, Supplement 40

Table F.2-4. Important Fire Areas and Their Contribution to Fire Core Damage Frequency

Event ID Description

CDF (Per Year)

PostIPEEE SAMA

Analysis

IE-FIR14 Fire in Diesel Generator Room A 4.2 x 10-5 4.9 x 10-6

IE-FIR5 Fire in Relay Room 3.3 x 10-5 5.6 x 10-6

IE-FIR8 Fire Near Buses 51 and 52 2.4 x 10-5 2.9 x 10-6

IE-FIR4 Fire in Diesel Generator Room B 1.8 x 10-5 1.8 x 10-6

IE-FIR6 Auxiliary Feedwater Pump A Oil fire 1.2 x 10-5 1.3 x 10-6

IE-FIR10 Fire in Bus 5 Switches in ECCA 5.5 x 10-6 5.5 x 10-6

IE-FIR11 Fire in Bus 6 Switches in ECCA 5.2 x 10-6 5.2 x 10-6

Total (All Fire Zones) 1.4 x 10-4 2.8 x 10-5

Considering the above conservatisms and procedure assessment and the response to the staff 

RAIs, the staff concludes that the fire CDF of 3.6 x 10-5 per year is reasonable for the SAMA 

analysis.

The IPEEE analysis of high winds, floods, and other (HFO) external events followed the 

screening and evaluation approaches described in Supplement 4 of GL 88-20 (NRC, 1991) and 

did not identify any significant sequences or vulnerabilities (WPSC, 1994a). Based on this 

result, the licensee concluded that these other external hazards would be negligible contributors 

to overall core damage and did not consider any plant specific SAMAs for these events. 

The NRC SER on the IPEEE (NRC, 1999) identified an open item pertaining to the protection of 

the vents on the underground diesel oil storage tanks against tornado-generated missiles. In 

response to an RAI, DEK indicated that these vents had been lowered so as to be less 

vulnerable to tornado missiles, thereby meeting the IPEEE requirements. A future modification 

is, however, planned to further minimize the tornado risk.

Based on the aforementioned results, the external events CDF is approximately 60 percent of 

the internal events CDF from the K101AASAMA PRA (based on a fire CDF of 3.6 x 10-5 per 

year, a seismic CDF of 1 x 10-5 per year, a negligible HFO contribution, and an internal events 

CDF of 8.1 x 10-5 per year). Accordingly, the total CDF from internal and external events would 

be approximately 1.6 times the internal events CDF from the K101AASAMA PRA. In the SAMA 

analysis submitted in the ER, DEK doubled the benefit that was derived from the internal events 

model to account for the combined contribution from internal and external events. The staff 

agrees with the licensee’s overall conclusion concerning the impact of external events and 

concludes that the licensee’s use of a multiplier of 2 to account for external events is reasonable 

for the purposes of the SAMA evaluation.

The staff reviewed the general process used by DEK 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 a staff RAI (DEK, 2009a). The current Level 2 KPS PRA is based on the IPE 

model with updates in 2004 and 2007, the latter using the results from the K101AASAMA Level 

1 PRA. The 2004 update incorporated a design change that ensured that water on the 

containment floor would spill into the reactor sump after reaching a level of 29 inches, thereby 

providing a flooded reactor cavity that could reduce the impact of core-concrete interactions in a 
Appendix F

NUREG-1437, Supplement 40 F-12 August 2010

severe accident. In addition, the 2004 update incorporated the results of reanalysis of accident 

sequences using a later version of the MAAP code and reflected a 6 percent power uprate at 

KPS. The 2007 update included consideration of induced SGTR sequences, separation of 

SGTR sequences into those that had a large early release and those that did not, and resolution 

of comments from the WOG peer certification.

Each PDS is analyzed through the Level 2 CET to evaluate the phenomenological progression 

of the sequence. The CET end states are then assigned to one of 14 release categories based 

on characteristics that determine the timing and magnitude of fission product release using a 

release category diagram (Figure F-2 of the ER). The frequency of each release category was 

obtained by summing the frequency of the individual accident progression CET endpoints into 

the release category.

Source term release characteristics were developed for each release category based on results 

of plant-specific calculations using the MAAP computer program, Version 4.0.5. The release 

categories and their frequencies and release characteristics are presented in Table F-6 of the 

ER. The MAAP case selected to represent each release category was the sequence with the 

highest frequency that bounded the release fractions for the release category. In response to an 

RAI, DEK stated that when the Level 2 sequences were reanalyzed in 2007, the previously 

analyzed sequences for each release category were reviewed to ensure that they still reflected 

the expected accident progression for the associated release category, and if not, new cases 

were run (DEK, 2009a). DEK indicated that in most cases the previously selected sequence still 

represented the new source term category. The exception was release category 4 for which a 

flood scenario was selected for the revised analysis since floods are the dominant contributor.

The staff’s review of the Level 2 IPE concluded that it appeared to have considered the most 

important severe accident phenomena, and it identified no significant problems or errors 

(NRC, 1997b). Based on the staff’s review of the Level 2 methodology and, in particular, the 

changes made since the IPE, plus the fact that the Level 2 model was reviewed as part of the 

WOG peer review and a subsequent self-assessment, the staff concludes that the Level 2 PRA 

provides an acceptable basis for evaluating the benefits associated with various SAMAs.

As indicated in the ER, the reactor core radionuclide inventory used in the consequence 

analysis was determined from the results of an end-of-cycle ORIGEN2 code calculation. The 

results for a power level of 1,772 MWt (the uprated power level) were increased by 0.6 percent 

for potential measurement error. In response to an RAI, the licensee indicated that KPS does 

not have any current plans that would cause fuel burnup/management to change during the 

renewal period.

The staff reviewed the process used by DEK 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 source term categories and the major input assumptions used in the offsite 

consequence analyses. The MACCS2 code was utilized 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 a 50-mi (80-km) radius for the year 2033, emergency 

evacuation modeling, and economic data. This information is provided in Attachment F of the 

ER.
Appendix F

August 2010 F-13 NUREG-1437, Supplement 40

All releases were modeled as occurring at the top of the containment approximately 180 feet 

above grade, with a thermal content the same as ambient (i.e., a non-buoyant plume). The 

impact of the shield building that surrounds the containment on initial plume size and release 

elevation was neglected. DEK assessed the impact of alternatively assuming a ground level 

release and a higher (buoyant) plume. The results of these sensitivity studies showed that a 

ground level release produces about a 6 percent reduction in population dose and offsite 

economic cost, while a conservatively large thermal content (buoyant plume) produces about a 

4 to 5 percent increase in population dose and economic cost. DEK also reported that an 

increase or decrease in initial plume size due to building wake size has no impact on population 

dose and a small (1 percent) change in offsite cost. In response to an RAI concerning the 

validity of release parameters for the dominant SGTR sequence, which has a release elevation 

somewhat lower than that assumed but with a buoyant plume, DEK stated that the base case 

assumption of perpetual rain fall in the 40 to 50 mile segment surrounding the site introduces a 

30 to 40 percent conservatism that more than offsets any increase from selection of alternative 

release parameters (DEK, 2009a). Based on the information provided, the staff concludes that 

the release parameters utilized are acceptable for the purposes of the SAMA evaluation.

DEK used site-specific meteorological data for the 2002 calendar year as input to the MACCS2 

code. The development of the meteorological data is discussed in Section F.3.5 of the ER and 

in response to an RAI (DEK, 2009a). The wind and atmospheric stability data were collected 

from the onsite meteorological tower. Precipitation data was from Sturgeon Bay, Wisconsin, 

approximately 40 mi north of KPS, which is the closest weather station collecting hourly 

precipitation data. Seasonal morning and afternoon mixing heights were determined for each 

year from National Weather Service (NWS) measurements at Green Bay, Wisconsin. Data from 

2003 and 2004 were also considered, but the 2002 data was chosen because results of a 

MACCS2 sensitivity case comparing the use of the data indicated that the 2002 data produced 

more conservative results. In response to an RAI, DEK described the sources of data used to fill 

in gaps due to missing and invalid data (DEK, 2009a). The principal source was onsite 

measurements at other elevations, followed by data from the Point Beach site (approximately 

4 mi to the south), followed by nearest NWS locations. The staff notes that previous SAMA 

analysis results have shown little sensitivity to year-to-year differences in meteorological data 

and concludes that the approach taken for collecting and applying the meteorological data in the 

SAMA analysis is reasonable.

The population distribution the licensee used as input to the MACCS2 analysis was estimated 

for the year 2033. This estimate was based on the U.S. Census Bureau population data for 

2000, as provided by the SECPOP 2000 program (NRC, 2003), transient population estimates 

used in the updated evacuation time estimate study for KPS (TOMCOD, 2005), and 

county-by-county growth rate estimates for the years 2000 to 2030 (State of Wisconsin, 2003). 

As described by DEK in response to an RAI, both geometric and exponential annual county 

growth rates were calculated for the 2030–2033 population growth (DEK, 2009a). The 

exponential rates were found to result in a larger 2033 population and were applied to the 

populations in each of the 160 population zones (10 distance rings and 16 directions). Individual 

county rates were applied to the fraction of area in each zone in each county. Transient 

population was extrapolated in the same manner. The staff considers the methods and 

assumptions for estimating population reasonable and acceptable for purposes of the SAMA 

evaluation.

The emergency evacuation model was modeled as a single evacuation zone extending out 

10 mi (16 km) from the plant. It was assumed that 95 percent of the population would evacuate. 

This assumption is conservative relative to the NUREG-1150 study (NRC, 1990), which 
Appendix F

NUREG-1437, Supplement 40 F-14 August 2010

assumed evacuation of 99.5 percent of the population within the emergency planning zone. The 

evacuation time used in the SAMA analysis was based on a projection for the year 2033. The 

evacuees were assumed to begin evacuating 80 minutes after a general emergency has been 

declared and to evacuate at an average radial speed of approximately 2.6 miles per hour 

(1.16 meters per second). The evacuation speed is based on that for adverse weather 

conditions from the 2000 evacuation study extrapolated to 2033 by the ratio of the year 2000 

population to the year 2033 population within the emergency planning zone (TOMCOD, 2005). 

The ER reports the results of several sensitivity analyses in which the evacuation modeling 

assumptions were varied. These analyses show that variations in the modeling assumptions 

had little or no impact on the results. Reducing the evacuation speed to half the base value, 

increasing it to the year 2000 value, or decreasing the evacuation effectiveness to 50 percent 

had less than a 0.5 percent impact on population dose or offsite costs. Changing the time of 

declaration of a general emergency to the time when the core gets uncovered had no 

measurable impact on population dose and reduced offsite costs by 1 percent. The staff 

concludes that the evacuation assumptions and analysis are reasonable and acceptable for the 

purposes of the SAMA evaluation.

Much of the site-specific economic data was provided from SECPOP2000 (NRC, 2003) by 

specifying the data for each of the counties surrounding the plant to a distance of 50 mi (80 km). 

This included the fraction of land devoted to farming, annual farm sales, the fraction of farm 

sales resulting from dairy production, and the value of non-farm land. SECPOP2000 utilizes 

economic data from the 1997 Census of Agriculture (USDA, 1998). Area-wide farm wealth was 

determined from 2002 Census of Agriculture (USDA, 2002) county statistics for farmland, 

buildings, and machinery, with only the fraction of each county within 50 mi of KPS considered. 

Non-farm wealth was similarly calculated from 2003 Wisconsin tax assessments but was found 

to be less than that from SECPOP2000, so the latter value was used.

In addition, generic economic data that applies to the region as a whole was obtained from the 

MACCS2 sample problem input. This included parameters describing the cost of evacuating 

and relocating people, land decontamination, and property condemnation. An escalation factor 

of 1.85 was applied to these parameters to account for cost escalation from 1986 (the year the 

input was first specified) to 2007. 

As described in the ER, the three recently discovered problems in SECPOP2000 have all been 

accounted for in preparing the input for KPS. These problems involved: (1) an inconsistency in 

the format in which several economic parameters were output from the SECPOP2000 code and 

input to the MACCS2 code, (2) an error that resulted in use of agricultural/economic data for the 

wrong counties in the SECPOP2000 calculations, and (3) an error that resulted in the economic 

data for some counties being handled incorrectly. 

The staff concludes that the methodology used by DEK to estimate the offsite consequences for 

KPS provides an acceptable basis from which to proceed with an assessment of risk reduction 

potential for candidate SAMAs. Accordingly, the staff based its assessment of offsite risk on the 

CDF and offsite doses reported by DEK.
Appendix F

August 2010 F-15 NUREG-1437, Supplement 40

F.3. POTENTIAL PLANT IMPROVEMENTS

This section discussed the process for identifying potential plant improvements, an evaluation of 

that process, and the improvements evaluated in detail by DEK.

F.3.1 Process for Identifying Potential Plant Improvements

DEK’s process for identifying potential plant improvements (SAMAs) consisted of the following 

elements:

● review of the most significant basic events from the plant-specific PRA

● review of potential plant improvements identified in the KPS IPE and IPEEE

● review of Phase 2 SAMAs from recent license renewal applications for six other 

U.S. nuclear sites

● review of generic SAMAs as documented in NEI 05-01 (NEI, 2005)

Additionally, in response to RAIs, DEK’s process for identifying potential plant improvements 

was expanded to include:

● review of dominant fire and seismic risk contributors from the IPEEE analysis for 

improvements that could potentially reduce the associated fire risk

● review of the results of importance analysis of the K107Aa PRA (completed 

after the original SAMA assessment) for any additional potential improvements

Based on this process, an initial set of 189 SAMA candidates, referred to as Phase 1 SAMAs, 

was identified (ER, Table F-17). In Phase 1 of the evaluation, DEK performed a qualitative 

screening of the initial list of SAMAs and eliminated SAMAs from further consideration using the 

following criteria: 

● The SAMA is not applicable at KPS due to design differences (21 screened out), 

● The SAMA has been effectively implemented at KPS (45 screened out), 

● The SAMA has estimated costs that would exceed the dollar value associated 

with completely eliminating all severe accident risk at KPS (28 screened out), or

● The SAMA would be of very low benefit because it is associated with a 

non-risk-significant system, and a change would have negligible impact on the 

risk profile (31 screened out).

Based on this screening, a total of 125 SAMAs were eliminated leaving 64 SAMAs for further 

evaluation. The remaining SAMAs, referred to as Phase 2 SAMAs, are listed in Table F-19 of 

the ER. Several of the SAMAs retained for further evaluation were considered to be similar in 

terms of their benefits. As noted in Table F-17 of the ER, these SAMAs were combined and 

analyzed together in the Phase 2 evaluations.
Appendix F

NUREG-1437, Supplement 40 F-16 August 2010

In Phase 2, a detailed evaluation was performed for the remaining SAMA candidates 

(46 evaluations after combining similar SAMAs), as discussed in Sections F.4 and F.6 below. To 

account for the potential impact of external events, the estimated benefits based on internal 

events were multiplied by a factor of 2, as previously discussed.

The review of the dominant fire and seismic contributors to risk did not identify any additional 

SAMAs. The review of the K107Aa PRA importance analysis identified one additional SAMA, 

involving implementation of temporary screenhouse ventilation. These reviews are discussed 

further in Section F.3.2

F.3.2 Review of Dominion Energy Kewaunee, Inc.’s Process

DEK’s efforts to identify potential SAMAs focused primarily on areas associated with internal 

initiating events but also included explicit consideration of potential SAMAs for fire and seismic 

events. The initial list of SAMAs generally addressed the accident sequences considered to be 

important to CDF from functional, initiating event, and risk reduction worth perspectives at KPS, 

and included selected SAMAs from prior SAMA analyses for other plants.

DEK provided a tabular listing of the PRA basic events sorted according to their Fussell-Vesely 

(F-V) importance with respect to CDF (DEK, 2008a). SAMAs impacting these basic events 

would have the greatest potential for reducing risk. DEK used an F-V cutoff of 0.005, which 

corresponds to about a 0.5 percent change in CDF given 100 percent reliability of the SAMA. 

This equates to a benefit of approximately $25,000. All 149 basic events in the listing were 

reviewed to identify potential SAMAs. Based on this review, 16 SAMAs were identified and 

included in the Phase 1 list of Table F-17. The remaining basic events were found to be events 

that had no physical meaning (such as complement events or constants), were covered by 

generic SAMAs already listed, or were due to conservative assumptions and could be 

eliminated by more detailed modeling. DEK also provided and reviewed the LERF-related F-V 

events down to an F-V value of 0.005. DEK correlated these basic events with the SAMAs 

already identified and did not find any additional SAMAs.

In addition to basic event importance review, DEK reviewed the top 200 core damage cutsets to 

identify any basic events not included in the importance analysis that might suggest additional 

SAMAs. The resulting list contained 47 basic events (excluding events that had no physical 

meaning) and is provided in Table F-18 of the ER. Two additional SAMAs were identified in this 

review. 

DEK considered the potential plant improvements described in the IPE and IPEEE in the 

identification of plant-specific candidate SAMAs for internal and external events, as summarized 

below.

The KPS IPE (WPSC, 1992) identified nine severe accident vulnerabilities and/or improvements 

associated with core damage. Six of these have either been implemented or assessed as not 

appropriate due to downside risk considerations (WPSC, 1994b). The Phase 1 SAMA list 

includes the remaining improvements identified in the IPE. No vulnerabilities or improvements 

associated with poor containment performance were identified in the IPE nor are there any 

identified in the IPEEE. While the IPEEE did not identify any vulnerabilities, as discussed above, 

a number of equipment outliers were identified during the walkdowns, all of which have been 

resolved.
Appendix F

August 2010 F-17 NUREG-1437, Supplement 40

The staff questioned DEK about the disposition of a number of the basic events listed in the 

importance analyses, including consequential loss of offsite power and requested consideration 

of alternative SAMAs (NRC, 2009a). In response, DEK discussed why the consequential loss of 

offsite power event is important at KPS and the impact that potentially cost-beneficial SAMAs 

would have on this importance. Conservatisms in the modeling of the impact of this event were 

also discussed. Based on this information, the staff concludes that no additional SAMAs would 

be effective in reducing the risk related to this event. DEK also discussed the benefit of 

additional refueling water storage tank (RWST) low-level alarms or an automatic RWST refilling 

system. DEK pointed out that the benefit of multiple low-level alarms is already included in the 

model and additional alarms would have a negligible impact on risk. A cost-benefit analysis for 

an automatic refill system, performed in a manner similar to the evaluation of other SAMAs, was 

provided, which showed that such a system would not be cost-beneficial.

The staff requested clarification and further information regarding the screening of a number of 

the Phase 1 SAMAs (NRC, 2009a). In response, DEK provided additional information regarding 

those SAMAs that were screened out because they had already been implemented, cited 

additional data indicating that trip circuitry failure is not important to diesel generator failures, 

and clarified why additional transfer and isolation switches would not have any benefit. DEK 

clarified that while the component cooling water (CCW) system can be cross tied, there is 

presently no provision to cross tie the fire water system to the CCW system. A cost-benefit 

analysis for adding a cross tie was provided that showed that such a modification would not be 

cost-beneficial.

The staff noted that KPS does not presently have a diesel-driven fire pump. In response to an 

RAI, DEK discussed the current fire pump design and the potential benefits and cost 

implications of adding a diesel-driven fire pump. While there is some opportunity for risk 

reduction by adding a diesel-driven pump, the benefits were qualitatively assessed by DEK to 

be small; whereas, the cost of a new pump, probably requiring a new building, was assessed as 

being more than any potential benefits. The staff considers this conclusion reasonable given the 

available information on fire risk.

DEK also clarified that while SAMA 151, “Increase training and operating experience feedback 

to improve operator response,” is stated to need further evaluation in ER Table F-17, it was not 

specifically evaluated since individual operator actions identified in the importance analysis 

review (ER, Table F-3) and the cutset review (ER, Table F-18) were evaluated separately.

As indicated above, a number of Phase 1 SAMAs were combined for the Phase 2 evaluation. In 

response to an RAI concerning combining SAMAs 170 and 171 (involving safeguards alley 

cooling) with SAMAs 81, 82, and others (involving diesel building and switchgear room cooling), 

DEK provided a description of the various rooms and areas referred to as the “safeguards alley” 

(DEK, 2009a). The safeguards alley consists of a series of interconnected rooms housing both 

motor-driven auxiliary feedwater pumps, the turbine-driven auxiliary feedwater pump, both 

divisions of 480 VAC switchgear, and both divisions of diesel generator/4,160 VAC buses. DEK 

stated that because of the proximity and interconnections between these rooms, the benefits of 

providing high-temperature alarms and temporary ventilation can most effectively be evaluated 

by considering all rooms of the safeguards alley together.

As requested in an RAI, DEK reviewed the results of importance analyses of the K107Aa 

completed after the original SAMA analysis to determine if any additional SAMAs would have 

been identified based on a review of the updated PRA. One of the modifications made in the 

PRA model involved adding screenhouse ventilation as a support system for the service water 
Appendix F

NUREG-1437, Supplement 40 F-18 August 2010

system. The K107Aa-based importance analysis showed that failures in screenhouse ventilation 

were important. In response, DEK indicated that a SAMA involving implementing temporary 

screenhouse ventilation and installing additional temperature detectors will be considered 

further (DEK, 2009a).

The staff questioned DEK about lower cost alternatives to some of the SAMAs evaluated 

(NRC, 2009a), (NRC, 2009b), including:

● automating the cross-tie of the existing condensate storage tank (CST) to other 

water sources rather than installing a new CST

● modifying procedures to direct primary system cooldown to further reduce the 

probability of RCP seal failures

● modifying procedures and equipment for using a portable diesel-driven or 

AC-powered pump to provide feedwater to the steam generators with suction 

from the intake canal

● developing a procedure to cross-connect the chemical and volume control 

system (CVCS) holdup tanks to the volume control tank (VCT) through the 

CVCS holdup transfer pump

● procuring and developing a procedure for using a gagging device to close a 

stuck-open steam generator safety valve on a faulted steam generator before 

core damage occurs

In response to the RAIs, DEK addressed the lower cost alternatives and gave specific reasons 

why they would not impact the results of the SAMA evaluation, including the fact that some of 

these items are covered by an existing procedure or are addressed by other SAMAs 

(DEK, 2009a), (DEK, 2009b), (DEK, 2009c). This is discussed further in Section F.6.2.

Based on this information, the staff concludes that the set of SAMAs evaluated in the ER, 

together with those identified in response to staff RAIs, addresses the major contributors to 

internal event CDF.

Although the KPS IPEEE did not identify any vulnerabilities for external events, at the request of 

the staff, DEK reviewed the results of the IPEEE fire and seismic risk analysis to determine if 

any KPS-specific external event SAMAs could be identified. This review is summarized below.

The top cutsets resulting from the IPEEE fire PRA were reviewed to identify potential SAMAs 

that might reduce the KPS fire risk. The fire risk cutsets include failures due to fire itself 

combined with non-fire related failures. DEK reviewed the non-fire related failures and 

determined that those in the dominant fire contributors were already addressed by multiple 

SAMAs identified in the internal events review (DEK, 2009a). To address the fire-induced 

failures, DEK estimated the total benefit that might result from entirely eliminating the fire risk 

from each fire risk contributor. This was done for the 7 percent discount rate base case as well 

as the 3 percent discount rate and the 95 percentile uncertainty sensitivity study cases. Six fire 

risk contributors were found to have a benefit that exceeded the $100,000 value used to 

estimate the minimum cost of a modification. DEK reviewed the fire induced failures for each of 

these six fire risk contributors and concluded that no cost-beneficial improvements in fire 
Appendix F

August 2010 F-19 NUREG-1437, Supplement 40

detection or mitigation were reasonably available (DEK, 2009b). At the request of the staff, DEK 

also considered the impact on identification of SAMAs of several weaknesses in the fire PRA 

identified in the NRC review of the IPEEE submittal (NRC, 1999). Based on consideration of 

each weakness, DEK concluded that no new SAMAs would be identified as a result of 

correcting these weaknesses (DEK, 2009a). The staff concludes that the opportunity for 

fire-related SAMAs has been adequately explored and that it is unlikely that there are additional 

potentially cost-beneficial, fire-related SAMA candidates.

Based on the IPEEE seismic analysis, six sequences dominate the seismic risk at KPS. Three 

of these sequences involve major structural failures. DEK estimated that the cost of 

strengthening structures would exceed any potential benefit associated with reducing seismic 

risk. One dominant sequence involved failure of the operator to switch AFW pump suction from 

the CST to the service water system. A sensitivity study performed for the IPEEE showed that 

reducing the operator error resulted in only a 2 percent reduction in seismic CDF. DEK also 

noted that internal event SAMA items address improvements to long-term AFW availability, 

hence no new SAMAs are indicated for this sequence. The two other dominant sequences have 

a CDF of 1 x 10-6 per year or less and involve the emergency AC and DC power systems. All 

components in the AC power system have median seismic capacities of 1.86g peak ground 

acceleration (PGA) or more while the components of the DC power system have median 

seismic capacities of 1.10g PGA or more. Considering these relatively high seismic capacities, 

the low frequency of the seismic sequences that would challenge these systems, and the 

expected cost of strengthening the components, DEK identified no new SAMA items for these 

sequences (DEK, 2009a). At the request of the staff, DEK also considered the impact on 

identification of SAMAs of the weaknesses in the seismic PRA identified in the NRC review of 

the IPEEE submittal (NRC, 1999). Based on a discussion of each weakness, DEK concluded 

that no new SAMAs would be identified as a result of correcting these weaknesses (DEK, 

2009a).

The staff notes that the set of SAMAs submitted is not all inclusive since additional, possibly 

even less expensive, design alternatives can always be postulated. However, the 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 staff concludes that DEK used a systematic and comprehensive process for identifying 

potential plant improvements for KPS and that the set of SAMAs evaluated in the ER, together 

with those evaluated in response to staff inquiries, 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, it is recognized that the 

absence of external event vulnerabilities reasonably justifies examining primarily the internal 

events risk results for this purpose.

F.4. RISK REDUCTION POTENTIAL OF PLANT IMPROVEMENTS

DEK evaluated the risk-reduction potential of the 64 remaining SAMAs that were applicable to 

KPS (46 SAMA evaluations after combining similar SAMAs). The SAMA evaluations were 

performed using generally conservative assumptions. On balance, such calculations 

overestimate the benefit and are conservative.
Appendix F

NUREG-1437, Supplement 40 F-20 August 2010

For most of the SAMAs, DEK used model re-quantification to determine the potential benefits. 

The CDF, population dose, and offsite economic cost reductions were estimated using the 2007 

version of the KPS PRA model (K101AASAMA). The changes made to the model to quantify the 

impact of the SAMAs are detailed in Section F.6 of Attachment F to the ER. Table F.5-1 lists the 

assumptions considered to estimate the risk reduction for each of the evaluated SAMAs, 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.5-1 reflect the combined benefit in both internal and external events. The determination 

of the benefits for the various SAMAs is further discussed in Section F.6.

The staff questioned the assumptions used in evaluating the benefits or risk reduction estimates 

of certain SAMAs provided in the ER (NRC, 2009a). For example, in the ER, DEK reported a 

negative benefit for SAMA 19, provide backup cooling to emergency diesel generators. In 

response to an RAI, DEK indicated the evaluation of SAMA 19 resulted in an increase in risk 

because of certain assumptions relative to operator response to the sequence after the 

modification was made. DEK provided an alternative assessment, incorporating procedure 

changes as well as hardware changes, which indicated a positive benefit. For SAMA 150, 

improved maintenance procedures, the staff questioned the applicability of the benefit 

determined by setting the maintenance unavailability to zero. In response, DEK stated that 

because no specific procedure improvement was identified by this generic SAMA, the 

maintenance unavailability for all of the Maintenance Rule (a)(1) equipment was used as a 

surrogate. DEK stated that this bounds the impact of improving the reliability of individual 

equipment items. Further, compliance with the Maintenance Rule will require reliability 

improvement actions be taken for any items failing to meet Maintenance Rule goals. DEK 

therefore concluded that no action for this SAMA is cost beneficial (DEK, 2009a).

The staff has reviewed DEK’s bases for calculating the risk reduction for the various plant 

improvements and concludes that the rationale and assumptions for estimating risk reduction 

are reasonable and generally conservative (i.e., the estimated risk reduction is higher than what 

would actually be realized). Accordingly, the staff based its estimates of averted risk for the 

various SAMAs on DEK’s risk reduction estimates.

F.5. COST IMPACTS OF CANDIDATE PLANT IMPROVEMENTS

DEK estimated the costs of implementing the candidate SAMAs through the application of 

engineering judgment, the use of other licensees’ estimates for similar improvements, and the 

use of KPS actual experience for similar improvements. The cost estimates conservatively did 

not include the cost of replacement power during extended outages required to implement the 

modifications nor did they include contingency costs associated with unforeseen implementation 

obstacles (DEK, 2008a).

For a simple procedure change, DEK assumed a minimum cost of $50K for preparation, review, 

approval, training, and implementation. Complex procedure changes or changes involving 

emergency operating procedures were assumed to cost more. For a simple design change, 

DEK assumed a minimum cost of $100K for completing and assembling the design change 

package, performing limited calculations, and minor drawing revisions. Complex design 

changes were assumed to cost considerably more (DEK, 2008a). The cost estimates for each 

SAMA are detailed in Section F.6 of the ER.

For a number of SAMAs (SAMAs 19, 26, 55, 56, 58, 59, 71, 81, 111, 112, 124, 125, 150, 178, 

179, 180, and 182) the estimated benefit for the 3 percent discount rate case and/or the 95th 
Appendix F

August 2010 F-21 NUREG-1437, Supplement 40

percentile uncertainty case was found to exceed the initial implementation cost estimate. The 

implementation costs for these SAMAs were further assessed to more realistically account for 

additional cost considerations. This is described in ER Sections F.7.1 and F.7.5 and in 

responses to staff RAIs (DEK, 2008a), (DEK, 2009a), (DEK, 2009b).

The staff reviewed the bases for the licensee’s cost estimates (See DEK, 2008a, Section F.6). 

For certain improvements, the staff also compared the cost estimates to estimates developed 

elsewhere for similar improvements, including estimates developed as part of other licensees’ 

analyses of SAMAs for operating reactors and advanced light-water reactors. The staff reviewed 

the costs and found them to be reasonable and generally consistent with estimates provided in 

support of other plants’ analyses. The staff concludes that the cost estimates provided by DEK 

are sufficient and appropriate for use in the SAMA evaluation.

Table F.5-1. Severe Accident Mitigation Alternative Cost/Benefit Screening Analysis for 

Kewaunee Power Station(a)

Case ID - Title

Potential 

SAMAs 

evaluated 

by case

Modeling 

Assumptions

% Risk Reduction(b) Total Benefit ($)

Cost ($)

CDF Population 

Dose

Baseline 

(Internal + 

External)

Baseline 

With 

Uncertainty

SAMA 1

Improved 

Availability and 

Reliability of DC 

Power

1, 3, 5, 6, 

74

AC power to safety 

related battery 

chargers completely 

available.

<0.1 <0.1 1.0K 1.9K 50K

SAMA 19

Provide Backup 

Cooling to 

Emergency 

Diesel 

Generators 

(EDGs)

19, 20 No service water 

required for EDGs.

See 

Note (c)

See 

Note (c)

(-)23K (-)41K 50K

0.1 probability of 

EDG cooling failure

1.9 1.9 81K 150K 100K(e)

SAMA 21

Develop 

Procedures to 

Repair 4kVAC 

Breakers

21 Failure probability of 

breakers supplying 

safety related buses 

5 and 6 set to zero.

0.2 0.9 8.6K 16K 50K

SAMA 26

Provide 

Additional 

Diesel-Powered 

Safety Injection 

Pump

26 Reactor coolant 

pump (RCP) seals 

and safety injection 

pumps would not 

fail.

41 27 1.7M 3.0M 2M (e)
Appendix F

NUREG-1437, Supplement 40 F-22 August 2010

Case ID - Title

Potential 

SAMAs 

evaluated 

by case

Modeling 

Assumptions

% Risk Reduction(b) Total Benefit ($)

Cost ($)

CDF Population 

Dose

Baseline 

(Internal + 

External)

Baseline 

With 

Uncertainty

SAMA 31

Provide for 

Manual 

Alignment to 

Emergency 

Core Cooling 

System (ECCS) 

Recirculation

31 Electric power is not 

required for the 

valves needed to 

switch to ECCS 

recirculation.

<0.1 0 360 650 50K

SAMA 32

Provide 

Automatic 

Alignment to 

ECCS 

Recirculation

32 HEPs associated 

with ECCS 

recirculation set to 

zero.

1.6 0.3 51K 92K 100K

SAMA 46

Add a Service 

Water Pump

46 Failure probability of 

service water pumps 

set to zero.

18 15 820K 1.5M 2.7M

SAMA 50

Enhance Loss 

of Cooling 

Water 

Procedures

50, 162, 

163

Failure probability of 

the basic event that 

represents failure of 

operator action to 

initiate reactor 

coolant system 

(RCS) cool down in 

response to a loss 

of seal cooling set to 

1.0E-04.

0.37 0.3 15K 28K 50K

SAMA 55

Install 

Independent 

RCP Seal 

Injection 

System With 

Dedicated 

Diesel

55 Failure probability of 

charging to RCP 

seals set to zero.

33 19 1.3M 2.3M 2M (e)

SAMA 56

Install 

Independent 

RCP Seal 

Injection 

System Without 

Dedicated 

Diesel

56 Failure probability of 

charging to RCP 

seals for all accident 

scenarios except 

station blackout set 

to zero.

29 14 1.0M 1.8M 1.5M (e)
Appendix F

August 2010 F-23 NUREG-1437, Supplement 40

Case ID - Title

Potential 

SAMAs 

evaluated 

by case

Modeling 

Assumptions

% Risk Reduction(b) Total Benefit ($)

Cost ($)

CDF Population 

Dose

Baseline 

(Internal + 

External)

Baseline 

With 

Uncertainty

SAMA 58

Install Improved 

RCP Seals

58 Failure probability of 

charging to RCP 

seals set to zero.

33 19 1.3M 2.3M 1.4M (e)

SAMA 59

Install an 

Additional CCW 

Pump

59 Failure probability of 

CCW pumps set to 

zero.

25 14 980K 1.8M 1.4M (e)

SAMA 66

Install a New 

Feedwater 

Source

[Proceduralize 

use of existing 

sources](d)

66 Failure probability 

for the hardware 

associated with 

water sources to the 

feedwater systems 

set to zero.

6.7 8.5 380K 690K 50K

SAMA 71

Install A New 

Condensate 

Storage Tank

71 Failure probability of 

events associated 

with providing a 

cross-tie of the 

CSTs to other 

sources set to zero.

19 18 1.0M 1.8M 1.7M (e)

SAMA 76

Change Failure 

Position of 

Condenser 

Makeup Valve

76, 184 Remove any power 

dependencies from 

valve MU-3A.

<0.1 <0.1 4.4K 7.9K 100K

SAMA 80

Add Redundant 

Ventilation 

Systems [Stage 

temporary 

equipment and 

provide 

procedures and 

power source 

connections](d)

80 Remove any 

ventilation system 

dependencies for 

equipment located 

in the auxiliary 

building from the 

fault tree models.

12 6.0 510K 910K 250K

SAMA 81

Diesel Room 

Cooling 

Improvements(f)

81, 160, 

166, 167, 

170, 171

Diesel room 

ventilation was 

always successful.

4.6 5.1 240K 430K 400K (e)
Appendix F

NUREG-1437, Supplement 40 F-24 August 2010

Case ID - Title

Potential 

SAMAs 

evaluated 

by case

Modeling 

Assumptions

% Risk Reduction(b) Total Benefit ($)

Cost ($)

CDF Population 

Dose

Baseline 

(Internal + 

External)

Baseline 

With 

Uncertainty

SAMA 82

Switchgear 

Room 

Ventilation 

Response 

[Stage backup 

fans in 

switchgear 

rooms, add 

switchgear 

room high 

temperature 

alarm, stage 

temporary fans 

and ducts along 

with power 

cords for 

safeguards 

alley room 

cooling, and 

provide high 

temperature 

alarms for 

safeguards 

alley](d)

82, 83, 170, 

171

Add an operator 

action to implement 

actions for 

temporary 

ventilation following 

any loss of 

switchgear room 

ventilation.

8.8 9.4 440K 800K 400K

SAMA 86

Proceduralize 

Backup Power 

to Air 

Compressors

86 Power to air 

compressors F and 

G does not fail.

0.2 0.2 11K 19K 50K

SAMA 87

Replace Air 

Compressors 

With 

Self-Cooled 

Units

87 Remove the service 

water and plant 

equipment water 

dependency of air 

compressors from 

the system fault 

trees.

0.7 0.4 26K 46K 100K

SAMA 111

Improve 

Prevention and 

Detection of 

Interfacing 

Systems Loss 

of Coolant 

Accident 

(ISLOCA)

111, 113 ISLOCA frequency 

set to zero.

1.1 3.8 130K 240K 190K (e)
Appendix F

August 2010 F-25 NUREG-1437, Supplement 40

Case ID - Title

Potential 

SAMAs 

evaluated 

by case

Modeling 

Assumptions

% Risk Reduction(b) Total Benefit ($)

Cost ($)

CDF Population 

Dose

Baseline 

(Internal + 

External)

Baseline 

With 

Uncertainty

SAMA 112

Enhance 

Containment 

Isolation Valve 

Indication

112 ISLOCA frequency 

set to zero and 

containment 

isolation set to 

success.

1.1 3.4 130K 240K 150K (e)

SAMA 114

Install 

Self-Actuating 

Containment 

Isolation Valves

114 Containment 

isolation set to 

success in the Level 

2 PRA models.

0 <0.1 1.3K 2.3K 100K

SAMA 118

Improve 

Training on 

ISLOCA

118 Failure probability of 

all human action 

events associated 

with ISLOCAs set to 

1.0E-04.

<0.1 0.1 4.7K 8.6K 50K

SAMA 122

Improve RCS 

Depressurization 

Capability

122 Hardware 

associated with 

primary 

depressurization 

does not fail.

0.1 <0.1 4.7K 8.4K 100K

SAMA 124

Improve 

Detection of 

SGTR

124 Probability of 

operator failure to 

detect and diagnose 

a SGTR is 1.0E-04.

0.1 4.2 130K 240K 150K (e)

SAMA 125

Prevent 

Release of 

SGTR From 

Steam 

Generators

125, 129 Level 2 PRA model 

changed so that 

SGTR events do not 

lead to containment 

bypass.

<0.1 64 1.8M 3.2M 2.7M (e)

SAMA 126

Install 

Closed-Loop 

Steam 

Generator 

Cooling System

126 Hardware 

associated with cool 

down and 

depressurization 

would not fail 

following a SGTR.

3.6 2.8 170K 300K 2.7M
Appendix F

NUREG-1437, Supplement 40 F-26 August 2010

Case ID - Title

Potential 

SAMAs 

evaluated 

by case

Modeling 

Assumptions

% Risk Reduction(b) Total Benefit ($)

Cost ($)

CDF Population 

Dose

Baseline 

(Internal + 

External)

Baseline 

With 

Uncertainty

SAMA 131

Install 

Additional 

Primary System 

Relief Capacity 

to Mitigate 

ATWS

131 Initiating event 

equation for ATWS 

events set to zero.

3.3 3.5 170K 310K 700K

SAMA 150

Improve 

Maintenance 

Procedures

150 Maintenance 

unavailability for 

Maintenance Rule 

(a)(1) equipment set 

to zero.

1.4 0.6 56K 100K 100K (e)

SAMA 168

Add Capability 

to Isolate 

Service Water 

Without Power

168 Eliminate from the 

fault tree models the 

requirement for 

power to close 

service water valves 

SW-10A and 

SW-10B.

1.2 <0.1 33K 59K 100K

SAMA 169

Provide Flood 

Protection for 

MCC-52E, 

-62E, and -62H

169 Eliminate 

flood-induced failure 

of the three MCCs 

from the fault tree 

models.

12 4.3 420K 750K 284K

SAMA 172

Provide 

Additional 

Alarm for 

Extremely Low 

CST Level

172 Failure probability 

for the associated 

basic event set to 

1.0E-04.

14 13 750K 1.4M 250K

SAMA 173

Protect 

Auxiliary 

Building 

Mezzanine 

Cooling Units 

From Spray

173 Remove 

flood-induced 

failures of the 

auxiliary building 

mezzanine cooling 

units from the fault 

tree models.

3.6 2.9 170K 310K 150K

SAMA 174

Protect Boric 

Acid Transfer 

Pumps From 

Spray

174 Remove 

flood-induced 

failures of the boric 

acid transfer pumps 

from the fault tree 

models.

3.3 2.5 160K 280K 150K
Appendix F

August 2010 F-27 NUREG-1437, Supplement 40

Case ID - Title

Potential 

SAMAs 

evaluated 

by case

Modeling 

Assumptions

% Risk Reduction(b) Total Benefit ($)

Cost ($)

CDF Population 

Dose

Baseline 

(Internal + 

External)

Baseline 

With 

Uncertainty

SAMA 175

Protect A-Train 

CCW Pump 

From Spray

175 Remove 

flood-induced 

failures of the 

A-train CCW pump 

from the fault tree 

models.

4.0 2.9 185K 330K 150K

SAMA 176

Install Larger 

Sump Pumps In 

Safeguards 

Alley

176 Eliminate 

submergence-induc

ed failures of 

equipment from the 

fault tree models.

8.7 6.7 360K 660K 269K

SAMA 177

Install 

Watertight 

Barrier Between 

480 VAC 

Switchgear 

Rooms

177 Remove flood 

propagation-induced 

failures of 

equipment in 

safeguards alley

from the fault tree 

models for events 

that initiate on the 

opposite side of the 

wall.

9.7 8.7 440K 790K 162K

SAMA 178

Install Flood 

Detection In 

Battery Rooms

178 Probability of the 

basic event that 

represents operator 

failure to isolate 

battery room floods 

set to zero.

2.0 2.5 110K 200K 150K (e)

SAMA 179

Add Diverse 

AFW Flow 

Indication

179 Probability of the 

AFW flow 

miscalibration errors 

set to zero.

3.2 2.6 160K 280K 200K (e)

SAMA 180

Remove AFW 

Low Lube Oil 

Pressure Start 

Interlock

180 Remove the 

auxiliary lube oil 

pump failure logic 

from the fault tree 

models.

2.5 2.7 130K 240K 150K (e)

SAMA 181

Install Break 

Away 

Mechanisms on 

EDG Room 

Doors

181 Remove 

flood-induced 

failures from the 

main, reserve, and 

tertiary auxiliary 

transformers.

2.7 4.6 180K 330K 100K
Appendix F

NUREG-1437, Supplement 40 F-28 August 2010

Case ID - Title

Potential 

SAMAs 

evaluated 

by case

Modeling 

Assumptions

% Risk Reduction(b) Total Benefit ($)

Cost ($)

CDF Population 

Dose

Baseline 

(Internal + 

External)

Baseline 

With 

Uncertainty

SAMA 182

Install Flood 

Relief Path In 

Screenhouse

182 Remove flood 

propagation-induced 

equipment failures 

from accident 

sequences that 

begin with a 

screenhouse flood.

1.4 1.5 72K 130K 100K (e)

SAMA 183

Install Flood 

Detection in 

Control Room 

Heating, 

Ventilation, and 

Air Conditioning 

(HVAC) Room

183 Remove flood 

propagation-induced 

equipment failures 

from accident 

sequences that 

begin with a control 

room HVAC room 

flood.

<0.1 0.4 17K 30K 100K

SAMA 188

Install Larger 

Capacity Sump 

Pumps In 

Turbine 

Building

188 HEP associated with 

isolating turbine 

building floods and 

assuming that small 

flooding events in 

safeguards alley 

cannot propagate 

set to 1.0E-04.

2.8 2.2 120K 210K 269K

SAMA 189

Install Diverse 

SI Flow 

Indication

189 Eliminate 

miscalibration errors 

from the SI fault 

tree.

0.4 0.5 23K 45K 100K

(a) SAMAs in bold are potentially cost-beneficial.

(b) Percent risk reduction determined from base case and uncertainty values provided in ER Sections F.6 and F.7.5.

(c) CDF and Population Dose increased for this SAMA due to modeling assumptions. Results of an alternate 

evaluation provided in Section F.6.2 based on DEK RAI response (DEK, 2009a).

(d) Description in brackets is more appropriate for understanding the SAMA evaluation.

(e) Costs and/or benefits of these SAMAs were further assessed. Based on further assessment, implementation 

costs were determined to be higher than the estimated benefits, even for the 95th percentile uncertainty case 

(ER Section F.7.5, DEK, 2008a; responses to RAI 6a, 7.b, and 7.c in DEK, 2009a and 2009b).

(f) SAMA 81 found to be cost-beneficial if implemented simultaneously with other SAMAs (ER Section 7.7, DEK, 

2008a).

F.6. COST-BENEFIT COMPARISON

DEK’s cost-benefit analysis and the staff’s review are described in the following sections.

F.6.1 Dominion Energy Kewaunee, Inc.’s Evaluation

The methodology used by DEK was based on NEI 05-01, Severe Accident Mitigation 

Alternatives (SAMA) Analysis Guidance Document (NEI, 2005), which in turn is based on NRC’s 
Appendix F

August 2010 F-29 NUREG-1437, Supplement 40

guidance for performing cost-benefit analysis, NUREG/BR-0184, Regulatory Analysis Technical 

Evaluation Handbook (NRC, 1997a). NEI 05-01 was endorsed by the NRC for use in license 

renewal applications (NRC, 2007). 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. DEK’s derivation of 

each of the associated costs is summarized below.

NUREG/BR-0058 has been revised to reflect the agency’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). DEK provided a base set of results using the 7 percent 

discount rate and a sensitivity study using the 3 percent discount rate (DEK, 2008a).

Averted Public Exposure (APE) Costs

The APE costs were calculated using the following formula:

APE = Annual reduction in public exposure (units of person-rem per year)

x monetary equivalent of unit dose ($2000 per person-rem)

x 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), the monetary value of the public health risk after 

discounting does not represent the expected reduction in public health risk caused by 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 caused by 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 caused by internal events, DEK calculated an APE of approximately $650,000 for the 

20-year license renewal period.

Averted Offsite Property Damage Costs (AOC)

The AOCs were calculated using the following formula:

AOC = Annual CDF reduction

x offsite economic costs associated with a severe accident (on a per event basis) 

x present value conversion factor
Appendix F

NUREG-1437, Supplement 40 F-30 August 2010

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, DEK calculated an 

annual offsite economic cost of about $49,700 based on the Level 3 risk analysis. This results in 

a discounted value of approximately $535,000 for the 20-year license renewal period.

Averted Occupational Exposure (AOE) Costs

The AOE costs were calculated using the following formula:

AOE = Annual CDF reduction

x occupational exposure per core damage event 

x monetary equivalent of unit dose

x present value conversion factor

DEK derived the values for AOE from information provided in Section 5.7.3 of the regulatory 

analysis handbook (NRC, 1997a). Best estimate values provided for immediate occupational 

dose (3,300 person-rem) and long-term occupational dose (20,000 person-rem 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, 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, DEK calculated an AOE of 

approximately $30,800 for the 20-year license renewal period.

Averted Onsite Costs

Averted onsite costs (AOSC) include averted cleanup and decontamination costs and averted 

power replacement costs. Repair and refurbishment costs are considered for recoverable 

accidents only and not for severe accidents. DEK derived the values for AOSC based on 

information provided in Section 5.7.6 of NUREG/BR-0184 (NRC, 1997a).

DEK divided this cost element into two parts—the onsite cleanup and decontamination cost, 

also commonly referred to as averted cleanup and decontamination costs (ACC) and the 

replacement power cost (RPC).

ACCs were calculated using the following formula:

ACC = Annual CDF reduction

x present value of cleanup costs per core damage event

x present value conversion factor

The total cost of cleanup and decontamination subsequent to the severe accident is estimated 

in NUREG/BR-0184 to be $1.5 x 109 (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, DEK calculated an ACC of approximately $939,000 for the 20-year license 

renewal period.
Appendix F

August 2010 F-31 NUREG-1437, Supplement 40

Long-term RPCs were calculated using the following formula: 

RPC = Annual CDF reduction

x present value of replacement power for a single event

x factor to account for remaining service years for which replacement power is 

required

x reactor power scaling factor

DEK based its calculations on the rated KPS net electric output of 556 megawatt-electric (MWe) 

and scaled down from the 910 MWe reference plant in NUREG/BR-0184 (NRC, 1997a). 

Therefore, DEK applied a power scaling factor of 556/910 to determine the replacement power 

costs. For the purposes of initial screening, which assumes elimination of all severe accidents 

caused by internal events, DEK calculated an RPC of approximately $390,000 and an AOSC of 

approximately $1.3M for the 20-year license renewal period.

Using the above equations, DEK estimated the total present dollar value equivalent associated 

with completely eliminating severe accidents caused by internal events at KPS to be about 

$2.54M. Use of a multiplier of two to account for external events increases the value to $5.09M 

and represents the dollar value associated with completely eliminating all internal and external 

event severe accident risk at KPS, also referred to as the Modified Maximum Averted Cost Risk 

(MMACR).

DEK’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), DEK identified 14 potentially cost-beneficial SAMAs. The potentially 

cost-beneficial SAMAs are:

● SAMA 66 – Install a New Feedwater Source (The evaluated SAMA actually 

involved proceduralizing use of existing water sources.)

● SAMA 80 – Add Redundant Ventilation Systems (The evaluated SAMA actually 

involved staging temporary equipment and providing procedures and power 

source connections.)

● SAMA 82, 83, 170, 171 – Switchgear Room Ventilation Response (The 

evaluated SAMA actually involved staging backup fans in switchgear rooms, 

adding switchgear room high-temperature alarm, staging temporary fans and 

ducts along with power cords for safeguards alley room cooling, and providing 

high-temperature alarms for the safeguards alley.)

● SAMA 169 – Provide Flood Protection for MCC-52E, -62E, and -62H

● SAMA 172 – Provide Additional Alarm for Extremely Low CST Level

● SAMA 173 – Protect Auxiliary Building Mezzanine Cooling Units from Spray

● SAMA 174 – Protect Boric Acid Transfer Pumps from Spray
Appendix F

NUREG-1437, Supplement 40 F-32 August 2010

● SAMA 175 – Protect A-Train CCW Pump from Spray

● SAMA 176 – Install Larger Sump Pumps In Safeguards Alley

● SAMA 177 – Install Watertight Barrier between 480 VAC Switchgear Rooms

● SAMA 181 – Install Break Away Mechanisms on EDG Room Doors

DEK performed additional analyses to evaluate the impact of parameter choices and 

uncertainties on the results of the SAMA assessment (DEK, 2008a). 

Based on an analysis using 3 percent, as recommended in NUREG/BR-0058 (NRC, 2004), 

DEK determined that four of the Phase 1 SAMAs were screened out due to excessive 

implementation cost (SAMAs 2, 104, 116 and 119) and would have been retained for further 

analysis. Thirteen of the Phase 2 SAMAs, which had a negative net value at a 7 percent 

discount rate (SAMAs 19, 26, 55, 56, 58, 59, 111, 112, 124, 178, 179, 180, and 182) would 

have a potentially positive net value at a 3 percent discount rate. In Section F.7.1 of the ER (and 

in RAI 6.a responses for SAMA 19), DEK discussed each of these SAMAs and concluded that 

in each case the cost of implementation would be higher than that utilized in the original 

cost-benefit analyses and would exceed the benefit using the 3 percent discount rate 

(DEK, 2008a, (DEK, 2009a), (DEK, 2009b).

If the benefits are increased by a factor of 1.8 to account for uncertainties, four Phase 1 SAMAs 

(the same four SAMAs mentioned above) would have been retained for further analysis, and 17 

Phase 2 SAMAs (the 13 SAMAs mentioned above plus SAMAs 71, 81, 125, and 150) would 

become potentially cost-beneficial. In Section F.7.5 of the ER (and in RAI responses for SAMAs 

19 and 58), DEK discusses each of these items noting: costs that were not included in the base 

case assessment, the optimistic nature of some of the estimates and, in some cases, the 

conservative nature of the benefit calculation. Based on this, DEK concludes that no additional 

SAMAs would be cost beneficial even at the 95 percentile risk values.

DEK also considered the impact of simultaneous implementation of several of the SAMAs from 

both a benefit and a cost standpoint. DEK concluded that while the simultaneous 

implementation of several SAMAs would not increase the total benefit beyond that for each 

SAMA individually, the implementation cost could be reduced. Based on the evaluation of 

similar SAMAs involving improvements in room cooling and ventilation, DEK concluded that the 

following three additional SAMAs involving diesel room cooling improvements would be cost 

beneficial:

● SAMA 81 – Add a diesel building high temperature alarm or redundant louver 

and thermostat

● SAMA 166 – Open Doors for Alternate DG Room Cooling

● SAMA 167 – Proceduralize Actions to Open EDG Room Doors on Loss of 

HVAC and Implement Portable Fans

As discussed above, DEK’s review of the results of importance analysis of the K107Aa PRA, 

prepared subsequent to the SAMA evaluation documented in the ER, indicated one new 

contributor to risk that could be impacted by a candidate SAMA. DEK concluded that a new 
Appendix F

August 2010 F-33 NUREG-1437, Supplement 40

SAMA addressing this contributor—loss of screenhouse ventilation—could be cost effectively 

combined with similar SAMAs 81, 82, 83, 160, 166, 167, 170, and 171.

● Implementation of temporary screenhouse ventilation, including installing 

additional temperature detectors

DEK committed to further review these SAMAs for implementation as part of DEK’s ongoing 

performance improvement program (DEK, 2008a, (DEK, 2009a).

F.6.2 Review of Dominion Energy Kewaunee, Inc.’s Cost-Benefit Evaluation

The cost-benefit analysis performed by DEK was based primarily on NEI 05-01, Severe 

Accident Mitigation Alternatives (SAMA) Analysis Guidance Document (NEI, 2006), which in 

turn is based on NRC’s guidance for performing cost-benefit analysis, NUREG/BR-0184, 

Regulatory Analysis Technical Evaluation Handbook (NRC, 1997a). NEI 05-01 was endorsed by 

the NRC for use in license renewal applications (NRC, 2007). The staff’s review indicated that 

the cost-benefit analysis was implemented in accordance with these guidance documents.

NUREG/BR-0058 has been revised to reflect the agency’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). DEK provided a base set of results using the 7 percent 

discount rate and a sensitivity study using the 3 percent discount rate (DEK, 2008a).

SAMAs identified primarily on the basis of the internal events analysis could provide benefits in 

certain external events, in addition to their benefits in internal events. To account for the 

additional benefits in external events, DEK multiplied the internal event benefits by a factor of 2. 

The staff notes that the KPS external events CDF is approximately 60 percent of the internal 

events CDF from the K101AASAMA PRA (based on a fire CDF of 3.6 x 10-5 per year, a seismic 

CDF of 1 x 10-5 per year, a negligible HFO contribution, and an internal events CDF of 8.1 x 10-5

per year). Accordingly, the total CDF from internal and external events would be approximately 

1.6 times the internal events CDF from the K101AASAMA PRA. Thus, the use a multiplier of 2 

is conservative. The staff concludes that the factor of 2 multiplier for external events is 

reasonable for purposes of the SAMA evaluation.

DEK considered the impact that possible increases in benefits from analysis uncertainties would 

have on the results of the SAMA assessment. In the ER, DEK presents the results of an 

uncertainty analysis of the internal events CDF for KPS, which indicates that the 95th percentile 

value is a factor of 1.8 greater than the mean CDF for KPS. DEK assessed the impact on the 

SAMA screening and if the estimated benefits were further increased by this uncertainty factor 

(in addition to the multiplier of 2 for external events).

DEK performed additional sensitivity analyses, including use of a 3 percent discount rate, use of 

a longer plant life and use of different evacuation assumptions, and considered the impact of 

unresolved peer review findings and recent plant modifications on the results of the SAMA 

analysis. These analyses did not identify additional potentially cost-beneficial SAMAs beyond 

those already identified through the uncertainty analysis.

The staff noted in an RAI that a number of important basic events involved failure of the 

operator to refill the RWST and requested that DEK consider an automatic refilling system as a 

potential SAMA (NRC, 2009a). In response, DEK provided a cost benefit analysis, based on a 

7 percent discount rate, which showed that this modification would not be cost beneficial 
Appendix F

NUREG-1437, Supplement 40 F-34 August 2010

(DEK, 2009a). In a request for clarification of the RAI response (NRC, 2009b), the staff pointed 

out that based on DEK’s analysis, the automatic refilling system would be cost-beneficial at a 3 

percent discount rate or when considering uncertainties in CDF. In response to the request for 

clarification, DEK agreed that using the original cost estimate of $850,000 for an automatic 

refilling system, the enhancement would be cost beneficial for these sensitivity cases. However, 

they indicated that this cost estimate was a conservatively low screening estimate. DEK 

provided an updated cost estimate of approximately $1.5 million, based on a more refined 

analysis similar to that for a CST refill system (discussed later). Since this is more than the 

benefit using a 3 percent discount rate ($972,000) or when accounting for uncertainty ($1.1 

million), DEK concluded that this enhancement would not be cost-beneficial (DEK, 2009b).

A similar situation was observed for SAMA 19. As noted previously, DEK’s evaluation of SAMA 

19, provide backup cooling to emergency diesel generators, resulted in an increase in CDF. In 

response to an RAI, DEK provided a cost benefit analysis that indicated that the SAMA was not 

cost beneficial. The analysis in this initial response was performed for a 7 percent discount rate. 

In a request for clarification of the RAI response (NRC, 2009b), the staff pointed out that based 

on DEK’s analysis, the SAMA would be cost-beneficial at a 3 percent discount rate or when 

considering uncertainties in CDF. In response to the request for clarification, DEK agreed that 

using the original cost estimate of $100,000, this SAMA would be cost beneficial for these 

sensitivity cases. However, they indicated that this cost estimate was a conservatively low 

screening estimate. DEK provided an updated cost estimate of at least $150,000, which 

accounted for additional hardware costs associated with the modification. Since this is more 

than the benefit using a 3 percent discount rate ($125,000) or when accounting for uncertainty 

($146,000), DEK concluded that this enhancement would not be cost beneficial (DEK, 2009b).

The staff noted that for certain SAMAs considered in the ER, there may be alternatives that 

could achieve much of the risk reduction at a lower cost. The staff asked the licensee to 

evaluate several lower cost alternatives to the SAMAs considered in the ER, including SAMAs 

that had been found to be potentially cost-beneficial at other PWR plants. These alternatives 

were: (1) automating the cross-tie of the existing CST to other water sources rather than 

installing a new CST, (2) modifying procedures to direct primary system cool-down to further 

reduce the probability of RCP seal failures, (3) modifying procedures and equipment for using a 

portable diesel-driven or AC-powered pump to provide feedwater to the steam generators with 

suction from the intake canal, (4) developing a procedure to cross-connect the CVCS holdup 

tanks to the VCT through the CVCS holdup transfer pump, and (5) procuring and developing a 

procedure for using a gagging device to close a stuck-open steam generator safety valve on a 

faulted steam generator before core damage occurs. The latter had been found potentially 

cost-beneficial in two previous SAMA evaluations (Entergy, 2008), (FENOC, 2007) and might be 

cost beneficial at KPS as a SGTR where failure to isolate contributes 64 percent of the 

population dose at KPS (See Table F.2-2). DEK provided a further evaluation of these 

alternatives, as summarized below:

● Automate the CST Cross-Tie. The cost benefit of automating the CST cross-tie 

was evaluated by setting the operator failure to perform the cross-tie to zero. 

This produced an 18 percent reduction in CDF and a 17 percent reduction in 

person-rem, yielding a benefit of $912,000 (based on a 7 percent discount rate 

and including the factor of 2 multiplier for external events). The cost of this 

enhancement was estimated to be approximately $1.5 million. Based on this 

assessment, the enhancement would not be cost beneficial. In a request for 

clarification of RAI responses, DEK addressed the impact of assuming a 3 
Appendix F

August 2010 F-35 NUREG-1437, Supplement 40

percent discount rate or accounting for uncertainty. A revised analysis using a 3 

percent discount rate and the K101AASAMA PRA model yielded a total benefit 

of about $1.4 million, which is less than the cost of the enhancement. To 

address the impact of uncertainty, DEK recalculated the base case and SAMA 

assessment case using the more recent K107AaILRT PRA model. Use of this 

PRA model and a more realistic (less conservative) assumption concerning the 

SAMA benefits (both operator failure and electrical bus failure required to fail the 

CST cross-tie rather than setting operator error to zero) resulted in only an 8 

percent reduction in CDF and a $333,000 benefit. Based on this alternative 

evaluation, DEK concluded that this enhancement would not be cost-beneficial 

even for the 95th percentile uncertainty case (DEK, 2009b).

● Modify Procedures to Reduce RCP Seal Failures. Modifying procedures to 

direct primary system cooldown was evaluated in SAMAs 50, 162 and 163 and 

found by DEK to not be cost beneficial.

● Modify Procedures to Use a Portable Pump to Provide Feedwater to Steam 

Generators. DEK described the procedures followed and actions taken by the 

operators following a reactor trip. These include determining status of AFW flow, 

attempting to restore AFW flow, if not available, or restoring main feedwater. If 

this is not possible, procedures include depressurizing the steam generators to 

establish condensate flow or initiating feed and bleed cooling. The time 

available and steps necessary to establish flow to a steam generator from a 

portable pump were also described. Based on the required actions and time 

available, DEK concluded that, unless significant plant impairments exist, it 

would be best for the operators to focus on restoration of cooling using 

permanently installed equipment. Modifying procedures to use a portable pump 

for steam generator makeup would provide a negligible risk reduction and would 

not be cost-beneficial.

● Modify Procedures to Provide Makeup to the Volume Control Tank. DEK 

discussed the potential use of the CVCS holdup tanks to provide makeup to the 

VCT and thereby provide a continued source of water for injection to the RCP 

seals and the RCS. DEK noted that makeup to the VCT is normally from the 

letdown flow. If this is interrupted, then flow is provided automatically from the 

RWST. If this fails, RCP seal integrity will be maintained as long as component 

cooling water to the seals continues. If this is lost, seals will fail if injection is not 

restored within 13 minutes. DEK indicated that provision of flow from the CVCS 

holdup tanks to the VCT in 13 minutes is not considered practical. While flow 

from the CVCS after a seal loss of coolant accident (LOCA) would provide RCS 

makeup, it would not remove decay heat nor prevent core damage. Based on 

the above, DEK concluded that this proposed enhancement would not offer 

significant risk reduction benefits and would not be cost-beneficial.

● Provide a Gagging Device to Close a Stuck-Open Steam Generator Safety 

Valve. DEK discussed and evaluated the conditions under which a gagging 

device could be used to close a stuck-open steam generator safety valve and 

the resulting benefit associated with it. As outlined in the DEK response, two 

circumstances contribute to the release of radioactivity following an SGTR event 

with a stuck-open safety valve. The first is an induced-SGTR, which occurs after 
Appendix F

NUREG-1437, Supplement 40 F-36 August 2010

core damage when hot gases and high RCS pressure cause a steam generator 

tube to fail, with subsequent safety valve opening and failure to re-close. The 

second circumstance is a spontaneous SGTR, in which a tube rupture is the 

initiating event and high pressure from the reactor coolant system causes the 

steam generator pressure to rise. If the operators fail to cool down and 

depressurize soon enough in this latter event, the secondary water level would 

increase along with pressure causing a safety valve to open and pass liquid. 

There would then be a significant chance that, when the pressure is reduced, 

the safety valve would fail to re-close.

For the induced-SGTR events (which account for approximately 80 percent of the total 

SGTR-related release frequency), the radiation levels in the vicinity of the valve are expected to 

be too high to permit operators to install and utilize the gagging device. Thus, the gagging 

device would not provide benefits in induced-SGTR events. With regard to SGTR-initiated 

events, the gagging device would only provide benefits for a limited subset of events, 

specifically, events in which the operators follow the emergency operating procedures (EOPs) 

but fail to cool down and depressurize in time to prevent overfilling the steam generator. (If 

operators were not following the EOPs, then secondary pressure would keep rising and the 

gagging device could not be used.) Given that operators follow the EOPs but fail to prevent 

overfilling the steam generator, the EOPs direct the operators to continue to cool down and 

depressurize the RCS to cold shutdown conditions and to establish heat removal using the 

residual heat removal (RHR) system. If this is successful, core damage is prevented. If a 

gagging device is used to re-close the stuck open safety valve, achieving cold shutdown and 

use of the RHR is not needed, as heat can be removed via the intact (or faulted) steam 

generator without loss of reactor coolant inventory. Thus, the risk associated with failure to 

achieve cold shutdown and use RHR would be eliminated by the gagging device.

To determine the benefit associated with the use of a gagging device, DEK revised the SAMA 

base case model to eliminate the operator execution error and the hardware failures associated 

with establishing RHR cooling following a SGTR with stuck-open safety valve. The result was a 

0.4 percent reduction in CDF (from 8.089 x 10-5 per year to 8.060 x 10-5 per year) and a 1.1 

percent reduction in offsite person-rem per year (from 30.19 person-rem per year to 29.86 

person-rem per year). The total averted cost is about $19,000 at a 7 percent discount rate and 

$35,000 accounting for uncertainty. Based on an estimated cost of procuring a gagging device 

and preparing procedures for its use of $50,000, DEK concluded that this potential 

enhancement would not be cost-beneficial (DEK, 2009c). The staff notes that this benefit 

estimate does not include doubling to account for external events but that this is considered 

appropriate because SGTR events would not generally occur as a direct result of an external 

event, and this SAMA would not have any associated benefit for these events.

The staff concurs with DEK’s conclusions regarding these alternative SAMAs because the staff 

finds the additional information provided by DEK for the aforementioned alternative SAMAs to 

be technically sound. 

In the discussion of the conclusions of the cost-benefit analysis, DEK identified the individual 

SAMAs that address improving the availability of HVAC. The SAMAs identified were those 

found to be cost-beneficial in the baseline analysis (SAMAs 80, 82, 83, 170, and 171), plus 

those found to be cost-beneficial due to synergies if the SAMAs were implemented concurrently 

(SAMAs 81, 160, 166 and 167). In response to an RAI, DEK noted that the latter four SAMAs 

would be included within the set of SAMAs that they intend to review further for possible 
Appendix F

August 2010 F-37 NUREG-1437, Supplement 40

implementation as part of DEK’s ongoing performance improvement program (DEK, 2009a). In 

a request for clarification, the staff noted that SAMA 160, Insulate EDG Exhaust Ducts, was not 

included in the evaluation of simultaneous implementation in Section 7.7 of the ER. In response, 

DEK agreed that SAMA 160 should not have been included as a SAMA to be considered further 

since it does not have any implementation synergisms with the HVAC SAMAs, and there would 

be no noticeable risk reduction if implemented alone. DEK, however, indicated SAMA 160 will 

be considered further when risk reduction strategies are evaluated in the future (DEK, 2009b).

The staff concludes that, with the exception of the potentially cost-beneficial SAMAs discussed 

above, the costs of the SAMAs evaluated would be higher than the associated benefits.

F.7. CONCLUSIONS

DEK compiled a list of 189 SAMAs based on a review of the most significant basic events from 

the current (at the time of the ER preparation) plant-specific PRA, insights from the 

plant-specific IPE and IPEEE, Phase 2 SAMAs from license renewal applications for other 

plants, and review of other industry documentation. An initial screening removed SAMA 

candidates that: (1) are not applicable at KPS due to design differences, (2) have been 

effectively implemented at KPS, (3) have estimated costs that would exceed the dollar value 

associated with completely eliminating all severe accident risk at KPS, or (4) have a very low 

benefit because they are associated with a non-risk-significant system. Based on this screening, 

125 SAMAs were eliminated, leaving 64 candidate SAMAs for evaluation.

For the remaining 64 SAMA candidates, a more detailed evaluation was performed as shown in 

Table F.5-1. The cost-benefit analyses in the ER showed that 14 SAMA candidates were 

potentially cost-beneficial in the baseline analysis (SAMAs 66, 80, 82, 83, 169, 170, 171, 172, 

173, 174, 175, 176, 177, and 181). DEK performed additional analyses to evaluate the impact of 

parameter choices and uncertainties on the results of the SAMA assessment. As a result, no 

additional SAMAs were identified as potentially cost-beneficial. In response to an NRC request, 

DEK reviewed the most recent KPS PRA, prepared subsequent to the SAMA evaluation 

documented in the ER, and identified one additional potentially cost-beneficial enhancement 

involving implementing temporary screenhouse ventilation and installing additional temperature 

detectors. DEK also considered the cost savings associated with simultaneous SAMA 

implementation and concluded that three additional SAMAs (SAMAs 81, 166 and 167) would be 

potentially cost-beneficial if implemented together with SAMAs 82, 83, 160, 170, and 171 (all but 

SAMA 160 were found to be potentially cost-beneficial in the baseline analysis). Although not 

cost-beneficial, SAMA 160 will also be considered during the evaluation of risk reduction 

strategies. DEK has indicated that all these potentially cost-beneficial SAMAs will be considered 

for implementation at KPS as part of the ongoing performance improvement program. 

The staff reviewed the DEK 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 DEK are reasonable 

and sufficient for the license renewal submittal. Although the treatment of SAMAs for external 

events was somewhat limited, 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.

The staff concurs with DEK’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 

SAMAs. Given the potential for cost-beneficial risk reduction, the staff agrees that further 
Appendix F

NUREG-1437, Supplement 40 F-38 August 2010

evaluation of these SAMAs by DEK is warranted. However, these SAMAs 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 pursuant to Title 10 of the Code of 

Federal Regulations Part 54.

F.8. REFERENCES

American Society of Mechanical Engineers (ASME). 2003. “ASME RA-Sa-2003, Addenda to 

ASME RA-S-2002 Standard for Probabilistic Risk Assessment for Nuclear Power Plant 

Applications.” 

Dominion Energy Kewaunee, Inc. (DEK). 2006. Regulatory Meeting Internal Flooding Risk 

Reduction Activities, November 30, 2006. ADAMS Accession No. ML063460495.

Dominion Energy Kewaunee, Inc. (DEK). 2008a. “Kewaunee Power Station, Licensee’s 

Environmental Report Operating License Renewal Stage,” August 2008.

Dominion Energy Kewaunee, Inc. (DEK). 2008b. Letter from Leslie N. Hartz, Dominion, to U.S. 

Nuclear Regulatory Commission Document Control Desk. Subject: Kewaunee Power Station, 

License Amendment Request 242: Extension of the One-time Fifteen Year Containment 

Integrated Leak Rate Test Interval, September 11, 2008.

Dominion Energy Kewaunee, Inc. (DEK). 2009a. Letter from Leslie N. Hartz, Dominion, to U.S. 

Nuclear Regulatory Commission Document Control Desk. Subject: Kewaunee Power Station, 

Response to Request Additional Information Regarding Severe Accident Mitigation Alternative 

for Kewaunee Power Station License Renewal Application, March 9, 2009.

Dominion Energy Kewaunee, Inc. (DEK). 2009b. Letter from Leslie N. Hartz, Dominion, to U.S. 

Nuclear Regulatory Commission Document Control Desk. Subject: Kewaunee Power Station, 

Response to Follow-up Questions Regarding Severe Accident Mitigation Alternative for 

Kewaunee Power Station, June 1, 2009.

Dominion Energy Kewaunee, Inc. (DEK). 2009c. Letter from J. Alan Price, Dominion, to U.S. 

Nuclear Regulatory Commission Document Control Desk. Subject: Kewaunee Power Station, 

Response to Follow-up Questions Regarding Severe Accident Mitigation Alternatives, July 28, 

2009.

Electric Power Research Institute (EPRI). 1991. A Methodology for Assessment of Nuclear 

Power Plant Seismic Margins, Revision 1, EPRI Report NP-6041-SL.

Entergy Nuclear Northeast (Entergy). 2008. Letter from Fred R. Dacimo, Entergy Nuclear 

Northeast, to U. S. Nuclear Regulatory Document Control Desk. Subject: Supplemental Reply to 

Request for Additional Information Regarding License Renewal Application – Severe Accident 

Mitigating Alternatives, May 22, 2008.

First Energy Nuclear Operating Company (FENOC). 2007. License Renewal Application. 

August 27, 2007.

Kennedy, R. P. 1999. “Overview of Methods for Seismic PRA and Margin Analysis Including 

Recent Innovations,” Proceedings of the OECD-NEA Workshop of Seismic Risk, Tokyo, Japan, 

August 10–12, 1999.

Nuclear Management Company, LLC (NMC). 2005. Letter from Michael G. Gaffney, Nuclear 

Management Company, LLC to U. S. Nuclear Regulatory Commission Document Control Desk. 

Subject: Response to Request for Additional Information Regarding Risk-Informed Inservice 

Inspection Program Plan (TAC No. MC2537), June 17, 2000.
Appendix F

August 2010 F-39 NUREG-1437, Supplement 40

Nuclear Energy Institute (NEI). 2005. “Severe Accident Mitigation Alternative (SAMA) Analysis 

Guidance Document,” NEI 05-01 (Rev. A), November 2005.

State of Wisconsin, 2003. “Final Population Projections for Wisconsin Counties by Components 

of Change: 2000–2003.” Available URL: 

http://www.doa.state.wi.us/docs_view2.asp?docid=2065

TOMCOD, 2005. “Evacuation Time Estimate Study for the Kewaunee Power Station Emergency 

Planning Zone (EPZ),” TOMCOD, Inc., August 8, 2005.

U.S. Department of Agriculture (USDA). 1998. “1997 Census of Agriculture, National Agriculture 

Statistics Service,” 1998. Available URL: 

http://www.nass.usda.gov/census/census97/volume1/vol1pubs.htm

U.S. Department of Agriculture (USDA). 2002. “2002 Census of Agriculture, Volume 1 

Geographic Area Series Census, State-county Data,” Available URL: 

http://www.nass.usda.gov/census/create_census_US_CNTY.jsp

U. S. Geologic Survey (USGS). 2008. “2008 NSHM Gridded Data, Peak Ground Acceleration,” 

Available URL: http://earthquake.usgs.gov/research/hazmaps/products_data/2008/data

U.S. Nuclear Regulatory Commission (NRC). 1990. Severe Accident Risks: An Assessment for 

Five U.S. Nuclear Power Plants, NUREG-1150, Washington, D.C., December 1990.

U.S. Nuclear Regulatory Commission (NRC). 1991. Generic Letter No. 88-20, Supplement 4, 

“Individual Plant Examination of External Events for Severe Accident Vulnerabilities,” 

NUREG-1407, Washington, D.C., June 28, 1991.

U.S. Nuclear Regulatory Commission (NRC). 1994. Revised Livermore Seismic Hazard 

Estimates for Sixty-Nine Nuclear Power Plant Sites East of the Rocky Mountains,

NUREG-1448, Washington, D.C., March 1994.

U.S. Nuclear Regulatory Commission (NRC). 1997a. Regulatory Analysis Technical Evaluation 

Handbook, NUREG/BR-0184, Washington, D.C., January 1997. 

U.S. Nuclear Regulatory Commission (NRC). 1997b. Letter from Richard J. Laufer, U.S. NRC, 

to M. L. Marchi, Wisconsin Public Service Corporation. Subject: Review of Individual Plant 

Examination for Internal Events (TAC No. M74424), January 15, 1997.

U.S. Nuclear Regulatory Commission (NRC). 1997c. Individual Plant Examination Program: 

Perspectives on Reactor Safety and Plant Performance, NUREG-1560, Washington, D.C., 

December 1997.

U.S. Nuclear Regulatory Commission (NRC). 1998. Letter from William O. Long, U.S. NRC to 

M. L. Marchi, Wisconsin Public Service Corporation, Subject: Kewaunee Nuclear Power Plant –

Safety Evaluation for USI A-46 Program Implementation, Revision 1 (TAC No. M69455), May 

26, 1998.

U.S. Nuclear Regulatory Commission (NRC). 1999. Letter from Tae Kim, U.S. NRC to M. L. 

Marchi, Wisconsin Public Service Corporation, Subject: Kewaunee Nuclear Power Plant –

Review of Individual Plant Examination for External Events (IPEEE) Submittal (TAC No. 

M83633), October 5, 1999.

U.S. Nuclear Regulatory Commission (NRC). 2003. “SECPOP 2000: Sector Population, Land 

Fraction, and Economic Estimation Program,” NUREG/CR-6525, Revision 1, Washington, D.C., 

August 2003.
Appendix F

NUREG-1437, Supplement 40 F-40 August 2010

U.S. Nuclear Regulatory Commission (NRC). 2004. Regulatory Analysis Guidelines of the U.S. 

Nuclear Regulatory Commission, NUREG/BR-0058, Revision 4, Washington, D.C., September 

2004.

U.S. Nuclear Regulatory Commission (NRC). 2007. Letter from Pao-Tsin Kuo, U.S. NRC, to 

James H. Riley, Nuclear Energy Institute, Subject: Final License Renewal Interim Staff guidance 

LR-ISG-2006-03: Staff Guidance for Preparing Severe Accident Mitigation Alternatives Analysis, 

August 2, 2007.

U.S. Nuclear Regulatory Commission (NRC). 2009a. Letter from Sarah Lopas, U.S. NRC, to 

David A. Christian, Dominion Energy Kewaunee, Inc., Subject: Request for Additional 

Information Regarding Severe Accident Mitigation Alternatives for the Kewaunee Power Station 

(TAC No. MD9409), January 8, 2009.

U.S. Nuclear Regulatory Commission (NRC). 2009b. Memorandum by Sarah Lopas, U.S. NRC, 

Subject: Summary of Conference Call with Dominion Energy Kewaunee, Inc. to Discuss 

Responses to Severe Accident Mitigation Alternatives Request for Additional Information for the 

Kewaunee Power Station (TAC No. MD9409), April 22, 2009.

Wisconsin Public Service Corporation (WPSC). 1992. Letter from C. R. Steinhardt, WPSC to 

U.S. Nuclear Regulatory Commission Document Control Desk. Subject: Docket No. 50-305, 

Operating License No. DPR-43, Kewaunee Nuclear Power Plant, Response to Generic Letter 

88-20, Individual Plant Examination, December 1, 1992.

Wisconsin Public Service Corporation (WPSC). 1994a. Letter from C. R. Steinhardt, WPSC to 

U.S. Nuclear Regulatory Commission Document Control Desk. Subject: Docket No. 50-305, 

Operating License No. DPR-43, Kewaunee Nuclear Power Plant, Response to Generic Letter 

88-20, Supplement 4. Individual Plant Examination of External Events, June 28, 1994.

Wisconsin Public Service Corporation (WPSC). 1994b. Letter from C. R. Steinhardt, WPSC to 

U.S. Nuclear Regulatory Commission Document Control Desk. Subject: Docket No. 50-305, 

Operating License No. DPR-43, Kewaunee Nuclear Power Plant, Response to Generic Letter 

88-20 Individual Plant Examination, September 21, 1994.

Wisconsin Public Service Corporation (WPSC). 1995. Letter from C. R. Steinhardt, WPSC to 

U.S. Nuclear Regulatory Commission Document Control Desk. Subject: Docket No. 50-305, 

Operating License No. DPR-43, Kewaunee Nuclear Power Plant, Response to Request for 

Additional Information Regarding Individual Plant Examination for External Events, October 13, 

1995.

Wisconsin Public Service Corporation (WPSC). 1998. Letter from Mark L Marchi, WPSC to U.S. 

Nuclear Regulatory Commission Document Control Desk. Subject: Docket No. 50-305, 

Operating License No. DPR-43, Kewaunee Nuclear Power Plant, Response to Supplemental 

Request for Additional Information Regarding Individual Plant Examination for External Events, 

September 28, 1998.